Content uploaded by Jim Vallette
Author content
All content in this area was uploaded by Jim Vallette on Jun 28, 2022
Content may be subject to copyright.
PVC Building Materials’ Reliance on Labor and
Environmental Abuses in the Uyghur Region
BUILT ON
REPRESSION
June 2022
Laura T. Murphy, Jim Vallette, Nyrola Elimä
2
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Acknowledgements
© 2022 Laura T. Murphy, Jim Vallette, and
Nyrola Elimä
Citation: Murphy, L., Vallette, J., and Elimä,
N. (2022). “Built on Repression: PVC Building
Materials’ Reliance on Labor and Environ-
mental Abuses in the Uyghur Region.” Shef-
eld, UK: Shefeld Hallam University Hele-
na Kennedy Centre for International Justice.
Available Online.
Acknowledgements: The authors would like
to express gratitude to the many people who
have contributed their knowledge and time
to the development of this report, including
but certainly not limited to Connie Murtagh,
Kendyl Salcito, Rian Thum, and Liz Carter,
and our student research team. We are grate-
ful for all of the experts who gave feedback
on this report or provided research support
who prefer to remain anonymous. Publication
costs for this report were supported by a grant
from the Freedom Fund. The information pre-
sented here is wholly the work of the authors;
funders had no role in the design, research,
writing, or review of this report.
Design and Layout: Southpaw Creative
This publication is designed to provide accu-
rate and authoritative information in relation
to the subject matter covered, based on the
evidence available. It is a point-in-time analy-
sis; some of the information presented herein
may change as supply chains or government
initiatives shift. It is provided with the under-
standing that the author and publisher are
not engaged in rendering any form of profes-
sional or other advice or services through the
publication of this report. The report reects
the authors’ own conclusions, based on in-
ferences drawn from an analysis of publicly
available sources. No person or entity should
rely on the contents of this publication with-
out rst obtaining professional advice.
About the authors:
Laura T. Murphy is Professor of Human Rights and Contempo-
rary Slavery at the Helena Kennedy Centre for International Jus-
tice at Shefeld Hallam University. She is author, most recently,
of Freedomville: The Story of a 21st Century Slave Revolt (Co-
lumbia Global Reports) and The New Slave Narrative: The Battle
over Representations of Contemporary Slavery (Columbia Univer-
sity Press, 2019) as well as academic articles on forced labor. She
has consulted for the World Health Organization, the U.S. Depart-
ment of Health and Human Services, and the U.S. Ofce of Vic-
tims of Crime. She has provided expert evidence briefs regarding
the situation in the Uyghur Region for the U.S., U.K., and Austra-
lian governments, as well as for the Uyghur Tribunal.
Nyrola Elimä is a researcher at Shefeld Hallam University’s Hel-
ena Kennedy Centre for International Justice. She has published
essays in The New Yorker and The Spectator. Her research has
contributed to a Pulitzer Prize winning media report. Nyrola tes-
tied before U.S. congress about global solar supply chains and
Uyghur forced labor. She conducts research in Chinese, Uyghur,
English, and Swedish. As a consultant, she provides research on
Chinese corporate structures, supply chain mapping, and ESG risk
assessment to scholars, investment rms, and international media
organizations.
Jim Vallette is president of Material Research L3C, a charitable
and educational business based in Maine and present on three
continents. Material Research works in service to impacted com-
munities, in collaboration with community members, reporters,
academics, data scientists, and campaign organizers. Jim and the
Material Research team investigate industrial practices, global
supply chain connections, and their societal, public health, and
environmental impacts. Advances that followed Jim’s research in-
clude the Basel convention ban on toxic waste trade, the end of
World Bank nancing of fossil fuel extraction, and the removal
of some toxic chemicals from building materials. Jim is the lead
author of an extensive catalog of plastics-related reports, includ-
ing Chlorine and Building Materials: A Global Inventory of Pro-
duction Technologies, Markets, and Pollution (Healthy Building
Network, two parts, released in 2018 and 2019), Post-Consumer
Polyvinyl Chloride in Building Products (Healthy Building Net-
work/StopWaste, 2015), and The New Coal: Plastics and Climate
Change (Beyond Plastics, 2021).
3
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
The Helena Kennedy Centre for Interna-
tional Justice at Sheffield Hallam Univer-
sity is a leading center for social justice and human
rights research, practice, and pedagogy. It provides a
vibrant environment at the cutting edge of legal and
criminal justice practice which prepares students for ex-
cellence in their chosen professional careers.
The center is home to a range of social justice and hu-
man rights activities that include research, global en-
gagement, impact on policy, professional training, and
advocacy.
Its central values are those of widening access to justice
and education, the promotion of human rights, ethics in
legal practice, equality and a respect for human dignity
in overcoming social injustice.
The center works on high-prole projects in a variety
of human rights and social justice areas. Research and
projects concern modern slavery, gender-based vio-
lence, hate crime, and more.
4
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Material Research is a charitable and ed-
ucational company based in Maine, USA.
It was launched in 2019 to expand public knowledge of
environmental, public health, and human-rights abus-
es and solutions. Its international team of researchers
connects the dots of many supply chains.
Much of its work is focused on toxic chemicals and cli-
mate pollution. It researches the movement of harmful
materials, such as tar sands oil from Alberta, leather
from the Amazon, and disinformation funded by fossil
fuel and other industries. Material Research identied
the contribution of plastics to greenhouse gas emissions
in Beyond Plastics’ 2021 study, The New Coal: Plastics
and Climate Change.
It works with leading environmental organizations, in-
cluding Center for Environmental Health, Blue Green
Alliance, ChemSec, Coming Clean, Environmental Jus-
tice Health Alliance, Earthjustice, Public Health Watch,
Women’s Voices for the Earth, Defend Our Health,
Greenpeace, Toxic Free Future, Black Women for Well-
ness, Breast Cancer Prevention Partners, and Interna-
tional Sustainable Chemistry Collaborative Centre.
Collaborative investigations form the basis for positive
actions, lead to policies that reduce harm to communi-
ties that suffer the most severe impacts, and increase
the proportion of ecologically-sound, socially-just pro-
duction worldwide.
5
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Table of Contents
Executive Summary 1
Introduction 4
PVC Manufacturing in the Uyghur Region 4
Stages of Manufacturing PVC in XUAR 6
Environmental And Health Hazards Of Manufacturing Pvc 7
Forced Labor in the Uyghur Region 9
The Harms of PVC Manufacturing in the Uyghur Region 10
1. Xinjiang Zhongtai Group 11
Labor Transfers and Corporate Participation in Repressive Government Campaigns 13
Environmental and Health Hazards 17
International Investments 17
Conclusion 18
2. Xinjiang Tianye and Other PVC Manufacturers in the Uyghur Region 19
Xinjiang Tianye Group Co., Ltd. 19
Xinjiang Yihua Chemical Co. 21
Aral Qingsong Chemical Co. 22
3. Tracing XUAR PVC to International Markets 23
Xinjiang Zhongtai Downstream Supply Chain Risk 23
Tianye Downstream Supply Chain Risk 26
Other PVC Downstream Supply Chain Risks 27
Conclusion 28
Notes 29
Online Annexes
Annex A — International Corporate Supply Chain Risk of XUAR Labor Transfers
Annex B — Examples of Jufeng Flooring Shipped to International Brands
Annex C — Corporate Responses
1
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Over the course of the last ve 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 sys-
tem of forced labor throughout the Xinjiang Uyghur Au-
tonomous 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 voluntari-
ly 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 employ-
ment transfers meet the standards of the denitions 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 im-
port 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 wari-
ness 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
signicant share of production within those sectors, the
PRC has guaranteed that avoiding Uyghur forced labor
made products will be challenging for governments, cor-
porations, and consumers by incentivizing manufactur-
ers 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 indus-
tries, including but not limited to agricultural prod-
ucts, apparel, electronics, technology, green energy
solutions, mining, pharmaceuticals, and chemicals.
As the United States and other countries ponder how to pre-
vent Uyghur forced labor made goods from reaching con-
sumers, 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 dam-
age 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 Shef-
eld Hallam University and Material Research indicates
the following:
• 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 prolic participant in the
government’s schemes.
Executive Summary
What is PVC?
Polyvinyl chloride, commonly known as vinyl or
PVC, is a plastic with a wide range of applica-
tions. 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.
2
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
• 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 ac-
counts of labor transfers in the XUAR.
• Zhongtai runs ideological and vocational training
schools that have trained thousands of rural farm-
ers to become compliant factory laborers.
• Despite signicant mechanization, Zhongtai con-
tinues 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 trans-
ferred employees from Uyghur and other Indige-
nous communities in the XUAR in only two weeks.
The company claimed to have taken advantage of
their access to Uyghur workers and the govern-
ment’s permission to assign them to work, putting
them at extraordinary risk. The company celebrat-
ed that this allowed them to increase their interna-
tional sales reach.
• Though it is a state-owned enterprise, Xinjiang
Zhongtai has raised signicant nancing from in-
ternational 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 trans-
ferred 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 plac-
es on earth where these extraordinarily hazardous
methods of PVC manufacturing are allowed to per-
sist. 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’ esti-
mated 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 man-
ufacturing on dirty coal, PVC plants in XUAR, run-
ning at full capacity, will release an estimated 49
million tons of global warming gases, each produc-
ing more than any other similar plant.
• Xinjiang Zhongtai is a contender for the most pol-
luting plastics producer in the world.
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 ooring. Many people build-
ing or remodeling homes in the U.S. would likely be sur-
prised to learn the following:
• XUAR-manufactured PVC is so inexpensive, it has
become the most common material of all oors
sold in the United States.
• PVC ooring resins made in China are present in
more than one-quarter of all ooring sold in the
U.S. The XUAR produces the lion’s share of PVC
resins used in that ooring.
• PVC ooring shipments from China to the U.S. in-
creased by 300% in the last several years.
• PVC made by Xinjiang Zhongtai is shipped direct-
ly to Vietnamese ooring manufacturer Jufeng
New Materials, which then ships luxury PVC-based
ooring to the top U.S. ooring brands sold in ma-
What is Luxury Vinyl Flooring?
The top export application for China-originat-
ing PVC is luxury vinyl oor coverings. These
are the synthetic wood and stone oors 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 ooring, and the oors of schools, nurser-
ies, and hospitals, as well as in common domes-
tic home ooring.
3
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
jor home improvement outlets and online. Brands
selling ooring 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 ooring man-
ufacturer and also a parent company of Vietnam’s
Jufeng New Materials, presenting a potential op-
portunity for transshipment of XUAR-made PVC
and PVC-based ooring 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 haz-
ards. The abuse of human labor and the environment
in the XUAR has signicantly reduced the price of
manufacturing PVC and thus of manufacturing lux-
ury ooring 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 protable 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 en-
vironmental degradation of the very worst kind are be-
ing perpetrated in the XUAR, and the products of those
abuses are being shipped all around the world. It’s the
ooring industry’s turn now to identify its risk and ex-
tract 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
oor 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 follow-
ing report can serve as a sort of roadmap for that neces-
sary and urgent work.
“In ord er to allow empl oyees to integrate i nto the new enviro nment
more qu ickly, the compa ny provided the m with Han supe rvisors ,”
repor ts China News . Maynur, pict ured here, onl y had a junior- high-
level ed ucation when s he was transfe rred to Zhongtai 's Huatai
plant . Here, she ins pects a packag e and manages m achiner y.
Credi t China News, Online.
4
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Polyvinyl chloride, commonly known as vinyl or PVC,
is a plastic with a wide range of applications. People en-
counter it every day in products from shower curtains to
shoes soles to credit cards. The more rigid form is used in
construction materials like pipes and vinyl siding, as well
as for plastic bottles. Flexible forms are used in the man-
ufacturing of inatable toys and coatings on wire racks.
Most products made from PVC are used in building and
construction. By far the most common use of this plastic
is in water, sewer and other pipes. Another leading ap-
plication is ooring. People work, play and live on plastic
sheets, tiles, and carpeting made of PVC. PVC is utilized
in the production of basketball court ooring, and the
oors of schools, nurseries, and hospitals, as well as in
common domestic home ooring.
China is the world’s largest producer (and consumer) of
PVC.1 Most China-origin PVC is consumed domestically
(especially as PVC pipes), but the top export application
for China-originating PVC is oor coverings, and the
leading destination is the United States. Indeed, a ood of
PVC made in China has transformed the ooring industry
in the U.S. over the past decade.
In 2020, the U.S ooring industry sold 1.77 billion square
meters of product. About 20% of those oors – 406 mil-
lion square meters – came directly from China.2 In ad-
dition, China established relationships with factories in
Vietnam and India to turn PVC made in China into oor-
ing for the U.S. market.
PVC MANUFACTURING
IN THE UYGHUR REGION
The production of PVC is extremely energy consuming.
In order to transform chlorine into PVC, manufacturers
require a carbon-based feedstock. Chinese plants use
coal as the primary source of energy for manufacturing
PVC and the chemicals used to make it: chlorine and vi-
nyl chloride monomer.
The Xinjiang Uyghur Autonomous Region (XUAR or the
Uyghur Region) is home to 40% of China’s coal reserves. As
a result, the Uyghur region has become a world leader in
the production of PVC plastics (and other energy-con-
suming manufacturing processes) in recent years.
The two largest PVC manufacturers in China are based in
the Uyghur Region: Xinjiang Zhongtai Chemical Co. (新
疆中泰(集团)有限责任 公司 ) produces 2.3 million tons of
PVC per year from four locations, and Xinjiang Tianye
Group Co. (新疆天 业集团有限 公司 ) produces 1.4 million
tons per year from one location.3 Both are state-owned,
one by the XUAR government, the other by the Xinjiang
Production and Construction Corps, a state-run para-
military government and corporate conglomerate. The
XUAR is home to at least two other coal-to-PVC plants.
Combined, the seven PVC plants of the XUAR have the
capacity to produce 4,120,000 tons a year, and a planned
expansion and a new plant are projected to add another
1.23 million tons by 2024. See Table 1.
These coal-to-plastics facilities in the Uyghur Region are
mostly self-contained systems. The PVC manufacturers
own the coal mines and power plants that feed their fac-
tories, which they operate in industrial parks in symbio-
sis with other industries.
China’s boom in building and construction drove the rap-
id expansion of PVC production in the Uyghur Region,
but demand slackened in the late 2010s. Capacity ex-
ceeded demand, and the buildout paused. The pandemic
turned out to be valuable for positioning XUAR-manufac-
tured PVC in the international market. Unlike the rest of
the world, even during the most serious COVID-19 lock-
downs, these manufacturers promised non-stop produc-
tion and found new customers overseas.
By 2021, foreign demand allowed Xinjiang Zhongtai to
revive a project to build a one-million-ton plant in Aksu
Prefecture in XUAR. On April 11, 2022, Zhongtai issued
a tender for bids to build the complex. It will be one of
the world’s four largest PVC plants upon completion4 and
is the largest new PVC project planned anywhere in the
world,5 set to produce 1 million tons of PVC per year.6
China became the world’s largest PVC producer in 2006
and has kept growing since. The “extreme cheapness of
Introduction
5
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
coal” in the Uyghur Region sparked a renewal in the acet-
ylene PVC manufacturing method that had almost disap-
peared worldwide, according to industry analyst Charles
Fryer in 2006.7 By 2018, the industry had grown so large
that “Chinese production and consumption dominates
[the] global market structure,” according to Ana Lopez,
another industry analyst.8
The current 4.12 million tons of capacity in the Uy-
ghur Region equals more than 16% of China’s total
PVC production capacity (estimated to be 25.1 million
tons in 2019),9 and could be more than 20% when
Zhongtai’s new plant comes online. This means that
PVC made in the Uyghur Region currently constitutes
about 10% of all PVC production worldwide (estimat-
ed to be 41.8 million in 2019).10
The PVC industry’s pace of expan-
sion in the Uyghur Region correlated
with the growth of building and con-
struction in the whole of China. The
pace of construction has slackened
in recent years. By 2016, according
to analysts, China’s PVC capacity ex-
ceeded domestic demand by nearly
10 million tons.11 Producers, espe-
cially those in the XUAR, turned
to international markets in which
their price points are highly com-
petitive.
Xinjiang and other coal- and mer-
cury-based PVC from China is so
inexpensive that it has become
the most common material of all
oors sold in the United States.
The Center for Environmental
Health’s May 2022 report on the
climate impact of vinyl ooring
found that PVC resins made in
China are present in more than
one-quarter of all ooring sold in
the U.S. From 2012 to 2021, PVC
ooring shipments from China to
the U.S. “increased by 300% and
now exceed 5.1 billion square feet
per year,” CEH’s study calculated.
“If each square foot were connect-
ed end-to-end, [ooring] ship-
ments that arrived [from China]
in 2020 would run 1,040,000 miles: that’s enough vinyl
ooring to connect Earth to its Moon, four times over.”12
And that only accounts for the PVC ooring shipped di-
rectly from China. While in the rst quarter of 2022, Chi-
na manufactured 63% of all vinyl oor and wall coverings
shipped to the United States, Vietnam is an increasingly
signicant player. In early 2020, it supplied less than
2% of these products, but by 2022 it was supplying
nearly 20% of the PVC tiles sold in the U.S.13 While we
are unable to access Chinese shipping records, and the
United States’ own records regarding ooring is unusu-
ally opaque, we do have access to Vietnam imports and
exports that provide a clearer image of Zhongtai PVC’s
international reach.
