Just as importers are preparing for implementation of the Uyghur Forced Labor Prevention Act (UFLPA)’s rebuttable import ban on any articles made wholly or in part in the Xinjiang Uyghur Autonomous Region (XUAR) effective Tuesday, June 21, a scholarly report was just released linking alleged environmental and labor abuses in the XUAR to a very common material – polyvinyl chloride (PVC).
The report notes that China is the world’s largest producer (and consumer) of PVC and 20 percent of China’s PVC comes from the XUAR, making the XUAR a world leader in the production of PVC plastics in recent years.
PVC is a plastic used in a wide variety of products including, but certainly not limited to:
- vinyl flooring
- pipe
- footwear soles
- everyday household items
The report also identifies the following products potentially having connections to the XUAR:
- rayon
- polyester
- spandex
- polyurethane
CBP’s recently published fact sheet identified chemicals (such as PVC) and apparel/textiles (for which chemicals are often a precursor into manmade fabrics), along with agricultural goods, as top commodities imported into the U.S. from the XUAR and at a high risk of being derived from forced labor. Importers are expected to know their supply chain past Tier 1 through to its underlying materials/inputs; or visibility from Earth to hearth.
© 2022, Sandler, Travis & Rosenberg, P.A. Originally published in the [June 17, 2022] issue of the Sandler, Travis & Rosenberg Trade Report. Reprinted by permission
