Report|Addressing Forced Labor in Seafood Supply Chains
2025-12-10
Date:December 10, 2025 (Wednesday), 13:30–16:00 (GMT+8, Taiwan Time)
Venue : 陽明交通大學光復校區管理二館1069室(NYCU, Hsinchu, Taiwan, Management Building 2, Room 1069)
Moderator : Assoc. Prof. Bo-Shone Fu 傅柏翔副教授/國立台北大學法律學院(College of Law, National Taipei University)
Keynote Speakers : Prof. Jennifer Gordon, School of Law, Fordham University (美國福特漢姆大學法學院)
Report by Ping-Chi Chen (Master’s Student, Graduate Institute of Technology Law, National Yang Ming Chiao Tung University)
Event Info:LINK
Event photo:LINK
Event viedo: https://youtu.be/rJkmASTs0xQ 、 https://youtu.be/nyyUO2BHrcg
Since 2013, several cases regarding forced labor have occurred in distant water fisheries in Taiwan, with four events triggering the issuance of Withhold Release Order (WRO) by the U.S. Customs and Border Protection (CBP) in 2016, 2019, and 2020. Aside from distant water fisheries, in September 2025, CBP issued a WRO against shipments from Giant Group, Taiwan’s largest bicycle manufacturer, citing credible indicators of forced labor and marking another Taiwan’s forced labor–related trade sanctions.
On 10 December 2025, the School of Law at National Yang Ming Chiao Tung University and ICCS hosted Professor Jennifer Gordon for a lecture on the structural causes of forced labor in global seafood supply chains and U.S. import bans.
Understanding the Causes of Forced Labor Through Supply Chain Structures
Professor Gordon emphasized that forced labor should not be viewed solely as individual misconduct, but as a structural outcome embedded in global supply chains. In the seafood industry, the U.S. market is highly concentrated among a small number of large retailers, whose pricing pressure is transmitted downstream to brand companies,
processors, and intermediaries, and ultimately borne by fishing vessels and workers. As profit margins shrink, cutting labor costs becomes the most immediate response, increasing the risk of forced labor.
Labor Supply Chains, Recruitment Debt, and Structural Risks
Beyond product supply chains, Professor Gordon highlighted the often overlooked “labor supply chains,” through which recruitment costs and risks are shifted onto migrant workers via multiple layers of brokers. Heavy recruitment-related debt, combined with employer-tied visa systems, weaker labor protections, and limited grievance mechanisms in distant-water fisheries, significantly heightens forced labor risks.
U.S. Import Bans and Implications for Export-Oriented Economies
Professor Gordon explained that U.S. forced labor import bans are enforced under Section 307 of the U.S. Tariff Act through CBP’s Withhold Release Orders, which allow goods to be barred based on “reasonable suspicion.” Although the U.S. has been cautious in imposing mandatory human rights due diligence on domestic firms, it remains one of the most active jurisdictions globally in enforcing import bans on forced labor grounds. This asymmetry poses significant challenges for export-oriented economies.
For export-dependent economies such as Taiwan, reducing forced labor risk is therefore not only a human rights issue but also a strategic trade imperative. The Giant case demonstrates how forced labor allegations can swiftly translate into concrete trade consequences, highlighting the importance of stronger labor protections and supply chain transparency.
Supply Chain–Wide Responses and the Role of Workers
Professor Gordon concluded that effective responses must address the entire supply chain. Retailers and brands should take responsibility for procurement practices, governments and enterprises must reform recruitment systems, and workers should be empowered to organize and participate in remediation mechanisms, particularly in export-dependent economies such as Taiwan.
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