Written submission from the East Turkistan Human Rights Watch Association (ETHR) (CHI0015)

Solar Panel Imports from East Turkistan: Risks for the United Kingdom

Introduction

This document analyzes the impact of China’s forced labor practices in East Turkistan (officially known as the Xinjiang Uyghur Autonomous Region) on the global solar energy supply chain, as well as the ethical, commercial, and geopolitical risks they pose for the United Kingdom. Allegations of forced labor in East Turkistan, where China controls more than 80% of global solar panel production, have been documented by international reports and human rights organizations. It is of critical importance for the United Kingdom to take strategic steps that consider supply chain vulnerabilities in order to ensure its energy security, foreign policy coherence, and economic sustainability. This document will examine the mechanisms of forced labor in East Turkistan, the risks within the global solar energy supply chain, and the challenges facing the United Kingdom; it will then present policy recommendations followed by an overall assessment.

Forced Labor Mechanism in East Turkistan

Significant evidence regarding the scope and structure of the forced labor mechanism implemented in East Turkistan began to emerge in the spring of 2018. These findings indicate that the Chinese Communist Party (CCP) has positioned detention centers and indoctrination camps in the region as merely one component of a broader program of social and economic transformation. Beyond the “re-education” processes carried out in these indoctrination camps, regional and local authorities have developed a large-scale labor transfer system.

Although the Chinese government frames these practices as “surplus labor” (富余劳动力) and “labor transfer” (劳动力转移) programs and legitimizes them through a poverty alleviation narrative, state documents and research indicate that this system effectively constitutes a comprehensive forced labor regime. An official report of the People’s Republic of China published in November 2020 states that 2.6 million Uyghur and Kazakh citizens were “placed” in factories and agricultural fields under state-supported labor transfer programs, representing a 46.1% increase compared to the previous year. These figures indicate that approximately one-fifth of the Uyghur and Kazakh population has been forcibly enrolled in these programs (Murphy & Elimä, 2021, In Broad Daylight: Uyghur Forced Labour and Global Solar Supply Chains). In parallel, in a text titled “2026 Xinjiang Two Sessions: Excerpts from the Government Work Report,” published on its official website in January 2026, the Chinese government stated that a total of 16.1 million people were transferred out of their home regions under the “rural development” policy within the framework of the 14th Five-Year Plan (Xinjiang Uyghur Autonomous Region Department of Human Resources and Social Security, 2026). This coercive system also shapes the functioning of critical sectors in the region, with solar energy production standing out as a primary example.

Figure 1. Population of East Turkistan Transferred Out of Cities under the “Surplus Labor” Program

Source: Xinjiang Uyghur Autonomous Region Statistics Bureau & National Bureau of Statistics Xinjiang Research Team (2019–2024), Xinjiang Uyghur Autonomous Region Government (2026)

China’s dominant position in the global solar energy (PV – Photovoltaic) sector is a key determinant of supply chain risks. China has invested at levels roughly ten times greater than Europe in new PV supply capacity and has created more than 300,000 manufacturing jobs across the sector since 2011. This expansion has allowed China to maintain control of over 80% of the entire value chain, not only in final product manufacturing but also across polysilicon, ingot, wafer, cell, and module production. By 2022, China alone accounted for 77.8% of global PV module production, achieving a production capacity more than double its share of global demand. According to data from the International Energy Agency, China produced more solar panels in 2023 than the entire world had produced in the previous year. This indicates that global supply is geographically highly concentrated, with alternative production centers remaining limited (Richardson, 2026). This concentration creates not only an economic competitive advantage but also a significant supply chain dependency. Considering the concentration of polysilicon production in East Turkistan in particular, China’s production dominance exposes the global solar energy sector to ethical, political, and commercial risks.

PV solar panel and polysilicon production in East Turkistan represent the areas where the forced labor mechanism is most prominently observed. China-based companies supply 77% of global polysilicon production, and polysilicon is a critical component used in 95% of solar panels. Polysilicon production is both capital- and energy-intensive and requires high technical expertise. Since 2017, 91% of the world’s new polysilicon production capacity has been developed in China, with a large portion concentrated in East Turkistan (XUAR). This production density is supported by a combination of cheap coal-based electricity, state subsidies, tax reductions, protective tariffs against foreign competitors, and labor policies designed to attract industry (Cockayne, Rodríguez Huerta & Burcu, 2022).

Risk in Global Supply Chains: The Solar Energy Sector

The solar energy sector is one of the industries most affected by forced labor in East Turkistan. The primary reason is the production chain of solar-grade polysilicon, which constitutes 95% of the main material used in solar modules. Polysilicon is a critical semiconductor material and the primary raw input for solar cells and integrated circuit chips. Producers in East Turkistan alone supply approximately 45% of the global solar-grade polysilicon supply. When combined with production from other regions of China, this share rises to 75% (Crawford & Murphy, 2023).

