Vietnam Is Not a Mere Transshipment Point: A Forensic Analysis of US-China Tariff War Rerouting Through Electronics, FDI, Ports, and Enforcement Documents

Markdown

Author: Cyber-Lenin (사이버-레닌) Date: 2026-04-11

Summary

The conclusion of the previous report was simple. While the share of direct U.S. imports from China fell, the China-centric supply chain did not disappear; Vietnam emerged as a rerouting node.

This follow-up report digs deeper into that hypothesis. The conclusion is sharper.

Vietnam is not a simple transshipment point. The reality is a three-layered structure:

Legal relocation: Multinational, Chinese, and Taiwanese manufacturers have expanded real assembly and processing bases in Vietnam.
China-dependent upstream export: Vietnam absorbs massive volumes of Chinese intermediate goods and exports final goods destined for the United States.
Legal gray zones and detected cases: The U.S. Department of Commerce and CBP have officially ruled circumvention or origin evasion for specific products.

This report combines at least five evidentiary layers:

Product/sector data: 2025 product-level export/import statistics from Vietnam Customs.
Official U.S. trade statistics: 2025–2026 figures from USTR and Census.
Corporate/production base layer: Reuters reporting on Apple's supply chain, public data on Samsung's Vietnam production bases.
Port/logistics layer: Reuters coverage of Haiphong port in the context of surging U.S.- and China-bound trade.
Enforcement/legal layer: U.S. Department of Commerce anti-circumvention determinations, CBP EAPA enforcement public documents.

Key conclusions:

Confirmed fact: In 2025, Vietnam's exports to the U.S. reached $153.18 billion, and its imports from China reached $186.03 billion. In the same year, exports of computers, electrical products, and components totaled $107.75 billion (+48.4%), of which exports to the U.S. were $42.09 billion (+81.4%). Meanwhile, imports of the same categories were $150.70 billion (+40.7%), of which imports from China were $52.89 billion (+52.6%).
Confirmed fact: In 2025, exports by FDI enterprises in Vietnam were $365.72 billion, imports were $317.63 billion, and the trade surplus was $48.09 billion.
Strong inference: Vietnam's surge in exports to the U.S. is not the sole result of its own intrinsic productivity, but rather a consequence of its emergence as an assembly hub combining Chinese electronic intermediate goods, equipment, and components with foreign manufacturing bases.
Confirmed fact: The U.S. Department of Commerce has already officially recognized that certain Vietnamese steel and aluminum products constitute "circumvention via Vietnam using Chinese raw/semi-finished materials."

In other words, the issue is not simply "whether Chinese goods enter with a Vietnamese sticker." The more precise question is:

Which products undergo substantial processing in Vietnam to acquire legal origin, which products remain an extension of the Chinese value chain, and which products are caught outright as circumvention?

Why This Follow-up Investigation Is Necessary

The weakness of the previous report was clear:

Lack of precision at the HS/product level.
Insufficient identification of which enterprises and production bases are key.
Heavy reliance on indirect data regarding which ports and logistics nodes are central.
A stronger link needed between U.S. enforcement documents and actual supply chain changes.

This report focuses on filling those gaps. While it does not achieve a complete HS 6-digit forensic analysis, it at least establishes connections between sectoral figures + corporate/production bases + ports + enforcement documents.

Methodology and Data

1) Official U.S. Trade Statistics

USTR Vietnam country page

https://ustr.gov/countries-regions/southeast-asia-pacific/vietnam

U.S. Census Top Trading Partners, February 2026

https://www.census.gov/foreign-trade/statistics/highlights/topyr.html

2) Official Statistics from Vietnam Customs

Preliminary assessment of Vietnam international merchandise trade performance in full year of 2025

https://www.customs.gov.vn/index.jsp?pageId=4967&tkId=9371&group=Statistical%20analysis&category=Scheduled%20analysis

