U.S. Transshipment Tariff: A Challenge for Vietnamese Firms and an Opportunity for Japanese FDI Enterprises in Vietnam

Transshipment and origin fraud have become major concerns in U.S.–Vietnam trade, especially after the U.S.–China trade war intensified.

15Jul2025

B&Company

Latest News & Report / Vietnam Briefing

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B&Company is the first Japanese company specializing in market research and investment consulting in Vietnam since 2008.

In this section “Vietnam Briefing”, young researchers of B&Company will provide timely information of Vietnam’s industrial trends, consumer trends, and social movements.

This article is written in English and automatic translation is used for other language versions. Please refer to the English version for accurate content. Although we strive to ensure the accuracy of the original information, please check separately for each information. Interpretations and future prospects are the personal opinions of each researcher.

Transshipment and origin fraud have become major concerns in U.S.–Vietnam trade, especially after the U.S.–China trade war intensified. Higher U.S. tariffs on Chinese goods created a tariff gap that encouraged circumvention via Vietnam. The new U.S. tariff policy—particularly the punitive rates on transshipped goods—signals a turning point, pushing Vietnamese firms to reevaluate and restructure their supply chains.

Detected Fraudulent Practices

The United States has initiated the highest number of trade defense investigations against Vietnamese exports, with 64 cases recorded as of 2024. Notably, anti-circumvention investigations are increasingly prevalent. Common fraudulent tactics include:

– Establishing superficial production lines in Vietnam, conducting only basic assembly or minor processing that does not meet the criteria for substantial transformation.

– Importing semi-finished products and performing only final-stage assembly.

– Importing fully finished Chinese products and relabeling them as “Made in Vietnam” for export.

A notable example occurred in 2020, when customs authorities uncovered widespread origin fraud. In inspections covering bicycles (4 companies), solar panels (5), and wooden furniture (12), 100% were found in violation. These firms primarily imported components or semi-finished goods and conducted only minimal processing, which did not alter the essential character of the products, thus disqualifying them from Vietnamese origin status.

Evolution of US Tariff Policy on Vietnamese Goods (April–July 2025)

The US–Vietnam Trade Agreement, announced on July 2, 2025, concluded the negotiation phase by formalizing a 20% general tariff on most Vietnamese goods and implementing a 40% punitive transshipment tariff. This policy shift marks a transition from initial pressure measures to a more structured approach focused on combating origin fraud while sustaining diplomatic cooperation.

Progress of the US tariff on Vietnamese goods

Date Policy Action Tariff on Vietnamese Goods Tariff on Transshipped Goods Rationale
April 2, 2025 Tariff Announcement Threat of 46% retaliatory tariff Not specified, but circumvention cited as key issue To address large trade deficits and perceived unfair practices
Apr 9 – Jul 9, 2025 90-Day Negotiation Suspension Reduced to the base rate of 10% Not specified To facilitate bilateral trade negotiations, including circumvention concerns
July 2, 2025 US–Vietnam Trade Agreement General tariff of 20% on most goods Tariff of 40% Bilateral agreement outcome aimed at curbing circumvention via Vietnam

Source: B&Company compilation

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