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LONDON – The operations of XPCC – the main producer of cotton in Xinjiang – have for years been tainted by the use of forced and child labour, the deliberate Sinicization of the region, the appropriation of Xinjing’s natural resources, and their transfer to Han control.

All of these undesirable traits PREDATED the BCI and Textile Exchange’s promotion of the sustainability of Xinjiang cotton. Moreover, knowing that the XPCC is Xinjiang’s major cotton producer, should have prevented such organisations making these claims in the first place.

In this detailed essay, which looks at the history of XPCC to present day, Veronica Bates Kassatly explains how by promoting Xinjiang cotton as preferred and more sustainable, both TE and BCI were deliberately deceiving both brands and consumers.

The Mao years

The Xinjiang Production and Construction Corporation, also known as the XPCC or Bingtuan, was founded by Chairman Mao in 1954, to stabilize the Xinjiang region through Sinification and economic development. Mao created several such Bingtuan at the time but the XPCC is the only one that still survives – and for a reason.

Initially, the Xinjiang Bingtuan consisted of 200,000 demobilised soldiers from both the Communist and Kuomintang armies. In the early years, Han recruits were duped into joining the XPCC and moving to Xinjiang, with films of cows, green pastures and flowing streams. Ten Thousand Miles Without a Clouddescribes the recollections of 2 such veterans. They arrived to find themselves in a predominately desert region without housing – initially they slept in holes in the ground. Many died.

The use of Xinjiang as a prison predates the Mao era – in 1794, under the Qing dynasty, 445 former officials were exiled there, along with political and religious dissidents and the odd criminal. Mao continued the tradition and in 1955, the Bingtuan guarded 160,000 mostly political prisoners from the rest of China – nationalists and others who had resisted the communist revolution, along with communists who had fallen afoul of Maoist ideology.

Under Deng Xiaoping

This political prison population dwindled over the years, but following a nationwide crackdown on crime in 1983, Beijing paid the Bingtuan US$80 million to transport and incarcerate prisoners from the rest of China. By the early 1990s, there were nearly 100,000 prisoners in the Bingtuan’s prisons. In general, only prisoners with five year minimum sentences were transferred to the Bingtuan and they were almost all Han. Historically, most Uighur prisoners were incarcerated in the Xinjiang Uighur Autonomous Region (XUAR) system. However, given that political prisoners were sent to the XPCC in the past, and in the light of the huge increase in Uighur political prisoners over the last 4 or 5 years, this may no longer apply.

In 1998, it was claimed that the Bingtuan had 24 jails. Most prisoners were kept by the first division in Aksu, second division in Korla, third division in Kashgar, fourth division in Ghulja, seventh division in Kuitun and eighth division in Shihezi. Ten regiments ran 36 prison farms. The 8th division based in Shihezi ran the largest agricultural division, and also had 22 labor squadrons engaged in prison manufacturing.

Esquel’s 2,700 hectare XPCC joint venture farm was in Kashgar, which falls under the third division. Textile Exchange (TE) speaks glowingly of “cotton that is produced organically and with integrity,” by Division 1, regiments 3,8,16, and 81 and Division 3, regiment 45, For Better Cotton Initiative (BCI) on the other hand it is XPCC Divisions 1 and 5. 

In 2005, the XPCC controlled over 4 million hectares of agricultural land. Most XPCC farms are not prison farms (although it is claimed that much of the initial land clearing on all the XPCC cotton farms was undertaken by prison labour).The farms are, rather, a combined tool of

Sinification and economic development. Most XPCC farms are predominantly settled with Han farmers – some apparently former prisoners – who were offered the opportunity to resettle upon their release. However, the majority of XPCC farmers are labourers who were brought from the rest of China to cultivate and harvest crops and were then offered the option of farming a plot of XPCC land, thus increasing the effective Han population in the process. It is presumably these kinds of XPCC farms that both BCI and Textile Exchange refer to.

After the first rumblings of unrest in 2008, the massacre of almost 200 Han in Ürümqi in 2009, and incidents in 2011, as well as in April and May 2014 (which resulted in some 70 fatalities), security in Xinjiang began to tighten. The heightened armed presence and identity checks were already obvious to visitors from the rest of China in 2010, and the XPCC was under increased pressure to Sinicize the region.