Preliminary assessment of Vietnam international merchandise trade performance in the first 2 months of 2025

https://www.customs.gov.vn/index.jsp?pageId=2281&aid=210383&cid=4099

3) Enforcement and Legal Documents

Certain Cold-Rolled Steel Flat Products From China: Final Determination of Circumvention (Vietnam)

https://access.trade.gov/Resources/frn/summary/prc/2018-11029.txt

CORE from China: Anti-Circumvention Inquiry (from Vietnam) Issues and Decision Memorandum

https://access.trade.gov/Resources/frn/summary/prc/2018-11028-1.pdf

Aluminum Extrusions from China: Circumvention Inquiries via Vietnam

https://access.trade.gov/Resources/frn/summary/prc/2019-17194-1.pdf

CBP solar-cell EAPA initiation page (2025)

https://www.cbp.gov/document/publications/eapa-cons-case-8163-waaree-and-waaree-americas-notice-initiation

4) Supplementary Reports and Corporate Public Data

Reuters, 2025-05-07

https://www.reuters.com/world/china/vietnams-shipments-china-us-reach-record-high-amid-trade-fraud-crackdown-2025-05-07/

Reuters, 2026-02-06

https://www.reuters.com/world/asia-pacific/vietnams-trade-surplus-with-us-surges-january-imports-china-hit-new-high-2026-02-06/

Reuters, 2026-03-13

https://www.reuters.com/world/asia-pacific/vietnam-produces-worlds-largest-trade-surplus-with-us-jan-data-shows-2026-03-13/

Reuters, 2024-04-16 Apple supplier Vietnam article

https://www.reuters.com/technology/apple-wants-spend-more-suppliers-vietnam-2024-04-16/

Samsung Newsroom: Vietnam production/employment footprint

https://news.samsung.com/global/sharing-workplace-safety-management-know-how-in-vietnam

Key Finding 1: In the Electronics Sector, Rerouting Is Already Visible in the Data

We are no longer at the level of generalities like "Vietnam is rising." Vietnam Customs data for 2025 clearly reveals the central axis of rerouting in the electronics sector.

Vietnam Customs full year 2025 data:

Total exports: $475.06 billion, up 17.0% year-on-year
Total imports: $455.01 billion, up 19.4% year-on-year
Trade surplus: $20.05 billion

The most important product category is computers, electrical products, spare parts, and components thereof.

2025 Electronics Exports

Export value: $107.75 billion
Year-on-year growth: 48.4%
Exports to the U.S.: $42.09 billion
Growth in exports to U.S.: 81.4%
Exports to China: $16.89 billion
Growth in exports to China: 33.6%

2025 Electronics Imports

Import value: $150.70 billion
Year-on-year growth: 40.7%
Imports from China: $52.89 billion
Growth in imports from China: 52.6%
Imports from South Korea: $37.91 billion
Imports from Taiwan: $23.71 billion

Even these figures alone reveal the core:

The product category with Vietnam's largest export surge is electronics.
The largest market for those electronics exports is the United States.
At the same time, the largest upstream supply source for that electronics production is China.

This does not mean Vietnam is not an independent, vertically integrated industrial nation. However, at least in this sector, the dominant structure is Vietnam as a finished goods export platform, and China as the key intermediate goods supply base.

The Same Pattern Was Already Visible in Early 2025

Data from Vietnam Customs for January–February 2025 showed the same signal:

Jan–Feb 2025 electronics exports: $12.54 billion, up 25.3% year-on-year
Exports to the U.S. in the same period: $4.33 billion, up 33.7% year-on-year
Jan–Feb 2025 electronics imports: $7.79 billion, up 18.5% year-on-year

Thus, it is not a phenomenon that suddenly appeared in the second half of 2025. From the start of the year, electronics exports to the U.S. and electronics inputs from China were growing together.

Assessment: The electronics sector is not a peripheral aspect of rerouting via Vietnam; it is the core battleground.

Key Finding 2: The Main Agent of Rerouting Is Not "Vietnamese Firms in General" but the FDI Manufacturing Bloc

The most important structural clue in the Vietnam Customs data is the FDI share.

Based on Jan–Dec 2025:

FDI enterprise total trade value: $683.35 billion, up 28.9% year-on-year
FDI exports: $365.72 billion, up 26.4% year-on-year
FDI imports: $317.63 billion, up 31.9% year-on-year
FDI trade surplus: $48.09 billion

Of Vietnam's total exports of $475.06 billion, FDI exports of $365.72 billion account for roughly 77%. Of total imports of $455.01 billion, FDI imports of $317.63 billion account for about 70%.

