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Sheffield Professor Warns Importers to Check Raw Materials for Xinjiang Ties

Importers need to look beyond the products specifically identified under the Uyghur Forced Labor Prevention Act to any products with raw materials processed in China, as the country moves more and more production to the Xinjiang province, said Laura Murphy, a professor at Sheffield Hallam University, speaking at CBP's Forced Labor Technical Expo on March 15.

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The Chinese government intends "to move as much manufacturing" to Xinjiang as it can, particularly raw materials processing, and keeps a list updated every five years on what production they want to move to the region, said Murphy, lead author of recent reports on forced labor in supply chains for auto parts, vinyl flooring and cotton (see 2212060054, 2206150023 and 2111220045).

"China has decided that they're going to move the dirty processing of the actual raw materials" to Xinjiang "where they don't care what happens to the environment" and where manufacturing isn't subject to rules that apply to the rest of the world, including elsewhere in China, Murphy said, adding that abundant coal reserves and cheap, dirty power make the region especially attractive for manufacturing.

In her team's research on auto parts, for example, they found that when they started to dig into the 30,000 parts that make up a car, all they had to do was look at the basic materials to see that the automotive industry was "wildly exposed," Murphy said. "But so are any other industries that are making things with aluminum, copper, steel, gold, graphite," she said. In that sense, the cover could be taken off her team's report on auto parts to change it to a report on railway equipment or electronics, she said.

This also includes manufacturing of polysilicon, an important material for making solar panels. "The Chinese government has intentionally held [the renewable energy] market captive by moving polysilicon manufacturing to the Uyghur region, and by moving so much of it they're holding all of us captive," Murphy said.

Chinese companies have now been learning to hide their tracks, including by deleting their websites because of something Murphy put on Twitter, she said. Some companies have deleted the names of their customers from press releases so that their customers can continue to receive the goods, Murphy said.

Other companies change their company name or rearrange the letters in their name on shipping records so they can pose as a seemingly new company, even if they are the same company exporting forced labor-made goods, Murphy said. Another strategy Murphy described is companies bifurcating their supply chains, a process whereby companies initially say they have products that don't use forced labor. "We're seeing all kinds of ways that companies are obscuring their supply chains and trying to fool you into continuing to buy their products," Murphy said.

Murphy recommended that importers check their supply chains and make sure that they do not "have any raw materials [that could] possibly be processed in China." She added that "if we can see it, you can see it."

"Google it, y'all. We Google it in Chinese. You can use Google translate ... you can be doing this work," Murphy said.

Murphy also announced that her team at Sheffield and Northeastern University are working on a free supply chain tracing tool to help "small and medium enterprises to be able to actually afford" to do some of the tracing work that Murphy and her team do, and help nonprofit advocates and analysts do some of the same tracing work as well. She did say that this product would not be available anytime soon and recommended buying other products available, if you can.