May 7, 2025 - Though the tariff heading under the Customs Import Tariff has not been changed as referred to in the preceding sub-paragraph as a result of manufacturing or processing operations, an important manufacturing process has been completed, or the ratio of added value has exceeded 35% percent. Notwithstanding the provisions of 1 and 2 above, the following operations are not considered to be "substantial transformation which confers a new character to the goods". (a) Operations necessary for the preservation of goods during the transportation or storage. (b) Sorting, grading, repackaging and packing operations of the goods for marketing or transportation. (c) Combination or mixing operations of goods which have not resulted in any important difference in the characteristics of the goods before such combination or mixing and after. ... (FOB value of exported goods - CIF value of direct and indirect imported raw materials and parts) ÷ FOB value of imported goods = Ratio of added value ·

July 31, 2025 - Our daily publication covering trade and customs news in the U.S. and worldwide.

February 3, 2026 - Importers should avoid over-reliance ... the agency responsible for implementing and enforcing tariffs. IV. The Hidden Provision: 40% Transshipment Penalty Tariff with No Mitigation...

September 5, 2025 - Ironically, the transshipment tariff might help Beijing. Pending ongoing trade negotiations, tariffs on China will stay below the rate for transshipments. This means that US importers may find it cheaper to buy directly from China, rather than risk high premiums on Vietnamese goods.

August 21, 2025 - Under the new policy, the U.S. Customs and Border Protection (CBP) imposes an additional, non-negotiable 40% tariff on goods identified as transshipped, i.e., goods routed through intermediary countries to evade higher duties.

August 14, 2025 - If it actually has significant content — like 30% — from any other country, then it should be taxed at that other country’s tariff.” · Implied in Lutnick’s soundbite was the notion that transshipment – the most common form of tariff evasion – has so far gone unaddressed, a premise U.S.

August 26, 2025 - President Donald Trump is pondering an executive order to define the percentage of content from high-tariff countries in imported goods that would trigger his recently announced 40% ‘transshipment’ tariffs, three sources familiar with the matter said.

August 7, 2025 - "Currently, all exported goods (from Thailand) are subject to a 19% rate because there are no rules on transshipment yet," Arada Fuangtong, head of the Thai Commerce Ministry's foreign trade department, told Reuters on Thursday. Her message was echoed by U.S. officials in Vietnam who told businessmen the tariff of 20% would apply to Vietnamese goods, even if they are entirely made with Chinese components and only assembled in Vietnam, according to one person familiar with those talks.

August 25, 2025 - On July 31, President Trump issued an Executive Order, “Further Modifying the Reciprocal Tariff Rates,” which established a 10% near-worldwide baseline tariff rate and certain higher country-specific tariff rates.[17] Notably, the Executive Order introduced a new category of “transshipment” tariffs.

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July 9, 2025 - Using the recent trade agreement ... Chinese content may be reclassified as “transshipped” and taxed at the higher tariff – in this case, at a 40% tariff....

The United States has recently formalized a trade agreement with Vietnam that introduces a 40% tariff on goods transshipped via Vietnam, targeting products rerouted from other countries to avoid existing US trade barriers. In exchange, a 20% tariff (substantially reduced from the tariff announced ...

September 23, 2025 - Section 3 of Executive Order 14326, Further Modifying the Reciprocal Tariff Rates, July 31, 2025, provides that an article determined by CBP to have been transshipped to evade applicable duties “shall be subject to an additional ad valorem rate of duty of 40 percent, in place of the additional IEEPA reciprocal ad valorem duty rate and (ii) any other applicable or appropriate fine or penalty, including those assessed under 19 U.S.C.

August 17, 2025 - Shipments that are loaded onto a vessel at the port of loading before August 7th, and that remain on that same vessel until U.S. entry before October 5, 2025, will bear the pre-existing 10% reciprocal tariff.

February 7, 2025 - Transshipment of a specific product through a third party is defined using the following four criteria: i. There is a 301 tariff on the product.

August 15, 2025 - Transshipment typically keeps the ... between different modes. When Customs deems that suspicious, they tack on a 40% surcharge on top of base tariffs (that’s in addition to any applicable duties), with no appeals, no ...

Through transportation means continuous transportation between origin and destination, for which a through rate is assessed and which is offered or performed by one or more carriers, at least one of which is a common carrier, between a United States port or point and a foreign port or point. Time/volume rate means a rate published in a tariff which is conditioned upon receipt of a specified aggregate volume of cargo or aggregate freight revenue over a specified period of time. Trade name means a name used for conducting business, but which is not necessarily its legal name. This is also known

July 31, 2025 - 1592, and (iii) any other United States duties, fees, taxes, exactions, or charges applicable to goods of the country of origin. CBP shall not allow, consistent with applicable law, for mitigation or remission of the penalties assessed on imports ...

November 12, 2025 - As a Pittsburgh Post-Gazette article on Christmas lights (those made in China now subject to 25% tariffs) explains, “Chinese suppliers are finding ways to ditch the ‘Made in China’ label to evade penalties, using neighboring countries like Vietnam to transport goods across borders, relabel them and ship them to the U.S.”. However, as both our experience with Univar and the Post-Gazette article make clear, the illegal transshipment of goods is an exceedingly risky endeavor.

President Trump’s July 2025 notifications to Southeast Asian partners introduced a new transshipment-based tariff framework. Even goods that traditionally meet rules of origin requirements could face higher tariffs if they contain a threshold level of Chinese content.