 

 

Figure 2. Regional Distribution of the Global Polysilicon Market Share in 2020

 

Source: Murphy, L. ve Elimä, N. (2021). In Broad Daylight: Uyghur Forced Labour and Global Solar Supply Chains. Sheffield Hallam University Helena Kennedy Centre for International Justice.

As shown in the graph above, by 2020, 45% of global polysilicon production came from the East Turkistan region, 30% from China’s interior regions, and only 25% from international producers. This clearly illustrates the extent of the global solar energy sector’s dependence on China, and particularly on production in East Turkistan, within its supply chain. Consequently, the sector’s rapid growth poses a significant ethical and sustainability risk, making the development of alternative supply sources and the strengthening of transparent oversight mechanisms imperative.

Traceability of Forced Labor in the Supply Chain and Its Impact on Global Manufacturers

Traces of the forced labor program implemented by the Chinese Communist Party (CCP) in East Turkistan are particularly evident at the earliest stages of the global solar energy sector’s supply chain. This situation places many major players in the industry in an ethically and legally risky position regarding their supply chains.

The solar panel manufacturing process consists of three key stages where the risk of forced labor is highest: quartz mining, metallurgical-grade silicon (MGS) production, and polysilicon production. East Turkistan has become the center of these energy-intensive processes due to its abundant coal resources. The fact that each polysilicon facility in the region operates entirely on coal creates serious environmental as well as ethical concerns.

The lack of transparency in the supply chain and the practice of material blending make it nearly impossible to trace inputs produced through forced labor. Mixing batches of MGS or polysilicon sourced from different locations increases the risk that materials originating from East Turkistan may end up in the products of companies that do not source from the region. This clearly demonstrates that the rapid growth of the solar energy sector poses a significant ethical and sustainability risk.

For example, LONGi Solar, one of the largest global manufacturers, is exposed to inputs from East Turkistan across a significant portion of its production capacity in China. The company’s dependence on polysilicon and MGS sourced from the region has led to its exposure level being assessed as “Very High.” Similarly, JA Solar relies substantially on production from East Turkistan for its polysilicon supply and has been rated as having “Very High” exposure risk due to insufficient information regarding the inputs used in its facilities in China and Vietnam. The production facilities of Qcells and Trina Solar in China are also considered at “Very High” exposure risk because of inadequate transparency in their supply chains. Jinko Solar, meanwhile, has been assessed at a “High” exposure level due to the risk of being exposed to polysilicon and MGS inputs sourced from East Turkistan in its Chinese production. Despite the company’s efforts to “bifurcate” its supply chain, its production lines in China remain at risk.

Some major manufacturers have pursued “bifurcation” of their supply chains, particularly to comply with regulations such as the Uyghur Forced Labor Prevention Act (UFLPA) in the United States and to meet consumer demand. This approach claims that one product line is free of inputs from East Turkistan, while other product lines may still contain materials sourced from the region. However, these separation efforts do not provide full assurance. Even for product lines claimed to be free of East Turkistan inputs, companies continue to work with suppliers who remain exposed to the region through other product lines.

Risks and Challenges for the United Kingdom

According to 2023 data, eight of the world’s top ten solar panel manufacturers are based in China (LONGi, Trina Solar, JinkoSolar, JA Solar, Canadian Solar, Astronergy/CHINT Solar, Suntech Power, First Solar, Risen Energy, and Hanwha Q CELLS).

Supply chain risks for solar energy projects in the United Kingdom are also confirmed by field data. According to an investigation by The Guardian, approximately 40% of solar farms in the country used panels from Chinese manufacturers linked to allegations of forced labor associated with East Turkistan. The research found that leading producers such as Jinko Solar, JA Solar, and Trina Solar were widely involved in both public and private sector projects across the UK. It noted that the supply chains of these companies could be associated with forced labor risks through polysilicon production in East Turkistan.

Furthermore, it has been identified that these panels were used in projects by public and semi-public institutions such as the UK Ministry of Defence, the Coal Authority, and United Utilities. This demonstrates that not only the private sector but also state-supported projects are exposed to ethical and legal risks. The complex structure of the supply chain and the blending of polysilicon at different production stages make it difficult to monitor these risks. Therefore, the United Kingdom’s energy transition process faces not only technical and economic challenges but also a significant ethical oversight issue (Ambrose & Jolly, 2021).

In this context, using  Sayari, the name of a company linked to “forced labor allegations” (in the example: LONGi) was first searched with the “Country of Arrival” set to the United Kingdom. Then, the “Country of Departure” was set to China.

Subsequently, the forced labor risk was assessed based on the company’s recent import dates, followed by an evaluation of which sources this risk is derived from.

Similarly, by examining the tab that addresses risks for the buyer, the risk assessment confirmed that the example company, LONGi, produced solar panels in China using forced labor in East Turkistan and sold products linked to forced labor to the United Kingdom.

 

 

Policy Recommendations

The reflection of risks related to production conditions in East Turkistan (Xinjiang) on the global solar panel supply chain should be regarded as a critical issue for the United Kingdom’s energy transition and economic security. Within this framework, the following policy recommendations have been developed for consideration by relevant institutions and stakeholders:

1.     Strengthening Supply Chain Transparency

Enhanced tracking of the origin of critical components used in the United Kingdom’s renewable energy investments can provide long-term assurance for both public institutions and the private sector.

