On the face of it solar panels have very little to do with cotton tee shirts.
One couldn't imagine, in fact, any two products that have less in common.
That being said, they have one thing in common and that is that they often contain raw materials that may be traced to a region in China where there are allegations of systematic forced labour.
Over the last two years, the United States has implemented the Uyghur Forced Labor Prevention Act (UFLPA). This legislation creates a rebuttable presumption that any product imported into the US - which contains inputs from certain regions in China (especially Xinjiang) is presumed to be a product of forced labour. Among the products that have been targeted for enforcement are solar panels (made from polysilicon mined in Xinjiang), apparel (using cotton harvested in Xinjiang) and tomato paste (using tomatoes grown in Xinjiang). More recently, a wider range of products have been stopped at the US border because of allegations that they contained inputs from Xinjiang.
Companies that have followed the UFLPA will be aware that Canada has not adopted similar legislation. However, Canada does have an obligation to prohibit the entry of goods made with forced labour (from any country of origin).
For the apparel industry, of particular concern are products that may contain cotton harvested in Xinjiang and further processed elsewhere in China or other countries. For many companies, the main issue is whether they have any insight into where the cotton inputs were harvested. Our view is that many companies do not understand fully the supply chain that supports their production of finished goods. Xinjiang produces approximately 20% of the world cotton supply.
Companies that have complex supply chains should take note of the fact that the CBSA is starting to detain imports of solar panels where there may be a reasonable basis to believe forced labour is present. There are also reports that CBSA has directed officials at ports of entry to increase the scrutiny of shipments of solar panels, cotton apparel and products derived from tomatoes. For reference, US Customs has published a dashboard providing statistics on shipments subjected to UFLPA reviews and enforcement actions. This video highlights actions taken under UFLPA and other initiatives.
We continue to follow this issue closely.
CAF members with questions about this policy should contact Executive Director, Bob Kirke, bkirke@apparel.ca.