Table 1. PVC Capacity in Xinjiang Uyghur Autonomous Region
NAME LOCATION
(XUAR)
OWNER CAPACITY
(TONS/YEAR)
YEAR
OPENED
Xinjiang Tianye Shihezi Xinjiang Tianye 1,400,000 1995
Fukang Energy Fukang Xinjiang Zhongtai 800,000 2012
Zhongtai Huatai Ürümqi Xinjiang Zhongtai 700,000 2006
Xinjiang Mahatma/
Shengxiong
Turpan Xinjiang Zhongtai 300,000 1958
Zhongtai Toksun Turpan Xinjiang Zhongtai 300,000 2019
Xinjiang Yihua Zhundong Hubei Yihua
Chemical
300,000 2015
Xinjiang Qingsong Aral , Aksu Pre-
fecture
XPCC/Qingdao
Haiwan
120,000 (*) 2015
Xinjiang Jinhui Zhaofeng
Energy
Baicheng
Industrial Park,
Aksu
Xinjiang Zhongtai 1,000,000 planned for
2024
Total current 4,120,000 (**)
Total planned 1,230,000
(*) Expansion to 3 50,000 ton s planned.
(**) Xinjiang Zho ngtai states tha t its total capac ity is 2.3 mi llion tons PVC. Pr oduction cap acity
gures found for the four exi sting plants total 2. 1 milli on tons, indicati ng that a potential 200, 000
tons of ad ditional ca pacity exis ts at these pla nts.
Xinjiang and other coal- and
mercury-based PVC from China is
so inexpensive that it has become
the most common material of all
oors sold in the United States.
6
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Most of the world’s PVC is made via the so-called
ethylene route of production. In the typical fac-
tory, natural gas liquids containing ethane are
“cracked” to make ethylene which is then react-
ed with chlorine to produce vinyl chloride mono-
mer (VCM), the precursor to PVC. In Xinjiang,
instead of natural gas liquids, PVC producers re-
act chlorine with coal to make VCM. This reac-
tion is fostered by the “acetylene” process. This
requires “much less capital investment than the
ethylene route,” according to chemical industry
analysts.14 It is in part the reliance on dirty coal
that makes that low price possible.
Stage 1: Extraction
Raw materials are mined.
• Coal is mined adjacent to or near the PVC
plants in the XUAR.
• Limestone is mined near the PVC plants in
the XUAR.
• Salt is extracted near the PVC plants in the
XUAR.
• Mercury is mined and rened in Guizhou
province, southeast of the XUAR.
Stage 2: Conversion to PVC.
Minerals are converted into chemical feed-
stocks, which are then manufactured into PVC.
Acetylene Production:
• Coal is heated for up to 36 hours to create coke.
• Coke is then mixed with lime in an electric arc fur-
nace to produce calcium carbide.
• The resulting calcium carbide is reacted with water
to form acetylene.
Chlor-Alkali Production:
• Salt is converted to chlorine and caustic soda at
chlor-alkali plants. (The caustic soda by-product of
this process is used for non-PVC products and sold
internationally.)
• Chlorine from the chlor-alkali plants is reacted
with hydrogen to form hydrochloric acid.
• Separately, chlorine is also reacted with mercury
to form crystals of mercuric chloride, which are
used as catalysts.
PVC Production:
• Hydrochloric acid is reacted with acetylene, in the
presence of mercuric chloride, to form vinyl chlo-
ride monomer (VCM) droplets. Initiators are mixed
into the droplets, starting a chain reaction called
polymerization that forms PVC plastic resins.
In addition to being used as a chemical feedstock, coal
is burned in on-site power plants that provide energy for
each of these processes.
STAGES OF MANUFACTURING PVC IN XUAR
Caustic Soda
Hydrogen
Hydrochloric
Acid
Calcium
Carbide
Chlor-Alkali
Electrolysis
Salt
VCM
PVC
Polymerization
Mercury-based
Synthesis
Hydrolysis
Acetylene
ChlorineMercury
Mercuric
Chloride
Limestone
Calcination
Coal
Coking
Coal-based PVC
Production
Adapted fr om Ran Hongtao , Zhou Wenji, Ma rek Makowski , and Yan Hongbi n,
“Inco rporation of l ife cycle emis sions and car bon price unc ertainty i nto
the sup ply chain net work manage ment of PVC prod uction,” Ann als of
Opera tions Resear ch, May 2021, Online.
7
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
XUAR-manufactured PVC is now often shipped rst to Viet-
nam, where one of Zhongtai’s biggest customers set up a
ooring factory in 2019. In recent months, PVC resin ship-
ments from manufacturers with plants located in the Uy-
ghur Region appear to have surged to this particular facto-
ry in Vietnam called Jufeng New Materials. Jufeng makes
vinyl oorings for most of the major ooring companies in
the U.S., which sell them under their own brand names.
(See the chapter on supply chains below for more details.)
ENVIRONMENTAL AND
HEALTH HAZARDS OF
MANUFACTURING PVC
The growth of PVC manufacturing in the Uyghur Re-
gion exacerbates pollution in a region that, by 2008,
was already plagued by some of the worst air in Chi-
na.15 These coal-to-plastics factories use and release ex-
tremely toxic substances and vast amounts of greenhouse
gases. The PVC industry worldwide produces many other
kinds of toxic air, water, and solid waste pollution. These
include persistent, bioaccumulative, toxic chemicals such
as polychlorinated biphenyls (PCBs). Air currents distrib-
ute these poisons and global warming agents worldwide.
This is especially the case in the Uyghur region, where
PVC production processes rely upon a combination of
coal, chlorine, and mercury.
The scale and intensity of pollution from PVC pro-
duction in the Uyghur Region is greater than in any
other part of the world and even in the rest of China,
yet in the last decade, this is where the U.S. ooring
has shifted its sourcing. Dozens of ooring factories
in the U.S. have closed as the industry has chosen to
offshore production to the dirtiest production meth-
od. PVC is formed from a chemical called vinyl chloride
monomer or VCM. Two different technologies are used to
produce VCM: the acetylene route, which uses coal and
a mercury-based catalyst to react it with chlorine, or the
ethylene route, which uses ethylene from natural gas or
oil and reacts it with chlorine without the use of mercu-
ry. The latter is predominant worldwide; according to a
2019 study by the Healthy Building Network, the only
countries where the acetylene route is still used are Chi-
na, India, and Russia.16 The twenty largest producers us-
ing the acetylene route are in China. Seven are located in
the XUAR. The mercury-based acetylene route is much
more polluting than the ethylene route of production. It is
also less expensive, often by $100 per ton or more.17 PVC
made in the XUAR, if produced at full capacity, offers
customers a potential $400 million in savings, but those
savings are based on a lack of environmental protections
that make the ultimate cost much, much higher.18 (See
text box for the process of manufacturing PVC in XUAR.)
Mercury Pollution
To accommodate the industry’s quest for cheap PVC, mer-
cury mining has made a startling comeback. The use of
mercury in XUAR-manufactured PVC factories leads to
the widespread release of mercury locally and globally.
Mercury is emitted into the air, poured into water and
deposited in soil throughout the course of its production
use and disposal for the PVC industry.
Mercury is also absorbed by people living at the fence
line of mines. Children living near the mercury mines of
China are in particular danger. A study of people in Wan-
shan, where most of the mercury is mined and rened for
the PVC industry, found that 18% of children have levels
of mercury exposure that are higher than U.S. standards
for action.19 Mercury in the air around these operations is
“highly elevated.”20
But it is not merely in mining that mercury is a hazard.
The Center for Environmental Health notes, “The use of
mercury in the production of vinyl chloride monomers
not only poses a health risk to workers, but also to pop-
ulations both proximate and distant to these plants as
mercury vapors can be transported long distances in the
atmosphere. Inorganic mercury is highly volatile and can
be aerosolized in the production process, exposing work-
ers to gaseous elemental mercury - known to cause lung
damage in the form of chemical pneumonitis and bron-
chiolitis. Moreover, this gaseous elemental mercury can
escape into the atmosphere, where it can be transported
over long distances and redeposited in terrestrial envi-
ronments far from the point source of pollution.”21
An estimation of mercury pollution created by PVC plants
in the Uyghur Region points to an untenably hazardous
situation. The World Bank reported in 2017 that, on av-
erage, 86.9 grams of mercury is consumed in the produc-
tion process of every ton of PVC made via the acetylene
method in China.22 In the early 2010s, independent Ger-
man scientists studied pollution at Xinjiang Zhongtai’s
plant near Ürümqi. They determined that, for every ton
of PVC produced, Zhongtai released 2.4 grams of mercu-
ry to the air.23 Considering the magnitude of PVC produc-
tion in the region, this amounts to signicant pollution.
See Table 2.
8
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Using the World Bank’s calculations,
PVC production in the XUAR current-
ly consumes an estimated 358 tons of
mercury per year, of which 9.9 tons
are released into the air. XUAR PVC
manufacturing alone accounts for the
consumption of 15% of all mercury
produced worldwide in 2021, based
on U.S. Geological Survey estimates
of China’s production.24
Furthermore, the seven Uyghur Re-
gion-based PVC plants’ estimated
combined air emissions are equal to
more than 60% of the air releases of
mercury reported in all manufactur-
ing in all of the United States in 2020
(14. 8 ton s). 25
Greenhouse Gases
The German study also calculated rates
of carbon dioxide releases from Xinjiang
Zhongtai’s Huatai plant. Researchers
found that that the Huatai plant released
12 tons of carbon dioxide gas for every
single ton of PVC production. At this
rate PVC plants in XUAR, running at full
capacity, will release an estimated 49.4
million tons of carbon dioxide-equiva-
lent gases. This measure, CO2e for short,
weighs the global warming potential of
each gas in relation to carbon dioxide.
For comparison, 140 plastics factories
in the U.S. reported releasing a com-
bined 114 million tons of CO2e gases
in 2020, which is a little more than
twice the climate impact caused by
the seven PVC plants in the XUAR.26
Xinjiang Tianye’s estimated 16.8 mil-
lion tons of carbon dioxide-equivalent
gas emissions are higher than any pet-
rochemical plant reported in the United
States in 2020. Zhongtai’s four plants’ combined esti-
mated emissions total 27 million tons. See Table 3. Both
companies’ emissions exceed what is expected from a
massive plant planned by Formosa Plastics in Louisiana,
which has become a rallying point for climate justice.27
Table 2. Estimated annual mercury pollution from PVC
production in XUAR, in metric tons
(Calcul ation s based upon 100% produ ction rates and Worl d Bank an d Germa n studi es)
PVC FAC TORY OWNER PVC CAPACIT Y
(TON S)
MERCURY
USE
MERCURY AIR
POLLUTION
Xinjiang Tianye Xinjiang Tianye 1,400,000 121.7 tons 3.4 to ns
Fukang Energy Xinjiang Zhongtai 800,000 69.5 to ns 1.9 to ns
Zhongtai Huatai Xinjiang Zhongtai 700,000 60.8 tons 1 .7 tons
Zhongtai Toksun Xinjiang Zhongtai 300,000 26. 1 tons 0.7 tons
Xinjiang Mahatma Xinjiang Zhongtai 300,000 26. 1 tons 0.7 tons
Xinjiang Yihua Hubei Yihua Chem-
ical
300,000 26.1 ton s 0.7 tons
Xinjiang Qingsong XPCC/ Qingdao
Haiwan
120,000 10.4 tons 0. 3 tons
Total current 4,120,000 358 tons (*) 9.9 ton s (*)
(*) Totals factor i n an addition al 200,0 00 tons Xinjia ng Zhongtai pro duction cap acity not
alloc ated above. Xin jiang Zhongta i states that its tota l capacity i s 2.3 mill ion tons PVC.
Production capacity gu res found for the four existi ng plants total 2.1 million tons, indicating that
a potenti al 200,00 0 tons of additi onal capaci ty exists at th ese plants .
Table 3. Estimated annual carbon dioxide-equivalent
pollution from PVC production in the XUAR
(Calcul ation s based upon 100% produ ction rates and Worl d Bank an d Germa n studi es)
PVC FAC TORY OWNER PVC CAPACIT Y
(TON S)
CARBO N DIOXIDE -
EQUIVALENT RELEASES**
Xinjiang Tianye Xinjiang Tianye 1,400,000 16.8 million tons
Fukang Energy Xinjiang Zhongtai 800,000 9.6 million tons
Zhongtai Huatai Xinjiang Zhongtai 700,000 8.4 million tons
Zhongtai Toksun Xinjiang Zhongtai 300,000 3. 6 million tons
Xinjiang Mahatma Xinjiang Zhongtai 300,000 3.6 million tons
Xinjiang Yihua Hubei Yihua Chem-
ical
300,000 3.6 million tons
Xinjiang Qingsong XPCC/ Qingdao
Haiwan
120,000 1.4 million tons
Total current 4,120,000 49.4 million tons (*)
* Xinji ang Zhongtai s tates that its total ca pacity is 2. 3 millio n tons PVC. Producti on capacit y
gures found for the four exi sting plants total 2. 1 milli on tons, indicati ng that 200,00 0 tons of
additi onal capac ity exists so mewhere amon g these plant s.
9
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Workplace Hazards
Beyond environmental hazards, PVC production presents
many health risks for laborers. Among them:
• Coal dust causes chronic obstructive pulmonary
disease (COPD), silicosis, coal workers’ pneumoco-
niosis (commonly known as “Black Lung disease”),
and other respiratory diseases.28
• Workers with prolonged exposure to PVC dust face
increased risk of lung cancer.29 Dormitory style
structures in the plant compounds suggest that
many workers spend 24 hours in close proximity to
these hazards.
• When vinyl chloride monomer was mostly pro-
duced using the acetylene process in the U.S.,
workers were exposed to high levels of this carcin-
ogen, and suffered elevated rates of liver tumors
and other cancers.30
• The acetylene-based process creates mercury con-
taminated wastes that impact workers at disposal
operations.31 In the 1990s, Borden Chemicals in the
United States was alleged to have illegally shipped
mercury wastes to a supposed recycling plant in
South Africa, where workers were severely injured
and died from mercury exposure.32 (This case
helped lead to the closure of the Borden operation,
and the end of acetylene-based PVC production in
the United States.) The fate of mercury-bearing
waste from XUAR PVC plants is yet unknown.
FORCED LABOR IN THE
UYGHUR REGION
Environmental pollution is not the only risk associated
with the shifting of signicant PVC production to the Uy-
ghur Region. As has been widely documented and publi-
cized, state-sponsored forced labor is practically ubiqui-
tous in the Uyghur Region.33
Since at least 2017, the government of the People’s Re-
public of China (PRC) has embarked on a massive sys-
tematic program of forced labor in the Xinjiang Uyghur
Autonomous Region. Through conscripted seasonal la-
bor, prison and internment labor, and state-coerced labor
transfers, the PRC has compelled Indigenous citizens of
the Uyghur Region to work in “labor-intensive” indus-
tries, as well as on farms and in municipal maintenance
both within the region and across China. Signicant ev-
idence reveals that labor transfers in the Uyghur Region
occur within an environment of unprecedented coercion,
undergirded by the constant threat of re-education, in-
ternment, and imprisonment. Because refusal to partic-
ipate in government assistance can be considered a
sign of religious extremism and punishable with in-
ternment or prison in the Uyghur Region, Uyghur and
other minoritized workers from the region are unable
to refuse or voluntarily exit jobs assigned to them by
the government. Thus, these state-sponsored labor
transfer programs are tantamount to forcible transfer
of populations, forced labor, human trafcking, and
enslavement.
Experts have determined that the PRC’s internment camp
and prison factories, as well as the “surplus labor” and
“labor transfer” initiatives as they are practiced in the Uy-
ghur Region, are mechanisms of a massive program of
compulsory labor.
State-sponsored forced labor operates through several
different (though sometimes overlapping) mechanisms in
the Uyghur Region:
Pr ison L abor. The PRC government requires that all in-
mates perform compulsory labor. In the XUAR, the ma-
jority of prison labor is in agricultural sectors, including
cotton planting, harvesting, and ginning. Prisons are
attached to farms and factories. Some private and state-
owned enterprises locate their factories within the walls
of the prisons.
Internment Camp Labor. Beginning in 2016, the PRC
began a campaign of mass extra-judicial internment in
the Uyghur Region, interning upwards of a million Indig-
enous citizens of the region, in contravention of numer-
ous international human rights protocols. The internment
camps are touted as an anti-terrorist campaign grounded
in “vocational training.” Many detainees are required to
work. Again, companies often locate factories within the
walls of these camps, but other companies receive intern-
ment camp victim workers each day at factories located
in proximity to the camps.
State-Sponsored Labor Transfers. The PRC has placed
millions of Indigenous citizens from the Uyghur Region
into what the government calls “surplus labor” (富余劳 动
力) and “labor transfer” (劳动力转移) programs. Through
state agency labor recruiters, the PRC government com-
pels people to be transferred to farms and factories
across the Uyghur Region. Others have been “trans-
10
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
ferred” thousands of miles into the interior of China to
work in factories. The XUAR government estimates that
it has deployed these programs 2.6 million times (some
people may count more than once if transferred more
than once).
State Conscription of Laborers. The PRC has made la-
bor compulsory in the Uyghur Region for generations
through the “hashar system,” through which Uyghur and
other minoritized citizens are conscripted to hand pick
cotton and other agricultural products seasonally. Chil-
dren as young as elementary school age are subject to the
hashar system, which continues to operate in the most
impoverished villages of the southern XUAR.
The government has deployed legions of state-employed
labor recruiters and other cadres who assign work to
those deemed by the state to be “surplus laborers.” Gov-
ernment directives require local governments and labor
agencies to meet quotas for labor transfers. The gov-
ernment also enrolls Indigenous citizens in compulsory
ideological, vocational, and Chinese language training.
A widely circulated government-issued document listed
refusal to participate in government assistance programs
as a sign of terrorism or extremism, which suggests that
refusal of a labor transfer could be punishable by intern-
ment or imprisonment.
