Sayari Analysts Say NGO Influence on UFLPA Enforcement Will Grow

Sayari analysts, who say their company crunches 600 million shipment records, say that the Uyghur Forced Labor Prevention Act has had more impact than British, German, Swiss, Canadian and French laws aimed at removing human rights abuses from supply chains.

In a webinar held Aug. 27, senior solutions analyst Harry Hayllar said Vietnam, the U.S. and India are the most common destinations for exports that Sayari has linked to China's Xinjiang region, and the most common Harmonized Tarriff Schedule codes for those goods were 8708.7, a car wheels category; 6117.8, knitted accessories or parts of garments' 8451.43 and 8541, both electronics related; 8418.99, a refrigeration or heat pump related part; and 8507, which covers storage batteries.

For shipments directly to the U.S., they said textiles, electronics and plastics dominated.

They listed these companies as the top suppliers: Hon Hai Precision Industry (FoxConn); Citic Dicastal Co., which makes automotive aluminum wheels; Changhong Meiling Co., an appliance manufacturer; Smart Shirts Limited; Risen Energy Company; Lu Thai Textile Co.; Contemporary Amperex Technology Limited (CATL), an electric vehicle battery manufacturer; Jiangsu LIanfa textile Co.; and the KTK Group, which is on the UFLPA Entity List.

Hayllar also noted that the Australian Strategic Policy Institute's report on labor transfers, which identified Hon Hai; Changhong Meiling; AcBel Polytech, an electronics supplier; and Bestway Recreation Corp., which makes sports equipment, accounted for about 50,000 shipments.

Hayllar noted that ASPI and Sheffield Hallam University have directly influenced policy for the Forced Labor Enforcement Task Force, and with the former head of the Sheffield Hallam office that put out reports on Uyghur forced labor, Dr. Laura Murphy, now serving as a policy adviser to the FLETF chair, he advised: "expect that trend to continue."

Hayllar and Zach Tvarozna, Sayari's director of analytical services, walked the audience through case studies of how Sayari consults its shipment information -- including departure and arrival date, shipper, receiver, origin and destination country, HTS codes and product descriptions -- to trace Xinjiang or Russian materials to U.S. imports. Hayllar showed how Cofco Tunhe Tomato Co. ships to Century Pacific Food in the Philippines, a company that combines fish or meat in tomato sauces and then cans them. Century Pacific exported sardines in tomato sauce to Liberty Gold Fruit Co., a California importer, he said.

He also put up a corporate map of Xinjiang Zhongtai Chemical Co., a company on the UFLPA entity list. While it's obvious that Xinjiang Zhongtai Import and Export Trade Co., the company listed on export records, is related to the chemical company of the same name -- and the chemical company is a part-owner of the trading company -- other times trading companies aren't so clearly named. Hayllar said companies need to map corporate relationships and connect them to shipment records to find out who their sub-tier suppliers buy from.