A 40% penalty on transshipped goods.
The US set Vietnam's reciprocal tariff at 20% with a 40% penalty on goods deemed transshipped. The enforcement framework makes that penalty one that cannot be reduced through standard mitigation.
Saola Origin
Prove where your goods actually come from.
Under the 2026 US enforcement regime, "Made in Vietnam" on a label isn't proof. Saola Origin builds a per-supplier origin evidence package your compliance team can hand to a broker, an auditor, or CBP.
Saola provides evidence and risk assessment, not a guaranteed customs ruling. We're clear about that below.
Why this is now a board-level question
The 2026 origin-enforcement regime, in plain terms
This is the regulatory reality your goods ship into today. The numbers below are as published, not rounded up to scare you.
CBP circumvention lists.
The regime created a biannual CBP list of circumvention-associated countries and facilities. Vietnam is flagged elevated-risk. Being on the wrong list is reputational and operational, not just financial.
De minimis suspended.
Duty-free de minimis entry was suspended globally: every parcel, any value, now needs formal entry. The e-commerce tariff workaround is gone.
Tariffs in flux.
The Supreme Court struck down the IEEPA tariffs, and a temporary Section 122 tariff (10%, capped at 15%) took their place until around July 24, 2026. Uncertainty itself is now a planning problem.
Two Section 301 probes name Vietnam.
USTR opened two Section 301 investigations naming Vietnam (manufacturing overcapacity and forced-labor enforcement), with determinations expected mid-to-late 2026. Section 301 is the durable, court-tested authority for whatever comes next.
Whichever way tariffs move, one question is now permanent: can your supplier prove origin?
From a listing, these two look identical.
A directory, a marketplace listing, even a C/O certificate doesn't tell you which one you're actually buying from. The difference is a 40% penalty and a CBP referral.
Inside a real factoryA real Vietnamese factory
Raw inputs arrive and real production transforms them in Vietnam. Under CBP's lens this is genuinely Made in Vietnam, and it can be proven with evidence.
Inside a transshipment frontChinese goods wearing a Vietnamese label
Near-finished goods are imported from China, lightly repackaged or minimally assembled, then exported as "Made in Vietnam." Under CBP's substantial-transformation test, this is transshipment, and the penalty cannot be mitigated away.
From a listing, you can't tell which one your supplier is. Saola Origin lets you tell, with evidence.
The product
A per-supplier, per-product-line origin evidence package.
Origin evidence is a body of work built around one product line at one factory. Here's what's in the package.
Input BOM with supplier-of-input declarations
We build a bill of materials for the product line, tracing each input to its supplier and where that input itself came from. This is the layer no listing or trade-data feed can see.
Value-add analysis vs substantial-transformation criteria
A % value-added assessment of the work done in Vietnam, framed against CBP's substantial-transformation criteria, so you can see how the product line sits relative to the test.
Photographic process evidence
A local Saola verifier captures geo-tagged, timestamped photos and video of the actual production process. Everything is hash-stamped at upload, so the evidence is tamper-evident.
C/O issuance history
We review the supplier's Certificate of Origin issuance history and supporting export documentation. The paper trail is checked against the physical reality.
Red-flag screen for near-finished Chinese imports
Because our supplier graph links input suppliers, we can flag a supplier that imports near-finished goods from China (the single biggest transshipment tell) as a graph edge rather than a hunch.
Buyer-shareable evidence vault
Everything lives in a vault you can share with your customs broker, auditor, or legal team, or hand to CBP on request. Every item carries its date, method, and verifier.
Every fact in the package carries its source, method, verifier, and date. Auditability is the point.
How an Origin Pre-Check runs
01
Scope
You name the supplier and the specific product line. We confirm what evidence is gettable and where the origin risk likely sits.
02
Ground truth
A local Saola verifier visits the factory, captures geo-tagged process evidence, and works the input BOM with the owner, in Vietnamese, on the floor.
03
Cross-check
We map inputs across the supplier graph, review C/O history and US bill-of-lading evidence, and run the near-finished-import red-flag screen.
04
Package
You receive the origin evidence package and a documentation-readiness report in your vault, ready to hand off.
Origin builds on Saola Verified — our S0–S5 trust ladder. See how verification works
Why only Saola can build this for Vietnam
Origin evidence requires four things at once. Each incumbent is missing at least two.
Factory access for BOM truth
The input BOM only exists on the factory floor, in Vietnamese, with the owner's trust. Our local verifiers and network get in.
Trade-data vendors see shipments, not processes.
Bilingual document work
We read C/Os, export declarations, and registry filings in Vietnamese, then structure them in English for your compliance team.
A marketplace listing doesn't even ask.
US compliance framing
We frame evidence against CBP's substantial-transformation lens — the question your importer-of-record actually has to answer.
Auditors check social compliance, not origin.
A graph that links input suppliers
Because we link suppliers to their input suppliers, we can see the near-finished-Chinese-import tell as a graph edge.
A listing of 2 million suppliers can't.
We build our intelligence from US bills of lading, public registries, and documents suppliers consent to share. Ask your current data vendor where their Vietnam records come from.
What Saola Origin is, and what it isn't.
Saola Origin gives you evidence and a risk assessment, not a guaranteed customs outcome or a legal ruling. No one can honestly promise how CBP will rule, and we never will. We gather dated, sourced evidence and assess it against published substantial-transformation criteria, so your compliance team can make a documented decision. The origin determination stays with you. We think being straight about this is exactly why you can trust the rest.
Origin Pre-Check pricing
Origin Pre-Check
$2,500–7,500
Per supplier / product line. Standalone, or add it to a Verified Shortlist or Managed RFQ.
- Input BOM with supplier-of-input declarations
- Value-add analysis vs substantial-transformation criteria
- Geo-tagged process evidence + C/O history review
- Near-finished-import red-flag screen
- Documentation-readiness report in a buyer-shareable vault
Stop guessing where your goods come from.
Request an Origin Pre-Check on a supplier you're sourcing from today and get evidence you can hand to your broker, your auditor, or CBP.