Hundreds of testimonies from people who have been
forced (or whose family members have been forced) to
work in the Uyghur Region reveal the strategies of co-
ercion that the government uses to compel people to
work. These include threats of being sent to internment
camps for refusing government-sponsored labor trans-
fers, repeated (sometimes daily, sometimes even over-
night) visits by agents of the state to pressure people to
be transferred for labor, coercive land transfers that leave
farmers landless and unemployed, false promises that
family members will receive reduced sentences if a per-
son accepts a labor transfer, and misrepresentation of the
labor as otherwise-required ideological training or pover-
ty alleviation.34
These state-sponsored forced labor programs are en-
demic to the Xinjiang Uyghur Autonomous Region and
are present in practically all sectors that mine, farm,
or manufacture there, including in the manufacturing
of PVC. This report documents the PVC industry’s reli-
ance on labor transfers and other worker exploitation
in the Uyghur Region. We found that every PVC com-
pany operating in the Uyghur Region have engaged in
state-sponsored labor transfer programs.
THE HARMS OF PVC
MANUFACTURING IN
THE UYGHUR REGION
This report examines the high human and environmental
cost of manufacturing PVC in the Uyghur Region, even
as it achieves rock bottom pricing for customers. Focused
primarily on Zhongtai as a case study, the report inves-
tigates the evidence regarding the PVC industry’s envi-
ronmental record and its participation in labor transfer
schemes in the Uyghur Region. The ndings are stark:
Zhongtai is both one of the region’s worst polluters and
one of its most enthusiastic adopters of the state-spon-
sored labor transfer system. The report also identies
similar environmental and rights violations in other PVC
producers in the region. The full extent to which PVC
made in the Uyghur Region pervades the global market is
unknown. Much of the resin made in the XUAR is shipped
by rail to factories in eastern and southern China, where
it is turned into plastic products that do not bear a mark
that would reveal the PVC’s origin. In order to better un-
derstand the international reach of PVC made in the Uy-
ghur Region, we analyze shipping records to identify the
likely paths XUAR-originating PVC travels as it makes its
way to stores and consumers worldwide, particularly in
the form of luxury vinyl ooring.
11
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Xinjiang Zhongtai Group is a wholly state-owned compa-
ny funded by the People’s Government of Xinjiang Uygur
Autonomous Region (XUAR) and directly supervised by
the State-owned Assets Supervision and Administration
Commission (SASAC) of the Autonomous Region. It is
headquartered in the Ürümqi Economic and Technolog-
ical Development Zone. The company was listed on the
Shenzhen stock exchange in 2006. The company employs
as many as 54,000 people and is one of the PRC’s “Top
500 Enterprises.”35 It reports annual revenue of CNY 62
billion.36 The XUAR is a strategic location because of its
centrality as a hub in the PRC’s Belt and Road initiative.
Xinjiang Zhongtai wholly owns at least 43 subsidiaries
and 38 joint-stock companies.37 The Zhongtai Group’s
leading product, in volume and impact, is polyvinyl chlo-
ride plastic, of which it produces more than two million
tons per year at four different plants. It is the largest PVC
producer in China, with a total capacity of 2.33 million
tons, according to a 2019 study.38 In support of this pro-
duction, Zhongtai owns coal mines, coal-red power
plants, and other infrastructure.
The Zhongtai Group produces other chemicals and plas-
tics. These include caustic soda (also called sodium hy-
droxide) which it uses in the production of viscose sta-
ple ber (rayon) for textiles. Zhongtai is also a leading
rayon producer in China.39 In Karamay, Zhongtai Chemi-
cal makes Puried Terephthalic Acid (PTA), an essential
feedstock for polyester. It is China’s largest producer of
butanediol (BDO), through a joint venture with global
chemical giant, BASF, in Korla.40 BDO is used in the pro-
duction of spandex and polyurethane plastics. Xinjiang
Zhongtai also produces biodegradable plastics and petro-
leum.41
Xinjiang Zhongtai grows tomatoes, grapes, peppers, and
other agricultural products as well. It claims to have a
million mu (more than 257 square miles) of cotton elds
in Yuli, Shaya, and elsewhere.42
Zhongtai’s core operations are its coal-to-plastics facto-
ries, where it uses a mercury-based process to turn chlo-
rine and coal into polyvinyl chloride resin. Zhongtai
alone produces about 10% of all PVC made in China.43
Xin jiang Zhon gtai su bsidiar y Xinj iang Hu atai Heavy Che mical Comp any’s plant in Ürümqi , XUAR. Photo © J. Carl Ga nter / Cir cle of Bl ue
1. Xinjiang Zhongtai Group
(新疆中泰 (集团)有限责任公司)
12
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Zhongtai produces PVC in four facilities:
Xinjiang Huatai Heavy Chemical Company (新疆华
泰重化工有限责任公司), is located in Midong District, a
large district of Ürümqi Prefecture. Zhongtai Chemical
opened this plant in 2006. It started with 120,000 tons
of PVC production annually.44 By 2010, Xinjiang Huatai
had the capacity to produce 300,000 tons of PVC. It then
completed a second phase of development in 2010, add-
ing another 360,000 tons of capacity.45 Zhongtai Group’s
website reports the Huatai plant’s current PVC capacity
as 700,000 tons per year.46
Xinji ang Huatai in th e Midong Dis trict Indust rial Park nea r Ürümqi. 47
Coordinates: 43.942935, 87.664081.
Xinjiang Zhongtai Chemical Fukang Energy Co. (新疆
中泰化学阜康能源有限公司) in Fukang opened in 2012.48
Zhongtai’s Fukang production capacity is 800,000 tons
of PVC resin and 600,000 tons of caustic soda.49 Another
subsidiary, Zhongtai Mining and Metallurgical Co., pro-
duces 380,000 tons of calcium carbide a year, 1.3 mil-
lion tons of lime, and also operates a massive coal mine,50
supporting the production of PVC at this location.
Fuka ng Ener gy in Fuka ng City, Changj i Hui Autono mous Pr efectu re.51
Coordi nates: 44.0809 8, 88.588 901.
Xinjiang Mahatma Energy (新疆圣雄能源股份有限公
司) is located in Turpan. Zhongtai acquired the plant in
2001. As of 2015, it has the reported capacity to produce
300,000 tons of PVC.52 The facility also has been called
Shengxiong Energy Resource Company.
Xin jiang Mah atma compl ex in Alehui Town, Toksu n (Tuokexun) Co unty. 53
Coordinates: 42.824936730621, 87.91506344380534
Xinjiang Zhongtai Chemical Toksun (新疆中泰化学托克
逊能化有限公司 ) is also located in Turpan, China. Plant
construction is ongoing. It has the capacity to produce 1.8
million tons of calcium carbide (used in the production of
PVC), 300,000 tons of vinyl chloride monomer, and the
same amount of PVC. Its production of PVC resin started
in 2016.54 Located in the same industrial park as a highly
polluting lead acid battery manufacturing and recycling
plant run by Camel Group, this plant is situated atop a
traditional irrigation system that has fed local farmers
for generations and is likely a signicant contaminator
not only for the farms situated only a little over a thou-
sand meters away but also for the crops grown on those
farms.55
Xinji ang Toksun in Toksun c ounty, Turpan pr efecture. 56
Coordinates: 42.736979, 88.645011.
(The capacity listed above for at least one of these plants
likely is undercounted because the Chinese chemical con-
sulting rm CNCIC conducted a study that places Zhong-
tai’s total capacity at 2.33 million tons, and Zhongtai it-
self states its capacity as 2.3 million tons.)57
13
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Xinjiang Zhongtai also controls coal mines that feed PVC
production. In 2021, the company said it had the capacity
to produce 7.3 million tons of coal per year, including 4.9
million tons at Mahatma/Shengxiong Energy. It noted
that the XUAR’s abundant coal resources give the compa-
ny “a certain cost advantage.”58
A German study in 2014 found
that the low cost of coal was
key to the industry’s growth in
the Uyghur Region. “PVC pro-
duction from the carbide pro-
cess yields high prots…main-
ly due to the low cost of coal
in Xinjiang…This situation
makes it difcult to implement
energy-efcient solutions.”59
LABOR TRANSFERS AND
CORPORATE PARTICIPATION
IN REPRESSIVE GOVERNMENT
CAMPAIGNS
The public record indicates that Zhongtai Group is an
avid participant in state-sponsored labor transfer pro-
grams and publicizes its engagement regularly. As an
XUAR state-owned company, Zhongtai Group is directly
engaged in party programs and government initiatives,
including ideological programming, political activism,
poverty alleviation, and labor transfers.60
In 2017, as internment camps were being built across
the Uyghur Region, Xinjiang Zhongtai staged a pub-
lic event on maintaining “social stability” and ghting
terrorism, in which all attending villagers were rst re-
quired to bring their thoughts “in line with the Central
Party’s analysis of the situation in Xinjiang and in line
with the plans of the Autonomous Region Party Commit-
tee.61 These practices continued with required corporate
oaths against “two-faced” people and the “three evils,”
“Speak Up” ceremonies, and patriotic ag raising cere-
monies.62 The Zhongtai Group dispatched its own em-
ployees to surveille Uyghur villagers through the “Visit
Huiju” program, through which state employees monitor
Uyghur behavior and regularly visit households to collect
data for the government. The Zhongtai employees input
data on Uyghur families through the Xinjiang Household
Village app and the notorious Integrated Joint Operations
Platform (IJOP) app. Zhongtai employees were deployed
to ensure that every household and person is accounted
for and that “micro-clue information” is veried. These
platforms are used for “prediction and prevention work,”
which is a local government method for detaining people
they deem likely to be guilty of supposed pre-crimes or
criminal thought.63
Zhongtai Group has transferred thousands of citizens
deemed to be “surplus laborers” – more than prac-
tically any other company described in academic or
journalistic accounts of labor transfers in the XUAR.
Indeed, by June of 2021, Zhongtai was reporting that
the company had engaged a total of 5,502 transferred
laborers from southern XUAR, achieving the status of
the state-owned enterprise that had “solved the most
surplus labor in urban and rural areas.” At that time,
after international scholars and journalists had identied
these labor transfers as coercive state-sponsored pro-
grams, state-owned Zhongtai celebrated that the compa-
ny “regards receiving and relocating the employment of
organized labor transfer in southern Xinjiang as an im-
portant political task.”64
Starting as early as spring 2017, in order to assist in the
XUAR’s plan to transfer 100,000 people from Kashgar and
Hotan within three years,65 Zhongtai Group alone trans-
ferred 2,000 minoritized citizens from the southern XUAR.
Of the rst thousand, 440 people were assigned to Zhong-
Workers ar rive at Zhongtai facilities in Toksun
Credi t: Zhongtai Zero Di stance, Online.
Zhongtai Group has transferred thousands of
citizens deemed to be “surplus laborers”—more
than practically any other company described
in academic or journalistic accounts of labor
transfers in the XUAR.
14
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
tai Group’s facilities in the Korla industrial Park, which
produces chemicals for spandex, while the remaining 560
went to nine of Zhongtai’s other facilities in Ürümqi.
In June of 2017, the company received a second “batch”
of 1,000 transferred workers, who they rst sent to the
Xinjiang Light Industry Vocational and Technical Col-
lege for training. The new workers were subjected to
six months of compulsory training, including “military
training in ‘feeling gratitude for the party and studying
[Xi Jinping’s] speeches.’”66 Zhongtai was integral in the
establishment, building, and equipping of this school.67
College staff were sent out to villages to coordinate the
transfer of the laborers, as part of a team that simultane-
ously “coordinated the care of the elderly and children of
the migrant workers, and the transfer and management
of their land and livestock,” in an apparent effort to solve
the issue that many people are not willing to be trans-
ferred due to their need and desire to tend to family and
property.68 The work tea m used the instit utionalization of
workers’ family members and expropriation of their land
as a strategy for reducing their resistance to transfers.
The Xinjiang Light Industry Vocational and Technical
College does not appear to be one of the internment
camps that were euphemistically called “vocational and
technical training” institutes.69 However, in 2018, stu-
dent representatives of the College were taken on a tour
of the internment camps, where they saw the victims of
the camps working and were introduced to the conse-
quences the internees faced because they had been ac-
cused of “religious extremism.” One of the students on
the internment camp study tour reected: “I can feel the
great harm of religious extremism from their experienc-
es, and also feel the happiness after they completely get
rid of religious extremism. We young students must keep
their eyes open, distinguish right from wrong, resist and
guard against ‘double-pan’ [pan-Islamism and pan-Turk-
ism] thinking and religious extremism, and be a new
force in maintaining social stability and long-term stabili-
ty in Xinjiang.” The deputy dean of the Light Industry Vo-
cational and Technical College noted: “Living examples
show that vocational skills education and training is an
effective measure to help people who have been eroded
by religious extremist ideology to return to normal life,
and an innovative move in social governance.” This kind
of scared-straight exposure to internment camps likely
conditions Zhongtai’s transferred laborers to recognize
the consequences of refusing government orders.70
The company also established the Zhongtai University
Vocational Skills Training School, where thousands more
transferred workers are trained in vocational skills, but
also in anti-terrorism drills, labor discipline, ethnic uni-
ty, patriotism education, cultural skills, legal knowledge,
and “to bear hardships and stand hard work.” Those
workers are then assigned to Zhongtai and other compa-
nies in the area.71
In June 2017, Zhongtai Group and its subsidiary Mahatma
Energy/Shengxiong Energy announced that, as a state-
owned corporation, it would take the lead “to receive and
resettle the surplus labor of ethnic minorities in south-
ern Xinjiang, which fully reects the mission of Zhongtai
Group as an inuential state-owned backbone enterprise
in the autonomous region.” Its rst efforts were focused
on developing pre-assignment training for transferred la-
borers from Kashgar and Hotan regions. The training the
company designed was an intensive 3-month “paramili-
tary and all-round training” that involved
fully respecting the religious beliefs and living hab-
its of the transferred employees, through training
and education in laws and regulations, corporate
culture, ideology and ethics, etc., gradually chang-
ing their ideological concepts, thinking patterns and
behavior habits, improving their ideological aware-
ness, and improving their comprehensive quality, so
that they can be transformed into workers in line
with modern enterprises as soon as possible and in-
tegrate into the new working environment.
In the guise of respecting religion, the company imposed
ideological and political training upon all of its trans-
ferred Uyghur workers, with a mind to transforming
them into workers suited to the company’s own needs.
Many of the employees were then assigned to work direct-
ly in the production of the PVC that is exported globally.
Workers were assigned to particular jobs based on their
uptake of the training, their skills, and their interests,
in coordination with the needs of the company. Those
with the highest skills would be assigned to front-line
production roles; those with poor performance would be
relegated to logistics, janitorial, gardening and company
secur ity.72 Zhongtai implemented a quantitative scoring
system, by which the workers would be evaluated, ac-
cording to which the company “regularly commends the
advanced and criticizes the backward.”73
15
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Within a couple of weeks of the story announcing the de-
velopment of training for transferred laborers, Mahatma
Energy announced that it had received 200 transferred
surplus laborers. The workers were received with a ban-
ner announcing that “national unity is the lifeline of
people of all ethnic groups.” The workers, outtted with
camouaged military uniforms, were disciplined in their
comportment toward the company and the government.
They were told they should “cherish the opportunity of
transferring employment, appreciate the kindness of the
party, keep in mind the entrustment of relatives in their
hometown, and use their hard-working hands to create
a better and happy life.” The workers responded obedi-
ently with formulaic statements of gratitude to the com-
pany and the party.74 Similar oaths were required of the
more than 100 workers who were assigned to Zhongtai’s
Huatai factory that summer and in 2018.75 There is no
room for dissent from these ideological standards, and all
transferred Indigenous workers are subject to these train-
ings and recitations.
Despite the fact that Zhongtai’s Mahatma Energy plant
in Turpan had automated much of its operations, the fac-
tory became one of the primary sites to which Zhongtai
would deploy transferred laborers. This suggests that,
even as automation or modern industrial manufacturing
reduces the need for laborers, it does not in fact obviate
the deployment of low-skilled transferred laborers from
southern XUAR.76 Zhongtai Group’s various social me-
dia accounts and media publicity stories have recorded
stories of Uyghur transferred laborers working in quality
inspection and conducting testing of the products manu-
factured by Mahatma.77 In the Zhongtai Fukang plant’s
new materials workshop, transferred laborers also work
in quality control, as well as in crushing the materials
for the mixing process.78 At Xinjiang Zhongtai Chemical
Toksun Energy, a transferred laborer is reported as feed-
ing the furnace for the production of calcium carbide.79
At the Xinjiang Zhongtai Chemical Fukang Energy Co.
plant, a transferred laborer was gradually promoted to
become the chief operator of the production team in the
PVC new material workshop (and he also served as an
unof cial “propagandist,” sharing the news of the compa-
ny and government with his colleagues).80 At Mahatma’s
caustic soda workshop, minoritized citizens of the region
make up 40% of the staff, at least some of whom are
transferred through state-sponsored programs and mon-
itored through “relative” pairing programs.81 Advanced
mechanization does not seem to have slowed Zhongtai’s
labor transfers.
Even in state media and corporate publicity, reports
reveal clear indicators that Indigenous people trans-
ferred from southern XUAR are not voluntarily work-
ing at Zhongtai. In one story celebrating a Han em-
ployee’s dedication to his job, Mahatma’s publicity arm
indicated that one of the things that this worker does
is “stabilize the emotions” of the transferred employees
who feel “the change of identity is too fast and inevita-
bly experience mood uctuations and confusion.”82 An-
other Zhongtai publicity piece told the story of Hasan
Imin whose “most common words” were “I want to go
home” and “I really can’t learn.” It is clear that Imin had
not been allowed to return home when he expressed
his desire to do so.83 In 2019, Xinhua, a state-run news
agency, told the story of how, based on the “employment
transfer policy vigorously promoted” in the XUAR, a Uy-
ghur woman named Maynur from Ketiki Village, Keriya
County was deemed “surplus labor” by the state. Maynur
was assigned to work at Zhongtai’s factory in Ürümqi,
over 1,000 miles from her home. She and her parents re-
sisted the placement that would transfer her so far from
home, according to Xinhua. Maynur was reported to be
working in the production
workshop at the time of the
report. The reporting about
her situation indicates both
that she was unwilling to
accept the transfer and that
she was nonetheless sent
As automation...reduces the need for laborers,
it does not in fact obviate the deployment of
low-skilled transferred laborers
Two transferred Uyghur workers test chemical sample s at Mahatma
Chlor-Al kali Plant credit: Mahatma Ch lor-Alkali, Online,
16
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
to work directly in the manufacturing of the goods pro-
duced by Zhongtai.84
In its 2018 annual report, Zhongtai Group detailed its
participation in the XUAR government’s poverty allevia-
tion programs and set explicit objectives. The company’s
poverty alleviation strategy included “accepting and relo-
cating surplus laborers from Southern Xinjiang and striv-
ing to achieve the goal of transferring 3,000 minorities
for employment within three years.”85
According to state media, Zhongtai Group achieved its
goals. The company received 3,160 “surplus labor” trans-
fers from the southern XUAR across its various companies
between 2017 and 2019. To transform the laborers from
“farmers to industrial workers,” Zhongtai Group system-
atically trains all transferred laborers in a “training plan
covering ideology, culture, and skills.” The workers are
typically assigned to jobs in packaging, forklifting, or
cleaning at rst.
