On September 24, 2025, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against bicycles, bicycle parts, and bicycle accessories produced by Giant Manufacturing Co. Ltd. in Taiwan. The WRO follows an investigation into the company where CBP discovered several International Labour Organization (ILO) forced labor indicators, including abusive working and living conditions, withholding of wages, and excessive overtime.

In a press release announcing the WRO, the CBP states that forced labor practices enabled Giant Manufacturing to benefit financially, “resulting in goods produced below market value and undercutting American businesses by millions of dollars in unjustly earned profits.”

The WRO is effective immediately and CBP personnel have been instructed to detain at the U.S. port of entry all bicycles and bicycle accessories manufactured in Taiwan by Giant under the assumption that they have been manufactured using forced labor. In order for any such goods to be released, the importer must either prove that they were not made with forced labor, or the goods can be re-exported.

Importers who have purchased covered goods or whose goods get detained under a WRO should seek assistance of legal counsel. This marks the third WRO issued by CBP in 2025 and brings the total number of active WROs to 53

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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.