In September 2025, US Customs and Border Protection issued a Withhold Release Order against bicycles and related products made by Giant Manufacturing in its Taiwanese factories. Giant is one of the largest bicycle makers in the world. The order meant the goods could be stopped at the American border.

Taiwan’s labour ministry issued forced-labour guidelines afterwards. The order of those two events is the story.

What CBP found

The investigation concluded that Giant had engaged in forced labour as defined by the International Labour Organization’s indicators. The ones cited were abuse of vulnerability, abusive working and living conditions, debt bondage, withholding of wages, and excessive overtime.

Those indicators are worth understanding, because they are not a description of unpleasant work. Debt bondage in this context typically means recruitment fees: a worker borrows to pay an agent for the job, arrives owing money, and cannot leave until it is repaid. Abuse of vulnerability means the worker’s position — language, immigration status, debt — is what makes the conditions enforceable. The ILO framework exists precisely so that “forced labour” can be established without anyone being chained to a machine.

The wider evidence

Giant was not an isolated finding. Multiple studies have documented widespread indicators of forced labour across Taiwanese industry — including a 2024 study by the organisation Orientation and a 2025 investigation by the independent journalist Peter Bengtsen.

Taiwan has relied on migrant labour since the late 1980s, drawing workers principally from Southeast Asia into manufacturing, fishing and care work. The recruitment-agency structure that brings them in is where most of the documented problems originate.

Regulation that arrives from outside

The pattern here is one that recurs across export economies: a domestic labour problem is documented for years by researchers and journalists without producing regulatory change, and then a foreign customs authority halts a shipment and guidelines appear within months.

Supporters of import bans argue this is exactly what they are for. Domestic enforcement in export sectors faces a structural obstacle — the industry is a source of national revenue, and the workers affected cannot vote — so attaching a cost at the point of sale is the one lever that reliably moves governments. On this reading, the sequence is not embarrassing but successful.

Critics make two objections. The first is about who bears the cost: an order that stops a shipment can cost the workers their jobs before it improves their conditions, and there is no mechanism guaranteeing they are compensated for the interval. The second is about consistency — enforcement of this kind is applied selectively, tends to follow diplomatic and trade priorities, and is not available to workers in countries that do not export to the enforcing market.

Both objections are about the same underlying fact: this is trade policy being used as labour policy, and it works only where trade leverage exists.

What guidelines do and do not do

Guidelines are not law. They set out what employers should do; they do not by themselves create an offence, a penalty or an inspection regime. Whether the Taiwanese guidelines change conditions depends on things that were not settled by issuing them: whether recruitment fees are prohibited and the prohibition enforced, whether workers can change employer without losing status, and whether inspection is unannounced.

Labour rights groups in Taiwan have argued that migrant workers’ position remains at risk despite the new framework. That is the thing to watch, and it will be measured in whether the next investigation of this kind originates in Taipei or in Washington.

Related: The Permit Names One Employer, and That Is the Whole Problem.

Sources

CBP findings, ILO indicators and ministry response reported by JURIST.