On September 24th, 2025 US Customs and Border Protection issued a Withhold Release Order under Section 307 of the Tariff Act of 1930 (19 U.S.C. §1307) against Giant Manufacturing Co LTD for any bicycles, parts or accessories manufactured in Taiwan based on reasonable indication of forced labor. CBP identified the presence of five of the ILO indicators of forced labor:

  • abuse of vulnerability,
  • abusive working and living conditions,
  • debt bondage,
  • withholding of wages and
  • excessive overtime.

Going forward, any shipment of the subject products manufactured by Giant Manufacturing’s Taiwan factories will be subject to immediate detention upon arrival into the United States. If a shipment is detained, under 19 CFR 12.43(a) the importer of record will have 3 months from the date of detention to provide adequate proof to CBP that the goods were not manufactured using forced labor. If the documentation sufficiently demonstrates that forced labor was not used then the goods will be released to the importer, otherwise the goods must be exported or destroyed pursuant to 19 CFR 12.44.

Giant Manufacturing has announced it plans on petitioning CBP to have the order revoked and reiterated the steps it proactively took to address possible forced labor concerns.

Tags: Forced Labor
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Photo of Simeon Yerokun Simeon Yerokun

imeon Yerokun is a counsel in Crowell & Moring’s International Trade group and based in the firm’s Washington, D.C. office. He advises clients on all areas of import regulatory compliance, trade remedies, and international trade litigation.

Simeon has extensive experience counseling companies in

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imeon Yerokun is a counsel in Crowell & Moring’s International Trade group and based in the firm’s Washington, D.C. office. He advises clients on all areas of import regulatory compliance, trade remedies, and international trade litigation.

Simeon has extensive experience counseling companies in the areas of business and human rights law, including compliance with global anti-forced labor and human rights requirements. He regularly represents companies before U.S. government agencies on forced labor-related matters, including securing the release of goods detained and seized by U.S. Customs and Border Protection. He also offers deep experience assisting companies in mapping their supply chains, including linking imported products back to their raw materials using enterprise software and other inventory management audit tools. Simeon is highly accomplished in forced labor supply chain mapping and risk assessments, as well as verifying due diligence efforts with on-the-ground visits to client facilities, incorporating third-party intelligence and audit resources.

Simeon’s experience also covers a broad spectrum of trade and customs issues, including those related to import regulatory compliance matters such as valuation, classification, duty drawback, marking and labeling, entry procedures, and penalties; free trade agreements; antidumping and countervailing duty issues; trade litigation; intellectual property issues such as trademark and copyright infringement; the enforcement of exclusion orders issued by the International Trade Commission (ITC); steel and aluminum tariffs under the Section 232 National Security Investigation; and the additional tariffs on products from China under Section 301 of the Trade Act of 1974.

Additionally, Simeon handles antidumping (AD) and countervailing duty (CVD) investigations before the U.S. Department of Commerce’s International Trade Administration (ITA) and the U.S. International Trade Commission (ITC) under the Tariff Act of 1930, and litigation involving the U.S. Court of International Trade (CIT).

Prior to joining Crowell, Simeon was a trade and finance attorney in the Office of Chief Counsel—U.S. Customs and Border Protection (CBP), and before that, he served as counsel to Commissioner Irving A. Williamson at the U.S. International Trade Commission.

Simeon is a proud graduate of Howard University School of Law, where he served as technical editor of the school’s Human Rights and Globalization Law Review.

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Photo of Brett Everett Brett Everett

Brett Everett is a senior international trade specialist II in Crowell & Moring’s Los Angeles office. He has over ten years of experience as a Licensed Customs Broker with a primary focus on trade with Asia. He has experience with client inquiries into

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Brett Everett is a senior international trade specialist II in Crowell & Moring’s Los Angeles office. He has over ten years of experience as a Licensed Customs Broker with a primary focus on trade with Asia. He has experience with client inquiries into the classification of merchandise under the Harmonized Tariff Schedule of the United States, antidumping/countervailing orders and circumvention, Section 232, and Section 301 matters. Brett has developed compliance and audit programs and has experience with Post Entry Correction filings, protests, and other filings with U.S. Customs and Border Protection (CBP).

He supports clients with import regulatory matters pending primarily before CBP in all areas of import regulatory compliance, customs valuation, country of origin and marking, trade preference programs and free trade agreements, and CBP inquiries (i.e., CF-28s and CF-29s).

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