In March 2020, in the midst of the COVID-19 pandemic,
Zhongtai Group announced that they had received 150
transferred laborers from Keriya County by train, when
other people were not allowed to take the train for fear of
COVID transmission. [PetroChina, Sinopec, Xinjiang En-
ergy Group, Xinjiang Nonferrous Metals Industry Group,
and the Xinjiang Airport Group also participated in the
welcome of transferred laborers.] According to the state
media, the pandemic provided the company “advantag-
es” in global trade. A press release declared that “in the
face of the sudden outbreak [of COVID-19],” the company
was committed to “making full use of Zhongtai Group’s
non-stop advantage during the epidemic period, continu-
ing to carry out in-depth foreign trade business,” noting
that both PVC and caustic soda sales had soared over
their performance the previous year.86
By mid-March 2020, Zhongtai reported having accept-
ed a total of 4,432 laborers from the southern XUAR and
purportedly having transformed them “from the coun-
tryside to the city, from ordinary villagers to modern
industrial workers.”87 Then, on March 29, 2020, Zhong-
tai Group reported having received an additional 1,180
transferred employees in the two weeks since March 15
alone, including at least one who had been not been a
poor farmer at all but instead was a car salesman who
had fallen on hard times because of the pandemic, and
another who had just gotten married a year before and
had to leave a newborn at home.88 During this period, the
XUAR and central governments strove to continue manu-
facturing in the midst of COVID by deploying Uyghur and
other minoritized citizens of the Uyghur Region to work
while Han people were on full lockdown. It appears that
in some of its operations, Zhongtai reduced its workforce
signicantly, sometimes leaving Uyghur workers alone
to complete the work of many people.89 Uyghur workers
were treated as expendable while other workers were
protected by the government lockdowns.
Zhongtai also owns textile manufacturing companies
that create cotton, rayon, and other fabrics. At Zhongtai’s
Aral Fulida cotton and cellulose processing plant, which
is celebrated for its advanced mechanization, Uyghur
workers were transferred to work on the production line
as early as 2017, starting with 1,000 transfers in the rst
year.90 In 2018 Aral Fulida claimed to be the company in
Aral with the highest number of transferred laborers on
staff.91 A March 2021 South China Morning Post article
revealed a high risk of forced labor and environmental
hazards in Zhongtai’s viscose fabric production.92
Workers ar rive from Keriya County to Ürümqi Rail way Station to work for
Zhongta i Credit: Wu Jun for Huatai Zero Distance, Online.
One of Zho ngtai’s cot ton processi ng factories rec eives over
100 transferred laborer s. Credit: China Yarn News, Online.
17
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
ENVIRONMENTAL AND
HEALTH HAZARDS
Xinjiang Zhongtai is a contender for the world’s most pol-
luting plastics producer. It releases unmatched amounts
of carbon dioxide and mercury because it uses dirty coal
as an essential feedstock and mercury as a chemical pro-
cessing agent.
Xinjiang Zhongtai owns a portion of the Zhundong coal
eld through its subsidiary, Xinjiang Zhongtai Chemical
Zhundong Coal Industry Co.93 Two major U.S. mining in-
dustry corporations – Peabody and Caterpillar – helped
to develop the Zhundong mine.94 In 2013, China Daily re-
ported, “Zhundong aims by 2015 to produce and process
118 million tons of coal every year; the installed capaci-
ty of coal-red power generators is expected to reach 22
million KW. Its projected annual output goals include 4.8
million tons of metallurgy, 1.2 million tons of olen, 1.2
million tons of carbamide, 600,000 tons of PVC, and 12
billion cubic meters of coal-derived natural gas.”95 (For
more on Zhundong, see text box in next chapter.)
In 2014, the People’s Daily reported that the
use of mercury catalysts contaminated soil
at the Xinjiang Huatai plant in Ürümqi and
poses “a safety hazard to the health of resi-
dents in the area.”96
A German study, published in 2014, warned
that plans to increase PVC production in the
Uyghur Region by ve million tons would
increase greenhouse gas emissions by 60 million tons per
year.97 Since then, Xinjiang Zhongtai has increased its ca-
pacity by one million tons of PVC, releasing 12 million
tons of greenhouse gases per year, based on the study’s
estimated predictions.
Zhongtai’s buildout continues. In June 2021, Shanxi Jin-
hui Energy Group and Zhongtai announced that the com-
panies planned to build a 1-million-ton PVC plant in Aksu
Prefecture that had initially been approved in 2011.98 On
April 11, 2022, construction bids were opened. The plant,
named Xinjiang Jinhui Zhaofeng Energy, is expected to
come online in Baicheng Industrial Park in 2024.99
When complete, Zhongtai’s Baicheng plant will be one of
the ve largest PVC factories in the world and will elevate
the Zhongtai Group into second place among all produc-
ers of PVC worldwide. Only Shin-Etsu (4.3 million tons
per year) will exceed Xinjiang Zhongtai’s 3.3 million per
year production capacity. No PVC manufacturer in the
world will match Zhongtai’s potential release of 40
million tons of carbon dioxide-equivalent gases.
INTERNATIONAL INVESTMENTS
Though it is a state-owned enterprise, Xinjiang Zhong-
tai has raised signicant nancing from international
banks and pension funds. According to the Global Coal
Exit List, as of November 2021, the Government Pen-
sion Fund of Norway owned $16.62 million in shares of
Xinjiang Zhongtai. Vanguard held over $7.78 million in
shares; Dimensional Fund Advisors held $4.48 million;
the Netherlands Algemeen Burgerlijk Pension Fund held
$2.38 million. See Table 4 for a list of Zhongtai’s interna-
tional investors.100 Some of these investments are quite
small and may represent only one investor, but several
banks and funds hold millions of dollars in shares.
In addition to these major bank investors, as of Sept.
30, 2021, the Alaska Permanent Fund Corporation held
43,400 shares, with a market value of $89,994.82.101
Xinjiang Zhongtai is a contender
for the world’s most polluting
plastics producer.
18
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
CONCLUSION
In December of 2021, several Zhongtai Group employees
from Indigenous communities participated in a propa-
ganda campaign, published in English, designed to de-
fend against the claims that forced labor is pervasive in
the XUAR.102 These protests against international outrage
at the use of forced labor are not adequate to erase the
signicant body of evidence Zhongtai itself has created in
its promotion of its participation in state-sponsored labor
transfer schemes, and indeed in the role the company has
played in managing labor transfers for other companies
in the region. Indeed, due to its accepting thousands of
transferred laborers from southern XUAR, its active
village recruitment of Indigenous people through the
institutionalization of their family members and the
expropriation of their land, and its training school
that provides ideological indoctrination before it
sends workers to its own and other companies’ fac-
tories, it appears that Zhongtai is a company that is,
more than most others, directly responsible for the
facilitation of the XUAR’s system of state-sponsored
transfer of labor.
Recent U.S. legislation banning the import of XUAR-made
goods (and other bills pending internationally, including
regarding importing goods and nancing of projects that
are connected to human rights abuses) means that under-
standing how Zhongtai’s products move into internation-
al markets is critical. In the third chapter of this report,
we examine the routes XUAR-manufactured PVC takes as
it enters international markets.
Table 4. International investors
and total investments in
Xinjiang Zhongtai Chemical Co.
INTERNATIONAL
INVESTOR
HEAD-
QUARTERS
TOTAL
INVESTMENT
Norwegian Government
Pension Fund Global
Norway $16.62m
Vanguard U.S. $7.78m
Dimensional Fund
Advisors
U.S. $4.48m
Algemeen Burgerlijk
Pension Fund
Netherlands $2.38m
BlackRock U.S. $1.77m*
Arrowstreet Capital U.S. $720,000
Eaton Vance U.S. $590,000
Invesco U.S. $480,000
Charles Schwab U.S. $400,000
Orix Corporation Japan $300,000
Prudential Financial U.S. $250,000
State Street U.S. $220,000
Legal & General U.K. $90,000
Credit Suisse** Switzerland $70,000
Franklin Resources U.S. $50,000
We Capital Brazil $30,000
Fubon Financial Taiwan $30,000
Mercer Global Advisors U.S. $30,000
Northern Trust U.S. $20,000
JPMorgan Chase U.S. $20,000
HSBC U.K. $10,000
* $1. 54m in bon ds; $220,0 00 in sh ares
** So urce: Glob al Coal E xit Lis t, Novem ber 202 1
19
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
XINJIANG TIANYE GROUP (新疆
天 业（ 集 团 ）有 限 公 司 )
Xin jiang Tia nye chem ical co mplex i n Shihe zi City. 103
Coordinates: 44.35801375500167, 86.0427517885306.
Xinjiang Tianye Group is a highly diversied enterprise
owned by the Xinjiang Production and Construction
Corps (XPCC or Bingtuan, see text box). It is a signicant
manufacturer of chemicals, and also has holdings in com-
panies that specialize in a range of industries that have a
strong presence in the Uyghur Region, including irriga-
tion, tomato processing, packaging, logistics, technology,
and new materials. Xinjiang Tianye Co., Ltd. (新疆天业
股份有限公) is a Tianye Group subsidiary and one of the
XPCC’s listed companies.
Its chemical complex in Shihezi is the world’s second
largest PVC producer.104 It can make 1.4 million tons per
year.10 5
Labor Transfers and Corporate Participation
in Repressive Government Campaigns
Xinjiang Tianye Group has won government awards for
its so-called “poverty alleviation” efforts.106 As part of
the company’s drip irrigation manufacturing, it extends
that technology to farmers in southern XUAR, which may
be a benet to the under-developed rural villages where
that program has been implemented. However, Xinjiang
Tianye also participates in many of the oppressive pro-
grams that are labelled as poverty alleviation by the gov-
ernment. Xinjiang Tianye’s 2018 annual report indicates
participation in a wide array of so-called poverty allevi-
ation programs, including labor transfers and vocational
training programmes. While the Tianye PVC project is
not mentioned explicitly as receiving workers, it is likely
that the plant has been part of the labor transfers, as it is
one of Tianye’s larger subsidiaries and Tianye is so active-
ly engaged in poverty alleviation across its portfolio of
subsidiaries.
The company reports that it established a subsidiary in
Shache Farm and invested CNY 20 million in a factory
there that has “absorbed” (吸纳) 100 local workers, which
are likely to be Indigenous farmers involved in labor
transfers (though the annual report does not make the
ethnicity of the workers clear other than by calling the
people “local,” which typically refers to Uyghurs).107 State
media has celebrated Tianye’s program of stationing cad-
res in southern XUAR villages to carry out labor transfers
on behalf of the company as part of their poverty allevi-
ation programming.108 Furthermore, a state media report
in 2020 provides evidence that the company has been the
recipient of surplus labor transfers as a “paired poverty
alleviation work unit” (对口帮扶单位 ).10 9
In its 2019 annual report, Tianye also reported that the
company is actively engaged in the “Becoming Family”
program. The company has stationed Han workers from
the company in Uyghur villages, where they are assigned
families to surveille. The Tianye workers determine plans
for the families to alleviate poverty, which included di-
recting them to engage in new agricultural enterprises.
The Tianye cadres set up mushroom planting coopera-
tives, despite that fact that the local people were resistant
and were already growing pomegranates and grapes,
which are local traditional crops consumed widely in the
region. In yet another village, an agent of Tianye went
to a village and prescribed that the villagers must turn
to monocrop farming, meeting signicant resistance
from the farmers, but the Tianye cadre insisted on the
implementation of his plan nonetheless, and the villagers
were required to comply. He also developed ideological
programming for the villagers, to “stimulate farmers’ en-
dogenous motivation for poverty alleviation and estab-
lish a correct concept of honor and disgrace.”110 These
programs, which are touted as “poverty alleviation,”
are both coercive and pay far under the state-mandated
wages.111 The company’s agents enforce their own pro-
2. Xinjiang Tianye and Other PVC
Manufacturers in the Uyghur Region
20
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
grams on Indigenous people, without regard for commu-
nity input, and these programs often lead to dangerous
monocrop agriculture in areas that had previously had a
diverse agricultural output. Furthermore, the programs
represent a systematic effort to eradicate Uyghur cultural
traditions and farming techniques/preferences.
In another example, the company set up our mills in
a small southern village in the Uyghur Region, where
it employed approximately twenty-ve farmers. While
it is unclear to what extent coercion was used to pres-
sure workers in this situation, it appears that the com-
pany is not meeting the minimum wage requirements in
the region. Xinjiang Tianye annual reports indicate that
the company paid forty rural workers in our mills and
mushroom farming operations a total of CNY 390,000
between March/April and the end of the year, which
means that the workers each received at most CNY 1,083
a month, far below the XUAR-mandated minimum wage
of CNY 1920.112
Environmental and Health Hazards
As the Xinjiang Tianye PVC complex grew, so too did
its impact on the local community, as reported in China
Youth Daily in 2008. One resident told reporters: “There
are constant loud noises and foul smells. It’s like living
in a war zone.” A group of retired workers protested that
Tianye had devastated their previously fertile farmland
and transformed it into “a polluted wasteland.” Tianye
had built its factories merely 200 meters from residential
housing, and residents were forced to keep their windows
closed at all times to avoid all of the pollutants in the air,
but they reported that they were unable to protect their
crops or land. The report indicated that “the leaves of
their cotton plants are dark grey instead of green. Cotton
output has dropped by a third, from 300 kg per mu to 200
kg per mu. Their sunowers wither and die after being
watered. Those given less water survive longer. Residents
say wastewater discharged by the factories has polluted
local water sources.” 68-year-old Wang Lixian said, “We
can’t go on living here. It’s literally killing us.” He con-
tinued: “There used to be eighteen retired living workers
here. Seven moved away and are all still alive, but eight
of the eleven who stayed have died. Living here is a death
sentence.”113 Tianye is an XPCC
company, so many of the residents
affected by their manufacturing
are Han migrant settlers who
have been stationed in Shihezi.
They were able to complain to the
media in 2008 about the effects of
living near a PVC plant. There are
no such published accounts of the
pollution from PVC production that communities near
other plants experience, but this Tianye story provides
signicant insight into what the effects of PVC production
might be for affected communities.
THE XINJIANG PRODUCTION AND
CONSTRUCTION CORPS
The Xinjiang Production and Construction
Corps (XPCC or Bingtuan) is a settler colonial
paramilitary force of the PRC government, the
mission of which is to stabilize the Uyghur Re-
gion. It has governmental control over an archi-
pelago of territories, ranging from farmland to
large cities. It is also a major corporate conglom-
erate, with thirteen listed companies and thou-
sands of corporate holdings. It owns and oper-
ates mines, logistics centers, and farms, and it
is involved in the manufacturing of textiles, ap-
parel, electronics, chemicals, pharmaceuticals,
beverages, food products, and, notably, PVC.
Xinjiang Tianye is one of the XPCC’s listed com-
panies.
The XPCC has been accused of facilitating op-
pression in the Uyghur Region through the
operation of internment camps and forced la-
bor schemes. For these reasons, the U.S. gov-
ernment has specically prohibited the import
of any goods made in whole or in part by the
XPCC. The U.S., U.K., and E.U. have placed
sanctions on members of the XPCC and/or par-
ticular arms of the organization.
“We can’t go on living here.
It’s literally killing us.”
21
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
International Investments
Xinjiang Tianye Group has come under scrutiny due to
recent international investments. The 2019 U.S. Customs
and Border Protection’s Withhold Release Order banning
the import of XPCC-made goods, and the Treasury De-
partment’s Ofce of Foreign Assets Control (OFAC) sanc-
tion on the XPCC prohibiting the “making of any contri-
bution or provision of funds, goods, or services by, to, or
for the benet ” of the named entity114 led to withdrawal of
investments from XPCC companies. However, in Septem-
ber of 2021 HSBC’s wholly owned Hong Kong subsidiary
bought 20,000 shares of Xinjiang Tianye stock, costing
CNY 16.68 million.115 In January 2022, the U.K. govern-
ment debated the ethics of a London-headquartered in-
vestment corporation proting from an investment in the
XPCC. HSBC has responded that the investment was for
one anonymous client alone.116
Xinjiang Yihua Chemical Co.
(新疆宜化化 工有限公司)
Open pit mi ne owned in part by Xinjiang Yihua, and related power and
chemical complex, in the Zhun dong Coaleld. Accordi ng to Global Energy
Monito r, “The coal m ine project w as an illega l coal mine that s tarted
construction without approval.”117 Coordinates: 44.933507，89.184722.
Xinjiang Yihua Chemical Co. is a subsidiary of state-
owned Hubei Yihua Chemical Group. As of 2020, Hubei
Yihua was the world’s eighth largest PVC producer.118 Hu-
bei Yihua’s coal-to-plastics complex in the XUAR has an
annual PVC production capacity of 300,000 tons of PVC,
representing about one-quarter of Yihua’s 1.35 million
tons of PVC production.119 Xinjiang Yihua is located in the
Zhundong Economic and Technological Zone on the edge
of the Zhundong Coaleld, and benets from the cheap
energy accessible there.
