Built on Repression: PVC Building Materials’ Reliance on Labor and Environmental Abuses in the Uyghur Region

Laura T. Murphy, Jim Vallette, Nyrola Elimä

Over the course of the last five years, the People’s Republic of China (PRC) government has embarked on a campaign of repression that nine governments have determined to be either “genocide” or “crimes against humanity.” The PRC has further instituted a massive state-sponsored system of forced labor throughout the Xinjiang Uyghur Autonomous Region (the XUAR or Uyghur Region). Because refusal to participate in government assistance can be considered a sign of religious extremism and punishable with internment or prison, Uyghur and other minoritized workers from the region are unable to refuse or voluntarily exit jobs assigned to them by the government. For this reason, experts have agreed that the PRC government’s programs of labor transfers and surplus labor employment transfers meet the standards of the definitions of forced labor instituted in international law and protocols. The United States legislature has found the evidence of forced labor so convincing and overwhelming that it has taken the unusual step of prohibiting the import of any product made in whole or in part in the Uyghur Region beginning in June 2022.

Despite the rights violations that have been documented in the Uyghur Region and increased awareness and wariness of the products of forced labor entering international supply chains, products made with Uyghur forced labor continue to pour across international borders, at times even directly from the Uyghur Region. While solar-grade polysilicon-, cotton-, and tomato-based products have garnered intense scrutiny because of the Uyghur Region’s significant share of production within those sectors, the PRC has guaranteed that avoiding Uyghur forced labor made products will be challenging for governments, corporations, and consumers by incentivizing manufacturers to move out to the region and utilize the forced labor programs sponsored by the state. The Uyghur Region is now home to a constantly growing number of industries, including but not limited to agricultural products, apparel, electronics, technology, green energy solutions, mining, pharmaceuticals, and chemicals.

As the United States and other countries ponder how to prevent Uyghur forced labor made goods from reaching consumers, China has moved yet another practically unnoticed product to the Uyghur Region: polyvinyl chloride (PVC).

This report investigates the increased manufacturing of PVC in the Uyghur Region, the manufacturers’ use of state-sponsored labor transfers, the environmental damage this manufacturing is causing, and the routes by which the resulting PVC-based products may make their way into international markets.

The evidence reviewed in this collaboration between the Helena Kennedy Centre for International Justice at Sheffield Hallam University and Material Research indicates the following:

What is PVC?

Polyvinyl chloride, commonly known as vinyl or PVC, is a plastic with a wide range of applications. People encounter it every day in products from shower curtains to shoes soles to credit cards. Most products made from PVC are used in building and construction. China is the world’s largest producer (and consumer) of PVC. 20% of China’s PVC comes from the Uyghur Region.

The Uyghur Region has become a world leader in the production of PVC plastics in recent years.

The two largest PVC manufacturers in China are both state-owned enterprises based in the XUAR:

  • Xinjiang Zhongtai Chemical (2.33 million tons per year)
  • Xinjiang Tianye (1.4 million tons capacity per year).

Together the XUAR’s PVC manufacturers produce 10% of the world’s PVC.

All of these companies have been active participants in the XUAR’s notorious labor transfer programs. The report focuses on Zhongtai Group, a prolific participant in the government’s schemes.

  • Zhongtai Group has transferred more than 5,000 citizens deemed to be surplus laborers,” according to its own reports—more than perhaps any other company described in academic or journalistic accounts of labor transfers in the XUAR.
  • Zhongtai runs ideological and vocational training schools that have trained thousands of rural farmers to become compliant factory laborers.
  • Despite significant mechanization, Zhongtai continues to bring in transferred low-skill laborers who work directly in the production of the PVC and their other products.
  • During the COVID-19 pandemic lockdown, Zhong- tai Group reported having received 1,180 transferred employees from Uyghur and other Indigenous communities in the XUAR in only two weeks. The company claimed to have taken advantage of their access to Uyghur workers and the government’s permission to assign them to work, putting them at extraordinary risk. The company celebrated that this allowed them to increase their international sales reach.
  • Though it is a state-owned enterprise, Xinjiang Zhongtai has raised significant financing from international banks and pension funds, including the Norway Pension Fund, Vanguard, and the Alaska Permanent Fund.

Even in state media and corporate publicity, reports reveal clear indicators that Indigenous people transferred from the southern XUAR are not voluntarily working at Zhongtai.

