Solar Stewardship Initiative Fails to Address Solar Industry Reliance on Uyghur Forced Labour

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March 10, 2024

[Below is a statement by the Coalition to End Forced Labour in the Uyghur Region, for which the Uyghur Human Rights Project is a Steering Committee Member]

The Solar Stewardship Initiative (SSI), a joint initiative of Solar Power Europe and Solar Energy UK, fails its members and the wider solar industry by remaining silent on Uyghur forced labour, the most pervasive and severe human rights risk in the solar sector. The SSI should provide clear and unequivocal guidance to its members that in state-imposed forced labour contexts, like the Xinjiang Uyghur Autonomous Region (Uyghur Region), ending business relationships is the only responsible course of action. Further, ‘certification’ against the SSI Standards should not be considered as reliable evidence of compliance with forced labour regulations.

Every level of the solar panel supply chain is exposed to Uyghur forced labour. Recent research confirms that the solar industry remains highly reliant on the Uyghur Region for key inputs, where state-imposed forced labour is an integral element of a government-imposed system of oppression against the Uyghur population. Abuses in the Uyghur Region may constitute crimes against humanity according to the UN High Commissioner for Human Rights. The SSI’s silence on the industry’s continued reliance on state-imposed forced labour severely undermines the credibility and effectiveness of the initiative, which portrays itself as an industry standard to create a more sustainable solar supply chain.

The Coalition to End Forced Labour in the Uyghur Region notes that several manufacturer members of the SSI are companies that have been alleged in reports to have a high risk of exposure to the Uyghur Region and forced labour. This could create a possible conflict of interest on the SSI’s ability to speak out publicly on the issue of Uyghur forced labour, to encourage diversification of the supply chains, and to call for an immediate exit from the Uyghur Region.

The SSI ESG Standard states that its members shall observe the UN Guiding Principles on Business and Human Rights including by undertaking human rights due diligence. However, as noted in the submission made by the Coalition to the SSI public consultation, it is a practical impossibility to conduct human rights due diligence in the Region, or to use or increase leverage to affect change in the Region due to the pervasive and systemic state-imposed human rights abuses occurring. Yet, the final version of the ESG Standard does not reflect this reality for its members and currently fails to address the exposure of the solar industry to Uyghur forced labour in any way.

Solar Power Europe published a position paper calling for the SSI to serve as a carve-out or safe haven under the the proposed EU Forced Labour Regulation, which would prohibit from the EU market all global products made with forced labour, stating, “The Regulation should propose a mechanism to exempt companies from investigations by national authorities, if the companies can prove by certificates, participation in recognised auditing systems or credible multi-stakeholder industry initiatives (such as the Solar Stewardship Initiative will be) that their business partners are compliant with the relevant norms and standards…”.

Participation in the SSI initiative should not in any way impact robust enforcement of the EU Forced Labour Regulation. Rather, the SSI should urgently provide members with the guidance and tools to comply with relevant regulations including the U.S. Uyghur Forced Labor Prevention Act (UFLPA), which prohibits any goods made in part or in whole in the Region from importation into the US, and in the future, the EU regulation.

The Coalition demands that:

  • Forthcoming EU regulation does not allow the SSI, or any comparable audit or certification scheme, to act as proof of absence of forced labour in any product made with inputs from the Uyghur Region.
  • Solar Power Europe and Solar Energy UK urgently issue a public statement clarifying the organisations’ positions on the solar industry’s exposure to the egregious human rights abuses in the Uyghur Region.
  • Solar Power Europe and Solar Energy UK publicly recognise the impossibility of audits and certification processes in the Uyghur Region, and adapt the SSI accordingly.
  • Solar Power Europe and Solar Energy UK require members to apply the SSI standards across all their product lines and operations. Otherwise, companies will have a green light to bifurcate supply chains and continue sourcing from or maintaining operations in the Uyghur Region.
  • Solar Power Europe and Solar Energy UK meaningfully engage with the Coalition on the SSI supply chain traceability protocol, which is under development. To ensure full transparency and reliability of such a tool, supply chain tracing should be publicly disclosed. All SSI standards should require companies to disengage from any business relationships in the Uyghur Region.