The Solar Energy Industries Association on Monday released a draft solar supply chain standard that aims to help companies comply with U.S. Customs and Border Protection traceability requirements. The proposed standard is the first of its kind, according to SEIA.
The standard “explains how to conduct forced labor-focused due diligence, including how to develop a material traceability system to trace the provenance of materials from upstream suppliers into finished products, and how to identify and address indicators of forced labor in supply chains,” according to its introduction.
The solar industry is vulnerable to unintentionally profiting from forced labor as it remains reliant on imports, which have skyrocketed since the Inflation Reduction Act. The Uyghur Forced Labor Prevention Act went into effect in June 2022, and by November, more than 1,000 shipments of solar imports had been seized at the border, according to Reuters.
“An importer must produce ‘clear and convincing evidence’ to rebut the presumption of the use of forced labor,” said law firm Locke Lord in a 2022 blog post. “This is a very high bar and will require substantive documentary proof that ties every component in a product to a source that is free of forced labor.”
SEIA’s Standard 101 “provides a rubric that manufacturers and importers can follow to trace product origins from raw materials to finished goods,” the group said in a release. SEIA says the standard was crafted from real-world examples of detained and released shipments.
SEIA is an American National Standards Institute-accredited standards developer, and has created ten other standards for the solar industry, including a consumer protection standard.
“Weaving product traceability into the entirety of the solar and storage industry’s supply chain will require organizations at each level of the supply chain to cooperate and make available sensitive information,” SEIA’s draft standards say. “Any traceability management program implemented by an organization should include specific metrics that are to be monitored, measured, and evaluated, with each organization periodically reviewing the effectiveness of its traceability management program.”
Actions the group recommends include identifying high-risk suppliers, identifying high-risk materials and components, and investigating employee grievances.
Standard 101 is open for public comment through Nov. 4. SEIA said it plans to finalize the standards in the first quarter of next year.