The Xi Jinping era

By the advent of the Xi era, this pressure had only been increased. To quote the New York Times:

In the 2014 speeches, Mr. Xi had singled out southern Xinjiang as the front line in his fight against religious extremism. Uighurs makeup close to 90 percent of the population in the south, compared to just under half in Xinjiang over all, and Mr. Xi set a long-term goal of attracting more Han Chinese settlers.

“He and other party leaders ordered a quasi-military organization, the Xinjiang Production and Construction Corps, to accelerate efforts to settle the area with more Han Chinese, the documents show.”

One way the XPCC attracts and retains such settlers is of course, by offering them plots on the XPCC farms. These farmers operate the XPCC properties on the following terms:

“A regiment generally owns hundreds of thousands of acres of land which are contracted by regimental farmers (workers) The regiment is responsible for necessary facilities, for example, construction of reservoirs, wells and irrigation pipelines. It is common to see aircraft spraying crops with pesticides, and dozens of combine harvesters rumbling in the fields in the harvest season.

“Currently, the strategy (launched in 2005) is to allow farmers to contract to farm an area of land. A farmer pays contract fees and social security costs to the regiment. The regiment must decide on a level of fees that covers its own costs while still being attractive to farmers. Contracting farmers pay for the use of the regiment’s materials and equipment, such as seeds, fertilizer, water, pesticides, electricity, and machinery such as combine harvesters. They also have to obey instructions from the regiment regarding which crops to grow. Produce from the land must firstly be sold to the regiment according to the prices and amount specified in the contract, and the remainder can be freely marketed by the farmer. This results in a net income for the farmer far higher than that of the local peasants, and two or three times the national average income”

In 2015, the XPCC had about 700,000 productive employees (25% of the XPCC’s total population), and 400,000 were regimental farmers. About 86% of this population was Han. This compares with 36% Han Chinese in the total XUAR in 2015, and about 43% Uighur.

To assert that XPCC settlement of Han farmers and import of Han prisoners has caused resentment and anger in the local, predominantly Uighur population, would be an understatement.

The fact that their farms are positioned at the headwaters of most of Xinjiang’s major rivers means that the XPCC has effective control over the surface water of the XUAR, and consequently of the lands and people in downstream areas. This has long fanned discontent in an area where water is in short and dwindling supply. Indeed in 2002, the Esquel/XPCC joint venture admitted they had been unable to plant as much cotton as originally intended, because of water shortages. Whilst TE states that approximately 60 percent of China’s organic cotton is grown in Hefeng, Xinjiang, an unusual choice of nomenclature  as Hefeng is actually an historic name. The county is now almost universally referred to as Hoboksar (the name TE used in its 2009-10 report) and is notorious for China’s own mini Aral Sea catastrophe, the death of the Alan Nur lake and considerable diminution of Lake Manas.

Textile Exchange will have been aware of all of this, which begs the question why they had no qualms about claiming that Hutubi, Xinjiang organic cotton is grown with a mere 150 tonnes of irrigation per hectare in their 2014 organic LCA. It has been suggested that this was a typo, or that a single water application was confused with the annual total. However, exactly the same claim is made in TE’s 2011-14 OC-SAT Summary of Findings  of 2011-12 production. This report states: “The majority of organic cotton is grown in Xinjiang Province in northwest China. Whilst the surveyed Producer group (PG) is located in Kashi, not Hefeng (the biggest organic cotton producing region in China) it is still considered representative of the Chinese farmers due to its size and experience.

“The Chinese producer group reported the use of drip irrigation and a reduced water use from around 12,000 m3 to 150 m3 per ha (a saving of 79 per cent).

“Average water usage per ha per year is 12,000 m3 in this area. We use drip irrigation which uses significantly less at only 150 m3/ha. Irrigation is paid for at a cost of 0.6 RMB/m3. – PG, Xinjiang province, China.”

The first thing to note is that it is now made clear that the water saving has absolutely nothing to do with switching from conventional to organic production. It is due to the introduction of drip irrigation. Exactly the same benefits will apply to conventional cotton producers switching from flood to drip irrigation. The second point to consider is that 150 is not 21% of 12,000. The third is that the farm is not in Hutubi but Kashi (Kashgar) yet has exactly the same figure for irrigation – 150 tonnes. The fifth, is that at current exchange rates, those 12,000 tonnes would have cost $1,000 per hectare, which is too high to be economically viable, even with the subsidies paid to farmers in Xinjiang. The sixth point, is that I contacted two Chinese professors last year, on the topic of Hutubi irrigation and they stated:

“The irrigation during the cotton whole growing stage is carried out more than 4 times at Hutubi.  In a thesis (in Chinese), the author investigated the cotton irrigation schedule and yield in Hutubi in 2013. The results show that the total irrigation amount during the growing stage of cotton is 400-788 mm under different irrigation methods. The irrigation during the cotton growing stages is carried out for 7-10 times. The yield of  cotton  is 4300-5370 kg/ha. However, all these results are based on the conventional cotton production.  

