The Department of Labor has added polysilicon from China, a product used in the production of solar panels, to a list of foreign-made goods it has reason to believe are produced by child and/or forced labor in violation of international standards. This list, which is available here, currently totals 156 goods from 77 countries.
The DOL is required to take steps to ensure that the goods on this list are not imported into the U.S. if they are made with forced or child labor, including working with producers to help set standards to eliminate the use of such labor.
In addition, according to a Politico article, the Biden administration is considering imposing a withhold release order against polysilicon from China’s Xinjiang Uyghur Autonomous Region. About 45 percent of the global supply of solar-grade polysilicon is made in the XUAR, the article notes, and another 35 percent comes from other regions in China. A WRO would direct U.S. Customs and Border Protection to detain imports of polysilicon at U.S. ports.
Sandler, Travis & Rosenberg offers a comprehensive suite of services to help companies address forced labor concerns, including supply chain reviews, due diligence strategies, and proactive remediation. For more information, please contact Amanda Levitt (at (212) 549-0148 or via email), David Olave (at (202) 730-4960 or via email), or Nicole Bivens Collinson (at (202) 730-4956 or via email). You can also click here for ST&R’s forced labor resources page.
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