A June 2025 report by the Global Rights Compliance Foundation (GRC) reveals that these companies appear in supplier declarations or customer listings of midstream manufacturers that source titanium and other minerals from Xinjiang, a region widely documented for the use of state-imposed forced labor targeting Uyghur and other ethnic minorities.
While these companies are not directly sourcing from the Uyghur Region, they are downstream users of materials that originate from mining and processing facilities in Xinjiang, raising red flags about traceability and due diligence.
“Traceability must go beyond finished goods. Without full transparency in sourcing, companies risk financing forced labor and environmental harm,” said Sarah Wood, Senior Counsel at Global Rights Compliance.
The report details how raw minerals such as titanium, magnesium, beryllium, and lithium are extracted in Xinjiang and processed by companies like Xinjiang Xiangrun (XRUN) and CNNC Jinguan Titanium, both of which have been tied to state-imposed labor systems.
These materials are then sold to midstream companies such as:
These midstream manufacturers, in turn, list companies such as Walmart, Coca-Cola, Starbucks, Disney, and Carrefour as cooperative partners or customers—placing those brands at risk of indirect exposure to forced labor–tainted supply chains.
For example, CHTi sources 28% of its titanium feedstock from Xinjiang suppliers. Its products, including pigments used in coatings and packaging, are sold globally to companies such as Sherwin-Williams, AkzoNobel, and BASFGRC-critical-minerals.
These critical minerals are essential to multiple sectors:
Under the Uyghur Forced Labor Prevention Act (UFLPA) in the U.S., all products tied to Xinjiang are presumed to be made with forced labor. Importers must provide “clear and convincing evidence” that goods are not linked to state-imposed labor systems—something many companies have not yet demonstrated at the raw material level.
The complexity of these supply chains does not absolve companies from liability or ESG responsibility. Boards must be proactive in tracing their suppliers to the point of extraction.
Regulators and investors alike are pushing for:
To reduce risk and comply with growing global expectations around ethical sourcing, major brands are turning to third-party verification tools that integrate both carbon and human rights data across their supply chains.
Downstream companies—especially those exposed to critical minerals like titanium, beryllium, and magnesium—can improve oversight by:
Sarah Wood, emphasized in the June 2025 report that traceability and disengagement are essential steps for companies seeking to comply with ethical sourcing laws and reduce forced labor exposure.
Companies are also encouraged to disengage from suppliers that cannot prove clean sourcing, and to disclose corrective actions when exposure to high-risk regions is confirmed. By aligning emissions tracking with human rights due diligence, companies not only reduce legal exposure but also build long-term resilience into their procurement systems.