“Generally opinion, any crop yield under organic production condition, as without the chemical agents applied, is less than that under conventional one.”

Or in other words – Hutubi cotton needs at least 4,000 tonnes of irrigation per annum, and since organic yields are lower than conventional, the irrigation per kilo of cotton, will be commensurately higher.

In their defence, in their RofR, TE stated the following:

 “In 2013/14, Textile Exchange was only aware of five organic farms in China. As part of the data collection process, templates were sent out to farms that we had contact with but not all responded. The data we report is based on the actual data collected from those that responded to the collection process.”

To suggest that the unverified responses of a handful of farms is not a sound scientific basis upon which to calculate the impact of what is now 20% of the global organic cotton supply, would be an understatement.

 In their RofR, TE further asserted:

our role is an educator of best practices through collecting and sharing data on fiber production globally

One has to ask: with such flimsy data, how can TE possibly know what best practice is?

But I digress, to return to the XPCC, it should be noted that all of these serious issues with XPCC practices – exploitation of prison labour, forced Sinification and appropriation of natural resources – not to mention the issue of pronounced local water concerns, pre-date TE and BCI’s designation of Xinjiang cotton as “preferred and more sustainable”.

And so did another major issue, which the US Congressional Executive Commission on China (CECC) has been reporting on repeatedly since at least 2006: the use of child labour to harvest Xinjiang cotton.

It is unclear how CottonConnect (CC), Solidaridad and the various other initiatives working in Xinjiang cotton have failed to pick up on this.

Like the use of prison labour, the euphemistically titled “work-study” and “help with agriculture,” programs that force Xinjiang school children to pick cotton is not something that either the XPCC or XUAR have ever tried to hide. Indeed, given that in 2008, a million students were apparently obliged to participate, it is hard to see how anyone working there can have missed them.

I quote the CECC:

“This year the use of student labor has continued, though reportedly to a lesser extent, according to a September 22 article published by the Metropolitan Consumers Morning News Over 1 million students in the region pick cotton through work-study programs each year… At the same time, the article reported that work-study programs requiring students in junior high school and above to pick cotton have decreased in recent years, and some schools have eliminated work-study programs that require physical labor. Those students in work-study programs to pick cotton at schools cited in the MCMN article must meet a daily quota of 30 to 35 kilograms of cotton and are penalized if they fall short of this amount. At some schools, students permitted to forgo picking cotton due to illness must perform other work on campus, according to the article.”

The CECC picked up on this issue again in 2011, noting that mandatory cotton picking for students sometimes exceeded official limits on hours, due to labor shortages. Indeed a September 24, 2011, Bingtuan News Net article profiled students organized to “help with agriculture” by picking cotton for the 3rd Agricultural Division, XPCC, in Kashgar – the area of the Esquel farm.

Since the recent crackdown moreover, there is evidence of a new and additional form of forced labour on the XPCC cotton farms, that did not exist when TE and BCI first started calling Xinjiang cotton “more sustainable and preferred,” and that should have hastened the elimination of Xinjiang cotton from the preferred category: I refer to the wives and dependents of Uighur detainees.

A 2017 Radio Free Asia report elaborated on this with the following claims:

“An officer from the Manglay police in Hotan told RFA that the local government had sent hundreds of women and children from his township to neighboring Aksu prefecture to join heavy labor details to make up for wages lost after the men in their families were detained.

“Many families with two or three young children, having lost male laborers to re-education camps in the last six months, are facing financial difficulties at home,” said the officer, who spoke to RFA on condition of anonymity.

“To resolve this problem, the township government organized women and children to go to Aksu prefecture to pick cotton [and take on other heavy labor jobs].”

“The women and children pick cotton and perform other duties “for their own family’s benefit,” rather than as part of a “re-education through labor” program, the officer said.

“But while “fundamentally, they have not” been involved in any “misconduct” themselves, “some could be” placed into re-education camps if they did not go to Aksu to join the heavy labor details, he added.”

