Sheffield Hallam Publishes Lists of Alleged XUAR Companies

Jul. 6, 2023
By: Ashley J. Bodden

In early July, Sheffield Hallam University’s (SHU) Helena Kennedy Centre International Justice published two spreadsheets detailing companies it alleges operate or produce in the Uyghur region. The intention is to allow the trade community to know which suppliers to avoid. The lists name the supplier’s addresses, and sectors, in both English and Chinese.

The first list contains information on over 50,000 companies relating to manufacturing and export, as well as professional services, construction, telecommunications, and retail. The second tab covers over 35,000 companies that relate to mining, farming, manufacturing, technology, and export. The second spreadsheet includes a list of companies that were identified using media or academic reports as having engaged in labor transfers within the Uyghur Region.

Last month, SHU’s Forced Labor Lab published a guide on how to identify products made with forced labor. This guide provides companies with strategies on identifying and excluding Uyghur forced labor from a company’s supply chain. The guide includes questions companies should ask before contracting with a Chinese supplier. The questions are also designed to help companies identify harmful practices that may not be otherwise revealed.

The guide suggests that if your company is involved in sectors with known exposure to Uyghur forced labor, it is important to revise or implement a supplier code of code that will provide a full list of all suppliers and sub-suppliers across all tiers of the value chain anytime upon request. Any refusal to sign or engage in addressing forced labor and the Uyghur region should been seen as a red flag for risk.

Importers have been working to avoid the legal, economic, and reputational risks that come with imports involving forced labor. The United States government does appear to utilize SHU materials in enforcement and policy making. Therefore, this massive, but not exhaustive list should be taken as a preview of Customs inquiries and concerns by importers.

If you have questions about forced labor or supply chain risk management do not hesitate to contact an attorney at Barnes Richardson, & Colburn LLP.