Furthermore, the manufacturing methods used by the XUAR plants are so dependent on both coal and mercury that the Uyghur Region is one of the very few places on earth where these extraordinarily hazardous methods of PVC manufacturing are allowed to persist. The production processes present extraordinary hazards, including

  • PVC production in the XUAR currently consumes an estimated 340 tons of mercury per year, of which 9.3 tons are released into the air.
  • The seven Uyghur Region-based PVC plants’ estimated air emissions are equal to more than half of the air releases of mercury (14.8 tons) reported in all manufacturing in all of the United States in 2020.

The estimated 340 tons of mercury consumed by the seven PVC plants in the XUAR accounts for 15% of all mercury produced worldwide in 2021 (2,300 tons).

PVC plants have been built in the Uyghur Region in part to take advantage of the extraordinary coal resources in the region. As a result of basing manufacturing on dirty coal, PVC plants in XUAR, running at full capacity, will release an estimated 49 million tons of global warming gases, each producing more than any other similar plant.

Xinjiang Zhongtai is a contender for the most polluting plastics producer in the world.

What is Luxury Vinyl Flooring?

The top export application for China-originating PVC is luxury vinyl floor coverings. These are the synthetic wood and stone floors that we see all around us. People work, play and live on plastic sheets, tiles, and carpeting made of PVC. PVC is utilized in the production of basketball court flooring, and the floors of schools, nurseries, and hospitals, as well as in common domestic home flooring.

This PVC is being shipped internationally to serve as the base material for a wide variety of products, the most prevalent of which is luxury flooring. Many people building or remodeling homes in the U.S. would likely be surprised to learn the following:

XUAR-manufactured PVC is so inexpensive, it has become the most common material of all floors sold in the United States.

PVC flooring resins made in China are present in more than one-quarter of all flooring sold in the U.S. The XUAR produces the lion’s share of PVC resins used in that flooring.

PVC flooring shipments from China to the U.S. increased by 300% in the last several years.

PVC made by Xinjiang Zhongtai is shipped directly to Vietnamese flooring manufacturer Jufeng New Materials, which then ships luxury PVC-based flooring to the top U.S. flooring brands sold in major home improvement outlets and online. Brands selling flooring at very high risk of Xinjiang inputs include Home Legend for Home Depot, Armstrong, Mannington Mills, Mohawk, Lumber Liquidators, Congoleum, and many others.

  • Zhongtai is a primary supplier of PVC to Zhejiang Tianzhen, which is a major Chinese flooring manufacturer and also a parent company of Vietnam’s Jufeng New Materials, presenting a potential opportunity for transshipment of XUAR-made PVC and PVC-based flooring that should be monitored.
  • Zhongtai’s PVC is also highly likely being used in the production of PVC piping, which is then shipped to distributors across Africa, Asia, the Middle East, Europe, the U.K., and South and Central America.

The Uyghur Region is being used as both a source of cheap labor and cheap coal, and also as a dumping ground for the most hideous of environmental hazards. The abuse of human labor and the environment in the XUAR has significantly reduced the price of manufacturing PVC and thus of manufacturing luxury flooring and other building materials worldwide.

Through these abusive practices, Uyghur forced labor makes its way into our homes, schools, and hospitals, serving as the very literal foundations upon which we work and play. PVC is not alone on these counts. Uyghur forced labor also makes its way into the food we eat, the computers we work on, the toys we play with, the clothes we wear.

Understanding the underlying circumstances that make manufacturing in the XUAR so incredibly profitable for companies is critical to recognizing the high costs that people and the planet pay for consumers to have access to ever-cheaper products. Human rights abuses and environmental degradation of the very worst kind are being perpetrated in the XUAR, and the products of those abuses are being shipped all around the world. It’s the flooring industry’s turn now to identify its risk and extract themselves from complicity in Uyghur forced labor.

But it cannot stop with them. We must investigate our supply chain connections to Uyghur forced labor from the floor up. Every company that sources from China should be conducting research similar to that presented in this report to identify exposure and eliminate it. The following report can serve as a sort of roadmap for that necessary and urgent work.

“In order to allow employees to integrate into the new environment more quickly, the company provided them with Han supervisors,” reports China News. Maynur, pictured here, only had a junior-high- level education when she was transferred to Zhongtai’s Huatai plant. Here, she inspects a package and manages machinery. Credit China News, Online.

Read full report here.