As stated earlier, Aksu is home to the first division, whose organic cotton TE were promoting, whilst BCI appears to have relationships with both divisions 1 and 5

To Summarize

When CottonConnect entered Xinjiang, CC was co-owned by Shell Oil through its Foundation and C&A.

When they were sent a draft of this article with a Right of Reply (RofR) CC responded with the following, and I quote: “On p4, you refer to CottonConnect being owned by Shell Oil. As you may be aware, CottonConnect was founded by Shell Foundation, alongside a number of other partners including C&A and Textile Exchange. The Shell Foundation is an independent charity with a separate governance structure https://shellfoundation.org/about/; and has never been a shareholder (owner) of CottonConnect.

Technically, this is correct, but the Shell Foundation was created by Shell Oil. In 2006, its sole source of funding was Shell trading International Ltd – to the tune of US$15.5m. All the staff who worked for the Foundation were Shell Oil staff. I quote the 2006 Financials:

 “The Foundation has no direct employees. Some employees of Shell Group companies work on the Foundation’s activities. The average staff employed by Shell Group companies to work for the Foundation during the year was 7.7 (2005: 6.2).”

Only 2 of these, or some 30%, received emoluments of over US$110,000.

The “founder” of CottonConnect was one such Shell Employee, who had previously been a Commercial and Business Development Manager for Shell Vivo Lubricants, and a Shell Retail Sales Manager and Marketing advisor prior to that. And no, I am not sure how that background  enabled CottonConnect to achieve so much in its first year of operation, either: “CottonConnect have helped C&A (a major European retailer and co-founder) increase sales of sustainable cotton clothes to over 38 million garments in 2010, enhancing the lives of 14,500 farmers in their supply chain. CC have recruited specialist staff in India and Europe and trained over 1,500 farmers in 2010.”

But to return to the topic of Xinjiang, Shell/C&A had been funding/working with Organic/Textile Exchange since 2006 (to promote cotton that could be marketed by C&A as “more sustainable”). When sent this article with a Right of Reply, TE responded and I quote:

Textile Exchange has never received funding from Shell Oil or the Shell Foundation”.

I refer the reader to the Shell Foundation Financials for 2006-2013, when Shell “led the creation of a partnership between Organic Exchange and C&A to improve the lives of poor Indian farmers”. As we can see, some eye watering sums were paid to Organic Exchange.

Organic Exchange became Textile Exchange in 2010. Are TE trying to claim that because that money was technically paid to Organic Exchange, they, despite having virtually the same management team, somehow did not receive it? Is that the purpose of these re-branding exercises? Will Laudes Foundation now disown studies and activities undertaken by the C&A Foundation (C&AF), despite being owned by the same family, and managed by exactly the same people?

If that is the intention, duplicity aside, it will not wash for Textile Exchange. As anyone can see from the Shell Foundation Financials referred to above, even more eye watering sums were spent in the development and promotion of CottonConnect, and this in addition to the €7.5 million that C&AF donated to CC.

In 2015 ownership of that valuable enterprise was transferred to C&AF and Textile Exchange, equally.

But to return to the topic of Xinjiang, Shell Oil was operating there as early as 2002, on the construction of a US$20 billion gas pipeline. They will obviously have been very aware of the nature and power of the XPCC, and Textile Exchange, CottonConnect and so BCI, must have benefited from Shell’s wealth of local knowledge. Indeed, the Shell Foundation’s 2011 annual report refers explicitly to giving US$1.1 million to CC China, as well providing pro bono China advice. Under the circumstances, it is hard to believe that all of them were completely unaware that XPCC farms were tainted with forced labour by convicts and schoolchildren, the deliberate Sinicization of the region, and the transfer of local natural resources to an incoming Han population.

From 2010 onwards, XPCC repression only augmented, and all of these abuses have intensified. The major brands and their funded initiatives were, of course, aware of the situation. I quote from a CottonConnect report from January 2015:

Of these regions, Xinjiang remains the most important, producing the best quality cotton. More than half of the country’s cotton comes from here, with large, government-owned or operated cotton farms still key players in the sector. Home to the largest Muslim population in China (the Uighurs), the region is not without its social issues. Ongoing tensions between the Chinese and Muslim minority communities in the past few years has increased the need for higher-than-normal levels of security in urban areas. While this currently poses no direct risk to the cotton supply chain to date, brands and their supply chain partners sourcing from the region should maintain a watching brief.”


