2025 China Tariffs: Vietnam Pact Triggers New Era of Transshipment Crackdowns
On July 2, 2025 (today), President Trump announced a new trade pact with Vietnam that sends a bold message. It is targeting any country—Vietnam included—that integrates Chinese components into its supply chain, however marginally. This development aligns with the broader trends we've been describing in U.S.-China trade relations.
The agreement imposes a 20 percent base tariff on Vietnamese imports. Goods deemed "transshipped"—those incorporating Chinese-origin content routed through Vietnam—face a 40 percent tariff. These tariffs represent more than tactical trade measures. They're designed to restructure global manufacturing by reducing China's embedded role in supply chains
As the enforcement of the 2025 China tariffs expands, companies should act now. This new regime rewards those who understand how to mitigate transshipment exposure, manage IP risks, and plan their manufacturing transitions. Everyone else risks being caught flat-footed.
Don't Rush for the China Exit
The urgency to exit China is understandable—but rushing out can backfire.
We've seen companies move their manufacturing out of China prematurely, only to encounter IP theft, supplier retaliation, and severe operational breakdowns. In many cases, these costs far exceed the tariffs they were trying to avoid. To avoid this, see: Moving Your Manufacturing Out of China: Do You Really Own Your Product?
How Much Chinese Content Triggers Tariffs?
One of the most pressing questions now is: How much Chinese content makes a product "Chinese" in the eyes of U.S. Customs?
The Vietnam agreement doesn't set a formal threshold. Trade analysts expect the U.S. government to apply a near-zero tolerance standard—possibly flagging goods with as little as 1 percent Chinese-origin content. While trade agreements typically define origin by value-added or transformation tests, no codified origin thresholds have yet been announced for this deal.
This means a single Chinese-sourced chip, zipper, or motor could trigger the 40 percent transshipment tariff on your entire product.
Although the tariff structure is numerically clear—20 percent base for Vietnamese goods, 40 percent for transshipped goods—enforcement remains opaque. There are:
- No formal rules of origin
- No published safe harbors
- No clear materiality thresholds
That's why traceability, compliance, and legal preparedness are no longer optional. Ditto for the need to do whatever you can to legally reduce your tariffs. For a comprehensive look at what you can and should be doing to reduce your tariffs, check out THE Guide for LEGALLY Avoiding Today's and Tomorrow's U.S. Tariffs.
Tariff Engineering: A Legal Necessity for a New Trade Era
To stay competitive, companies must reexamine how they source, label, and ship products. This is the heart of tariff engineering—adapting operations to reduce duty exposure without violating transshipment rules.
Here are the five most common strategies our clients are contemplating or adopting:
1. Split Shipments
Ship Chinese components separately from Vietnamese-assembled goods. The Vietnamese portion may enter at 20 percent, while Chinese components are handled under different tariff lines, then assembled post-import.
2. Final Assembly in the U.S. or Mexico
Bringing final assembly to the U.S. or Mexico (under USMCA) can reset origin and reduce tariff exposure—especially for high-margin or modular products.
3. Use of Foreign Trade Zones (FTZs)
FTZs enable companies to defer entry, reclassify goods during storage or processing, and potentially change their tariff treatment.
4. Component Substitution
Swapping Chinese components with alternatives from India, Eastern Europe, Latin America, or Taiwan could avoid the transshipment tariff. Even replacing a few key components might be enough to shift origin status.
5. True Substantial Transformation
Some companies send Chinese goods to third countries for further processing. This only works if the transformation is legally significant under U.S. rules. Minor assembly or packaging is insufficient. The new Vietnam tariffs suggest that even substantial transformations may no longer protect against penalties if any Chinese content is present.
Understanding these tariff engineering strategies is crucial, but equally important is knowing where to relocate operations. The choice of alternative manufacturing locations will largely determine your tariff exposure
Tariff Outlook: Manufacturing Alternatives to China in 2025
I have long cautioned clients against shifting production to places like Cambodia, where transshipment of Chinese goods is rampant and regulatory enforcement is weak—making them likely targets for China-mirroring tariffs. I am convinced that China's tariffs will be Cambodia's tariffs (plus or minus a few percentage points) for many years to come.
In contrast, the governments in countries like Vietnam, Thailand, and Mexico are working to try to curtail illegal transshipping to avoid U.S. penalties. I strongly suspect this is what enabled Vietnam to secure today's deal and also makes me think that these other countries will reach similar or better trade agreements with the United States.
Here's how I see tariffs evolving over the next several months across key manufacturing jurisdictions:
| Country | Expected Tariff | Transshipment Risk | Notes |
|---|---|---|---|
| Bangladesh | 10–15% | Moderate | Textile-heavy, China-reliant inputs |
| Brazil | 15–20% | Medium | Strengthening China ties |
| Cambodia | 25–50%+ | Incredibly High | Major transshipment concern |
| China | 25–55%+ | Incredibly High | Primary decoupling target |
| Colombia | 5–10% | Low | Small volume, low risk (for now) |
| Guatemala | 5–10% | Low | Apparel nearshoring, rising China inputs |
| India | 5–15% | Low | Strategic ally with growing capacity |
| Indonesia | 20–40% | Moderate–High | Complex supply chains |
| Kenya | 5–10% | Low | Early-stage but clean sourcing |
| Malaysia | 20–40% | Moderate | High-tech sector under scrutiny |
| Mexico | 10–15% | Moderate | USMCA-compliant, but components flagged |
| Peru | 10–15% | Low | Light industrial footprint, low China integration |
| Thailand | 20–40% | Moderate | Automotive and electronics |
| Turkey | 10–20% | Medium | Geopolitical complexity |
| Vietnam | 20–40% | Very High | New enforcement model |
Choosing where to move your manufacturing is as much a legal decision as an operational one.
These operational strategies must be grounded in sound legal analysis. Why? The wrong supplier, a misclassified component, or improper documentation can trigger penalties that wipe out entire margins.
This isn't about optimizing your bill of materials anymore. It's about protecting your entire business model.
We've Been Warning About This for Years
Back in October 2018, in China, the United States and the New Normal, I warned of a coming rupture between China and the West and urged companies to start reducing their China exposure.
In April 2019, the Wall Street Journal quoted me in Trade Deal Alone Won't Fix Strained U.S.-China Business Relations:
"There is no way any deal between China and the U.S. will cause everyone on both sides to say, 'We were just kidding.' The tariffs and the arrests and the threats and the heightened risk have impacted companies and that will not go away."
Then on May 4, 2019, I wrote The US-China Trade War: Winter is Coming forecasting that decoupling had begun in earnest and wouldn't reverse.
That winter has now fully arrived—and it's expanding beyond China.
Your Next Steps: Building Tariff-Resilient Operations
The Vietnam agreement signals a new phase of trade enforcement that will only intensify. Companies that act now to build transparent, traceable supply chains will have a significant competitive advantage.
If your business relies on cross-border manufacturing, now is the time to audit your supply chain and tariff risk. Our international trade lawyers can help you act before enforcement does.
President Trump's H-U-G-E Vietnam Tariff Deal Targets China's Shadow Supply Chains
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