In 2017, Xinjiang Yihua had two fatal explosions. In Feb-
ruary, a gas leak led to an explosion in its calcium carbide
facilities, killing two people, seriously injuring seventeen
others and injuring another thirteen.120 In July, an explo-
sion in Xinjiang Yihua’s South Gas Plant killed two people
and injured 30 people.121
Xinjiang Yihua had its safety license revoked and was put
on a blacklist of operations with poor safety production
records. The parent company was forced to suspend pro-
duction at that facility and also suspend expansion, reor-
ganization, or merger plans for high-risk projects and en-
terprises for three years. Following inspections initiated
in the aftermath of the explosion, Xinjiang Yihua had to
suspend production in the majority of its facilities, includ-
ing the PVC manufacturing facility.122 Xinjiang Yihua’s fa-
cilities came back online by April 2019, and then another
explosion rocked another Yihua plant’s carbide produc-
tion area.123 As of April 2022, Xinjiang Yihua was selling
PVC on the open international market.124
Fatal explo sion, February 12, 2017, at the Xinjiang Yi hua carbide plant.
Uncredited photo published by The Hans India.
Xinjiang Yihua receives transferred surplus laborers “ex-
ported” to the Zhundong Economic and Technological
Development Zone.125 In a 2021 article posted to social
media, Xinjiang Yihua was held up as an example of a
company that has participated in a program in Zhundong
Economic and Technological Development Zone that had
transferred eight “batches” of 175 Uyghur people each
from one neighboring county, and had transferred more
from other communities.126 See the text box about Zhun-
dong Economic and Technological Development Zone for
more on the region’s prolic use of labor transfers.
22
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Zhundong Economic and
Technological Development Zone
Spanning 15,500 square kilometers across the
Gobi Desert, the Zhundong Economic and Techno-
logical Development Zone provides the vast coal
reserves – 7% of the PRC’s total coal reserves –
necessary for the cheap production of a wide range
of industrial products.127
To encourage companies to make the distant move
out to the XUAR in the mid-2010’s, the PRC govern-
ment promoted the development of the Zhundong
Coal Power Base, which has powered the corpo-
rations that moved into the region (and will even-
tually power a great deal of the PRC).128 To better
facilitate the growth of the economy in Zhundong,
the government planned an expansion of the rail-
road and airports into the otherwise largely de-
serted region as well.129
The Zhundong Zone employs 80,000 people.130
The Zone also has a strong relationship with the
local labor transfer programmes. The Wucaiwan
Industrial Park, where Xinjiang Yihua is located, is
just one park located inside the enormous Zone. It
operates its own Wucaiwan Supply and Marketing
Cooperative Member Service Center that “actively
communicates with the transfer of labor in various
towns and villages in Jimsar County” and with
the corporations located in the park to determine
matches between workers and available jobs. The
Center had successfully matched companies with
9,000 rural surplus laborers by 2016, before the
internment camp system was operational. Since
2016 and the increasing rise of repression in the
Uyghur Region, labor transfers continued apace
upon a backdrop of internment camps, supplying
the park’s resident companies with laborers who
were compelled to participate.131 The Human Re-
sources and Social Security Bureau of Changji
Prefecture boasted in 2018 that it had conducted
11,631 transfers of surplus labor to date.132 The
programs continue even now, supported by incen-
tives provided by the Bureau to companies within
Zhundong for “absorbing” the transfers. By 2020,
the Bureau announced that it had distributed “1.6
million yuan in rewards and subsidies to 52 labor
service cooperation organizations and allocated
800,000 yuan in special funds for small factories...
to absorb poor laborers.”133
Aral Qingsong Chemical Co.
(阿拉尔青松化工有限责任公司)
Xinjiang Qingsong Building Materials complex, including Aral Qingsong,
nea r Aral ci ty.134 Coor dinates: 40. 5929 04, 81 .1974 62.
Xinjiang Qingsong Building Materials Group Co. is one of
the XPCC’s listed companies. It produces a wide range of
products, including being the XPCC’s largest producer of
cement.135 Aral Qingsong Chemical Co. was established
in 2010 as a joint venture between Xinjiang Qingsong
and the Qingdao Haiwan (sometimes translated as Hai-
jing or HyGain) Chemical Group. Located in Aral, con-
siderably southwest of the rest of the PVC industry in the
Uyghur Region, the Qingsong plant started production in
2012. As of 2019, the two companies, along with the XP-
CC’s Xinjiang Tarim Agricultural Development Co., joint-
ly operated the facility, with an annual production capac-
ity of 120,000 tons of PVC. A 230,000-ton expansion is
planned.136
In its 2020 annual report, Qingsong noted that the Aral
Qingsong Chemical Co. had conducted an “overhaul” of
the plant in the previous year, but the company contin-
ued to experience some setbacks in production due to its
relatively small scale and its aging equipment.137 PVC ac-
counts for less than 10% of Xinjiang Qingsong’s sales.138
The company’s 2020 Annual Report states that it “has
established a labor export relationship with the local
government to solve the employment of local ethnic
minorities,” indicating that the company participates
in state-sponsored surplus labor programs. Though the
Aral Qingsong subsidiary is not named explicitly, it is
possible that it has received transferred laborers.139 Ev-
idence suggests that various subsidiaries of Xinjiang
Qingsong have engaged in these labor transfers for sev-
eral years.140 In addition, in the 2019 corporate annual
report, Qingsong reported that it had matched over 320
cadres from among the company’s employees with local
ethnic minority workers, who “eat, study, and work with
the matched households” in a corporate effort to “ensure
long-term stability” in the region.141
23
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Companies that import the goods that are produced
through these programs are at signicant legal, econom-
ic, and reputational risk. They risk breaking U.S. laws,
including the Tariff Act, the Trafcking Victims Protec-
tion Act, the Uyghur Forced Labor Prevention Act, and
the laws of other countries within which they operate
or ship. Companies that import goods made in whole or
in part in the XUAR also risk being in non-compliance
with their own internal social responsibility policies or
Modern Slavery Statements prohibiting the use of forced
labor in the manufacture of goods. They further risk con-
tributing to the oppression of minoritized people in Chi-
na, legitimizing the PRC government’s repressive regime
in the region and economically beneting the private,
public, and state-owned suppliers in China that prot
from forced labor.
XINJIANG ZHONGTAI DOWN-
STREAM SUPPLY CHAIN RISK
The company’s website indicates Xinjiang Zhongtai ex-
ports to the rest of China and to the U.S., Brazil, the U.K.,
Spain, Germany, Finland, France, Italy, India, Cambodia,
Korea, Japan, and Australia.142 Zhongtai’s Alibaba page
suggests even wider distribution, mapping fty countries
on nearly every continent in their sales network. The
company takes advantage of the increasingly well-devel-
oped railway system between Ürümqi and Central Asia,
the Middle East, and Russia to get its products into in-
ternational markets, but the Alibaba site also makes the
products accessible to anyone worldwide.143
Shipping records paint a more specic portrait of some of
the routes Xinjiang Zhongtai products take on their way
into international markets. Available shipping records ac-
cessed via Panjiva provide access to 19 countries’ bills of
lading for goods shipped internationally. Zhongtai is cer-
tainly shipping via routes that are not publicly published
(including within China), but some trends can be identi-
ed through what is available.
According to shipping records, it appears that Zhongtai
ships its PVC and caustic soda internationally through at
least four subsidiaries: Xinjiang Zhongtai Import & Ex-
port, Zhongtai International Development (Hong Kong),
Xinjiang Zhongtai Chemical, and Xinjiang Shengxiong
Chlor-Alkali.144 Through these various entities, Xinjiang
Zhongtai ships to manufacturers in Vietnam, Indonesia,
India, the Philippines, U.A.E., Singapore, and Russia.
Those companies then ship PVC-based ooring, pipes and
ttings, and electronics coverings to the U.S., U.K., Hong
Kong, Myanmar, Singapore, China, Taiwan, Belize, Ne-
pal, Tanzania, Seychelles, Bhutan, Zambia, Sierra Leone,
Indonesia, Sri Lanka, and Iraq. Caustic soda goes on to be
used in manufacturing in Canada, the U.S., India, Spain,
Denmark, Hong Kong, England, Russia, Germany, Mexi-
co, Poland, Australia, and the P.R.C. A complete table of
these supply chains connections can be found in Annex A
on this report’s website.
International intermediaries seem to have become more
important to Zhongtai in the last few years. In April
2020, a company ofcial reported that the pandemic had
encouraged them to diversify geographically. He said,
“We are actively coping and adjusting our strategies. We
now focus more on Southeast Asian countries where con-
ditions are more stable. We are also planning to set up
overseas warehouses to offset future risks.”145
Zhongtai was added as a supplier for the Vietnam-
ese-based ooring company Jufeng New Materials in
3. Tracing XUAR PVC to
International Markets
PVC Floor and Wall Covering Shipments
to U.S. (March 2022)
China
60.8%
Vietnam
19.6%
South Korea
9.9%
Others
9.7%
24
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
2020.146 In that year, Jufeng purchased “a large amount”
from Zhongtai and entered into a cooperative agree-
ment regarding sourcing.147 Indeed, between 2020 and
2022, Zhongtai was Jufeng New Materials’ second
largest supplier of PVC resins, accounting for nearly
35% of all of shipments of the product to Jufeng in
terms of value (between all of Zhongtai’s varied sub-
sidiaries).148 Between March 2020 and February 2022,
Xinjiang Zhongtai shipped at least $24.6 million worth
of PVC resins to Jufeng Vietnam. In the last quarter of
2021 alone, Jufeng sourced more than $6 million dollars’
worth of PVC resin from Zhongtai.149
According to US International Trade Commission Da-
taweb, China accounts for 63% of all vinyl oor tiling
shipped to the United States in the last two years, but
Vietnam comes in second at 20%.150 Jufeng (itself a
subsidiary of a Chinese company) alone accounted for
81% of all vinyl oor tile (HS code 3918.10.11) ship-
ments from Vietnam to the United States between
May 2020 and May 2022.151 In the rst quarter of 2022
alone, Jufeng exported at least 5200 shipments of PVC-
based ooring to the US, amounting to a total value of
$80 million. Home Legend (largely sold at Home Depot)
alone accounted for nearly $20 million – about a quarter
of the value of all the imports from Jufeng in the rst
quarter of 2022.152 By comparison, Jufeng only exported
a total of $203 million worth of ooring to all destina-
tions in the world in all of 2021 (given the available ship-
ping records), suggesting another increase in production
in 2022. See Figure 7 for potential PVC supply chain risks
related to Xinjiang Zhongtai.
In addition to Home Depot products, Jufeng also
shipped PVC-based ooring products to many of the
most well-known ooring brands in the United States,
including Armstrong, Mannington, Mohawk, Congo-
leum, Shaw, Lumber Liquidators, Flooret, and more.
Zhongtai is not Jufeng’s only supplier of the relevant SG5
grade PVC resins, but Zhongtai is likely even more sig-
nicant to Jufeng than it initially seems. In fact, accord-
ing to shipping records,
Jufeng’s most signicant
supplier of PVC is Zheji-
ang Tianzhen, accounting
for 51% of Jufeng’s PVC
resin sourcing between
2020 and 2022 in terms of
value.153 Zhejiang Tianzhen
is Jufeng New Materials’
parent company. Zhejiang
Tianzhen’s 2021 IPO lings
reveal that the company
established a Hong Kong
subsidiary as an “overseas
platform company for invest-
ment paths,” through which
the company established
Jufeng New Materials in
Vietnam.154 Zhejiang Tian-
zhen’s does not itself manu-
facture PVC, but it exports
it to its subsidiary in Viet-
nam, and increasingly so in recent months. According to
the companies 2021 IPO prospectus, Zhejiang Tianzhen
sources 27% of its PVC from Xinjiang Zhongtai. Zhejiang
Tianzhen also reported that the company sources 29%
PVC from a rm that deals in PVC futures (apparently not
itself a manufacturer), which obscures the actual manu-
facturer and could mean that the PVC procured through
the futures rm could come from XUAR-based producers
as well.155 This means that Jufeng Vietnam is receiving
PVC directly from Zhongtai and likely through Zheji-
ang Tianzhen as well.
In addition to supplying Jufeng, Zhejiang Tianzhen ships
its own PVC ooring at very high risk of exposure to Xin-
jiang Zhongtai PVC and its attendant labor practices to a
wide swathe of North American ooring retailers. Zheji-
ang Tianzhen counts among its customers the following
Xin jiang Zhon gtai PVC : Potential Down strea m Suppl y Chain Ris k
25
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
major retailers: A Canada, Airbase Carpet Mart, Arm-
strong Flooring, Derr Flooring, Happy Feet International,
Home Depot, Mannington Mills, Mohawk, and Shaw. For
the full details of Zhejiang Tianzhen’s supply chain and
others, see Annex A.
Two clear examples of Jufeng’s shipments involve the
United States’ largest home improvement retailer, Home
Depot. Home Legend is a primary supplier to Home De-
pot. Jufeng Vietnam has made more than 1,300 ship-
ments to Home Legend LLC in two years. Several of the
vinyl ooring products available on Home Depot’s web-
site and in their brick-and-mortar stores match the prod-
uct code and thickness in records detailing PVC based
ooring (note: SPC stands for stone plastic composite)
shipments between Jufeng and Home Legend. Home De-
pot sells these products under the LifeProof brand name.
Home Depot indicated in correspondence with the au-
thors that Zhejiang Tianzhen, Jufeng’s parent company,
had assured Home Depot executives that Home Depot
products have never contained PVC sourced from the
XUAR. Furthermore, Home Depot said that it had been
told by Zhejiang Tianzhen that on January 24, 2022, it
had “explicitly instructed all their PVC sourcing agents
to cease purchasing PVC resin from the XUAR.” Clari-
cation has been sought regarding whether or how Home
Depot has been able to verify these claims, particularly
given that PVC from different sources can be blended at
the manufacturing facilities and that Jufeng and Tian-
zhen both have reported that they source such a signi-
cant proportion of their PVC from the Uyghur Region.156
Further, Vietnamese shipping records indicate that sub-
sidiary Jufeng has received nearly 4,000 metric tons of
PVC from Xinjiang Zhongtai since January 24, 2022.
Zhejiang Tianzhen’s own purchases of PVC are not avail-
able for review due to China not publishing internal or
external shipping records, and because the company did
not respond to our inquiries before publication. However,
as public records show that the company’s subsidiary did
not cease sourcing from the Uyghur Region on January
24, 2022, it remains unclear at the time of publication
whether Zhejiang Tianzhen in fact ceased purchasing
from Zhongtai and whether the company is able to veri-
ably exclude Xinjiang products if they continue sourcing
from the futures rm. Zhejiang Tianzhen’s own corporate
Engineered vinyl ooring model
SPC030-C from Jufeng New Materials
Vietnam to Home Legend LLC
Home Depot product number SPC030-C
Engineered vinyl ooring SPC022-C-3
from Jufeng New Materials Vietnam to
Home Legend LLC
Shipment of engi neered vinyl oor ing from Jufeng New Materials
Vietnam to Home Legend LLC
Produc t sold by Home Dep ot that inclu des the same pro duct number
(SPC022- C-3) as in ship ping record s from Jufeng to Hom e Legend LLC
Produc t sold by Home Dep ot that inclu des the same pro duct number
(SPC030 -C) and produ ct thickness (6. 5mm) as in shi pping record s
from Ju feng to Home Legend L LC
Shipment of engi neered vinyl oor ing from Jufeng New Materials
Vietnam to Home Legend LLC
Home Depot product number
SPC022-C-3
26
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
reports show Zhongtai and the futures rm accounted for
more than 50% of Zhejiang Tianzhen’s PVC purchases in
the rst half of 2021, so the company would have to sig-
nicantly and swiftly shift its supply chains in order to
make good on its promise to Home Depot.
Shipping records reveal hundreds more identi able ooring
models delivered to most of America’s largest ooring dis-
tributors. See Annex B for a summary of the products that
are at high risk of being made with Xinjiang Zhongtai PVC.
In addition to PVC, Zhongtai’s other XUAR-made prod-
ucts are also likely affected by the company’s engagement
in state-sponsored labor transfer schemes and are being
shipped internationally. The caustic soda produced by
Zhongtai is exported internationally as well and seems to
be used in the production of animal feed and a seaweed
product called carrageenan. One company that sources
caustic soda from Zhongtai is Indonesia’s Biota Lau Gang-
gang. This company produces carrageenan using caustic
soda, which international companies typically then use
to create a variety of gum products.157 Zhongtai’s 2020
semi-annual report lists Xinjiang Markor Chemical as
a subsidiary, the parent company of which is one of the
largest furniture manufacturers in China.158 It is yet un-
clear whether Zhongtai’s PVC is used the manufacture of
Markor products, though the two companies entered into
a strategic cooperation agreement in 2020.159 Shipping
records show Markor Furniture ships to many U.S. and
international furniture companies, though none directly
from the XUAR.160 Siemens was a major investor in the
building of Zhongtai’s polyester ber plant in 2018 and
provides the company with
the requisite technology
for production.161 Corpora-
tions around the world are
at risk of being connected to
forced labor through these
investments and supply
chains.
Of course, it is highly like-
ly that far more Zhongtai
PVC and caustic soda are
moving through the rest of
China and that it is being
used in the production of
other ooring and plastic
product factories in eastern
China, before entering into
international markets. It is
also likely moving from the Uyghur Region through oth-
er countries in Central Asia, Russia, or elsewhere, where
shipping records are not publicly available.
