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Forced Labor in the Textile Industry: Understanding the Risks

Forced labor is a critical issue in the textile supply chain, with both ethical and regulatory implications. Certain regions, such as Xinjiang in China, are of particular concern. In response to these risks, several regulations have been implemented, requiring companies to be increasingly vigilant about the traceability of their raw materials.

Forced Labor in Xinjiang and the Relocation of Uyghur Workers

Xinjiang is a strategic region for global cotton production, but also a major area of human rights concerns.

📌 Identified Risks:

  • Reports confirm the presence of forced labor involving Uyghurs and other minorities.
  • A worker transfer program organizes the relocation of these workers to other Chinese provinces, placing them in factories under strict surveillance.
  • This dispersion of workers complicates the traceability of raw materials and increases the risk of indirect integration into the supply chain.

Key Regulations and Supply Chain Implications

In response to these issues, several legal frameworks have been strengthened, especially in the United States, to limit the entry of goods linked to forced labor.

UFLPA (Uyghur Forced Labor Prevention Act)

In effect since 2021, the UFLPA prohibits the import of products from Xinjiang unless formal proof demonstrates they are not linked to forced labor.

➡ Implication: Any raw material suspected of being produced in the region may be blocked at U.S. customs unless clear and verifiable traceability is provided.

WRO (Withhold Release Order)

WROs allow U.S. customs authorities to detain goods suspected of being produced with forced labor, even beyond the UFLPA framework. Several WROs have already been issued against cotton and other textiles from Xinjiang.

➡ Implication: Enhanced vigilance is necessary, as these blockages can affect finished products containing at-risk raw materials, even if manufactured elsewhere.

How to Secure the Supply Chain and Avoid Risks?

🔍 Actions to Implement:

  • Strengthen traceability by demanding full transparency on the origin of raw materials.
  • Avoid Xinjiang cotton by diversifying sourcing and favoring verified suppliers.
  • Rely on certifications and independent audits to ensure compliance with labor standards and reduce regulatory risks.
  • Establish robust due diligence procedures to anticipate restrictions and prevent border detentions.

By integrating these best practices, companies can reduce exposure to legal and commercial risks while ensuring ethical standards that meet market expectations.