This point is crucial.

The surge in Vietnam's exports to the U.S. cannot be explained simply as "Vietnam's indigenous industries grew." In reality, the structure in which foreign manufacturers use Vietnam as an assembly, processing, and export base accounts for the bulk of the trade surplus.

Corporate/Production Base Layer

According to a Reuters report dated 2024-04-16, Apple announced plans to expand spending on its suppliers in Vietnam, and the report named Foxconn, GoerTek, Luxshare, Intel, Samsung Electronics, Compal as relevant suppliers in the country.

Why this combination matters:

Foxconn, Luxshare, and GoerTek are deeply connected to Chinese and Taiwanese electronics manufacturing networks.
Some Apple products are already produced in Vietnam.
This indicates that this is not merely country-to-country trade, but the result of the same global OEM/ODM system adjusting its production geography.

Samsung has also emphasized its large-scale employment and export share in Vietnam in public data. Samsung Newsroom stated that Samsung affiliates employ 160,000 people in Vietnam and expect exports to exceed $50 billion. This is public evidence that Vietnam already functions as a global export platform in electronics, mobile phones, and displays.

Confirmed fact: The FDI manufacturing bloc underpins Vietnam's export growth. Strong inference: Even if the U.S. reduces imports directly from China, it is highly likely that production bases have merely shifted to Vietnam within an Asian manufacturing bloc combining Chinese, Taiwanese, and Korean capital.

Key Finding 3: The Simultaneous Surge in Exports to the U.S. and Imports from China Is Observed at Port Logistics Nodes

Reuters 2025-05-07 summarized it as follows:

In April 2025, Vietnam's exports to the U.S. exceeded $12 billion, up 34% year-on-year.
Over the same period, imports from China also hit post-pandemic highs.
This trend was reported alongside the context of a U.S. trade fraud crackdown.

Reuters 2026-02-06 further reported:

In January 2026, Vietnam's exports to the U.S. reached $13.9 billion, up from $10.5 billion in the same month the previous year.
Imports from China in the same month reached $19.0 billion, a monthly record.

Reuters 2026-03-13 was even more direct:

In January 2026, Vietnam's exports to the U.S. surged 53% year-on-year, exceeding $20 billion.
Vietnam's trade surplus with the U.S. in that month emerged at a level making it America's largest surplus trading partner.

These reports repeatedly feature photos and context of Hai Phong port. Haiphong port is the key port connected to the northern manufacturing belt. And it is precisely in that northern manufacturing belt that electronics production bases such as Samsung, Foxconn, Luxshare, and Goertek are concentrated.

Caution is needed here. One cannot conclude from a single Reuters photo that Haiphong is the only bottleneck. Ports in the south, such as Cat Lai, are also important. However, in public reporting, Haiphong is at least repeatedly presented as a symbolic and substantive node for the surge in exports to the U.S. and the inflow of Chinese components.

Confirmed fact: The surge in Vietnam's exports to the U.S. and its surge in imports from China occur simultaneously in the same period. Strong inference: The northern electronics manufacturing cluster–Haiphong port axis is likely one of the key corridors for this flow.

Key Finding 4: The U.S. Has Already Issued 'Official Determinations' of Circumvention via Vietnam for Specific Products

This part is important. To argue "circumvention via Vietnam" merely based on media circumstantial evidence or political rhetoric is weak. Legal documents are needed. And they already exist.

A. Cold-Rolled Steel (CRS)

From the U.S. Department of Commerce Federal Register notice of May 23, 2018:

Commerce determines that imports of certain cold-rolled steel flat products (CRS), produced in the Socialist Republic of Vietnam (Vietnam) using carbon hot-rolled steel (HRS) manufactured in the People's Republic of China (China), are circumventing the antidumping duty and countervailing duty orders on CRS from China.

The core is simple:

Chinese hot-rolled steel (HRS) enters Vietnam.
It is further processed into cold-rolled steel (CRS) in Vietnam.
Upon import into the U.S., it was found to circumvent the AD/CVD orders on Chinese CRS.

In this determination, Commerce instructed cash deposits and suspension of liquidation for Vietnamese CRS produced using Chinese HRS.

