Core conclusions:Vietnam Customs has carried out strict inspections of origin across the country and designated 18 categories of key monitored commodities. If a company fails to prove that local raw materials account for more than 30% and complete substantial processing, it may be judged to be origin fraud. In the first quarter of 2026, Vietnam's exports to the United States fell by 12.8% year-on-year, and categories such as plywood and textiles that are highly dependent on China's raw materials fell by more than 30%. The old path of relying on "OEM for origin" is being blocked.
1. What is Vietnam investigating this time?
In the past, it was common practice to ship semi-finished products to Vietnam, make simple packaging or light assembly, label them as "Made in Vietnam" and export them to the United States, in order to circumvent the high U.S. tariffs on China goods. What Vietnam Customs is currently focusing on is this kind of "entrepot trade."
There are two main verification standards:Does the proportion of local raw materials exceed 30%, andWhether substantial processing has been completed in Vietnam(Not just labeling, sub-packaging, and simple assembly). If the two clauses are not satisfied, it may be considered origin fraud.
Key monitoring covers 18 categories of commodities, includingPlywood, textilesThis category, which relies heavily on China raw materials, has been the most affected.
2. The triple impact on China factories
1. Tariff costs are rising again.Tariffs originally saved through Vietnam's re-entry will now be factored into costs, and the price advantage will be directly compressed.
2. The risk of goods in transit increases.Goods may be inspected, detained, or even returned after arriving at Vietnam ports, and the port fees and risk of breach of contract will fall on the factory.
3. Requirements for overseas buyers have become stricter.U.S. purchasers have begun to require a complete chain of certificate of origin and dare not purchase goods with questionable origin. Orders will flow to suppliers who can provide compliance documents.
3. Factory compliance self-inspection list
- Is the source of raw materials for the product traceable? Do you have the supplier's purchase certificate and material certificate?
- Can processing processes in Vietnam (or a third country) be identified as "substantial processing"? Are the process records complete?
- Is the application content of the certificate of origin (such as FORM E) consistent with the actual production situation?
- Are the name and quantity of the customs declaration, invoice, bill of lading, and packing list mutually verified?
- If it is randomly checked, can complete production and procurement ledgers be provided within a reasonable time?
As long as one of the above five items cannot be answered, it is recommended to suspend the shipment of that route first and make up for the data before leaving.
4. Four feasible response paths
Path 1: Return to compliance and direct exit.Be honest as the origin of China and use AI to directly develop U.S. terminal purchasers, eliminating intermediate links, and the profit margin may be greater.
Path 2: Optimize product and supply chain competitiveness.Build competitive advantages on quality, delivery dates, certification and service, rather than tax avoidance-advantages built by tax avoidance will return to zero when policy changes.
Path 3: Develop emerging markets.The demand for manufacturing in China in Southeast Asia, the Middle East, and Latin America is still growing rapidly, and the compliance threshold is relatively controllable.
Path 4: True localized layout.If you really want to set up a factory overseas, you must truly localize raw materials, processes, and personnel, rather than just setting up a packaging workshop.
5. Common questions
Q: I just sell the goods to a Vietnam customer, and he will export them to the United States himself. Is the risk on me?
A: If the downstream uses your goods to replace them with local origin, once they are inspected, the entire chain will be traced back. It is recommended to clearly stipulate the responsibility for declaration of origin in the contract and keep complete transaction certificates.
Q: How about local raw materials accounting for 30%?
A: The regional value component is usually calculated according to rules of origin. Different agreements and commodity categories have different calculation standards. It is recommended to follow specific rules of origin and customs identification, and do not estimate yourself.
Q: Without re-exports, is the American market still worth doing?
A: It's worth it, but it needs to change the style. withcustoms dataDirectly screening purchasers in the United States with true import records and using compliance documents to build trust is a slower but more stable path.
Data sources: Vietnam General Administration of Customs of China, Sichuan Province Department of Commerce, September 2026 Foreign Trade Industry Report
