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Your importer needs an origin record before the shipment sails.

The origin documentation pack: the record a US importer's broker asks a Vietnamese supplier for, assembled from your bill of materials.

The rule, as the US states it

US importers now ask suppliers for signed, dated origin documentation.

The standard: non-preferential country of origin under 19 C.F.R. § 134.1(b)[1]; the test itself is quoted here as fixed reviewed text once the review is logged. The penalty: 40%[2] additional duty on goods US Customs determines were transshipped to evade duties, under HTS 9903.02.01[3], with no mitigation or remission. The timing: The documentation supporting an origin claim should exist before the shipment departs[4]. The enforcement: US Customs conducted inspections of factories in Vietnam in July 2026 examining value-added and origin[5]. The tariff base keeps changing. The rules in this memo live in configuration, so a change patches the memo; it does not rebuild it.

Verified against the sources listed on 2026-09-09

  1. [1] substantial_transformation_cite · verified 2026-09-09 · www.cosmosourcing.com/blog/vietnam-origin-compliance-transshipment-rules
  2. [2] transshipment_penalty · verified 2026-09-09 · www.cosmosourcing.com/blog/vietnam-origin-compliance-transshipment-rules
  3. [3] penalty_hts_line · verified 2026-09-09 · www.cosmosourcing.com/blog/vietnam-origin-compliance-transshipment-rules
  4. [4] documentation_timing · verified 2026-09-09 · www.cosmosourcing.com/blog/vietnam-origin-compliance-transshipment-rules
  5. [5] enforcement_context · verified 2026-09-09 · www.techtimes.com/articles/322039/20260729/cbp-raids-china-linked-vietnam-factories-over-transshipment-40-penalty-looms.htm

Reviewed text: pending the reviewer of record · Sources: pending registration

Who this pack is for

ForVietnamese factories and exporters whose US importer or broker has asked for origin documentation.
Not hereWhether your goods meet the origin standard is not decided here; the record organizes the facts for the importer's counsel or broker.

What the pack produces for this

Your BOM and your process steps in. A dated record and its attachments out.

  1. 01The country-of-origin documentation record: legal frame in fixed text, bill of materials by origin, processing performed in Vietnam, indicators for name, character and use stated without a conclusion, a value-added support table presented as supporting evidence, an evidence inventory.
  2. 02One supplier origin declaration per non-Vietnamese supplier.
  3. 03An evidence-pack checklist ordered as a broker would ask for it.

Delivered as documents and web pages; the format of each is read from the template specification. Every document carries the reviewer of record, the verified date and its disclaimer on the final page.

Whether these facts satisfy the substantial-transformation standard is a determination for the importer's customs counsel or broker.

See the vietnam origin memo

Learn

Have the record reviewed by the importer's customs counsel or licensed broker before use.