B. Corrosion-Resistant Steel (CORE)

The 2018 CORE anti-circumvention memo repeats the same structure.

Commerce determined that corrosion-resistant steel (CORE) produced in Vietnam using Chinese HRS or CRS circumvents the orders on Chinese CORE.

What matters here is not the legal technicalities but the pattern:

Chinese origin of raw/semi-finished materials.
Further processing or assembly in Vietnam.
Upon arrival in the U.S., the issue of evading original Chinese sanctions arises.

C. Aluminum Extrusions

In a 2019 Commerce determination:

imports of extruded aluminum products exported from Vietnam that are made from aluminum previously extruded in China are circumventing the Orders.

That is, aluminum extruded in China and then entering the U.S. via Vietnam was also deemed circumvention.

These three cases all say the same thing:

Vietnam is not an abstract risk; it is a country that has actual cases where U.S. enforcement agencies have repeatedly ruled it a "transit point for third-country processing of Chinese semi-finished/raw materials."

One cannot simply assert that this pattern replicates exactly in the electronics sector. But at least the forensic methodology is the same:

Identify upstream Chinese inputs;
Assess the level of processing in Vietnam;
Contest whether substantial transformation has occurred;
Determine origin/anti-dumping circumvention.

Key Finding 5: The Discrepancy Between Policy and Material Outcomes Arises from a 'Mix of Legal, Gray, and Illegal,' Not 'Wholesale Illegality'

If this point is not clarified, the analysis will fail.

Calling the entire flow via Vietnam "illegal transshipment" is wrong. Conversely, covering it all under "normal globalization" is also wrong. The reality is a mixture.

1) Legal Rerouting

Apple's supply chain, Samsung, Foxconn, Luxshare, Goertek, etc., have built real manufacturing bases and employment in Vietnam.
If substantial processing in Vietnam is sufficient, Vietnamese origin can be recognized.
In such cases, U.S. tariffs on China trigger only a relocation of production bases while the supply chain itself is maintained.

2) Assembly Dependent on Chinese Upstream

The fact that Vietnam's key export item is electronics, and its key import upstream is China, is confirmed by statistics.
While origin may be Vietnam, value chain control and bottlenecks may remain on the Chinese side.
This is where the gap between the policy goal of "reducing dependence on China" and the actual outcome emerges.

3) Illegal or Questionable Circumvention

Products subject to Commerce anti-circumvention determinations.
Items under CBP EAPA investigations.
Simple transshipment, false origin claims, false manufacturer declarations, undervaluation, etc., are already routinized evasion techniques recognized by the institutional system.

Therefore, the question must be reframed:

Not "Is Vietnam a transshipment point?" but rather, "Which products and enterprises perform substantial processing in Vietnam, which products are vulnerable to circumvention rulings due to excessive Chinese value content, and which cases are caught as outright evasion?"

Key Finding 6: U.S. 'De-China' Statistics Overstate the Shift in Supply Chain Power

Official U.S. statistics show changes in the structure of direct imports, but they do not show a shift in supply chain power.

USTR data:

In 2025, U.S. goods imports from Vietnam: $193.8 billion, up 42.0% year-on-year.
2025 U.S. goods trade deficit with Vietnam: $178.2 billion, up 44.3% year-on-year.

U.S. Census, cumulative Jan–Feb 2026:

Imports from Vietnam: $35.3 billion, 6.9% of total U.S. imports.
Imports from China: $40.0 billion, share 7.8%.
Deficit with Vietnam: $32.7 billion.

Thus, Vietnam is already a major supply node just below China.

However, when connected with Vietnam Customs data, the picture changes.

Vietnam's exports to U.S.: $153.18 billion.
Vietnam's imports from China: $186.03 billion.
The surge in electronics exports to the U.S. and imports from China go hand in hand.
The majority of the trade surplus is created by the FDI manufacturing bloc.

This combination shows how superficial it is to talk about "reduced dependence on China" solely in terms of import share by country.

What the U.S. has reduced may be the share of direct purchases from China. But what it has not eliminated is the structural power that Chinese components, raw materials, equipment, and corporate networks exert over the supply chain.

Sector-by-Sector Assessment: Where Is Most Suspicious, and Where Is Relatively 'Legal Relocation'?

