The Long Cycle Notes
How do you prove Vietnam origin so goods aren't treated as Chinese transshipment?
A Certificate of Origin alone does not prove it. U.S. and EU customs decide origin themselves, and goods count as Vietnamese only if they are made, or substantially transformed, in Vietnam. What holds up is a production trail: a bill of materials showing where each part comes from, records of forming, firing or assembly in Vietnam, matching purchase and payment records, and a Certificate of Origin from Vietnam's Ministry of Industry and Trade on every shipment.
Why buyers are asking this now
Moving an item from China to Vietnam only changes its duty if the item is genuinely made in Vietnam. Customs authorities on both sides of the Atlantic know that some goods are not, and they have spent the last two years acting on it.
- U.S. enforcement. CBP has published evasion findings under the Enforce and Protect Act (EAPA) against Chinese goods routed through Vietnam, in categories from wooden cabinets and vanities to hardwood plywood. Its regulations name transshipment as a textbook example of evasion.
- Shifting U.S. duty rules. The 40% duty on transshipped goods that the U.S. announced in July 2025 was part of the reciprocal tariffs imposed under IEEPA. In February 2026 the Supreme Court held that IEEPA does not authorize tariffs, and those duties were terminated. The origin rules below never depended on IEEPA, and they still apply.
- Vietnam tightened its own paperwork. Since 5 May 2025, Vietnam's Ministry of Industry and Trade has been the single body issuing non-preferential Certificates of Origin, after it withdrew that authority from the Vietnam Chamber of Commerce and Industry to curb origin fraud.
- EU duties on Chinese ceramics. With a 79% anti-dumping duty on Chinese ceramic tableware, the incentive to disguise origin is high, and so is EU scrutiny. See what the EU duty means for buyers.
The result: buyers are being asked to prove origin, not just declare it.
What customs looks at, and what actually proves Vietnam origin
In the U.S., the country of origin is where an article is manufactured or grown; work done in another country must cause a substantial transformation to change it. In the EU, goods made in two or more countries take the origin of the last substantial, economically justified processing, and processing done mainly to avoid duties does not count. Neither system treats a certificate as the final word.
| What customs asks | Evidence that holds up | Red flags |
|---|---|---|
| Where was the product made? | Production records and dated photos or video of forming, firing, molding or assembly at a named Vietnam site | A supplier that cannot show the line, only finished goods |
| Where did the materials and parts come from? | A bill of materials with the origin of each component, and purchase records that match it | Finished or near-finished goods bought from China |
| Was the work in Vietnam substantial? | The Vietnam process turns inputs into a new article: clay into fired ware, glass batch into vessels, parts into a working appliance | Only packing, labeling, cleaning or simple assembly done in Vietnam |
| Can the site actually make this volume? | Capacity, equipment and staffing that fit the order; an audit or inspection report | Output far above what the floor could produce |
| Do the documents agree? | Invoices, payments, packing lists and shipping records that match the factory and the goods | Payments to a third party, or contracts that allow transshipment |
| Is there an official origin document? | A Certificate of Origin from Vietnam's Ministry of Industry and Trade with every shipment | A certificate with no production trail behind it |
For products with mixed origin, such as a Vietnam-assembled item with some imported parts, the answer can differ by market and by item. Confirm it item by item, and ask your customs broker or counsel whether a binding ruling is worth requesting before volume moves.
What we see on the factory floor
When tariffs first hit our categories, a lot of companies rushed into Vietnam. By the time we were back on the ground in early 2026, the market was already settling: some players were pulling out, and the ones staying were those with real manufacturing strength, management and delivery discipline. That shake-out is the clearest origin test there is. A relabeling operation has nothing to stay for.
We started our Vietnam ceramic supply chain in 2024, before tariffs on our categories were more than a rumor, and the work looked nothing like paperwork. It was factory development, technical transfer and trial after trial, until stoneware dinnerware held retail standard on a Vietnam line. Silicone kitchenware meant working through food-grade materials, factory audits and new molds in Vietnam. Supply chains don't move. They get built. Goods that were built that way have a production trail by default.