In addition to Zhongtai’s chemical manufacturing, they
are also involved in the manufacturing of cotton and
synthetic yarns that are exported globally through its
subsidiary Aral Fulida. The Fulida website claims H&M,
Zara, Uniqlo, Gap, Lee, Esprit, Polo, Urban Revivo, Levi’s,
Guess, Jack Jones, Massimo Dutti, Ralph Lauren, Vero
Moda, and Banana Republic among their international
partners for strategic cooperation.162
TIANYE DOWNSTREAM
SUPPLY CHAIN RISK
While Tianye sells much of its chemical products do-
mestically (which makes their routes into international
markets less traceable), the company also exports inter-
nationally. Shipping records suggest that the company
predominantly shipped caustic soda akes and PVC res-
ins internationally to Brazil, India, Indonesia, and Paki-
stan, where international intermediary manufacturers
produce a variety of end products that they sell into the
global market. It appears that Xinjiang Tianye ceased
exporting directly from its XUAR locations in Septem-
ber of 2020, which could be a result of the U.S. setting
a deadline that no products made by the XPCC could be
imported after the end of that month.163 It is likely that
Tianye continued to ship their products internationally
but through non-XPCC intermediaries.
Xin jiang Zhon gtai Ca ustic Soda : Potential D ownstrea m Suppl y Chain Ris k
27
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
A review of 2020 shipments, however, suggests that
Tianye’s products had been shipped to many inter-
national destinations. For instance, Xinjiang Tianye
Group shipped $457,000 worth of PVC resin to Pioneer
Polyleathers in New Delhi, India in April of 2020.164 Pi-
oneer Polyleathers in the following months sent plastic
garments, polybags, and PVC foam boards and adhesive
vinyl on to Jeewa Plastic Ltd, plastic accessories to Ami
Lanka (which ships fruits and vegetables to Saudi Arabia,
perhaps in plastic packaging), and PVC banners to adver-
tising company Traderst, all companies in Sri Lanka.
Interestingly, when Pioneer Polyleathers stopped buying
PVC Resin Suspension Grade SG5 from Tianye in 2020, it
began sourcing it from Xinjiang Zhongtai Chemical Co.,
Tianye’s biggest rival. By April of 2021, however, Pioneer
Polyleathers began sourcing its PVC SG5 from chemical
distribution company Tricon Energy in Texas, but the
shipments originated in China, making it more difcult
to trace who actually manufactured the PVC.165 However,
because Tricon was the shipper of record for some Zhong-
tai products originating in the company’s Shengxiong
factory, there is some risk that Pioneer Polylethers could
have sourced from Zhongtai.
Similarly, Indonesian company Mavica Maju Bersama re-
ceived 4 shipments totaling 35 million kilograms of PVC
Resin SG5 from Tianye between August 2019 and August
2020, but in October 2020, the company began sourcing
from Sincere Cooperation Material in Zhengzhou. Sree
International Indonesia received ve shipments of caustic
soda akes totaling 744,000 kg between April and July
2020, after which point the company sourced from other
companies, including Zhongtai briey. The company now
sources its caustic soda akes largely outside of China.
Tianye shipped to many other international manufac-
turers, none of which received shipments directly from
Tianye (at least not directly as far as available shipping
records can reveal) after September of 2020.
The fact that these companies have shifted their supply
chains away from Tianye and then away from the Uyghur
Region altogether suggests that the sanctions on XPCC
and other XUAR-made products could be signicantly af-
fecting sourcing decisions globally. Nonetheless, compa-
nies that procure caustic soda and PVC should be aware
of the potential risk of sourcing from Tianye indirectly,
as Tianye is still in operation and remains China’s second
most signicant producer of those products. Their prod-
ucts are likely continuing to reach international markets
through intermediaries.
OTHER PVC DOWNSTREAM
SUPPLY CHAIN RISKS
In winter of 2020 and spring of 2021, Hubei Yihua
shipped PVC resins to India and Sri Lanka, but available
shipping records reveal nothing more recent. Since a
quarter of Yihua’s PVC production happens in the Uyghur
Region, those 2020 and 2021 shipments suggest a risk of
XUAR-exposure for Yihua PVC. And since Xinjiang Yihua
continues to produce PVC, it is likely that it could still be
moving into international markets.
Aral Qingsong does not appear to ship PVC directly from
the XUAR to any of the nineteen countries that make
their customs records available. However, one of its par-
ent companies, Qingdao Haiwan, ships a variety of PVC
resin grades internationally under the HyGain brand,
some of which may be sourced from the joint venture in
the Uyghur Region, though this cannot be determined for
certain with publicly available records.166 Available ship-
ping records indicate that since March of 2021 Haiwan’s
PVC shipments have been sent to Abra Logistics (Brazil),
Tag Comercio International (Brazil), Cong Ty Co Phan An
Thanh Bicsol (Vietnam), Cong Ty Co Phan Nhua Chau A
(Vietnam), S Long Lanka (Sri Lanka), and St. Anthony’s
Industries Group (Sri Lanka). S Lon Lanka then shipped
PVC roong products to Aqua Star in India, and St. An-
thony’s shipped PVC gutters on to Deluxe Gutters in Ken-
ya. Haiwan produces PVC resins in both Qingdao and the
XUAR, so its products likely are entering the global mar-
ket through other channels as well.167
***
Of course, there are many Chinese manufacturers of
luxury vinyl ooring and other products made of PVC or
caustic soda for which we do not have shipping records
to identify XUAR PVC sourcing. Any XUAR-manufac-
tured PVC sourcing for those companies is much harder
to identify because domestic China shipping records are
unavailable, and companies do not declare the source of
their PVC publicly. In order to be in compliance with the
Uyghur Forced Labor Prevention Act of 2021 and other
human rights standards, any company sourcing ooring
or other PVC-based products from China should require
that its suppliers identify and prove the provenance of the
PVC, given the high proportion of the product manufac-
tured in the Uyghur Region.
28
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
In a 1991 memo, then-World Bank chief economist Law-
rence Summers remarked “a given amount of health
impairing pollution should be done in the country with
the lowest cost, which will be the country with the low-
est wage.” He said “the problem with the arguments
against…proposals for more pollution in [Less Devel-
oped Countries] (intrinsic rights to certain goods, moral
reasons, social concerns, lack of adequate markets, etc.)
could be turned around and used more or less effectively
against every Bank proposal for liberalization.”168 Three
decades later, the end result of the “impeccable logic” of
liberalization expressed by Summers is revealed in the
PVC oors beneath the feet of consumers throughout the
world.
The XUAR is uniquely suited for manufacturing the
lowest cost polyvinyl chloride. The land is topped with
stores of coal, limestone, and salt, the plastic’s required
ingredients. The state owns everything from the mining
of these resources to the production of the plastics. Low
wages are achieved through forced labor programs under
the guise of “poverty alleviation.” State ownership of the
factories ensures an absence of accountability for mercu-
ry and carbon dioxide pollution and labor abuses – all of
which are unmatched anywhere, creating vast “polluted
wastelands” populated by oppressed minorities. The state
kept running these PVC plants even while it shut down
the rest of the country’s industry during the pandemic,
and said it was doing so to capitalize upon the region’s
position in the global marketplace, which meant treating
Uyghur workers as disposable.
The externalized savings of this amoral trade is worth
a mere $100 per ton. That is the discount for PVC resin
made in region. These slightly lower prices provide the
apparent justication for the rapid increase in products
being made of materials manufactured through process-
es dependent that are on health-impairing pollution and
state-sponsored labor in the XUAR. It is why international
banks and pension funds own shares in Xinjiang Zhong-
tai while it enthusiastically participated in the ideological
programming of Uyghur people in its PVC factories.
This report exposes the “impeccable logic” of this trade
and its utter inhumanity and sweeping environmental
destruction. The next step is for the marketplace, govern-
ments, and law enforcement ofcials to hold to account
those who prot from it.
Conclusion
29
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
Note: Links may expire or be deleted. Most links here are to
archived versions of the cited sources. Where cited content
cannot be archived in full, it has been archived at the Shef-
eld Hallam Helena Kennedy Centre website. All companies
identied in the report as having a risk of supply chain con-
nections to the Uyghur Region were invited to respond, and
their responses can be found in Annex C.
***
1. Daisy Du and Noam David Stern, “Analysis of the Chi-
nese PVC industry,” ChinaDirect.Biz, March 2021, On-
line.
2. “Flooring’s dirty climate secret: Quantifying carbon
dioxide emissions and toxic chemicals used in vinyl oor-
ing manufacturing,” Center for Environmental Health,
May 2022, 3, Online.
3. Zhongtai Chemical, Homepage, Accessed March 13,
2022, Online; China National Chemical Information
Centre (CNCIC). “Has PVC already entered the next
round ‘up cycle’ in China?” CNCIC Consulting, Taipei,
Taiwan, May 17, 2019. Online; “Xinjiang Tianye Group
Co. Ltd.” China Daily, July 18, 2019. Online; “Company
Prole,” Xinjang Tianye, n.d., Online.
4. The only larger plants are Shin-Etsu’s plant in Free-
port, Texas (1.45 million tons), Xinjiang Tianye’s plant
in the XUAR (1.4 million tons, cited above), and Shaanxi
Coal’s plant in Shenmu County, Shaanxi, China (1.1 mil-
lion tons); “About Us: Freeport,” Shintech, n.d., Online;
“Shintech shuts Texas PVC operations on lack of feed-
stock: sources,” S&P Global, September 7, 2021, Online; “
企业简介” [Enterprise introduction], Beiyuan Group, n.d.,
Online.
5. Global Data, “‘Asia set to drive global polyvinyl chlo-
ride capacity additions by 2025’, says GlobalData,” June
17, 2021, Online.
6. “中国化学工程第十一建设有限公司和新疆金晖兆丰能源
股份有 限公司年产100万吨PVC项目(一期工程 )75万吨/年
电石项目建筑工程四标段电石项目建筑工程项目公告”[Chi-
na National Chemical Engineering Eleventh Construc-
tion Co., Ltd. and Xinjiang Jinhui Zhaofeng Energy Co.,
Ltd. project with an annual output of 1 million tons PVC
(Phase I) and 750,000 tons/year calcium carbide project
construction project public announcement], BiDizHao-
biao.com, April 11, 2022, Online.
7. Charles Fryer, “VCM and PVC in China,” Presented at
the APIC Meeting, Bangkok, Thailand, July 2006, Online.
8. Ana Lopez, “Global chlor-alkali market outlook,” Clo-
rosur Technical Conference, Monterrey, Mexico, IHS
Markit, November, 15, 2018, Online.
9. Du and Stern, “Analysis.”
10. Jim Vallette, “Chlorine & building materials project:
Phase 2: Asia • including worldwide ndings,” Healthy
Building Network, 2019, 12, Online.
11. Federation of Indian Chambers of Commerce and
Industry, “White paper on enhancing competitiveness
of Indian PVC & caustic soda industries,” n.d. (ca. 2017),
Online.
12. “Flooring’s dirty climate secret,” 5.
13. US International Trade Commission Dataweb, Coun-
try-specic, monthly data for commodity code 391810
(Floor coverings and wall or ceiling coverings of vinyl
chloride polymers), January 2020 to January 2022, On-
line.
14. Fryer, “VCM and PVC in China.”
15. In 2008, Ürümqi was “one of the most polluted cities
in China—with both severe air pollution and low-qual-
ity water. A 2008 report by the U.N. Environment Pro-
gramme (UNEP) and the World Health Organization
(WHO) underscored how Ürümqi’s severe air pollution
was contributes [sic] to a high mortality rate from respi-
ratory diseases, cardiovascular diseases, and tumors.” Er-
ika Scull, “Environmental health challenges in Xinjiang,”
A China environmental health project research brief, Fall
2018, Online.
16. Vallette, “Chlorine & building materials project,” 76-
81.
17. ChemOrbis, “Buyers turn to acetylene Based PVC in
China,” Plastemart.com, March 14, 2018. Online; “Acety-
lene and ethylene-based PVC move in opposite directions
in China,” December 12, 2018, Online.
18. Rough estimate based on $100/ton price differential
Notes
30
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
and 4 million tons production.
19. Buyun Du, Ping Li, Xinbin Feng, Guangle Qiu, Jun
Zhou and L. Maurice, “Mercury exposure in children of
the Wanshan mercury mining area, Guizhou, China,” In-
ternational Journal of Environmental Research and Public
Health 13, 1107 (2016): 7, Online.
20. Li Peng, Feng Xinbin, Qiu Guangle, Shang Lihai, and
Wang Shaofeng, “Mercury pollution in Wuchuan mercury
mining area, Guizhou, Southwestern China: The impacts
from large scale and artisanal mercury mining,” Environ-
ment International, 42, July 2012, 59, Online.
21. “Flooring’s dirty climate Secret,” 28.
22. Global Environment Facility, “GEF-6 request for
project endorsement/approval: demonstration of mercu-
ry reduction and minimization in the production of vinyl
chloride monomer in China.” GEF Project ID 6921, On-
line.
23. Bundesministerium für Bildung und Forschung
(BMBF), “RECAST Ürümqi – Steigerung der Ressou-
rcenefzienzin einem semiariden Milieu: Ürümqi als
Modellstadt für Zentralasien. Teilvorhaben 3: Förderung
nachhaltiger Megastadtentwicklung durch energieef-
zientes Wirtschaften in einem semiariden Milieu (FKZ
01LG0502C),” Bundesministerium für Bildung und For-
schung (BMBF)
Federal Ministry of Education and Research, Bonn/Ber-
lin, Germany Research Program Framework: Sustainable
Development of the Megacities of Tomorrow: Energy and
Climate Efcient Structures in Urban Growth Centres,
Submitted by ifeu-Institut für Energie- und Umweltfor-
schung Heidelberg GmbH, Institute for Energy and En-
vironmental Research (IFEU) (Heidelberg, Germany),
December 31, 2014, Online.
24. “Mercury,” US Geological Services, 2022. Online.
25. US Environmental Protection Agency, “Mercury Air
Releases Trend,” 2022, Online.
26. Author’s calculation based on reports reported by
manufacturers. Spreadsheet available upon request.
27. If built, the Formosa plastics factory has the poten-
tial to release 13.6 million tons of CO2e. See Oil and Gas
Watch, “Formosa Sunshine Project,” 2022, Online.
28. “Coal mine dust exposures and associated health out-
comes - a review of information published since 1995.”
Current Intelligence Bulletin 64, Centers for Disease Con-
trol: Department of Health and Human Services, 2011,
Online.
29. G. Mastrangelo, U. Fedeli, E. Fadda, G. Milan, S. Pa-
vanello, and A. Turato. “Lung cancer risk in workers ex-
posed to poly(vinyl chloride) dust: a nested case-referent
st udy,” Occup Environ Med. 60, no. 6 (2003): 427, Online.
30. “1,3-butadiene, ethylene oxide and vinyl halides (vi-
nyl uoride, vinyl chloride and vinyl bromide),” IARC
Monographs on the Evaluation of Carcinogenic Risks to
Humans, 97, 2008: 421, Online.
31. Danielle Knight, “Foreign mercury waste still con-
taminating South Africa,” Inter Press Service, March 28,
2001, Online; Jim Vallette, “Still crazy after all these
years: Mercury cells in the heart of America,” Healthy
Building Network, March 22, 2016, Online; Tony Carney,
“At long last, Thor’s poisonous mercury is getting cleaned
up,” Daily Maverick (South Africa), April 17, 2021, On-
line.
32. “U.S. les multi-million dollar action against Bor-
den Chemicals and Plastics for illegal hazardous waste
management practices and for cleanup of contaminated
groundwater,” U.S. Environmental Protection Agency
Press Release, October 27, 1994, Online.
33. Evidence of the claims that follow can be found in
the following: Amy Lehr and Mariefaye Bechrakis, “Con-
necting the dots in Xinjiang: forced labor, forced assimi-
lation, and Western supply chains,” Center for Strategic
and International Studies, 2019, 4-8, Online; Amy Lehr,
“Addressing forced labor in the Xinjiang Uyghur Autono-
mous Region: Toward a shared agenda,” Center for Stra-
tegic and International Studies, July 2020, Online; Vicky
Xiuzhong Xu et al., “Uyghurs for sale: ‘Re-education’,
forced labor, and surveillance beyond Xinjiang,” Austra-
lian Strategic Policy Institute, 2020, Online; Adrian Zenz,
“Coercive labor and forced displacement in Xinjiang’s
cross-regional labor transfer program: A process-ori-
ented evaluation,” Jamestown Foundation, 2021, 19–21
and 24–25, Online; Adrian Zenz, “Beyond the camps:
Beijing’s long-term scheme of coercive labor, poverty al-
leviation and social control in Xinjiang,” Journal of Polit-
ical Risk 7 (12) (December 2019), Online; Alison Killing
and Megha Rajagopalan, “The factories in the camps,”
BuzzFeed News, December 28, 2020 (updated January 4,
2021), Online; Laura T. Murphy and Nyrola Elimä, “In
broad daylight: Uyghur forced labour in global solar sup-
ply chains,” Helena Kennedy Centre, Shefeld Hallam
University, May 2021, Online; and Laura T. Murphy, et
al., “Laundering cotton: How Xinjiang cotton is obscured
in international supply chains,” Helena Kennedy Centre,
Shefeld Hallam University, November 2021, Online.
34. See Xinjiang Victims Database, Online.
31
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
35. China Chemical Workers Ideological and Political
Work Research Association, “党建 思政交流会经验分享之
六 | 中泰集团：国企担当 为民情怀 ” [Party building ideo-
logical and political exchange meeting experience shar-
ing no. 6丨Zhongtai Group: State-owned enterprises take
responsibility for the people], June 24, 2021, Online.
36. “Xinjiang Zhongtai Chemical Co. Ltd,” The Wall Street
Journal Market Data, Accessed March 13, 2022, Online.
37. “Company Prole,” Zhongtai Chemical Group, On-
line.
38. CNCIC Consulting, “Has PVC already entered the
next round.”
