No Taiwan fastener is on the US forced-labor list. Why your customers may still ask about 113,700 migrant workers
The US Labor Department lists one Taiwan product as made with forced labor, and it's fish. But the US import ban applies to any product, listed or not, the EU's ban will from December 2027, and Taiwan's metal products plants employ more migrant workers than any other manufacturing industry. Here's what Taiwan's rules say about their fees, pay and passports, and what a supplier check should cover.
The short version
- Taiwan's only entry on the US Department of Labor's 2024 list of goods made with child or forced labor is fish. No Taiwan manufactured good is on it.
- That doesn't settle anything for a fastener importer. US law bars goods made "wholly or in part" with forced labor from any country, and the EU's forced labour regulation will apply from December 14, 2027.
- At the end of August 2026, 113,700 migrant workers held permits in Taiwan's fabricated metal products industry, the industry fasteners belong to: 22% of all manufacturing migrant workers, and more than in any other manufacturing industry. About half are from Vietnam.
- Taiwan caps what Taiwan brokers can charge these workers and bans employers from holding their passports. It doesn't regulate what a recruiter in the worker's home country charges, which is where a supplier check needs to look.
When a customer's compliance team sends a forced-labor questionnaire, the first instinct with a Taiwan supplier is to check the lists. On the US Labor Department's list, Taiwan appears only for fish. But the laws behind those questionnaires don't depend on a list, and the workforce they tend to ask about, migrant workers recruited through brokers, is large in the industry fasteners come from. This note covers what the US and EU rules cover, how many migrant workers Taiwan's metal plants employ and on what pay, what Taiwan's own rules protect and leave open, and what to check at a supplier.
What the lists say, and what the law says
The US Department of Labor's List of Goods Produced by Child Labor or Forced Labor, last updated September 5, 2024, covers 204 goods from 82 countries and areas. Filtered for Taiwan, it returns one row: fish, forced labor.
The list informs; the ban doesn't depend on it. Section 307 of the Tariff Act (19 U.S.C. 1307) says goods "mined, produced, or manufactured wholly or in part in any foreign country by convict labor or/and forced labor or/and indentured labor under penal sanctions" aren't entitled to entry. It defines forced labor as work exacted under the menace of a penalty, for which the worker didn't volunteer. In the EU, Regulation (EU) 2024/3015 bars placing products made with forced labour on the EU market or exporting them (Article 3), and applies from December 14, 2027.
So the question your customer is really asking is not whether Taiwan is listed. It's whether forced labor was used anywhere in producing your goods, including the inputs and outside processing, under conditions that meet that definition.
How many migrant workers make Taiwan's metal products
That question is concrete for fasteners because of who staffs the plants. The Ministry of Labor publishes monthly counts of migrant workers by the industry their permits are for. At the end of August 2026:
| Industry (permits valid) | Migrant workers | Vietnam | Indonesia | Philippines | Thailand |
|---|---|---|---|---|---|
| Fabricated metal products | 113,700 | 59,425 | 25,277 | 15,571 | 13,426 |
| Electronic parts | 94,682 | 9,377 | 2,783 | 78,394 | 4,128 |
| Food products | 45,789 | 23,266 | 11,697 | 6,033 | 4,793 |
| Machinery | 42,435 | 23,427 | 7,610 | 7,719 | 3,676 |
| Basic metals | 19,242 | 5,253 | 5,157 | 3,063 | 5,769 |
| All manufacturing | 515,004 | 202,100 | 93,136 | 164,494 | 55,270 |
Rows don't add across because a few workers of other nationalities aren't shown. Fabricated metal products, which includes screws, nuts and rivets among much else, accounts for 22% of all manufacturing migrant workers. Vietnamese workers are 52% of them, against 39% across manufacturing.
The Ministry's 2025 employer survey, which covered June 2025, puts numbers on pay and hours. In fabricated metal products, migrant workers' regular monthly wage averaged NT$29,586, and with overtime NT$33,498. They worked 189.8 hours that month, 21.8 of them overtime. The legal minimum monthly wage in 2025 was NT$28,590. So the average regular wage sat about 3.5% above the minimum, and overtime made up most of the gap between the minimum and what workers earned. Those are averages; they don't tell you about any one plant.
What Taiwan's rules protect, and what they leave open
Numbers on pay don't show the risk forced-labor rules focus on, which is debt and control. Taiwan's rules address both, up to a point.
