Investigations by UN bodies (most notably by the UN Special Rapporteur on Contemporary Forms of Slavery in its July 2022 report to the UN General Assembly ), academics and journalists have presented evidence on a number of human rights abuses including the use of forced labour in the Xinjiang Autonomous Region of China (XUAR). According to recent data, approximately 35% of the world’s polysilicon, and 32% of global metallurgical grade polysilicon, the material from which polysilicon is made, is produced in XUAR.

Considering the risk of forced labour can be several layers removed in companies’ supply chains, the global solar value chain remains at risk of exposure to the human rights risks in XUAR.

In response to the issue, for example, the USA has introduced the Uyghur Forced Labor Prevention Act and the EU recently adopted its Forced Labour Import ban. Critics are concerned that such regulations risk creating "bifurcated" supply chains – with solar panels with "clean" supply chains sent to the US market and solar panels with supply chains exposed to risks of forced labour are shipped to markets where similar regulations are not in place. Calls for a more coordinated global response are increasing.

Supply chain transparency and traceability is critical to start addressing the issue. In 2023, the Resource Centre approached 24 companies in the solar sector asking them to outline their response to the risk of exposure to forced labour in XUAR. Responses are available here and analysis of key findings in the accompanying briefing.

In the 2025 Benchmark, companies were once again assessed on whether they publish independently verified full solar panel supply chains to raw materials level. In addition, they were also assessed on whether they have a public commitment to undertake such a mapping and identify links with areas at high risk of forced labour.

No company currently has such a commitment or mapping in place, but a few companies have increased their traceability efforts, iin response to recent regulations.

Companies at different stages of the renewable energy value chain can play a significant role in using their leverage to increase transparency and accountability on the issue. For example, Brookfield Renewables stated: “Large developers pushing for traceability helped move the market. We were one of the first to get one of the large solar panel suppliers to undertake traceability.”

In cases where companies are linked to human rights abuses, the OHCHR’s Interpretive Guide to the UNGPs and Considerations for Remaining and Exiting outline that companies are expected to seek to increase leverage and if unsuccessful, consider ending the business relationship. In its July 2022 report, the UN Special Rapporteur on Contemporary Forms of Slavery refers to the abuses in the context of “State mandated systems”, where it is difficult, if not impossible, for companies to have leverage.

Moreover, as OHCHR explains, the UNGPs expect companies to consider the severity of the impacts in case of crucial relationships. It is reasonable to conclude that in the case of XUAR, where the severity of the impact is high (as documented by the UN Special Rapporteur on Modern Slavery and related UN expert body report) and companies lack the ability to undertake HRDD or use their leverage, ending business relationships with suppliers active in or linked to XUAR through sourcing of raw materials remains the only tool available for companies that want to ensure supply chains are not at risk of exposure to forced labour.