39. Collaboration for Sustainable Development of Vis-
cose, “2019 sustainability report,” Social Responsibility
Ofce of the China National Textile and Apparel Coun-
cil (CNTAC) and the China Chemical Fibers Association,
2020, 12, Online; Canopy, “Xinjiang Zhongtai Textile Co
Ltd Including Xinjiang Fulida and Aral Fulida,” Canopy
Planet, 2020, Online; Jacob Fromer, Cissy Zhou, and Fin-
barr Bermingham, “Beyond cotton, another thread in
Xinjiang supply chain creates new snag for global textile
rms,” South China Morning Post, March 28, 2021, On-
line.
40. BASF, “BASF and Markor inaugurate new produc-
tion plant for butanediol in Xinjiang, China,” January 29,
2016, Online.
41. ECHEMI, “120,000 tons per year of PBAT project in
Xinjiang will be built soon,” March 10, 2022, Online.
42. China Chemical Workers Ideological and Political
Work Research Association.
43. “Xinjiang Zhongtai (Group) Co. Ltd. Assigned ‘BB+’
Rating; Outlook Stable,” Sina, October 29, 2018, Online.
44. “Carbide economics still work,” Independent Com-
modity Intelligence Services, October 23, 2005, as cited
in Healthy Building Network (2019).
45. “China’s Xinjiang Zhongtai Chemical expects 68%
rise in 2011 prot,” Independent Commodity Intelligence
Services, February 27, 2012, as cited in Healthy Building
Network (2019).
46. Zhongtai Chemical, “Beauty chemical,” Online.
47. Google Earth image. Location conrmed through
visual matching of ground-level images in Mapio; com-
pany videos; Global Energy Monitor, “Xinjiang Zhongtai
Huatai power station,” Global Energy Monitor Wiki, April
30, 2021, Online; and Figure 1 in Guo Bin, Geng Yong,
Thomas Sterr, Dong Liang, and Liu Yaxuan, “Evaluation
of promoting industrial symbiosis in a chemical industri-
al park: A case of Midong,” Journal of Cleaner Production,
135, 2016, P995-1008, ISSN 0959-6526, Online.
48. Ibid; “Announcement of Xinjiang Zhongtai Chemical
Co., Ltd. on the production and operation of new projects
of Fukang Energy and Zhongtai Mining and Metallurgy,”
Securities Times, Online.
49. Zhongtai Chemical, “Beauty Chemical.”
50. “First unit of Zhongtai Chemical’s Fukang Industri-
al Park Power Station begins operations,” Industrial Info
Resources, December 6, 2012, Online; Li Jiahao , “中泰化
学热电厂六台机组全部建成投产且并网发电低成本战略落地
生根” [All six units of Zhongtai Chemical Thermal Power
Plant were completed and put into operation and connected
to the grid for power generation, and the low-cost strategy
took root], Zhongtai Chemical, January 30, 2013, Online;
“新疆中泰化学股份有限公司关于阜康能源及中泰矿冶新建项
目生产 运行情况的公告” [Announcement on the production
and operation of new projects of Fukang Energy and Zhong-
tai Mining and Metallurgy], January 25, 2013, Online.
51. Apple Maps image (undated). Screenshot taken on
May 19, 2022. Location based on coordinates provided by
Global Energy Monitor. “Xinjiang Zhongtai Fukang pow-
er station,” Global Energy Monitor Wiki, April 30, 2021,
Online.
52. Margaret Volkova, “Mahatma Xinjiang Energy to shut
PVC plant this week,” MRC, September 2, 2015, Online.
53. Apple Maps image (undated). Screenshot taken on
May 19, 2022. Online. Location conrmed through Glob-
al Energy Monitor. “Toksun Mahatma power station,”
Global Energy Monitor wiki, Online.
54. Human Resources Department of Zhongtai Chemi-
cal Toksun Energy Chemical Co., Ltd., “新疆中泰化学托
克逊能化有限 公司招聘简章 ” [Xinjiang Zhongtai Chemi-
cal Toksun Energy Chemical Co., Ltd. Recruitment Bro-
chure], School of Chemistry and Chemical Engineering,
March 13, 2018, Online; Wang Xia, “考察调研 | 中共湘潭
县委副书记周艳希一行14人赴圣雄氯碱公司参观考察” [In-
vestigation | Zhou Yanxi, deputy secretary of the Xiang-
tan County Party Committee of the Communist Party
– 14 travel to Shengxiong Chlor-Alkali for inspection],
Mahatma Today, August 30, 2017, Online.
55. For an extended discussion of the industrial park and
its relationship to the karez irrigation system, see Mur-
phy, et al., “Financing and genocide,” 33-36.
56. Apple map (undated). Screenshot taken May 19,
32
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
2022, Online; Location based upon Global Energy Mon-
itor, “Zhongtai Toksun power station,” Global Energy
Monitor wiki, Online.
57. Zhongtai Chemical. “Xinjiang Zhongtai Chemical
- About Us,” Online; China National Chemical Informa-
tion Centre (CNCIC). “Has PVC already entered the next
round.”
58. Securities Star, “Zhongtai Chemical: Shenwan
Hongyuan, Shenwan Hongyuan and other twenty-two
institutions investigated our company on October 29,” Lai
Times, November 9, 2021, Online.
59. Bernd Franke, Li Niu, Jiarheng Ahati, Andreas De-
tzel, Zhao Chenxi, Mirjam Busch and Cassandra Derre-
za-Greeven, “Technological and economic challenges in
making Urumqi’s PVC industry more energy efcient,”
JOVIS Verlag GmbH, 2014, Online.
60. Shi Xin, “千名南疆贫困家庭劳动力将在国企转移就业”
[Thousands of laborers from poor families in southern
Xinjiang will be transferred to state-owned enterprises],
Xinjiang Daily, March 12, 2020, Online.
61. Repiketti, “中泰责任 | 贯彻自治区维护 稳定工作电视
电话会议精神 村民纷纷发声亮剑 喀提亚克村举行维护稳定
大宣讲大揭批大讨论活动” [Zhongtai Responsibility | Im-
plementing the spirit of the video and teleconference on
the maintenance of stability in the autonomous region,
villagers have spoken out and held a large number of
discussions on maintaining stability in Katyak Village],
Weixin, January 13, 2017, Online.
62. Various correspondents for Zhongtai Zero Distance,
“中泰头条 | 新疆中泰集团各监管单位分别举行庆”五一 ”升国
旗仪式暨持续 ‘发声亮剑’ 活动” [Zhongtai Toutiao | Xinji-
ang Zhongtai Group’s supervisory units held a ag-rais-
ing ceremony to celebrate the “May 1st” and continued
the “Sound and Sword” activity], Weixin, May 5, 2019,
Online.
63. He Xu for Zhongtai Zero Distance, “中泰责任 | 斯也
克村工作队扎实用好 ”新疆入户走访”APP 推动入户走访信息
化” [Zhongtai Responsibility | The Siyek Village Work
Team makes good use of the “Xinjiang Home Visit” app
to promote the informatization of home visits], Weixin,
July 31, 2017, Online. For more on these ideological and
surveillance programs, see Darren Byler, In the camps:
China’s high-tech penal colony, New York: Columbia Glob-
al Reports, 2022; “‘Hundred questions and hundred ex-
amples’: Cadre handbooks in the Fanghuiju campaign,”
The University of British Columbia, Online; “China: Vis-
iting ofcials occupy homes in Muslim region ‘Becoming
Family’ campaign intensies repression in Xinjiang,” Hu-
man Rights Watch, May 13, 2018, Online; Dake Kang and
Yanan Wang, “China’s Uighurs told to share beds, meals
with party members,” AP News, November 30, 2018, On-
line; Nyrola Elimä, “China cannot silence me,” The New
Yorker, December 2021, Online; Peter Goff, “‘Become
family’: China sends ofcials to stay with Xinjiang mi-
norities,” The Irish Times, December 17, 2019, Online;
Darren Byler, “Why Chinese civil servants are happy to
occupy Uyghur homes in Xinjiang,” CNN, November 10,
2018, Online; “Male Chinese ‘relatives’ assigned to Uy-
ghur homes co-sleep with female ‘hosts,’” Radio Free Asia,
October 31, 2019, Online.
64. China Chemical Workers Ideological and Political
Work Research Association.
65. Fu Xiaobo, Aynor, “新疆聚焦22个深度贫困县(市)计划
3年转移就业10万人” [Xinjiang focuses on 22 deeply im-
poverished counties (cities) and plans to transfer and em-
ploy 100,000 people in three years], Xinhua, January 10,
2018, Online.
66. Xinjiang State-Owned Assets Supervision and Ad-
ministration Commission, “新疆中泰通过多样培训助南疆
新员工早日上岗 ” [Xinjiang Zhongtai helps new employees
in southern Xinjiang to take up jobs as soon as possible
through various trainings], Xinjiang State-Owned Assets
Supervision Administration, July 4, 2017, Online.
67. Zhang Ming, “新疆中泰集团-新疆轻工职业技术学院
签订集团化办 学 协议” [Xinjiang Zhongtai Group-Xinjiang
Light Industry Vocational and Technical College signed a
group-based school-running agreement], Xinjiang Indus-
try Technical College website, May 8, 2017, Online.
68. Lin Ling, Zhang Yanjun, “麦盖提县驻 村工作队全程 为
外出务工人员保驾护航” [The working team in the village
of Makit County escorted the migrant workers through-
out the process], Tianshan News, July 31, 2018, Online.
69. See Adrian Zenz, “‘Wash brains, cleanse hearts’: Ev-
idence from Chinese government documents about the
nature and extent of Xinjiang’s extrajudicial internment
campaign,” Journal of Political Risk, 7:11, November
2019, Online.
70. Sui Yunyan, Li Chunxia, “自治区中高职院校师生代表
赴喀什和田参观调研 ‘这项工作有必要有效果有意义’” [Rep-
resentatives of teachers and students from secondary and
higher vocational colleges in the autonomous region went
to Kashgar and Hotan to visit and investigate, ‘This work
is necessary, effective and meaningful’], Xinjiang Daily,
November 23, 2018, Online.
71. Zhongtai University, “技能培训 | 中泰大学职业技能
33
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
培训学校圆满完成南疆四地州转移就业人员培训” [Skills
training | Zhongtai University Vocational Skills Training
School successfully completed the training for transfer
employees from four prefectures in southern Xinjiang],
Weixin, May 21, 2020, Online; Ma Lijuan, “【雪 峰要闻】
集团公司45名南疆转移就业人员军训生活结束” [[Xuefeng
News] 45 Southern Xinjiang employees of the group
company’s military training life ended], Weixin, June 27,
2017, Online.
72. Wujun for Mahatma Today, “头 条！ 集团公司领导赴
圣雄园区调研南疆籍新员工安置就业工作” [Headlines!
The leaders of the group company went to the Mahatma
Park to investigate the placement of new employees from
southern Xinjiang], Weixin, June 22, 2017, Online.
73. Department of Human Resources and Social Securi-
ty of Xinjiang Uyghur Autonomous Region, “聚焦稳定就
业目标 全力加强喀什和田地区转移就业人员管理服务” [Fo-
cus on the goal of stabilizing employment, fully enhance
Kashgar and Hotan transferred labor personnel manage-
ment services], Xinjiang.gov, August 15, 2017, Online.
74. Wujun for Mahatma Today, “民族团结| 圣雄顺利接
收 喀 什 、和 田 200名富余劳 动力到工业园 区 就业 ” [National
Unity | Mahatma successfully accepts 200 surplus la-
borers from Kashgar and Hotan to work in the industrial
park], Weixin, July 4, 2017, Online.
75. “华泰责任 | 华泰公司接收新一批批南疆新进少数民族
员工” [Huatai Responsibility | Huatai Company receives
new batches of minority employees in southern Xinjiang],
Pinlue, August 6, 2017, Online; Lu Juan for Zhongtai Zero
Distance, “中泰责任 | 华泰公司召开2018年新疆富余劳动力
转移就业安置人员座谈欢迎会” [Zhongtai Responsibility |
Huatai Company held a welcome meeting for the 2018
Xinjiang surplus labor transfer and employment resettle-
ment personnel symposium], Weixin, May 16, 2018, On-
line.
76. Wang Xia, “Investigation.”
77. Bai Cuicui for Zhongtai Zero Distance, “中泰人 | 勤
学苦练提技能奋力追逐幸福梦 --圣雄氯碱公司质检中心分析
工热比娅·麦麦提成长记” [Zhongtai people | Study hard,
improve skills, strive to pursue a dream of happiness --
the growth of Rabiye Memet, an analyst at the Quality
Inspection Center of Shengxiong Chloralkali Co., Ltd.]
Weixin, August 18, 2018, Online.
78. Du Lei, “中泰责任 | 南疆四地州贫困家庭富余劳动力
转移就业员工在新疆中泰化学阜康能源公司的 ‘一年四季’“
[Zhongtai Responsibility | The “four seasons” of the sur-
plus labor force of poor families in four prefectures in
southern Xinjiang transferred to employment in Xinjiang
Zhongtai Chemical Fukang Energy Company], Weixin,
September 15, 2018, Online.
79. “有事干有钱挣！让贫困劳动力端稳就业 ‘饭碗’“ [There
are jobs to do and money to make! Let the poor laborers
stabilize their employment “rice bowls”], Tianshan Net-
work, June 10, 2020, Online.
80. Zhongtai Zero Distance, “最 美中泰人 | 记阜康能源
PVC新材料车间生产班组主操卡米力江•阿布都瓦依提的成长
之路” [The most beautiful Zhongtai people | Remember
the growth path of Kamiljan Abduwayit , the leader of
the production team of Fukang Energy’s PVC new materi-
al workshop], Weixin, September 3, 2020, Online.
81. “民族团结 | 我 是 一 颗 石 榴 籽：用 心 用 情 浇 灌 民 族 团 结 之
花” [National Unity | I am a pomegranate seed: Water-
ing the ower of national unity with heart and affection],
Mahatma Today, January 8, 2019, Online.
82. Zhong Juntang for Mahatma Today,”榜样的力量 |
脚踏实地干工作 真心帮扶聚人心 —记圣雄水泥公司生产技
术处塔依尔·依明” [The power of role models | Down-to-
earth work and sincere help gather people’s hearts - Tayer
Emin, Production Technology Department of Mahatma
Cement Company], Weixin, October 5, 2018, Online.
83. Du Lei, “Zhongtai Responsibility.”
84. “新疆龙头企业助推转移就业 南疆农民从田间走上流水
线” [Leading enterprises in Xinjiang boost employment
transfer for farmers in southern Xinjiang from the eld to
the assembly line], Xinhua, June 29, 2019, Online.
85. “新疆中泰化学2018年年度报告” [Xinjiang Zhongtai
Chemical Co., Ltd. 2018 Annual Report], March 2019, 88-
90, Online.
86. “Zhongtai Import and Export Corporation opened up
the Zhongtai Import & Export; Company international
market to achieve a sharp rise in foreign trade business,”
October 27, 2020. Online.
87. Wu Jun for Huatai Zero Distance, “中泰头条 | 中泰集
团接收南疆深度贫困县150名劳动力就业 ” [Zhongtai Head-
lines | Zhongtai Group accepts employment of 150 labor-
ers from deeply impoverished counties in southern Xinji-
ang], Weixin, March 17, 2020, Online.
88. Tian Xuejun for Mahatma Today, “助力脱贫攻坚 | 圣
雄园区接收第一批南疆深度贫困县转移就业人员” [Helping
poverty alleviation | Mahatma Park receives the rst
batch of transferred workers from deeply impoverished
counties in southern Xinjiang], Weixin, March 29, 2020,
Online.
89. Tian Xuejun for Mahatma Today, “榜样的力量 | 圣雄
34
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
能源热电厂检修车间阿不力孜·阿布来海提的逆袭之路” [The
power of example | The turnaround of Abliz Abulahat,
the Maintenance Workshop of Mahatma Energy Thermal
Power Plant], Weixin, July 7, 2020, Online.
90. “新疆富丽震纶年产17. 5 万 吨高品质纱线项目投产 ” [Xin-
jiang Fuli Zhenlun’s high-quality yarn project with an
annual output of 175,000 tons was put into operation],
China Yarn Net, December 6, 2017, Online; “新疆富丽震
纶在”一带一路”建设中积极承担社会责任接纳126名南疆少
数民族就业” [Xinjiang Fuli Zhenlun actively undertakes
social responsibilities in the construction of the “Belt
and Road” and accepts 126 ethnic minorities in southern
Xinjiang for employment], China Yarn Net, May 3, 2017.
Online; “新疆富丽震纶勇于担当积极作为不忘初心砥砺前行
接收安置第三批60名南疆地区富余劳 动力” [Xinjiang Fuli
Zhenlun has the courage to take an active role and move
forward without forgetting their original intentions, re-
ceives and resettles third batch of 60 surplus laborers
in southern Xinjiang], Chain Yarn Net, August 22, 2017,
Online; Dina, “中泰集团阿拉尔富丽达全面发展硕果 ‘今非昔
比’” [The all-round development of Zhongtai Group Aral
Fulida is “not what it used to be”], Xinjiang China News,
October 1, 2018, Online.
91. Chai Xuechun, “中泰管理｜新疆生产建设兵团第一师党
委 常 委、副 师 长 李文彬一行到阿拉尔富丽达调研” [Zhongtai
Management｜Li Wenbin, member of the Standing Com-
mittee of the Party Committee and Deputy Division Com-
mander of the First Division of Xinjiang Production and
Construction Corps, and his party went to Aral Fulida for
investigation], Sohu, September 22, 2018, Online.
92. Jacob Fromer, Cissy Zhou, and Finbarr Bermingham,
“Beyond cotton, another thread in Xinjiang supply chain
creates new snag for global textile rms,” South China
Morning Post, March 28, 2021, Online.
93. “Zhongtai Chemical 002092.SZ,” Stock.US, Decem-
ber 31, 2021, Online; Tanmi, “中泰化学1.1亿增资准东煤
业” [Zhongtai Chemical’s 110 million capital increase in
Zhundong coal industry], February 22, 2012, Online.
