Risk at the source: Critical mineral supply chains and state-imposed forced labour in the Uyghur Region
The report analyses how critical minerals sourced in the Uyghur Region—titanium, lithium, beryllium and magnesium—are linked to state-imposed forced labour. It identifies companies involved, downstream exposure risks, and implications for global supply chains, underscoring the need for stronger due diligence and avoidance of forced-labour-tainted inputs.
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OVERVIEW
Introduction
The report examines how critical minerals essential for modern economies—including those used in construction, electronics, energy systems, and defence—are increasingly sourced and processed in the Xinjiang Uyghur Autonomous Region (XUAR). The People’s Republic of China (PRC) dominates global mining and processing of critical minerals, producing 30 of 44 minerals designated as critical by the United States. Decades of domestic policy have placed the PRC in a strategic position across mineral value chains.
The PRC has identified the Uyghur Region’s resources as vital to national industrial development. However, the Region is also the site of extensive state-imposed forced labour, mass surveillance, internment, and the coercive transfer of Uyghur and other Turkic minority populations. These conditions undermine corporate due diligence, with auditors facing harassment, restricted access, and unreliable worker interviews. The opacity of supply chains and government censorship further complicate verification of labour conditions.
Supply chain exposure is heightened by the PRC’s increasing investment in exploration and mineral processing in the region, where 153 mineral types have been identified—103 with proven reserves. Seventy-seven of these rank among China’s top national reserves.
Critical minerals and the Uyghur region
The Uyghur Region has become an extractive hub due to its mineral reserves, coal-powered energy, and weaker labour and environmental standards. Mining and processing operations frequently rely on state-imposed labour transfer programmes, which experts describe as forms of forced labour. These programmes facilitate familial separation, restricted movement, and coerced participation in government-led employment schemes.
Minerals from the Region routinely enter global supply chains through unregulated distribution channels, exposing multiple industries to forced-labour-tainted inputs. The report highlights difficulties for companies attempting to conduct responsible sourcing, noting that products mined or processed in the Region are presumed to involve forced labour under the U.S. Uyghur Forced Labor Prevention Act (UFLPA).
Titanium
Titanium is widely used in aerospace, automotive, medical devices, and paints. China is the world’s largest producer and consumer of titanium products. The Uyghur Region contributes approximately 17% of China’s titanium sponge production and over 11% of global output. It also produces titanium dioxide for paints.
Processing is dominated by subsidiaries of Hunan Wujo Light Chemical Group and CNNC Hua Yuan Titanium Dioxide Co., Ltd. Products from the Region feed into supply chains for aerospace components, automotive parts, paint manufacturers, and internationally sold titanium homeware.
Lithium
Lithium is essential for electric vehicles, energy storage systems, and electronics. China processes nearly 56% of global lithium (lithium carbonate equivalent). Lithium mining, processing, and downstream battery production are expanding rapidly in the Uyghur Region.
In 2024, all active lithium production in the Region was conducted by Xinjiang Zhicun New Energy Materials Co., Ltd., which is linked to labour transfer programmes. These operations pose significant downstream exposure risks for battery, electronics, and vehicle manufacturers.
Beryllium
Beryllium has specialised uses in aerospace, telecommunications, and defence technologies. The Uyghur Region accounts for 11% of global beryllium production. Xinjiang Nonferrous/Western Gold’s subsidiary, Fuyun Hengsheng Beryllium Industry, participates in state labour transfers, including “poverty alleviation” initiatives documented since 2017.
During COVID-19 lockdowns, workers were quarantined onsite without adequate provisions, with production continuing despite safety gaps. Labour transfers persisted post-pandemic, with graduates from Altay Regional Vocational School funnelled into mining enterprises. Downstream distribution primarily serves companies in Jiangsu and Zhejiang, making exposure in global supply chains difficult to avoid.
Magnesium
China produces 95% of global magnesium, with the Uyghur Region contributing over 5%. Companies such as Xinjiang Banchao Group participate in labour programmes and maintain extensive downstream supply relationships with aluminium and alloy manufacturers. These connections create exposure risks for industries reliant on magnesium alloys, including automotive and construction.
Conclusions & recommendations
The report identifies 77 companies operating in the Uyghur Region in the four mineral sectors, 15 companies with direct sourcing links in the past two years, and 68 downstream customers potentially exposed to Region-based inputs. Eighteen parent companies may source inputs from their regional subsidiaries.
Recommendations include ceasing all state-imposed forced labour in the Region, ending labour transfer programmes, enforcing laws prohibiting forced-labour-based imports, and adopting mandatory human rights and environmental due diligence. Companies are advised to map and trace supply chains, disengage from Uyghur Region sourcing, publish supplier lists, and avoid social audits in the Region due to safety and credibility concerns.