Is the Vietnam 40 percent transshipment tariff still in effect for imported metal parts?

What did Executive Order 14326 say about transshipment?

Section 3 of the order said that an article customs determined had been transshipped to evade the reciprocal duties would pay a flat additional duty of 40 percent instead of the rate for its claimed country of origin, plus any other penalties and duties that applied. It also barred mitigation of those penalties, as far as the law allowed.

The order, signed July 31, 2025 and published in the Federal Register on August 6, 2025 (Executive Order 14326), reset the country rates first announced in April 2025 and added the transshipment clause on top. Three details in the text matter more than the headline number:

• It applied to every country. Nothing in section 3 names Vietnam. The clause reached any article routed through any trading partner to dodge the duty on its real origin.
• It needed a finding by customs. The higher rate attached only to an article that customs had determined was transshipped to evade duties. It was not an automatic surcharge on goods that contained foreign inputs.
• It stacked with existing law. The clause kept in place any fine or penalty under existing customs law, including the false-statement penalty statute, and any other duty owed on goods of the true origin.

Section 3 also told the Commerce and Homeland Security departments to publish, twice a year, a list of countries and facilities used in circumvention schemes. The order did not define “transshipped” beyond that. The definition an importer actually faces still comes from the long-standing country-of-origin rules covered further down this page.

The Vietnam angle came later. A joint statement released on October 26, 2025 (United States–Viet Nam framework) said the United States would keep the reciprocal rate on originating goods of Vietnam at 20 percent under the April 2025 order as amended. That is where the pairing of “20 for Vietnamese goods, 40 for transshipped goods” in so many headlines comes from.

What duty applies to Vietnamese-origin metal parts now?

Per the USTR Section 301 notice published July 28, 2026, products of Vietnam carry a Section 301 duty, alongside the normal column 1 duty on the part’s tariff line. Metal parts that fall under the Section 232 steel, aluminum or copper actions follow those rules instead, whatever their origin.

The notice itself (USTR, Section 301 forced-labor investigations) sets 12.5 percent for Vietnam, and the same notice sets a duty for China as well. Parts of Chinese origin also still carry the older Section 301 duties from the 2018–2019 lists, which is why origin keeps its value even with the reciprocal regime gone. The site’s tariffs and origin page sets out the stacking in more detail, including where Section 232 cancels most of the difference between the two origins.

For a sourcing decision, the useful takeaway is that the gap between a Vietnamese-origin part and a Chinese-origin part now comes from Section 301 history and the column 1 rate, not from the 2025 headline numbers. That gap is what a transshipment scheme tries to capture, and it is the gap customs protects.

What counts as minimal processing for castings and bar stock?

Processing is minimal when the imported input already has the essential shape and function of the finished part and the work in Vietnam only finishes, cleans, coats, tests or packs it. The question customs asks is whether the article that leaves the plant has a new name, character or use.

The regulation states the test in one line and leaves the detail to case-by-case rulings, which customs publishes at rulings.cbp.gov. Read rulings for your own part family before drawing conclusions, because small facts decide them. As general orientation for metal parts, the fact patterns tend to sort like this:

• Weak: a finished-shape casting imported, then trimmed and coated. If a casting arrives from abroad already at its final geometry and is only deburred, shot-blasted, painted or plated, the character of the part was set where it was cast. Surface work alone rarely changes the name or use.
• Weak: a machined part imported, then assembled or packed. Fastening two imported parts together, adding a label, or repacking into a Vietnamese carton describes the fact pattern the 2025 order was aimed at.
• Stronger: the part is cast where origin is claimed. When the melt is poured and the casting is formed in the same country, as with die casting from ingot, the shaping step itself happens there. Ingot is a raw material, not a part.
• Case by case: bar stock turned into a part. Generic round bar has no part-specific shape. Turning it into a component with its own design, as in CNC turning, is the kind of change the test looks for, but the answer still depends on how much of the final form and value is created by the machining.
• Case by case: an imported rough casting machined extensively. A blank cast abroad and then heavily machined sits between the two. Whether the machining creates the functional features, or only refines ones the casting already had, is usually the deciding fact.

None of these outcomes is guaranteed by the category. Two parts that look alike on a drawing can land on opposite sides of the line because of what the input looked like when it arrived.