Guidance to Licensees on Uyghur Forced Labor


July 22, 2020

Dear Colleagues,
Please find here a summary of the WRC’s guidance to licensees concerning the steps necessary to meet university labor standards, in light of the forced labor crisis in the Xinjiang Uyghur Autonomous Region (“XUAR”) of China. We will send the guidance to all licensees next week.
We appreciate universities’ recognition of the extraordinary gravity of the human rights violations unfolding in the XUAR and the challenge this creates for the collegiate supply chain. We recently updated you on new reports of atrocities, including the forced sterilization of Uyghur women. As you know, the Chinese government has rounded up more than one million Uyghurs and other Turkic and Muslim people in forced labor camps, the largest internment of an ethnic and religious minority since World War II.
Evidence continues to arise of goods made with Uyghur forced labor entering the US market, including a New York Times investigation, for which the WRC provided analysis, documenting the use of forced labor to make face masks.
In short, we are advising licensees that the following actions are necessary to ensure they are not putting university logos on garments made with forced labor:

  1. Ensure that no fabric, yarn, cotton, or other material from the XUAR is being used to make collegiate apparel. The WRC will ask licensees to show, via supplier disclosure data, that their collegiate supply chain is free of XUAR yarn within six months and cotton within 12 months;
  2. Immediately stop sourcing university logo goods from companies that are implicated in forced labor in the XUAR;
  3. Immediately instruct suppliers in China outside of the XUAR not to use labor from the XUAR supplied by the Chinese government’s labor transfer scheme; and
  4. Disclose all entities in China utilized in the production of collegiate goods, including sources of cotton and yarn. The WRC will work with licensing agents to assist licensees in providing this disclosure.

It should be noted that the WRC is not recommending any new standards or policies to universities. Collegiate codes of conduct already prohibit forced labor. We are advising licensees on steps needed to comply with that prohibition given the situation in the XUAR.

Based on our consultations with licensees, it is clear that some will be able to complete these steps relatively quickly. The process may be more challenging for others. The human rights abuses are so egregious, and the risks to the university supply chain so severe, that decisive action by licensees is essential, even where the work proves difficult.

Finally, as we have previously reported, the WRC continues to work with a broad network of human rights, labor rights, and Uyghur organizations to develop broader recommendations for the apparel industry, beyond the university sphere. These recommendations will be announced later this week.

As always, please let us know if you have questions or would like to discuss this information.


Scott Nova
Penelope Kyritsis
Ben Hensler