The harder cases are mixed builds. For electric aroma diffusers, we moved plastic injection, plug assembly, printing, packaging and final assembly to a Vietnam partner, while decorative ceramic and glass parts that Vietnam could not yet make to standard still came from China. Because that product combines two origins, we never assume the answer. Origin is confirmed item by item before shipment, against the destination market's rules.
Vietnam's capability changes fast. A product that was not possible last quarter can be ready next quarter because a machine arrived or a supporting supplier moved in. So we keep visiting, and we keep sorting factories into three groups: ready, almost ready, and still only telling a good story. Only the first group ships under a Vietnam origin.
Our position is simple. We do not transship. What we ship from Vietnam is made in Vietnam, and every shipment travels with a Certificate of Origin. When an item moves to Vietnam, we move the making of it, not just the paperwork. We don't own the factories; as a sourcing and product development company, qualifying partner factories and keeping that trail intact is the job.
What to check before you place the order
- See the line, not just the sample. Ask for production photos or video of the item on the Vietnam line, or visit. A sample proves the design; only the line proves the origin.
- Get the bill of materials with origins. List every component and where it comes from. Flag any part sourced from China and ask what happens to it in Vietnam.
- Test the transformation. If the Vietnam work is only packing, labeling or light assembly, assume the goods keep their Chinese origin.
- Match capacity to volume. Check that the factory's equipment, staffing and audit reports fit the quantity you are ordering.
- Keep the documents consistent. Invoices, payments, packing lists and the Certificate of Origin should all point to the same supplier and the same goods.
- Ask for a Certificate of Origin on every shipment. Issued by Vietnam's Ministry of Industry and Trade, and backed by the records above.
- Put responsibility in the contract. State who carries the duty if an origin claim fails, and keep records for as long as your customs authority can audit the entry.
- Check the duty for your code. U.S. duty rules changed several times in 2025 and 2026. Confirm the classification and the rate in force at entry with your customs broker.
Sources (accessed 2026-10-12): 19 CFR 134.1(b), country of origin; 19 CFR 165.1, definition of evasion (EAPA); CBP, EAPA Case 7603 determination and EAPA actions archive; Supreme Court, Learning Resources, Inc. v. Trump (20 February 2026); Executive Order 14389, Ending Certain Tariff Actions; Executive Order 14326 (July 2025); European Commission, non-preferential origin (Article 60 UCC; Article 33 UCC-DA); Vietnam Ministry of Industry and Trade, non-preferential C/O issuance (Decision 1103/QĐ-BCT).
Moving an item to Vietnam? See when Vietnam is the right origin, the Vietnam aroma diffuser case study for a mixed-origin build, and our Vietnam ceramics capability, or start a conversation.
At a glance: MOQ, sampling and testing for ceramic dinnerware; MOQ, sampling and testing for candle vessels; HTS and CN codes for these products.
Frequently asked questions
Is a Vietnamese Certificate of Origin enough to prove Vietnam origin?
No. It is evidence, not a final ruling. U.S. Customs applies its own substantial-transformation test, and EU customs normally do not even ask for a non-preferential certificate. What settles origin is proof of where the product was actually made: materials, process records and production you can inspect.
Can a product with some Chinese parts still be made in Vietnam?
Sometimes. It depends on whether the work done in Vietnam substantially transforms those parts into a new article, and on the rules of the destination market. Simple packing, labeling or light assembly does not. We confirm origin item by item before shipment for any product that combines parts from two countries.
What happens if customs decides goods were transshipped?
The goods take their real origin and the duties that come with it. In the U.S., where antidumping or countervailing duties are evaded, CBP can open an EAPA investigation, require cash deposits and suspend liquidation. In the EU, processing done to avoid duties is not treated as conferring origin.
Does Jason Craft transship goods through Vietnam?
No. What we ship from Vietnam is made in Vietnam, and every shipment travels with a Certificate of Origin. When an item moves to Vietnam, we move the making of it, not just the paperwork.
Jeffrey Chen is the second-generation CEO of Jason Craft Corporation, a Taipei-based sourcing and product development company founded in 1981. More about Jeffrey · About Jason Craft.