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CBP Blocks Giant Manufacturing: What Importers Must Learn from Taiwan’s Bicycle Giant

Written by Eldad Shashua | Sep 28, 2025 10:15:18 PM

Giant Manufacturing WRO: A Wake-Up Call for U.S. Importers

When U.S. Customs and Border Protection (CBP) issues a Withhold Release Order (WRO), it’s not symbolic. It’s an enforcement action with serious consequences: goods detained at the port, financial harm, and reputational risks.

On September 24, 2025, CBP announced a WRO against Giant Manufacturing Co. Ltd. for bicycles, bicycle parts, and accessories manufactured in Taiwan, citing forced labor indicators. U.S. Customs and Border Protection+2GovDelivery+2 This WRO is the third issued in 2025 and the fourth in Fiscal Year 2025. U.S. Customs and Border Protection+1

What CBP Found in the Giant Case

CBP’s investigation identified five International Labour Organization (ILO) forced labor indicators during its review of Giant’s Taiwan production. U.S. Customs and Border Protection+1 These include:






Because of this, CBP ordered that all shipments of Giant-manufactured bicycles, parts, and accessories from Taiwan be detained at U.S. ports until importers prove admissibility. U.S. Customs and Border Protection+2Lexology+2

CBP’s press release emphasizes that Giant’s practices allegedly permitted goods to be produced below market value, undercutting U.S. businesses by millions. U.S. Customs and Border Protection+1

At the time of the announcement, CBP reported managing 53 active WROs and 9 Findings under the forced labor statute (19 U.S.C. § 1307). U.S. Customs and Border Protection+1

Background: Giant & the Hidden Risks of Outsourcing

Giant is a globally recognized bicycle brand headquartered in Taiwan, established in 1972. Giant Group Cycling+2Lexology+2 Many people know the logo more than the name. While this WRO applies to Taiwan production, Giant also has global operations and manufacturing presence in multiple countries, including China, Vietnam, Hungary, and the Netherlands. Cyclingnews+2Giant Group Cycling+2

Importantly, the risk isn’t limited to Taiwanese brands. Many importers believe they are paying a trusted company in one country—but in practice production gets subcontracted, often across borders, sometimes into unvetted factories in China or other jurisdictions.

In that scenario:

  • The importer may think they’re sourcing from “Company X” in Taiwan or elsewhere, but the actual factory doing work is in China with weaker oversight.

  • Supplier subcontracting is often opaque, and paperwork may not match actual operations.

  • When CBP uncovers forced labor or compliance gaps deeper in the chain, the importer is held responsible—even if misled.

If a giant brand with name recognition can be flagged, smaller importers are all the more vulnerable when relying on outsourcing without full verification.

What CBP Expects Importers to Prove

To challenge a WRO or force a release, importers must provide:

  • Full supply chain mapping, from raw materials through subcontractors to finished goods

  • Transaction flow documents (POs, invoices, payments, shipping records)

  • Factory & worker rosters, origin documentation

  • Independent audits and certifications that stand up to scrutiny

Without this, CBP will maintain detention or move toward seizure.

The Asia Agent Approach

Many importers rely solely on supplier self-certifications—but CBP doesn’t. That’s the “unspoken conflict”: suppliers want plausible truth; importers need actual truth.

Asia Agent’s solution:

  • In-person, on-the-ground factory verification (China & Vietnam)

  • Evidence packs: BOM → HS mapping, origin memos, licensing, geo-tagged photos

  • Legal contracts with supplier obligations, inspections, and audit rights

  • Training your team on internal audits and evidence management

  • A 24–48 hour CBP response binder, always audit-ready

What You Should Do Right Now

  • Review your supplier roster for forced labor and outsourcing risk

  • Require subcontractor traceability and enforceable contracts

  • Maintain documentation continuously—don’t scramble when CBP shows up

  • Prepare internal teams through mock audits and response planning

Enforcement from CBP is intensifying. The Giant WRO shows this is no theoretical risk—it’s real, current, and escalating.

Want to know whether your suppliers are WRO-proof?

In three months, Asia Agent can help you build an internal compliance system, supported by enforceable contracts and evidence-backed audits. Don’t wait for a port detention to force your hand.

Book a Strategy Call Today

 

FAQ

Q: What does the Giant Manufacturing WRO mean for U.S. importers?
CBP will detain bicycles, bicycle parts, and accessories manufactured by Giant in Taiwan. U.S. importers must now provide admissibility evidence, including supply chain maps and proof of no forced labor, before shipments can be released.

Q: Why should importers sourcing from China and Vietnam care about the Giant WRO?
Even if you source from Taiwan, Vietnam, or other countries, many suppliers subcontract production into China. If those subcontractors use forced labor or fail compliance checks, CBP holds the U.S. importer liable.

Q: Can CBP audits and WROs impact companies outside of China?
Yes. CBP enforcement applies to any product entering the U.S. If your supplier in Vietnam, India, or Taiwan is outsourcing to China—or hiding parts of their supply chain—you face the same risk Giant is facing now.

Q: How does CBP detect forced labor in Asia-based supply chains?
CBP uses a mix of factory visits, document analysis, and advanced risk targeting. They verify BOMs, transaction flows, worker rosters, and supplier audits. If discrepancies appear, shipments are detained under WROs or flagged for UFLPA.

Q: What steps can importers take to avoid a CBP WRO when sourcing in Asia?
Importers should:

  • Conduct on-the-ground factory verification in China & Vietnam

  • Build a full supply chain map from raw materials to finished goods

  • Secure affidavits and local lawyer-backed contracts with suppliers

  • Maintain an internal CBP audit binder ready for detention or audit

Q: Can shipments from Taiwan, Vietnam, or India still be detained if subcontractors in China are used?
Yes. If CBP determines that subcontracted production occurred in China under noncompliant or forced labor conditions, the importer is responsible—even if the contract was with a Taiwanese or Vietnamese supplier.

Q: What happens if I cannot provide supply chain transparency during a CBP audit?
Shipments may be detained, storage fees will rise, penalties may be assessed, and repeated violations can result in broader scrutiny or exclusion orders.

Q: How can Asia Agent help importers avoid CBP penalties?
Asia Agent provides local factory audits in China and Vietnam, legal contracting with supplier obligations, and ready-to-deploy CBP audit binders. Our on-the-ground approach ensures importers hold evidence that CBP will accept, not just supplier promises.