Tariffs & country of origin · Vietnam vs China · September 2026
What a Vietnam-made part actually costs to land in the US.
Most Vietnam supplier websites still advertise "avoid the 25% Section 301 tariff" — a rule that stopped applying on July 24, 2026. This page uses the regime in effect as of September 2026, with the arithmetic shown, not just the headline.
Read this before you use any number on this page
Figures are current as of September 2026. Tariff classification is the importer's responsibility, not the supplier's. Everything below is a starting point, not legal or customs advice. Confirm it against your own HTS classification with your customs broker before you rely on it for a landed-cost decision.
01 — What changed in 2026
Four steps from a Supreme Court ruling to today's rate.
The 25% Section 301 tariff you may still see quoted on Vietnam supplier sites left the picture in February 2026. What replaced it changed twice more before the regime now in force took hold on July 24, 2026.
| When | What changed |
|---|---|
| Feb 2026 | The US Supreme Court rules 6–3 that IEEPA tariffs exceeded presidential authority. Those tariffs are struck down. |
| Feb 2026 | Replaced by a 10% across-the-board tariff under Section 122 of the Trade Act of 1974 — capped by statute at 150 days. |
| Jul 24, 2026 | The Section 122 tariff expires on schedule. |
| Jul 24, 2026 | New Section 301 "forced labor" duties take effect across roughly 60 economies, in two tiers: 10% where USTR found partial steps taken, 12.5% where it found none. |
Sources: Honigman, on the Section 122 expiry and the new Section 301 tiers · Congressional Research Service, on the IEEPA court decisions.
02 — Section 301, current
Vietnam and China are no longer taxed the same way.
Vietnam carries no legacy Section 301 exposure — only the new forced-labor tier. China carries both. Most-favored-nation duty on machined parts and castings typically runs 2–6% and stacks on top of either.
| Origin | Legacy 301 | New 301 | MFN (typical) | Rough total |
|---|---|---|---|---|
| Vietnam | — | 12.5% | 2–6% | ~15–19% |
| China | 25% | 12.5% | 2–6% | ~40–44% |
A rough 25-percentage-point gap, Vietnam over China — before Section 232 metals duties are considered. See below.
03 — The Section 232 trap
Metals duties don't care where the part was made.
This is the part almost every Vietnam supplier's tariff page leaves out. Section 232 duties on steel, aluminum and copper are assessed regardless of country of origin — Vietnam gets no relief from them at all.
The rates
Articles made primarily of steel, aluminum or copper: 50%. Listed derivative articles — pipe and tube fittings, fasteners, closures and similar parts, across HTS chapters 73, 81–85 and 87: 25%.
How it's assessed
From 2026, these duties are assessed on the full customs value of the part, not only the metal-content portion as before. Goods subject to Section 232 are exempt from the new Section 301 duty — Section 232 replaces it there, rather than stacking with it.
The consequence, stated plainly
Vietnam keeps roughly the full 25-point advantage shown above for part families not caught by Section 232 — zinc die castings, many aluminum parts, assemblies. For steel pipe fittings, brass ball valves and copper parts on the Section 232 lists, that advantage shrinks sharply. Both origins pay the same metals duty.
A blanket "Vietnam saves you 25%" is not true, and we will not say it. Landed cost has to be computed per part, against its specific HTS code.
| Part family | Examples | What applies |
|---|---|---|
| Not on the Section 232 lists | Zinc die castings, many aluminum parts, assemblies | Section 301 + MFN only. Vietnam keeps roughly the full ~25-point advantage above. |
| On the Section 232 lists | Steel pipe fittings, brass ball valves, copper parts — HTS chapters 73, 81, 82, 83, 84, 85, 87 | Section 232 duty (50% articles / 25% listed derivatives) on full customs value — same rate for both origins, and exempt from the new Section 301 duty. Vietnam's advantage shrinks sharply. |
04 — Country of origin, and the 40% cliff
Transshipment isn't a paperwork risk. It's a cliff.
CBP's transshipment penalty is 40%, filed under HTS code 9903.02.01, with no mitigation and no remission. CBP treats it as customs fraud, not a compliance slip.
The legal test
Origin isn't decided by where a part was assembled or packed. The test is substantial transformation under 19 CFR 134.1(b): the process performed here has to produce a new name, character or use. Assembly or relabeling of Chinese components does not qualify.
What CBP has treated as insufficient
Finishing a Chinese casting or blank with only a paint booth pass, or only a screw-together step, is the weakest possible fact pattern. CBP has treated that kind of last-step work as insufficient on its own.
The certificate isn't the whole answer
Certificate of Origin Form B is now issued solely by Vietnam's Ministry of Industry and Trade. VCCI lost its issuing authority on April 21, 2025. CBP still evaluates the underlying manufacturing process against the substantial-transformation test, regardless of what the certificate says.
A binding ruling can be requested from US Customs, free of charge, and rulings are searchable at rulings.cbp.gov. Very few Vietnamese suppliers do this. That's exactly why we offer it — see below.
05 — What we do about it
Five process commitments. Not certifications.
We can't certify an origin outcome — only CBP decides that. What we can do is build the paper trail that makes your case, and be candid about where the raw material actually comes from.
06 — Get your own numbers
Send a part number. Get a comparison, not a slogan.
Send us a part number, a drawing, and what you're paying today in landed cost. We'll return a per-part comparison built against your specific HTS classification — Vietnam versus your current origin, Section 301, Section 232 and MFN included.
What you get back
A written note showing which duties apply to your part's HTS code at each origin, and the resulting landed-cost range. We'll flag anywhere the numbers are uncertain enough that you should confirm with your own broker before deciding.
07 — Before you send a drawing
Questions every buyer asks first.
Short, direct answers. None of this replaces your own customs broker.
Does a Vietnam-made part definitely save me money?
Not automatically. Section 301 favors Vietnam by roughly 25 percentage points over China today, but Section 232 metals duties apply at the same rate regardless of origin. If your part is a steel, aluminum or copper article on the Section 232 lists, that advantage shrinks sharply. The only way to know is to run your specific HTS code against both origins — which is what we offer to do, not guarantee.
If my part's origin claim is challenged, who is liable?
Tariff classification and origin claims are the importer of record's responsibility under US customs law. That responsibility does not transfer to us by virtue of a quote or a Certificate of Origin. We build a material traceability file and a written process routing for every part number so you have the evidence. The compliance decision, and the liability, sit with you.
How long does a CBP binding ruling take?
CBP does not publish a guaranteed turnaround for a rulings.cbp.gov request, and filing is free. Because timing isn't guaranteed, we recommend filing early in your qualification process rather than after tooling is committed. We'll prepare that filing for your highest-exposure parts on request.
Does buying Chinese raw material break Vietnam origin?
Not automatically. Origin turns on substantial transformation under 19 CFR 134.1(b): whether the process performed here produces a new name, character or use. It does not turn on where the raw material was purchased. Assembly or relabeling of a Chinese casting or blank does not qualify. Neither does finishing one with only a paint pass or a screw-together step. That's why we document both the material source and the transformation, part by part.
Can you quote DDP?
Yes — we quote FOB Ho Chi Minh City or DDP to your dock. Under DDP we handle the customs process and duty payment at your dock. The classification and origin facts on this page still apply, and they're still worth confirming with your own broker.
Send one drawing. Get the real number.
STEP or PDF, one part or a whole family. You get a landed-cost comparison built on your own HTS classification — not a headline tariff rate — within two business days.