China’s Solar Industry Redesigned Itself Around U.S. Forced Labor Law

Last month, firsthand testimony from a former Han Chinese police officer who supervised Uyghur labor transfers in Xinjiang described how the system works. Workers are taken to cotton fields under armed escort. Identity cards are confiscated to prevent escape. Those who refuse state-mandated assignments are sent to short-term detention facilities where, in the officer’s words, they are “intentionally subjected to hardship and suffering” until they comply.

Uyghur forced labor continues despite U.S. law

The same coercion architecture underpins the labor that sustains Chinese crystalline silicon solar manufacturers, which continue to seek access to the U.S. market.

Five years after the United States moved to specifically ban Uyghur forced labor, it remains the largest system of state-imposed forced labor in the world – and it is larger than ever. Our research found that China recorded more than 3 million labor transfers of Uyghurs and other ethnic groups in 2025. This was the highest figure on record and a year-on-year increase, despite the Uyghur Forced Labor Prevention Act (UFLPA), which was meant to curb the practice.  China’s silicon solar industry, which has lobbied for years to preserve its access to the U.S. market, remains an active participant in it.

At the center of China’s solar supply chain sits Hoshine Silicon Industry, the world’s largest producer of metallurgical-grade silicon. In 2021, the United States blocked Hoshine’s products at the border after extensive evidence of forced labor at its Xinjiang operations. Yet, despite the ban by one of the largest solar markets in the world, Hoshine’s sales volume has grown from 530,000 metric tons in 2021 to more than 1.2 million tons in 2024, with roughly 90% still originating in Xinjiang.

How communist China circumvented the forced labor law

That surge reflects both the difficulty of enforcing UFLPA and the Chinese crystalline silicon industry’s success in circumventing U.S. laws. In December 2023, two years after UFLPA was enacted, a Chinese county government signed a formal employment cooperation agreement with a Hoshine facility and dispatched 65 workers in a state-organized send-off ceremony, describing the arrangement as a “long-term labor export and strategic partnership.”

A 2024 government video – posted the same year Hoshine sued the U.S. government to maintain access to the American market – reveals what these placements entail. Workers sign a three-party agreement with the local government and a state-owned human resources company. The contract requires them to adopt a “correct employment ideology” and remain employed for at least one year. Officials later sent cadres to the facility to monitor workers, reporting a 91.2% retention rate as a government performance metric.

No genuine labor market requires ideological compliance – in this case, to communist ideology –  as a condition of employment. The model has been deliberately redesigned to withstand international scrutiny by removing the camp-style features that drew global attention in 2017 and 2018.

America is supposed to get the non-coercion silicon

After the UFLPA passed, Chinese manufacturers signed pledges and bifurcated their supply chains: U.S.-bound modules are documented as using non-Xinjiang polysilicon, even as the same companies remain deeply tied to Xinjiang production. This created enforcement challenges compounded by the nature of the product itself – no laboratory test can determine whether polysilicon originates in Xinjiang. And Chinese manufacturers have a long history of shifting manufacturing stages to third countries and claiming non-Chinese origin for what remains, in effect, a Chinese-made product to circumvent U.S. laws.

Even as American manufacturers built large amounts of domestic capacity free of exposure to Chinese crystalline silicon supply chains, the U.S. has detained solar products under UFLPA from India, Malaysia, Vietnam, Thailand, and Ethiopia.

In 2025, nearly half the companies whose shipments were denied U.S. entry simply redirected them elsewhere. Direct exports from Xinjiang to Canada, Britain, and the European Union rose 465% between 2021 and 2025, and Xinjiang’s total exports have more than tripled since the UFLPA took effect. The result is a global enforcement gap.

Closing the gap

The U.S. Trade Representative’s ongoing Section 301 investigation into 60 of America’s trading partners is the clearest opportunity since UFLPA’s passage to close this gap. It should require partners to adopt equivalent import bans within a defined timeline, with a presumption against goods from regions where state-imposed forced labor has been documented. It should mandate information sharing between U.S. Customs and Border Protection and trade partners, so that goods rejected at the U.S. border cannot simply be diverted. Tariff consequences should apply to transshipment hubs. And UFLPA liability should extend to module manufacturers sourcing polysilicon from designated entities to prevent sanctioned material from entering the U.S. either as polysilicon or embedded in derivatives such as ingots, wafers, cells, and finished panels.

The system the police officer described in Xinjiang is not contained. It is the largest of its kind, it is expanding, and it has been redesigned to look like ordinary employment – with China’s solar manufacturing juggernaut among its most active beneficiaries.

Laws are only as effective as their enforcement. Congress took the right step with the Uyghur Forced Labor Prevention Act. China’s crystalline silicon industry has proved nimble, and each round of U.S. enforcement has produced a new workaround.

Inaction is no longer an honorable option

Let us be precise about what inaction means: U.S. companies continue purchasing goods produced through the forced labor of ethnic groups that have been systematically detained, surveilled, and conscripted by a state – not because there is no alternative, but because no one has compelled them to use one. American-made solar panels exist, and there is no trade-off to be made. Nor is there a neutral position.

Continuing to look away is a choice, and the people living inside this system will bear the consequences long after the next procurement cycle closes.

This article was originally published by RealClearPolitics and made available via RealClearWire.