Broker fees in Taiwan are capped. Under the fee standard for private employment agencies (私立就業服務機構收費項目及金額標準, Article 6), a Taiwan broker serving a migrant worker in these jobs may charge the worker a monthly service fee of at most NT$1,800 in the first year, NT$1,700 in the second and NT$1,500 from the third, counted by the worker's cumulative time in Taiwan since that entry, and may not collect it in advance. A worker who returns to the same employer after two or more years of employment is capped at NT$1,500 from the start. Charging more than the standard is banned by the Employment Service Act (Article 40), and the fine is 10 to 20 times the excess (Article 66).
Employers can't hold documents. An employer may not unlawfully retain or take a migrant worker's passport, residence permit or property (Employment Service Act, Article 57(8)). The fine is NT$60,000 to NT$300,000 (Article 67), and the employer's recruitment and employment permits are to be revoked in whole or in part (Article 72).
Home-country fees are recorded, not capped. The fee standard governs employment agencies operating in Taiwan. What a recruiter in Vietnam or Indonesia charges before departure is set by the sending country. Taiwan does require a wage and expenses affidavit (外國人入國工作費用及工資切結書), and since an August 10, 2022 amendment it says the placement fee is set and verified by the sending country, and that the costs and loans for coming to Taiwan are verified by the sending country and confirmed by the worker. So the paperwork can show a debt. Our inference is that it shows what was declared at departure, not how the debt is being repaid or whether it is still owed.
A hypothetical shows why that matters. Suppose a worker borrowed the equivalent of four months' regular pay to cover recruitment costs at home, and sends most of the overtime pay home to service the loan. Debt like that can make it harder to refuse overtime or to leave. Whether it amounts to forced labor depends on the facts, but it is the kind of situation forced-labor rules ask about. We have no data on how common it is at Taiwan fastener plants, and we haven't seen a public source that measures it by industry.
What a supplier check should cover
A questionnaire returned by the supplier's office answers the list question. The definition question needs evidence from the plant. At least these:
- Documents: do workers hold their own passports and residence cards? Ask to see where they're kept, not just the policy.
- Pay: payslips for a sample of migrant workers, compared with time records, including overtime hours and what's deducted for housing and meals.
- Brokers: which Taiwan agency the plant uses, receipts for the monthly service fee, and the workers' wage and expenses affidavits, compared with what workers say they paid and borrowed.
- Recruitment at home: what workers paid before departure and whether they still owe it, asked in their own language, away from supervisors.
- Outside processors: the same questions for heat-treatment and plating shops, which may also employ migrant workers and are part of "wholly or in part".
None of this assumes a supplier is doing anything wrong. Most of what the list question can't tell you is simply unknown until someone asks. Back to the questionnaire on your desk: the absence of Taiwan fasteners from the US list is a fact worth stating, but the answer your customer needs comes from the workers on the line.
Need the plant visit done?
We visit the plant and its outside processors, see where passports and residence cards are kept, and compare payslips, time records and broker fee receipts. You get an English report of what we found and what we couldn't verify. We don't run social audits or issue certifications; interviews in workers' own languages need an interpreter or an auditor who speaks them.
Send a taskThis is a practical guide for buyers, not legal advice. Worker counts are people holding valid employment permits, by the industry on the permit; fabricated metal products covers far more than fasteners, and none of these figures describe individual plants.
Sources
- List of Goods Produced by Child Labor or Forced Labor, US Department of Labor, as of September 5, 2024, filtered for Taiwan, read October 13, 2026
- 19 U.S.C. 1307, convict-made goods; importation prohibited
- Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market, Articles 3 and 39
- Foreign workers in Taiwan by industry and nationality (引進移工在臺人數-按核配行業及國籍分), table 12-4, end of August 2026, Ministry of Labor
- Migrant worker management and employment survey, 2025 (移工管理及運用調查), wages, hours and days off by industry, Ministry of Labor, via data.gov.tw; and the Ministry's release on the survey, January 12, 2026
- Minimum Wage Council decision on the 2026 minimum wage, Ministry of Labor, which gives the 2025 rate of NT$28,590 a month
- Amendment of the wage and expenses affidavit for foreign workers (外國人入國工作費用及工資切結書), Ministry of Labor order of August 10, 2022, as published by the Tainan City Labor Affairs Bureau
- Standards for fees charged by private employment agencies (私立就業服務機構收費項目及金額標準), Article 6, amended April 6, 2017
- Employment Service Act (就業服務法), Articles 40, 46, 57, 66, 67 and 72, amended January 20, 2025