The point, that I seek to make here, indeed, would argue that I do make, is that all XPCC operations are tainted by the use of forced and child labour, the deliberate Sinicization of the region, the apropriation of Xinjing’s natural resources, and their transfer to Han control. All of these undesirable traits predated the BCI and TE promotion of the sustainability of Xinjiang cotton and knowing that the XPCC is Xinjiang’s major cotton producer, should have prevented them from making such claims in the first place.

In their RofR both CottonConnect and Textile Exchange insisted that they do not, and never have had any involvement with XPCC. However, TE also claimed “Textile Exchange has never received funding from Shell Oil or the Shell Foundation”. And that is patently untrue.

Is the claim that neither TE nor their jointly owned subsidiary, CottonConnect ever had any relationship with the XPCC equally false?

What we can say for sure is that in November 2019, the TE website stated that the Textile Exchange Governance Board included none other than Mr. YickChung Man, Director of China XPCC Cotton Association. I pointed this out to TE, and duly sent them the screenshots.

That section of Mr. Man’s bio was promptly deleted from the website, for which TE sent the following explantation, and I quote:

I wanted to provide a quick update on Mr. Man. We have connected with him to inquire about his involvement with XPCC. Mr. Man has confirmed that he has not been involved with XPCC at all recently and he does not believe the organization has been active for many years (thus the reason they have not been mentioned in any of our reports since 2010). His online profile has been updated accordingly.

To say that the idea that the XPCC has not been active for many years is belied by all the evidence, would be an understatement.

Whilst the  “2010 reports” in question are the TE” 2010 FARM & FIBER REPORT Organic by Choice”. This states:

Division and regiments are the names used for cotton production units under the China Xinjiang Production and Construction Corps (XPCC), which is so far the dominant organic cotton producer in China”

And for those in any doubt, herewith a partial screenshot:

As already mentioned, in their RofR, TE stated: “In 2013/14,Textile Exchange was only aware of five organic farms in China.”

As we can see from the Chart above, for 2009-10 TE knew of 4 organic farms in Xinjiang, 3 of which were XPCC. They also knew of 4 farms in conversion. Two of these were XPCC.

Which of these 8 farms had ceased organic production to reduce the total to only 5 by 2013, TE did not explain, but by definition, at least 2 of the farms must have been XPCC.

Yet in their RofR TE also stated:

“Textile Exchange has not been involved in interventions in China and,There are 16 organic producer groups in the Xinjiang region which have participated in the market report data collection. Textile Exchange does not know of any affiliation of these farms to XPCC.”

All of these claims become increasingly difficult to reconcile when we consider that long time TE Board Members, Esquel, invested US$2.4 million in a Kashgar farm co-owned by the XPCC.

In 2002 Marjorie Yang Esquel’s Chairwoman, gave an interview to SCMP. I quote:

“In 1998 – the same year that Esquel bought Gitic’s bankrupt spinning mill – the company established a US$2.4 million, 2,700-hectare joint-venture cotton farm in Kashgar, in southwestern Xinjiang.

“Its partner was the People’s Construction Corps, an unusual organism – better known in Mandarin as the bingtuan – that is best described as a hybrid state-owned enterprise and field army. Established after the revolution, to pioneer development and Han settlement of Xinjiang, the bingtuan runs a diversified range of commercial operations, schools, hospitals and even has its own armed police force and court system.

“Among its areas of expertise is agriculture, and maps of Xinjiang are dotted with the farms run by its various regiments and divisions.

‘They’re very professional and very disciplined,’ Ms Yang said of her paramilitary partner. ‘They’re probably the most efficient farmers in Xinjiang.’”

Whilst TE’s Organic in Action Story No 2 is titled “Esquel China redefining Corporate Success” and refers specifically to this XPCC farm: “Esquel started growing organic cotton in 2000 at the farm near Kashgar, Xinjiang, and the farm and ginning mill were certified by OCIA (Organic Crop Improvement Association International)”. As the title suggests, it is a ringing endorsement of Esquel’s operations and concludes with the company contact details. The article certainly reads as a recommendation to purchase the Esquel XPCC farm’s cotton. The page even offers a “Find a Producer” tab:

“The Find a Producer interactive database helps you search for Producer Groups the world over. It gives visibility to organizations, their products and their stories.”