94. “Breaking new ground: Shenhua leads the way in
new Chinese coal mining region,” Viewpoint Mining Mag-
azine, n.d., Online; “Caterpillar sustainability in China,”
2013, Online; “UPDATE 1-Peabody to develop 1,200 MW
power plant in China,” January 20, 2011, Online.
95. Hu Xiaodong and Pan Zhongming. “National Xinji-
ang Zhundong Economic and Technological Development
Zone,” China Tod a y, August 20, 2013, Online.
96. “新疆首个场地 污染土壤修复项目实施 ” [Implementa-
tion of Xinjiang’s rst site-contaminated soil remediation
project], People’s Daily, August 26, 2018, Online.
97. Bundesministerium für Bildung und Forschung
(BMBF), “RECAST Ürümqi – Steigerung der Ressou-
rcenefzienzin einem semiariden Milieu: Ürümqi als
Modellstadt für Zentralasien. Teilvorhaben 3: Förderung
nachhaltiger Megastadtentwicklung durch energieef-
zientes Wirtschaften in einem semiariden Milieu (FKZ
01LG0502C),” Bundesministerium für Bildung und
Forschung (BMBF) Federal Ministry of Education and
Research, Bonn/Berlin, Germany Research Program
Framework: Sustainable Development of the Megacities
of Tomorrow: Energy and Climate Efcient Structures in
Urban Growth Centres, Submitted by ifeu-Institut für En-
ergie- und Umweltforschung Heidelberg GmbH, Institute
for Energy and Environmental Research (IFEU) (Heidel-
berg, Germany), December 31, 2014, Online.
98. Xinjiang Jinhui Zhaofeng, “Company prole,” Ac-
cessed April 23, 2022, Online; “投资260亿元 新疆100万吨
聚 氯 乙 烯 项 目，75万吨 /年 电 石 项 目 开工！ ” [26 billion yuan
investment in Xinjiang’s 1 million-ton PVC project, the
750,000-ton/year calcium carbide project started!], Ten-
cent, June 3, 2021, Online.
99. Ibid; Carmen, “Xinjiang Zhongtai Chemical Compa-
ny Baicheng Complex, China.” Offshore Technology, Octo-
ber 22, 2021, Online
100. Global Coal Exit List, “Xinjiang Zhongtai Chemical
Co Ltd,” Accessed April 15, 2022, Online.
101. Alaska Permanent Fund Corporation, “Holdings of
publicly traded companies,” September 30, 2021, Online.
102. Amina Obul, “I work and I am happy,” Tianshan Net,
December 15, 2021, Online; Shadetgul Wali, “Knowledge
changes fast, and knowledge is wealth,” Tianshan Net,
December 17, 20221, Online; Arzigul Mamut, “The lie of
‘forced labor’ will be nally revealed,” Tianshan Net, De-
cember 28, 2021, Online.
103. Image from Apple Maps (undated). Screenshot tak-
en May 20, 2022, Online; Global Energy Monitor, “Tianye
power station,” Global Energy Monitor wiki, April 30,
2021, Online.
104. Healthy Building Network, “Chlorine & building
materials project: Phase 2: Asia • including worldwide
ndings,” Online; Only Shin-Tech’s 1.45-million-ton PVC
factory in Texas is larger.
105. “Xinjiang Tianye Group Co. Ltd.,” China Daily, July
18, 2019, Online.
106. He Caizhen, “解读天业人的脱贫攻坚 ‘密码’“[Inter-
35
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
pretation of Tianye people’s “password” for poverty alle-
viation] , Weixin, April 19, 2021, Online; “新疆天业股份有
限公司 2020年年度报告” [2020 annual report of Xinjiang
Tianye Co., Ltd.], April 22, 2021,60, Online; Company
prole, Xinjiang Tianye (Group) Co., Ltd., n.d. Online; “先
进 个人——北京农业工程学会副理事长严海军” [Advanced
individual - Yan Haijun, vice chairman of Beijing Agricul-
tural Engineering Society], Bastnet, July 14, 2020, On-
line;
107. “新疆 天业股份有限 公司2018年年度报告” [2018 an-
nual report of Xinjiang Tianye Co., Ltd.], Sina, April 8,
2019, 47- 49, Online.
108. He Caizhen, “Interpretation of Tianye people’s
‘password’ for poverty alleviation.”
109. Huozhou Family, “一枝一 叶总关情” [One branch and
one leaf are always affectionate], Weixin, July 9, 2020,
Online.
110. He Caizhen, “Interpretation of Tianye people’s ‘pa ss-
word’ for poverty alleviation.”
111. See Murphy, et al., “Laundering Cotton,” and Mur-
phy, Salcito, and Elimä, “Financing and Genocide.”
112. “新疆天业股份有限公司2019年年度报告” [2019 an-
nual report of Xinjiang Tianye Co., Ltd.], April 28, 2020,
43, Online.
113. Ming’ai, Zhang. “Tough to make polluters pay.” Chi-
na.org, August 6, 2008, Online.
114. U.S. Department of the Treasury, “Treasury sanc-
tions Chinese entity and ofcials pursuant to global Mag-
nitsky human rights executive order,” July 31, 2020, On-
line.
115. “新疆天业行情走势” [Xinjiang Tianye market
trends], Eastmoney, Accessed May 16, 2022, Online.
116. Gabriel Pogrund and Jack Hazlewood, “HSBC hold-
ing shares in Chinese company linked to Uighur atroci-
ties,” The Sunday Times, January 9, 2022, Online.
117. Apple map (undated). Screenshot taken May 20,
2022, Online; Global Energy Monitor, “Wucaiwan No.1
open-pit mine,” Global Energy Monitor wiki, April 30,
2021, Online.
118. Orbia Advance Corporation, S.A.B. de C.V. 2020.
“Annual report.” Mexico City, Mexico, 179, Online.
119. Chen Hongxia and Wan Ru, “湖北 宜化 新 疆 公司公 告
继续整改” [Hubei Yihua Xinjiang Company announced
that it will continue to rectify], 21st Century Economic
News, August 8, 2017, Online; “新疆宜化化 工有限公司专
场招聘会” [Xinjiang Yihua Chemical Co., Ltd. job fair],
School of Chemistry and Chemical Engineering, March
30, 2018, Online; “湖北宜化集团 有限责任 公司” [Introduc-
tion of Hubei Yihua Group Co., Ltd.” Baidu, Online.
120. Li Qirui,”湖北宜化刚预告2016年 巨亏又 遇 子 公 司发 生
闪爆” [Hubei Yihua just announced huge losses in 2016
and saw internal explosion at subsidiary], Daily Econom-
ic News, February 14, 2017, Online; “Talking about the
characteristics of the calcium carbide process PVC indus-
try and the future prospects of Zhongtai Chemical,” May
5, 2020, Online; “Two killed in chemical plant explosion
in China,” Times of India. February 12, 2017, Online.
121. Chen Hongxia and Wan Ru, “Hubei Yihua Xinjiang
Company announced that it will continue to rectify.”
122. “Two killed;” Hubei Yihua Chemical Co., Ltd. Board
of Directors, “湖 北 宜化：关 于 子 公司新疆宜化化 工有限公
司”2.12”电石炉喷料灼烫一般事故调查报告及整改进展情况
的公告” [Hubei Yihua: Announcement on the “2.12” gen-
eral accident investigation report and rectication and
development of the subsidiary Xinjiang Yihua Chemical
Co., Ltd.] Sohu, April 26, 2017, Online.
123. CommoPlast Empowering Insights, “China PVC
market pick up as local supply curtails following explo-
sion,” April 25, 2019, Online.
124. “生 意 社：3月24日新疆宜化PVC价格动态” [Business
club: Xinjiang Yihua PVC price dynamics on March 24],
chemrp, March 24, 2020; “新疆宜化 PVC报价” [Xinjiang
Yihua PVC quotation], Business Club, March 28, 2022,
Online.
125. Gai Youjun and Liu Qian, “脱贫攻坚答卷, 托起群众脱
贫梦——记自治区脱贫攻坚先进集体昌吉州扶贫办” [Hold-
ing up the dream of the masses to get rid of poverty,],
Tianshan Net News, May 23, 2021, Online.
126. Ibid.
127. “新疆准东经济技术开发区” [Xinjiang Zhundong Eco-
nomic Technological Development Zone], Baidu, Online.
128. “新疆维吾 尔自治区国民经济和 社会发展 : 第十三个五年
规划纲要 ” [National economic and social development of
the Xinjiang Uygur Autonomous Region: Outline of the
thirteenth ve-year plan], May 2016, Online, 40.
129. Ibid, 65-66, 82-84.
130. The State Council Information Ofce of the People’s
Republic of China, “Employment and labor rights in Xinji-
ang,” [English version], September 2020, Online.
131. Zhundong Development Zone Up Close, “准东开发
36
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
区转移乌恰县25名农村富余劳动力来准东就业” [Zhundong
Development Zone transferred 25 surplus rural labor-
ers from Ulugqat [Wuqia] County to Zhundong for em-
ployment], Weixin, December 27, 2016, Online; “天山早
春图—最美的是你们追梦的模样” [Tianshan early spring
picture -- The most beautiful thing is the sight of you pur-
suing your dreams], Weixin, February 26, 2019, Online.
132. “新疆昌吉市劳务经济助力农民增收” [The labor econ-
omy of Changji City in Xinjiang helps farmers increase
their income], China’s Employment, May 7, 2018, Online.
133. Changji People’s Government, “昌吉州决战决胜脱贫
攻坚系列报道之二” [The second part of a series of reports
on Changji Prefecture’s decisive victory in poverty allevi-
ation], Weixin, July 2, 2020, Online.
134. Location based on Google Maps listing, Online; Im-
age from Apple Maps, screenshot taken May 20, 2022,
Online.
135. “新疆青松建材化工(集团)股份有限 公司2020 年年度
报告” [Xinjiang Qingsong Building Materials and Chemi-
cals (Group) Co, Ltd. 2020 annual report], Xinjiang Qing-
song Building Materials and Chemicals (Group) Co, Ltd,
March 18, 2021, 10, Online.
136. Ministry of Economy Trade and Industry, “世界の
主要石油化学プラント （ 既 存 及 び ２０２２ 年ま で の 新 増 設 計
画）” [World’s major petrochemical plants (existing and
new expansion plans by 2022)], Government of Japan,
n.d., Online; “西北分公司承建的新疆青松项目生产出合格产
品 来 源：澳 客 比 分直 播 最 快 最 准 |浏览” [The Xinjiang Qing-
song Project undertaken by the Northwest Branch pro-
duced qualied products], CNCEC, September 4, 2012,
Online; Xinjiang Zhian Tongchuang Security Technolo-
gy Service Co., “2019年）阿拉尔青松化工有限责任公司10
万吨/年烧 碱、12万吨/年PVC生 产 装 置、14万吨/年电石生产
装置安全现状评价报告 ” [(2019) Safety status evaluation
report of 100,000 tons/year caustic soda, 120,000 tons/
year PVC production equipment, and 140,000 tons/year
calcium carbide production equipment of Alar Qingsong
Chemical Co., Ltd.], Jan 17. 2020, Online; “Suspension
polyvinyl chloride resins for food containers and packag-
ing materials,” Haiwan Chemical, 2017, Online; “Xinjiang
Qingsong Building Materials Chemical (Group) Co., Ltd.
foreign investment announcement,” Sina Finance, Octo-
ber 28, 2009. Online.
137. Xinjiang Qingsong 2020 Annual report.
138. Wang Jinlong, “Qingsong Jianhua participates in
the reorganization of Meifeng Chemical to resume pro-
duction in doubt,” Min.news, May 10, 2022, Online.
139. “新疆青松建材化工(集团)股份有限公司2020 年年度
报告” [Xinjiang Qingsong Building Materials and Chemi-
cals (Group) Co, Ltd. 2020 annual report], Xinjiang Qing-
song Building Materials and Chemicals (Group) Co, Ltd,
March 18, 2021, 29, Online.
140. “新时代新气象 新作为,十 四 师 接 收城乡富余 劳 动力转移
就业成效明显” [In the new era, new weather and new ac-
tions, the 14th Division has achieved remarkable results
in accepting the transfer of surplus urban and rural labor
force],Weixin, December 27, 2017, Online; “新疆青松建材
公司吸纳地方少数民族群众就业的探索：欢乐和富足缘何而
来?” [Xinjiang Qingsong Building Materials Company’s
exploration of absorbing the employment of local ethnic
minorities: Where do joy and prosperity come from?],
Weixin, September 10, 2018, Online; “复工复产 | 十四师
昆 玉 市：靠 前 服 务 解 难 题 ” [Resumption of work and pro-
duction | The 14th Division of Kunyu City: Solving prob-
lems with front service], Weixin, April 20, 2020, Online.
141. “新疆青松建材化工(集团)股份有限公司2019 年年度
报告” [Xinjiang Qingsong Building Materials and Chemi-
cals (Group) Co, Ltd. 2019 annual report], Xinjiang Qing-
song Building Materials and Chemicals (Group) Co. Ltd.,
March 27, 2020, 29, Online.
142. Zhongtai Chemical, Homepage, Accessed March 13,
2022, Online. [See map on website at http://www.zthx.
com/en/]
143. “Zhongtai Import and Export Co., Ltd.” Alibaba.
com, Accessed March 13, 2022, Online.
144. Shipping records accessed through Panjiva Market
Intelligence and Descartes Datamyne. See Zhongtai’s
announcement of its subsidiary in Hong Kong: Ren Yue,
“中泰国际发展(香港)有限公司注册成立” [Zhongtai Inter-
national Development (Hong Kong) Co., Ltd. was incor-
porated], Zhongtai Chemical Press Release, March 9,
2019, Online.
145. “Coronavirus pandemic: China Europe Express
Railway shipments rise in April,” China Global Television
Network, May 8 2020, Online.
146. “关于浙江天振科技股份有限公司首次公开发行股票
并在创业板上市: 申请文件的审核问询函回复” [About Zhe-
jiang Tianzhen Technology Co., Ltd. IPO and listing on
GEM: Reply to the inquiry letter of review of application
documents] Zhejiang Tianzhen, October 2021, 201, On-
line.
147. Ibid, 201.
148. Shipping data accessed via Panjiva Market Intelli-
gence.
37
BUILT ON R EPRESSI ON: PVC BUI LDING MATER IALS’ REL IANCE ON LA BOR AND ENV IRONME NTAL ABUSES I N THE UYGHUR R EGION
149. Shipping data accessed via Panjiva Market Intelli-
gence.
150. US International Trade Commission Dataweb,
Country-specic, monthly data for commodity code
391810 (oor coverings and wall or ceiling coverings of
vinyl chloride polymers), January 2020 to January 2022,
Online.
151. Shipping data accessed via Panjiva Market Intelli-
gence.
152. Shipping data accessed via Descartes Datamyne.
153. Ibid.
154. “关于浙江天振科技股份有限公司首次公开发行股票
并在创业板上市: 申请文件的审核问询函回复” [About Zhe-
jiang Tianzhen Technology Co., Ltd. IPO and listing on
GEM: Reply to the inquiry letter of review of application
documents] Zhejiang Tianzhen, October 2021, 39, On-
line.
155. Ibid, 206-207; Conrmed through MOFCOM Over-
seas investment lings via Sayari Graph.
156. Updates from Home Depot (or any other company
responding to this report) after the time of publication
will be made available in Annex C on the report’s website.
157. Shipping records accessed via Panjiva Market Intel-
ligence.
158. “新疆中泰化学股份有限公司 2020 年半年度报告” [
Xinjiang Zhongtai Chemical Co., Ltd. 2020 semi-annual
report], August, 26, 2020, 51, Online.
159. “强强联合 美克集团与中泰集团达成战略合作协议”
[Strong alliance, Markor Group and Zhongtai Group
reach strategic cooperation agreement], Markor Invest-
ment Group Co. Ltd., September 23, 2020, Online.
160. Shipping records accessed through Panjiva Market
Intelligence.
161. “西门子为中泰 集 团打造年产120万吨PTA数字化工
厂” [Siemens builds PTA digital factory with an annual
output of 1.2 million tons for Zhongtai Group], Manufac-
turing Today, July 18, 2018, Online; Xinjiang Zhongtai
Chemical Co., Ltd. 2018 annual report, 2019, 15, Online.
This plant also engages in the labor transfer programs:
Yan Wenlu, “中泰集团举办公众开放日活动 PTA项目建设 顺
利” [Zhongtai Group held public open day activities, PTA
project construction went smoothly], Xinjiang Metropolis
Daily, August 25, 2019, Online; “新疆库尔勒中泰石化PTA
项目复工复产 ” [Xinjiang Korla Zhongtai Petrochemical
PTA project resumes work and production], Bayingoleng
Daily, March 30, 2020, Online.
162. Fulida Group, “Strategic cooperation,” Accessed
March 13, 2022, Online.
163. U.S. Department of the Treasury, “Treasury sanc-
tions Chinese entity and ofcials pursuant to global Mag-
nitsky human rights executive order,” Press Release, July
31, 2020, Online.
164. All shipping records access via Panjiva Source Intel-
ligence.
165. According to its own website, Tricon is “an indus-
try leader in the global trade and distribution market.”
See Tricon Energy, Homepage, Accessed May 4, 2022,
Online; Shipping records accessed via Panjiva Market In-
telligence indicate that Tricon distributes for a number of
Chinese manufacturers.
166. Qingdao Haiwan Chemical (Group) Co., Ltd., “Sus-
pension polyvinyl chloride resins for food containers and
packaging materials,” Qingdao Haiwan Chemical, Ac-
cessed May 10, 2022, Online.
167. Shipping records accessed through Panjiva Market
Intelligence.
168. Jim Vallette, “Larry Summers’ war against the
Earth,” Counterpunch, Global Policy Forum, 1995, On-
line.