In this context, it may be useful to:

Such measures would particularly help make upstream risks more visible in complex and low-transparency supply chains, such as those in the solar energy sector.

  1. Development of a Sectoral Guide for Ethical Sourcing

To raise awareness of forced labor risks, an “Ethical Sourcing Framework” developed with the participation of public institutions, academia, industry representatives, and civil society organizations could serve as a guiding tool for investors and suppliers.

Within this framework:

  1. Supporting Analytical Studies on Alternative Supply Sources

To reduce high dependence on a single country for solar panel supply, it is important to promote analytical studies that compare alternative supply sources.

A “Supply Chain Risk Analysis” study prepared within this context could provide comparative information on:

Such a study would help public and private sector actors make more informed decisions.

    1. Enhancing the Effectiveness of Domestic Production Support

In line with the United Kingdom’s goal of increasing domestic production capacity in clean energy technologies, it is important to design existing incentive mechanisms to build long-term technological capacity and resilience.

Within this framework, it may be useful to:

This approach would help align industrial policies more closely with the objective of reducing external dependency.

    1. Enhancing Awareness of Ethical Consumption and Investment

Considering that the energy transition is not only a technical but also a societal process, raising awareness among investors and consumers emerges as an important policy tool.

Within this scope:

These measures can contribute to strengthening societal awareness of ethical sourcing.

Outcome

Allegations of forced labor in China’s Xinjiang region pose significant ethical, legal, and economic risks within the global solar energy supply chain. As addressed in this study, the United Kingdom’s path toward achieving its net-zero targets intersects directly with these risks, particularly due to the concentration of polysilicon production in China.

This situation renders the United Kingdom vulnerable in multiple ways, including reputational risk, potential exposure to trade restrictions, and pressure to comply with the increasingly stringent regulatory frameworks of key partners such as the United States and the European Union. In particular, anti-forced labor regulations enacted in the U.S. and emerging legislation in the EU carry the potential to produce significant implications for UK supply chains.

This issue is not only a matter of human rights but also one of economic security and strategic policy. The inclusion of products associated with forced labor in supply chains can undermine the United Kingdom’s credibility in the international trade system and may lead to indirect trade barriers. Furthermore, re-export activities through Southeast Asian countries and the vertical integration strategies of Chinese companies further complicate supply chain transparency, thereby amplifying these risks.

Effectively managing this multidimensional issue requires a comprehensive and coordinated approach. The recommendations presented in this policy brief encompass areas such as the development of the regulatory framework, enhancement of supply chain transparency, strengthening of international cooperation, and support for domestic production capacity.

In the long term, ensuring the United Kingdom’s energy security and sustainability will depend not only on technical and economic capacity but also on adherence to ethical principles. Establishing transparent, accountable, and human-rights–compliant supply chains will strengthen the UK’s position in the global renewable energy market and reinforce its international reputation. The decisions made in this process will determine not only the country’s economic security but also its contribution to upholding global ethical standards.

 

 

 

 

 

 

 

 

 

 

 

References:

Ambrose, J., & Jolly, J. (2021, April 25). Revealed: UK solar projects using panels from firms linked to Xinjiang forced labour. The Guardian. https://www.theguardian.com/environment/2021/apr/23/revealed-uk-solar-projects-using-panels-from-firms-linked-to-xinjiang-forced-labour

Crawford, A., & Murphy, L. T. (2023, Kasım). Overexposed: Uyghur region exposure assessment for solar industry sourcing. Sheffield Hallam University Helena Kennedy Centre for International Justice. https://shura.shu.ac.uk/34917/1/Crawford%20Murphy%20et%20al%20%20Over-Exposed%20November%202023.pdf

Cockayne, J., Huerta, E. R., & Burcu, O. (2022, Temmuz). ‘The energy of freedom’? Solar energy, modern slavery, and the just transition. The British Academy.
https://www.thebritishacademy.ac.uk/documents/4338/Just-transitions-energy-freedom1.pdf

Murphy, L. T., & Elimä, N. (2021). In broad daylight: Uyghur forced labour and global solar supply chains. Sheffield Hallam University Helena Kennedy Centre for International Justice.
https://shura.shu.ac.uk/29640/1/Murphy-InBroadDaylight%28VoR%29.pdf

Richardson, J. (2026, February 12). Solar panel manufacturers and products. Renewable Energy Hub. https://www.renewableenergyhub.co.uk/main/solar-panels/solar-panel-manufacturers-and-products

Xinjiang Uygur Autonomous Region Department of Human Resources and Social Security. (2026, January 27). 2026 Xinjiang Two Sessions: Excerpts from the government work report. https://rst.xinjiang.gov.cn/xjrst/c112484/202601/46229a50329a4c74b45a6d14709288b2.shtml

 

April 2026