Curiously, when you click on it, the data set appears to be empty. How, when, and why that happened, is unclear.

It seems quite inconceivable that such a close associate, who by all accounts, ran one of the most efficient, innovative, and fair farms in the entire area, did not contribute to TE’s market report data collection. Indeed, although many might not agree, I would submit that Esquel cotton, whilst definitely not preferred and more sustainable, might be – if the  farm was wholly owned by Esquel and no money was going to the XPCC – as sustainable as much else that is traded in the cotton commodity market. Unfortunately, Esquel announced in April 2020, that they had sold their share of their Kashgar joint venture back to the XPCC for an undisclosed sum, following “XPCC’s change of policy direction and the expiration of the leasing agreement”. So my proposition is now irrelevant.

All of this is, in any case, tangential to my main argument, which is that by promoting Xinjiang cotton as preferred and more sustainable, both TE and BCI were deliberately deceiving both brands and consumers.

In their RofR, Textile Exchange also asserted, and I quote: “nor do we advise companies where to source.” This may come as a surprise to many brands who thought that sourcing organic cotton from Xinjiang was precisely what they were being advised to do if they wished to receive recognition and free publicity for their “sustainable” cotton purchases.

For example, as recently as February 2020, the World Wildlife Fund (WWF), Solidaridad, and the Pesticide Action Network (PAN) UK, published the Sustainable Cotton Ranking. Included in the more sustainable cotton ranked by these worthies were organic and BCI cotton from Xinjiang.

Their sustainable cotton clarion call was: “With this ranking, PAN UK, Solidaridad and WWF hope to accelerate demand and uptake of more sustainable cotton by clothing and home-textile retailing companies.”

The brands who answered that call, particularly the top performers: Adidas, IKEA, H&M, C&A, Otto, Marks and Spencer, and Levi Strauss, may be disconcerted to find that they are now on their own, and that responsibility for sourcing XPCC cotton rests solely upon their shoulders.

Similarly, in June, Textile Exchange issued their own 2020 Preferred Fiber and Materials Market Report. This stated that China produced 941,336 mt of “preferred” cotton fiber in 2018/19, of which: BCI: 896,000 mt, Organic: 41,247 mt, REEL: 4,089 mt. Almost all of this came from Xinjiang and XPCC farms. Whilst for their 2025 Sustainable Cotton Challenge TE state:

“The 2025 Sustainable Cotton Challenge (2025 Challenge) serves as a cornerstone for change in the apparel and textile industry by encouraging brands and retailers to commit to source 100 percent of their cotton from the most sustainable sources by the year 2025.

All of this certainly sounds like “advice to companies where to source” to me.

As an aside, it is important to note that the argument I am making here is not that the Esquel joint venture farm itself, or indeed any of the XPCC farms referred to by the initiatives, is employing detainees forced into agricultural labour.

This is something that they all vehemently deny, and that could be correct. Indeed many of the farmers, both Uighur and Han, may be very happy with their situation (although I am unclear how the farms managed to avoid the school cotton picking that the XPCC/XUAR finds so character building and educational).

Demonstrating that Uighur political prisoners have been forced to labour at these farms is not required to demonstrate that XPCC cotton is not “preferred and more sustainable” as WWF, Solidaridad, PAN, BCI, and TE all claim.

Indeed, it is quite beside the point.

The real issue here is that all XPCC cotton has been cultivated and harvested on the back of forced, prison, child (and now possibly Uighur detainees dependent’s) labour. It has been developed through the appropriation of local resources, and imposed Sinicization. Moreover all of these characteristics were in the public domain from the start. The situation has merely considerably worsened.

This is not a case that can be resolved, as some are suggesting, by establishing a Task Force, or by sourcing only cotton that is organic or certified. We are referring to cotton that has been labeled organic or BCI. And combining GOTS with Blockchain, as others have proposed, will have absolutely no impact. In 2019, China was number 5 in the world for GOTS-certified facilities (it had 448), and to quote GOTS themselves:

“GOTS is the stringent voluntary global standard for the entire post-harvest processing (including spinning, knitting, weaving, dyeing and manufacturing).”

All the practices that I have just described occur at the farm level – so they are not post-harvest and are therefore, not covered by GOTS.

My original draft referred to BCI and TE “sourcing” cotton to which TE responded and I quote: “there is no such thing as “TE certified organic cotton.” However, Textile Exchange does own the Organic Content Standard (OCS), which addresses chain of custody for tracking and labeling organic cotton post-harvest stages (gin-onwards). The OCS does not apply to the production (growing) of organic cotton.”

