Recent concerns over the expansion of organ transplant facilities in Xinjiang, China have reignited serious human rights concerns, particularly regarding allegations of forced organ harvesting from prisoners of conscience and the use of those organs in medical research across the globe.
This development, alongside the potential for medical experts to be conducting legitimate research using (even unwittingly) organs forcibly harvested, underscores the urgent need for stronger policies to address the risks embedded within the global medical supply chain. Applying the framework for the UN Guiding Principles on Business and Human Rights (UNGPs) offers a sensible starting point to ensure transparency, reinforce that dignity and accountability are not optional, and to ultimately avoid disciplinary action being taken against medical professionals.
The Scale of Expansion
A letter sent to over 20 Special Rapporteurs in July 2025 suggests there is evidence that that Xinjiang currently has three approved transplant centres, with plans to establish six more by 2030. The writers indicated that there appears to be no clear justification for this outsized expansion: the region itself has a low organ donation rate at just 0.69 per million people, far below China’s national average of 4.66. The proposed number of facilities therefore vastly exceeds what comparable regions with similar populations and GDP maintain, raising a reasonable inference that organs will not simply be for local supply.
The final judgment of the Independent Tribunal into forced organ harvesting concluded in 2020 that forced organ harvesting from prisoners of conscience has occurred in China, particularly in Xinjiang, on a significant scale and over a sustained period. This is compounded by evidence of mass detention of Uyghurs and Falun Gong practitioners, including satellite imagery, WHO reports, and testimony from former inmates. The Uyghurs, a predominantly Muslim ethnic group with a history spanning over a millennium in Xinjiang, have endured generations of political discrimination and economic marginalization.
In 2017, Beijing intensified its crackdown on Uyghurs and other ethnic minorities through pervasive surveillance, mass detentions, and forced assimilation. Leaked government documents, known as the China Cables, reveal that in a single week in June 2017, authorities rounded up over 24,000 Uyghurs, sending more than 15,600 to so-called re-education camps. U.S. government estimates suggest more than one million Uyghurs, about 10% of the community’s population in Xinjiang, are now imprisoned under these policies. This marks China’s second large-scale campaign of mass detention, the first being the arbitrary detention of Falun Gong practitioners beginning in 1999, which is inextricably linked to forced organ harvesting.
Transparency and Accountability
In well- regulated ethical organ donation systems, countries generally publish detailed statistics on donor activity, consent rates and transplantation outcomes. These figures are typically made publicly accessible online or through official reports, allowing for independent analysis, research and auditing, while more granular data can also be requested for access. Both the WHO’s Guiding Principles on Human Cell, Tissue and Organ Transplantation and the Declaration of Istanbul explicitly call for transparency and independent oversight of national organ donation systems.
The issue of limited transparency regarding organ procurement and allocation in China is a significant concern in transplantation medicine. The official China Organ Transplant Response System (COTRS) exists and headline numbers are sent to international registries, but underlying data remains largely inaccessible, offering no clear way to verify transplant figures or methodology for collection.
This opacity matters. Past evidence of data manipulation and coerced or forced organ harvesting indicates that robust prevention and protection measures are necessary under international frameworks relating to organ trafficking. Such issues are recognised as raising ethical issues for the medical profession globally. It is here that the business of organ transplantation intersects with human rights and professional ethics.
The Role of the UN Guiding Principles
The UN Guiding Principles on Business and Human Rights are built on three pillars: governments must protect people by passing and enforcing laws, companies must respect rights through due diligence, and victims must have access to remedy when harm occurs. These principles are not just theoretical; sector-specific guides for the medical industry, such as those produced by Global Rights Compliance, offer practical tools for risk-based assessments, model contract clauses, and board-level oversight in organ transplantation medicine, research, and training.
Applying these frameworks in a meaningful and practical way ensures that rights are not just empty promises, but that transplant organisations are putting in place the building blocks for ethical medicine in what has become a global oragn transplant business , where a transplant in some countries can cost hundreds of thousands.
Conclusion
We seek to highlight the urgent need for transparency, accountability, and the application of international human rights standards in the context of organ transplant expansion in Xinjiang, before the lack of transparency in China leads to the disciplining of members of the global medical profession and the removal of literature produced using forcibly harvested organs.
About the Co-Author
Eleanor Stephenson is a barrister at 5 St Andrew’s Hill chambers in London specialising in international criminal law and human rights. She has prosecuted and defended at several of the international tribunals in The Hague and has represented clients in human rights complaints to the European Court of Human Rights and the various UN Individual Complaints Mechanisms. She acts in a range of Chambers’ practice areas including extradition & international law, sanctions, public inquiries & inquests and general crime.
Image: C.E. Bock, Atlas of human anatomy with explanatory text. Source: Wellcome Collection.
