Uighur Forced Labor & Xinjiang-based Medical Device Manufacturers

January 28, 2021

6 minute read

China’s internment of Uighur Muslims, an ethnic minority in Xinjiang province, continues to present an alarming violation of human rights. Reports of Uighur “re-education” camps have turned into signs of forced labor, and companies with manufacturing ties to Xinjiang must ask themselves if there is forced labor occurring in their supply chain. Medical device manufacturers must do so as well, particularly as demand for many medical supplies skyrockets amidst the coronavirus pandemic. Further, it is incumbent on governments to work to identify instances of forced labor in products arriving on their shores. For the awareness of manufacturers and distributors sourcing from China, we compiled a list of companies whose FDA registration and listing shows that they operate in Xinjiang.


Reports of re-education camps first emerged in September 2017, when Human Rights Watch called on the Chinese government to “immediately free people held in unlawful ‘political education’ centers in Xinjiang.” The years since have further clarified the atrocities: over 1 million Uighurs have been arbitrarily imprisoned since the 2017, in addition to facing “intense surveillance, religious restrictions, and forced sterilizations.” In January 2021, the US State Department declared the atrocities against Uighurs to be genocide.

Since initial reports, a new dimension has emerged to the human rights abuses perpetrated by the Chinese government against Uighurs: forced labor. The Australian Strategic Policy Institute, among the groups raising the alarm, highlighted last year “the mass transfer of Uyghur and other ethnic minority citizens from the far west region of Xinjiang to factories across the country. Under conditions that strongly suggest forced labour, Uyghurs are working in factories that are in the supply chains of at least 82 well-known global brands in the technology, clothing and automotive sectors, including Apple, BMW, Gap, Huawei, Nike, Samsung, Sony and Volkswagen.”

Forced labor in the healthcare supply chain

But forced labor exists beyond these brands and has already entered the healthcare supply chain. In July 2020, a New York Times investigation uncovered 17 companies participating in the labor transfer program that were producing PPE. The investigation tracked masks made with forced labor from ports in China arriving in Los Angeles and being distributed across the United States. 100,000 masks from another company revealed in the same investigation were also documented to have reached the NHS in the United Kingdom. However, tracking such violations is difficult. Manufacturers must ensure both that their factories and other companies within their supply chain are utilizing fair labor practices.

Symmetric list of Xinjiang-based manufacturers

We are publishing a list, downloadable here, of Xinjiang-based manufacturers for informational purposes. We do not know whether there are labor violations occurring at the listed companies, nor do we have the resources to investigate. However, given the severity of the human rights abuses occurring in Xinjiang, we believe that publishing the data is worthwhile so that everyone has the information necessary to make informed decisions

The list includes five Xinjiang-based manufacturers, their addresses, and their Owner Operator Number, based on their active FDA registration and listing. It also includes the fifteen products these manufacturers produce, along with product descriptions and FDA product codes.

However, as the map below demonstrates, forced labor is not confined to Xinjiang. Uighurs are being transferred out of Xinjiang to factories across the country. Thus, another drawback of our list is that it does not reflect the possible use of forced labor at medical supply factories across China. We do have data on supply manufacturers across the country, but we have no way of determining which are using forced labor.

Mass transfer of Uighurs to factories across China, Australian Strategic Policy Institute

Our commitment

Beyond the list, we will support any stakeholder seeking information on particular manufacturers suspected of utilizing forced labor by sharing information from our comprehensive database that includes data on millions of medical devices and thousands of device manufacturers, including their registrations, listings and manufacturing addresses.

We urge stakeholders across healthcare to join us in working to eliminate forced labor from the healthcare supply chain through the following recommendations:

Governments and intergovernmental organizations should:

  • Investigate any reports of forced labor in the supply chain of medical devices sold in their country.
  • Proactively identify labor violations and collaborate with relevant agencies.
  • Inspect and stop shipments of medical supplies if there is credible evidence of production via inhumane labor practices.
  • Maintain an updated list of suppliers under investigation or discovered to be utilizing forced labor. U.S. Customs and Border Protection has one such list.
  • Vocally support calls for access to Chinese medical device manufacturers’ facilities so that audits of labor practices can be conducted.
  • Manufacturers should:
  • Conduct rigorous audits of their suppliers across China to verify that no forced labor is being used in their supply chain and publish their findings.
  • Develop ongoing methods to ensure that their supply chain remains free of forced labor.
  • Cooperate with FDA to identify suppliers suspected of or verified to be using forced labor.
  • Providers, particularly large health systems with substantial purchasing power, and distributors should ask to see audit results prior to contracting with manufacturers.

    Our recommendations build on those produced by ASPI. ASPI cautions against sudden rejections of Uighur labor, stating, “it is vital that, as these problems are addressed, Uyghur labourers are not placed in positions of greater harm or, for example, involuntarily transferred back to Xinjiang, where their safety cannot necessarily be guaranteed.”

    With these values in mind, our hope is that governments, manufacturers and providers will work together to ensure humanity in the production of medical supplies like the masks that we all use everyday.