Since the release of “In Broad Daylight” in May 2021, the solar industry has taken action to comply with new regulations and address public outrage over the crisis in the Uyghur Region. Public pressure and legislation like the Uyghur Forced Labor Prevention Act (UFLPA), an import ban on all goods made in the Uyghur Region, has led to solar firms bifurcating their supply chains in an effort to produce some XUAR-free modules. Despite this bifurcation, most solar module manufacturers remain exposed to XUAR-sourcing.
At the same time as scrutiny of solar supply chains has increased, transparency has decreased in the solar industry since the initial reporting on the complicity of the industry in state-imposed forced labour in the Uyghur Region, where millions of Uyghurs and other Turkic ethnic groups face mass oppression. The lack of transparency has made it increasingly difficult to verify whether supply chains are free from risk of Uyghur forced labour and reduces trust in the solar industry.
To address the lack of transparency, this report deploys the expertise of a solar industry expert to create a model that can be used to assess solar module exposure to XUAR-sourcing at every stage of production– including metallurgical grade silicon (MGS) sourcing, a precursor to polysilicon that has received less attention. The report assesses ten manufacturers, including the top five manufacturers that create 70% of the world’s solar modules combined.
The most significant findings of the report include the following:
- The Uyghur Region now accounts for approximately 35% of the world’s polysilicon (down from 45%) and as much as 32% of global metallurgical grade silicon production.
- The vast majority of modules produced globally continues to have exposure to the Uyghur Region. Production in China significantly increases exposure.
- Some of the world’s largest module manufacturers appear to have bifurcated their supply chains to create a product line that they claim to be free of XUAR inputs, though evidence of these claims varies by supplier. Most companies have suggested that these supply chains are dedicated to the US market or designed with UFLPA compliance in mind. The portion of modules made by China-based companies on these dedicated supply chains appears to range from 7–14% of the companies’ total production capacity globally.
- Companies that have created supply chains purportedly free of XUAR inputs continue to source from suppliers or sub-suppliers that have exposure to the Uyghur Region for other product lines.
- It is sometimes impossible to determine if it is indeed the case that there dedicated product lines are XUAR-input-free because companies do not disclose sufficient supply chain information.
- Despite significant global pressure for increased transparency, information regarding solar industry sourcing is becoming less transparent over time, thwarting the world's ability to source ethically.
The shift to renewable energy is necessary and urgent. Solar energy is a key part of the clean energy transition. It must also be a just transition. Human rights cannot be ignored in the process, and any future we build must not entail the suffering of those who work to create it.
The report uses publicly available records, including corporate annual reports, press releases, announced production capacity, customs records, and correspondence with responsive solar producers. It also applies more than thirty years of expertise in auditing the most obscure parts of the solar supply chain (quartz – metallurgical grade silicon – polysilicon) to determine risk where visibility is least possible.
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