And they are of course correct, they don’t source cotton and it seems, can tell us absolutely nothing about which type of cotton has been responsibly farmed, and which not. As they further stated in their RofR: “We do not engage with any specific farms beyond collecting and sharing organic cotton production data” and “Textile Exchange has not been involved in any interventions in China”.

In short, it would appear that TE simply prints whatever their producer groups tell them, without any means of verifying that it is an accurate reflection of what is actually happening on the ground.

This makes a complete mockery of the aforementioned World Wildlife Fund (WWF), Solidaridad, and the Pesticide Action Network (PAN) UK, Sustainable Cotton Ranking, which claims (as elaborated in an email response from Solidaridad to Apparel Insider, dated 06 March 2020) that organic and BCI cotton are “ more sustainable” because: “Sustainability standards aim to address the challenges associated with conventional cotton cultivation by prescribing sustainable farming practices. Together with their associated Chain of Custody, they assure buyers that the product meets specified requirements.”

Indeed, it makes a mockery of all global initiatives and brands claiming to have identified/sourced more sustainable cotton. When it comes to what is really going on at the farm level, as TE admits, none of them have any (verified) idea.


  1. Given all this, duping consumers into believing that organic and BCI cotton from Xinjiang is preferred and more sustainable is false advertising, and always has been. Xinjiang cotton not only consumes inordinate amounts of irrigation water in a water scarce region, but this and other resources have been diverted from the local, predominantly Uighur population, to XPCC/Han use. It is impossible to extricate prison and child labour from the narrative, and the aim of engineering the population from ethnic minority, to a Han majority has been one of the XPCC’s publicly declared roles and objectives since its creation.
  2. All these abuses enable XPCC farms to produce more cheaply than their supposedly “less sustainable and less preferred” US, Australian, and other competitors. Making these claims then, is not just false advertising, it is also anti-competitive practice.
  3. Above all, however, the money that the XPCC makes and has made from this so-called “preferred and more sustainable cotton” has enabled and actually is enabling them to fund the current abuses.

This means that absolutely anyone promoting or indeed purchasing such cotton is complicit in the very practices that they are now rushing to deplore.


https://books.google.com.ag/books?id=wrHACQAAQBAJ&source=gbs_book_other_versions_r&cad=4 1998

https://www.scmp.com/article/389658/esquel-cottons-opportunity-desert 2002


https://books.google.co.uk/books/about/Ten_Thousand_Miles_Without_a_Cloud.html?id=figRAQAAIAAJ&source=kp_book_description&redir_esc=y 2003

https://www.cecc.gov/publications/commission-analysis/xinjiang-government-continues-controversial-work-study-program 2006

https://shellfoundation.org/financials/  2006-2013

http://english.mofcom.gov.cn/aroundchina/xinjiangbingtuan.shtml 2007

https://www.cecc.gov/publications/commission-analysis/work-study-programs-using-child-labor-continue-in-xinjiang 2008

http://docs.uyghuramerican.org/Bingtuan.pdf 2009

http://farmhub.textileexchange.org/upload/library/Farm%20and%20fiber%20report/Farm%20and%20Fibre%20Report%202010%20Final%20-%20Small.pdf 2010

https://www.cecc.gov/publications/commission-analysis/xinjiang-students-continue-to-harvest-cotton-directive-allows-child 2011

https://textileexchange.org/wp-content/uploads/2017/05/OC-SAT-Summary-of-Findings.pdf 2011-14

https://docs.uhrp.org/Uyghur-homeland-Chinese-Frontier.pdf 2012

http://farmhub.textileexchange.org/upload/library/Farm%20reports/LCA_of_Organic_Cotton%20Fiber-Full_Report.pdf 2014


http://cottonconnect.org/wp-content/uploads/cottonconnect_china_report_final.pdf 2015


https://www.refworld.org/docid/5a9427b4a.html 2017

https://docs.uhrp.org/pdf/bingtuan.pdf 2018




https://sustainablecottonranking.org/ 2020

https://www.esquel.com/news/divestment-xinjiang-white-field-farming-co-ltd 2020https://textileexchange.org/wp-content/uploads/2020/06/Textile-Exchange_Preferred-Fiber-Material-Market-Report_2020.pdf

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