German economic engine roars thanks to forced labor: Complaint filed against VW, BMW and Mercedes Benz

China – Supply chains – Forced labor

In the manufacture of their vehicles, VW, BMW and Mercedes-Benz use raw materials and components that, according to multiple reports, are mined and produced under conditions of forced labor in the Xinjiang Autonomous Uyghur Region (Uyghur Region). ECCHR has now filed a complaint against the three automakers with the German Federal Office for Economic Affairs and Export Control (BAFA). They are accused of failing to take appropriate measures to identify, prevent or remediate these severe human rights violations in their supply chains – measures that are now required under the German Supply Chain Act, which came into effect on 1 January 2023. We are demanding that these companies cease their business practices in the region, as long as they cannot demonstrate that adequate due diligence assessments are being conducted and that these operations are free of human rights violations.


The complaint with the BAFA provides evidence indicating that Uyghur forced labor is widespread in the supply chains of car manufacturers. Despite this, VW, BMW and Mercedes-Benz have not detailed how they are addressing these risks as part of their human rights due diligence. In particular, the system of state surveillance and repression in the Uyghur Region makes it impossible to carry out reliable factory inspections to ensure compliance with human rights standards. The BAFA should urgently intervene and carry out targeted inspections to assess whether these companies are fulfilling their due diligence obligations.

With the enactment of the Supply Chain Act, companies are required to ensure social, environmental and  human rights standards along their entire supply chain networks. This includes taking appropriate measures to prevent and stop human rights-related violations within the operations of their supplier companies.

A report published by Sheffield Hallam University and NomoGaia in December 2022 clearly documents that the entire supply chain of German car manufacturers is highly likely to be exposed to Uyghur forced labor. VW, BMW and Mercedes-Benz are all named in the report in connection with suppliers that are involved in the Uyghur forced labor program. Based on this report, ECCHR filed the complaint under the Supply Chain Act.

These companies should be taking urgent action to analyze the risk of forced labor within their manufacturing operations – and disengage from any supply chain relationships they have with companies active in the region.  

The complaint is supported by the World Uyghur Congress (WUC) and the Association of Ethical Shareholders Germany.


In the Uyghur Region, Uyghur people and other ethnic minorities are subjected to massive repression, systematic surveillance, and forced labor. This was also the conclusion of a report by the UN Special Rapporteur on the human rights situation in the region. Thus, companies operating in the Uyghur Region are either actively or implicitly condoning the use of forced labor within their production facilities and supply chains – and thereby are potentially making themselves complicit in crimes against humanity.

Already in 2021, ECCHR and partner organizations in Germany, France and the Netherlands filed criminal complaints against leading European textile companies that also profit from forced labor and exploitation in the Uyghur Region. German companies must comply with their legal obligation to guarantee that their supply chains are free of human rights abuses.

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Due diligence

A company's s human rights due diligence obligations reguire it to manage potential risks to human rights.

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Corporate responsibility

Both in economic and legal terms, transnational corporations are the winners of the globalized economy. They are often caught up in a borad range of human rights violations, but the people running the firms are only rarely called before the courts, and even more rarely convicted for their wrongdoing.

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