US Expands Uyghur Forced Labor List: Xinjiang Aluminum Supply Chain Becomes New Risk Point for Auto Industry

US Expands Uyghur Forced Labor List: Xinjiang Aluminum Supply Chain Becomes New Risk Point for Auto Industry

The US has added more Chinese companies to the list of entities related to Uyghur forced labor, with a focus on Xinjiang aluminum. As aluminum is widely used in car frames, wheels, and battery foils, automakers face stricter risks of raw material tracing and import compliance.

US enforcement of imports related to forced labor in Xinjiang is expanding from cotton and textiles to aluminum and automotive supply chains. Human Rights Watch pointed out on August 5 that the US government has recently added 43 Chinese companies to the list of entities related to Uyghur forced labor, including aluminum producers in Xinjiang.

According to the Uyghur Forced Labor Prevention Act, goods produced by companies on the list are presumed to be related to forced labor unless importers can provide sufficient evidence to rebut this presumption, in which case the goods are not allowed to enter the US market.

Figure: Human Rights Watch illustration related to Xinjiang aluminum and forced labor supply chains.

Human Rights Watch stated that the list now covers five major aluminum producers in Xinjiang. The organization previously estimated that about 15% of China's aluminum production comes from Xinjiang, accounting for about 9% of global supply. The Xinjiang aluminum industry and its upstream coal mines and power plants have been linked to government-led labor transfer programs, which are considered to have a coercive nature by human rights organizations.

Aluminum has become a new focus of enforcement because it is deeply embedded in the automotive industry chain. From engine components, frames, and wheels to new energy vehicle battery foils, aluminum materials are used in many components. As long as the source of raw materials cannot be traced, automakers may be exposed to the risk of import detention even if they do not directly purchase products from Xinjiang companies, due to secondary or tertiary suppliers.

The US government has already listed aluminum as a key industry for enforcement under the Uyghur Forced Labor Prevention Act. For automakers, this means that supply chain audits cannot stop at the list of component suppliers but need to continue to trace back to smelters, power sources, and primary aluminum production.

It is necessary to distinguish that being listed on the US administrative list is not equivalent to a court having made a criminal judgment against a company. The list is part of the import and enforcement mechanism; companies and importers can still submit evidence according to US law to prove that specific goods do not involve forced labor.

However, for multinational automakers, the risk has transformed from a moral reputation issue to a real trade risk. If the source of aluminum materials cannot be proven, whole vehicles or parts may be detained at US customs. The Xinjiang forced labor issue is thus entering the global automotive industry's procurement, compliance, and market access systems along the raw material chain.