Key Takeaways#
- On 24 September 2025, US Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against Taiwanese bicycle manufacturer Giant Manufacturing on the grounds of forced labour — the first time such an order has targeted a Taiwanese manufacturer.
- The investigation found that Giant violated 5 of the ILO’s 11 indicators of forced labour: debt bondage arising from recruitment fees, withholding of wages, excessive overtime, abuse of vulnerability, and abusive working and living conditions.
- Over more than a year, Giant has rolled out remediation measures, including reimbursing recruitment fees, providing new dormitories for migrant workers and submitting a Corrective Action Plan (CAP). Industry peers such as Merida and Cheng Shin Rubber have also adopted zero-recruitment-fee policies. As of August 2026, the WRO remains in place.
1. What happened?#
On 24 September 2025, US Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against Giant bicycles and components produced in Taiwan by Giant Manufacturing.
This was the first time US Customs had taken border enforcement action against a Taiwanese manufacturer on the grounds of forced labour. For Taiwanese companies, the action had immediate financial and reputational impacts in the US market.
2. Which violations did US Customs identify?#
In this case, CBP drew on the International Labour Organization’s (ILO) 11 indicators of forced labour and found that Giant’s factories in Taiwan exhibited at least five of them: debt bondage, withholding of wages, excessive overtime, abuse of vulnerability, and abusive working and living conditions.
According to the findings, migrant workers had to pay recruitment fees of roughly USD 3,200 to 6,700 to agencies in their home countries before coming to work in Taiwan. Once in Taiwan, they also paid monthly service fees to Taiwanese brokers, amounting to about NT$60,000 over a three-year contract. Living conditions were also poor: in some older dormitories, up to 20 people shared a single room, in crowded and unsanitary conditions.
This reflects one of the most overlooked forms of forced labour: heavy debt that effectively strips workers of the freedom to refuse work. Debt bondage caused by recruitment fees is one of the most common risks faced by Southeast Asian migrant workers coming to Taiwan.
3. What was the impact?#
Once the WRO was issued, the rest of the industry moved quickly. Merida, Cheng Shin Rubber (Maxxis), Fritz Jou, and Fox Factory’s plant in Taiwan all subsequently announced zero-recruitment-fee policies. The case is no longer one company’s crisis. It has exposed a structural problem that Taiwan’s whole bicycle supply chain now has to face.
As the first time the US has invoked its forced labour ban against a Taiwanese manufacturer, the case is a wake-up call for Taiwan’s government, its industries and even its recruitment agencies.
4. How has Giant responded?#
A zero-recruitment-fee policy at Giant started in January 2025. After the WRO took effect, the company began formally reimbursing recruitment fees in October. According to reports, Vietnamese workers each received NT$50,000 and Thai workers NT$30,000; the following year, reimbursement was also extended to former employees, and 400 migrant workers moved into new dormitories. According to Giant’s Q1 2026 financial report, these reforms cost the company around NT$80 million.
As of August 2026, more than 10 months after it was issued, the WRO has still not been lifted. Of the 27 WROs issued by CBP since 2020, only 8 have been lifted or modified, taking an average of around 29 months. Giant remains in ongoing dialogue with CBP, but whether and when the order will be lifted remains uncertain.
6. What’s the role of the Taiwanese government?#
As early as June 2024, journalist Peter Bengtsen published an investigation naming Giant and several other Taiwanese bicycle manufacturers as being exposed to forced labour risks. Yet it was only when CBP formally issued the WRO that the authorities recognised the urgency of the issues.
This year, Taiwan’s Control Yuan, the government’s top oversight body, also opened an investigation into this case, and its report highlighted two structural problems. First, Taiwan still largely relies on existing domestic labour laws to determine legality, rather than fully adopting the ILO forced labour indicators as an inspection standard. What is legal in Taiwan may still fall short internationally. Second, unless the government addresses the issue systemically rather than through piecemeal fixes, it will struggle to meet international human rights expectations.
In response to these findings, the Ministry of Labor (MOL) introduced Guidelines on the Prevention of Forced Labour in February. It also plans to amend the law to prohibit employers and brokers from confiscating migrant workers’ identity documents or collecting deposits. Since March, the MOL has been working together with the Ministry of Economic Affairs to help companies identify and address forced labour risks.
At the international level, this commitment also extends to the Taiwan–US trade agreement signed in February this year, under which the Taiwanese government committed to legislating within three years to prohibit recruitment fees and related costs from being borne by workers.
7. What This Means for Taiwan’s Supply Chains#
As an export-oriented economy, Taiwan’s manufacturers are tightly woven into global supply chains. As international markets increasingly incorporate human rights standards, market access is becoming tied to human rights practices. A compliant supply chain will become the threshold for doing international business.
The Control Yuan’s report has already pointed to the most critical warning: being legal in Taiwan is not the same as being compliant internationally. A company can fully comply with Taiwan’s labour laws and still fall short of international standards, and so fail its buyers’ supply chain requirements.
The impact of the Giant case goes far beyond a single company. As bicycle makers dropped recruitment fees one after another, the message was clear: worker-paid recruitment fees are an industry-wide risk, not an isolated case.
Companies and the government have long treated migrant workers’ rights reactively, acting only after a problem comes to light. Because forced labour is a systemic risk, companies and the government must adopt a risk-based approach that puts prevention first. For Taiwanese suppliers, respecting workers’ rights is no longer optional. It is the basis of trust with global buyers and the price of access to global markets.