Vietnam in Tier 2: US origin checks move from paper to data

The White House Office of Trade and Manufacturing Policy published "The Great Transshipment Scam: Rise, Scope, and Costs" on 13 August, sorting more than 40 countries and territories into three tiers of transshipment risk. Vietnam sits in Tier 2 alongside Brazil, Indonesia, Malaysia, Thailand and Türkiye. Hanoi answered on 20 August, with the foreign ministry saying Vietnam is determined to stop origin fraud and illegal transshipment. The report carries no penalties. What it does carry is a preview of how US agencies intend to test Vietnamese cargo from here: against supply-chain data, not just a certificate of origin.

The report describes a shadow transshipment network spanning more than 40 economies, each playing a role somewhere along the chain: manufacturing, processing, finishing, logistics, bonded warehousing, free-trade zones, transshipment ports and re-export. The three tiers are drawn on economic scale, depth of integration with Chinese supply chains, and whatever specific advantage a market offers.

Tier 2 is defined as economies with the manufacturing base, port infrastructure, supplier networks and logistics capacity to handle serious volumes of China-linked goods. Estimates of the money involved vary widely by who is counting: the US Commerce Department's Office of Trade and Economic Analysis puts it near $109 billion, while Altana, a US data firm, reaches as high as $303 billion. Being tiered is not a finding that any given shipment breached origin rules. Goods that are found to have been illegally transshipped, however, can face an additional 40% duty on top of other penalties.

The whole practice runs on a tariff gap. The report argues that exporters in high-tariff jurisdictions exploit that spread by routing cargo through a third country, and the overall US tariff burden on Vietnamese goods still sits well below what Chinese goods pay. Under Section 301 itself, Vietnam landed in the 12.5% band from 24 July.

Foreign ministry spokesperson Pham Thu Hang told the regular briefing on the afternoon of 20 August that Vietnam is building out its legal framework and enforcement capacity against origin fraud, is determined to block illegal transshipment, and will keep talking to Washington in a constructive spirit consistent with the comprehensive strategic partnership between the two countries.

The plumbing was already being laid before that statement. Vietnam Customs and US Customs have signed a memorandum on exchanging electronic declaration data, so both sides can reconcile shipment records and flag origin fraud or trade-remedy evasion early. For shippers the implication is blunt: the export declaration you file in Vietnam and the entry filed on arrival in the US now have to tell the same story.

The report splits the network in two, and each half gets examined differently. The first is manufacturing and processing sites, where Chinese goods and components go through light assembly, finishing, testing, packing or labelling before shipping to the US. For these, US agencies look at plant capability, machinery, labour, input sourcing, value added and the production process itself to decide whether substantial transformation actually occurred.

The second is logistics hubs: rerouting, bonded warehousing, re-export, reinvoicing, swapped documents or relabelling with no meaningful production behind it. Here the examination lands squarely on the file a forwarder handles every day. Routing, the bill of lading, dwell time, the relationships between parties to the transaction, bonded warehouse records, invoices and origin documents.

The enforcement machinery is already visible. Executive Order 14411 tightens the rules on who may act as importer of record in the US, adding bonding and asset requirements, disclosure of ownership and business affiliations, good-standing conditions and data transparency. Alongside it, Washington is building an AI-driven investigative border that ingests trade, customs, shipping, tariff-code, product-composition and production-capacity data to test declarations against the physical route a consignment took. Where the two diverge, the consequences run past back duties to inspection, cargo holds, sanctions, penalty duties and, at the far end, exclusion from the US market.

The phrase "China-linked goods" is drawn broadly in the report. Chinese inputs or components, ownership or financing ties to a Chinese producer, a single processing step or a shipping history with a Chinese leg are all enough to put a product in scope. Which reframes what your paperwork is for: a certificate of origin states that goods are Vietnamese, while the production file explains why that statement holds.

A certificate of origin states that goods are Vietnamese. The production file explains why that statement holds.

The report ties Vietnam, Thailand, Malaysia and Indonesia to manufacturing networks closely bound to China, naming electronics, machinery, plastics, footwear, garments and components. That list maps almost exactly onto what Vietnam sells hardest into the US. Vietnam's trade office in the US identifies the country's competitive strengths as electronics, machinery, textiles and garments, footwear, wood products, seafood, agricultural produce and consumer goods.

Electronics and machinery are the hardest cases, because a substantial transformation call turns on plant capability, input sourcing and value added, which are precisely the things the report says US agencies will open up and inspect. Textiles and footwear are exposed at the raw-material end, so consumption norms and batch-level production data need to already sit in the file rather than be assembled once a question lands. Wood products know this drill, as the US final determination on Vietnamese plywood showed.

The real exposure from a tier listing is not a new tariff line, it is conflation. Plenty of genuine Vietnamese manufacturing runs on Chinese inputs sourced through regional supply chains, so if actual production is not examined properly, legitimate factories get swept in with pass-through trade. The report also refers to a "Ho Chi Minh City corridor", which is offered as an illustration of regional transshipment risk rather than a finding against any named company or plant.

The US remains Vietnam's largest export market, taking $104.7 billion in the first seven months of 2026, up 23% year on year, against $153.1 billion for all of 2025. That growth curve is itself what draws scrutiny to origin files. Exporters are being advised to build the file shipment by shipment from the outset, rather than assembling it after cargo is already on hold.

• Map the supply chain for each US-bound product line: where inputs and components originate, who supplies them, and which operations happen in Vietnam.
• Keep invoices, import declarations for raw materials, consumption norms and batch production records, each traceable to the bill of lading of the matching export.
• Reconcile the calendar: input arrival, production and stuffing dates must leave room for the work the factory claims to have performed.
• Review the transport file US authorities will open first: routing, bills of lading, bonded warehouse dwell time, and the relationships between parties to the transaction.
• If you sell DDP into the US, re-check your importer-of-record arrangement against the tightened requirements under EO 14411 before signing the next order.

Homexim handles documentation and customs clearance on US lanes, including the origin-file review that happens before a declaration is filed and the work of tying raw-material import entries back to the finished export. To find out whether your current file would survive a data-led verification, send the HS codes you declare, your imported input list and the routing.