Position on forced labor by Uyghurs in the textile industry
INretail and Modint are Dutch trade associations representing smaller and larger garment and textile
companies like retailers, fashion brands and suppliers of garment and textile articles as well as
international retailers 1 present on the Dutch market. We work together on international corporate
responsibility, for example in the Dutch agreement on sustainable garment and textile (AGT) and the
Sector plan Circular Textiles. Our contribution for this round table reflects the opinion and
experiences of different kind of business.
INretail
INretail is the Dutch Business Association for Fashion and furniture retail. INretail represents grosso
modo all business active in fashion retail in the Netherlands. These are micro retailers, SME’s and
national and international retail chains. Most of the SME’s are selling different brands and are not
sourcing themselves. Some large retailers exclusively sell brands. Examples are retailers like Bijenkorf
or Van Tilburg. In regard of this Roundtable the chain stores are most interesting, as they directly
source garments from manufacturers in production countries and are impacting the value chain.
Modint
Together with more than 400 members, mainly fashion brands and suppliers of garment and textile
articles, we are building a valuable future for our sector by making a positive contribution working on
relevant themes like Corporate Responsibility. Modint has an important social value. It contributes to
the economic importance, cultural heritage, creative and commercial spirit of the Netherlands, but
we also feel responsible for the social and economic impact we have in production countries. We will
bring practical insights to the round table of integrating due diligence and working with the (Chinese)
supply chain.
The global industry context
The textile and fashion industry works according its commitment to responsible business conduct and
sustainable development as defined by the UN Guiding Principles for Business and Human Rights and
by the OECD Due Diligence Guidelines for responsible business conduct in the garment and footwear
sector. By applying these guiding principles as guidelines for responsible business conduct, businesses
can be drivers of positive societal change and can contribute to the fulfilment of the SDGs.
China is one of the most important purchasing countries for Dutch garment and textile companies.
The forced labor of ethnic and religious minorities in the Xinjiang Uyghur Autonomous Region
(XUAR), as part of a broader pattern of severe human rights abuses, is a significant and growing
concern that demands the attention of governments and private-sector actors across the world.
Forced labor is unacceptable according to core ILO conventions which are the base of implemented
code of conducts in the industry.

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For this reason it is important that this contribution is also accessible for the non-Dutch speaking in our
industry.

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Xingjiang produces around 20 per cent of globally required cotton, which is converted into clothes in
either Chinese factories or in garment manufacturers all across the world. However, the length and
complexity of the apparel supply chain makes it tough to track the origin of the raw materials used in
garments. Ready-made garments from all over the world may contain cotton produced in Xinjiang or
form other regions where Uyghur workers are situated.
Industry needs support of the government for proper due diligence
The UNGPs clearly define roles for business and for government in complex human rights issues in
global supply chains. In the Xinjiang alleged forced labour case, the core concern of European apparel
brands and retailers’ sourcing products and particularly components from the XUAR region is to
implement proper due diligence grounded in the UNGP and OECD guidance. By nature of this
particular situation industry needs European government(s) (State) to support industry in their due
diligence approach. The industry is asking government to help to enable it to be able to carry out
proper due diligence in China and particularly in the Xinjiang region. This issue stands apart from
many other RBC issues in the sense that the root cause of the problem does not lie with industry,
which makes the case for strong government support to industry even stronger.
The OECDs due diligence guidance stipulates that focus should be on assessing what steps could be
taken to address and mitigate harms rather than simple de-risking. Boycotts and sanctions block
necessary attempts at improvement that may not yet have been sufficiently taken. A collaboration of
all stakeholders, including industry and government and intergovernmental organisations is a
necessary condition to improvement of the situation, or at the very least, to enable meaningful due
diligence.
Need for transparency
Many businesses have already taken important steps to map their supply chains and to prevent or
mitigate risks of forced labour wherever they can, in line with the UN Guiding Principles. However, in
some situations, individual and collective action by international companies and engagement with
their suppliers alone will not resolve the issues. There are reported challenges in conducting supply
chain due diligence within the XUAR. As the CSIS report documents, the particular conditions in
which the recruitment and employment of these workers is occurring mean that obtaining reliable
information by interviewing the workers is difficult. There are also constraints on access by
independent auditors to the region. As it has become increasingly difficult to conduct credible due
diligence in the region, BCI, for example, has decided to suspend licensing of BCI cotton in XUAR.
Furthermore, in collaboration with the industry and supply chain partners, we will continue our work
to strengthen the traceability of cotton. The road to obtaining full transparency however is long and
challenging.”
In our view simply boycotting this region now is definitely not the best option because this will only
result in the region getting more isolated. It will not end the problem with forced labor. The OECD’s
due diligence guidance stipulates a responsible disengagement. Companies need to ensure that they
have done enough to try to remedy the adverse situation and this includes calling on government
and other stakeholders to support them in these efforts. It is up to the full international society to
create urgency for these violations.

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Companies cannot solve this problem by themselves. It is a (geo) political question about human
rights violations which affect all kind of businesses with operations in China. A diplomatic
intervention by States and intergovernmental organization with China is needed to address the
situation.
The secretary of the AGT found out that signatory companies have no registered direct or indirect
production locations in Xinjiang, but can’t guarantee that Xinjiang cotton is not processed in their
apparel. The cotton market is a commodity market with a huge number of suppliers and middlemen
which makes it difficult to track and trace cotton precisely. It might be interesting to implement a
duty for registration of cotton to realize more transparency. In this regard it is interesting to take a
closer look into the lessons learned of conflict minerals and the way in which due diligence was
found to be possible despite complex and extreme situations. Upcoming mandatory due diligence,
also in our sector, may facilitate due diligence further and therefore our multi-stakeholder
collaboration to make progress.

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