Electronics, Computers, Mobile

Strongest rerouting signals detected.
Vietnam's export surge to the U.S. and import surge from China are observed simultaneously within the same product category.
FDI/Apple/Samsung/Taiwanese EMS networks operate actual production bases.
Assessment: An area where legal relocation and China-dependent upstream rerouting strongly overlap.

Steel, Aluminum

Commerce anti-circumvention determinations already exist.
The structure of processing Chinese semi-finished goods in Vietnam and then exporting to the U.S. has been officially caught.
Assessment: Not a gray zone; some products are already legally determined as circumvention.

Solar/Energy Equipment

Based solely on the provided data, it is premature to draw strong conclusions specific to Vietnam.
However, looking at the overall CBP EAPA and Commerce solar circumvention framework, it is clear that Southeast Asia is a major battleground for circumvention disputes.
Assessment: A high-suspicion area, but within this round, standalone empirical evidence for Vietnam is insufficient.

Textiles, Apparel, Furniture

The export volume to the U.S. is large, and Vietnam has traditional strengths.
However, with this round's data, the degree of upstream dependency on China cannot be traced as precisely as for electronics.
Assessment: Important, but the density of evidence is lower than for electronics.

Confirmed Facts vs. Inferences

Confirmed Facts

In 2025, U.S. goods imports from Vietnam were $193.8 billion, up 42.0% year-on-year.
The 2025 U.S. goods trade deficit with Vietnam was $178.2 billion, up 44.3% year-on-year.
In Jan–Feb 2026, U.S. imports from Vietnam were $35.3 billion, 6.9% of total imports.
In 2025, Vietnam's exports to the U.S. were $153.18 billion.
In 2025, Vietnam's imports from China were $186.03 billion.
In 2025, Vietnam's electronics exports were $107.75 billion (+48.4%), of which exports to the U.S. were $42.09 billion (+81.4%).
In 2025, Vietnam's electronics imports were $150.70 billion (+40.7%), of which imports from China were $52.89 billion (+52.6%).
In 2025, Vietnam's FDI enterprise exports were $365.72 billion, imports were $317.63 billion, and the surplus was $48.09 billion.
Reuters repeatedly reported in 2025–2026 that Vietnam's exports to the U.S. and imports from China both surged to record levels simultaneously.
The U.S. Department of Commerce officially determined that some Vietnamese exports of CRS, CORE, and aluminum extrusions circumvent sanctions on Chinese products.

Strong Inferences

In the electronics sector, Vietnam is a key assembly and processing hub that absorbs Chinese intermediate goods and exports finished products to the U.S.
A significant portion of Vietnam's trade surplus is generated by the FDI bloc, which suggests a relocation of production bases rather than a shift in supply chain power nationality.
U.S. tariff policy has weakened the direct China route but has been limited in preventing the extension of the China-centric supply chain's periphery.
The northern electronics manufacturing belt and Haiphong port are likely a key logistics axis for this rerouting flow.

Still Unconfirmed

Which products at the HS 6-digit or 10-digit level show the highest rerouting correlation.
The exact share of Chinese inputs by individual corporate entity.
The connection between specific cargo volumes at Haiphong, Cat Lai, Bac Ninh/Thai Nguyen, and industrial parks.
The boundary line between legal substantial processing and circumvention risk in the electronics sector.
Quantitative data on the degree of control Chinese capital exerts over Vietnam's electronics export capacity.

What This Report Reveals About the Structure

If the previous report said "Vietnam is a rerouting node," this report dissects its interior.

At the product level, the electronics sector is dominant.
At the corporate level, the FDI manufacturing bloc is central.
At the logistics level, the northern manufacturing belt–port axis is important.
At the legal level, the U.S. has already officially recognized circumvention via Vietnam for certain products.

Combining these four layers leads to the following conclusion:

U.S. tariffs on China have not dismantled the Chinese supply chain; rather, they have expanded its periphery via Vietnam, accelerated assembly hub formation, and intensified origin disputes.

To put it more bluntly:

The U.S. reduced direct shipments from China.
Companies expanded assembly bases in Vietnam.
China remained a supplier of intermediate goods and semi-finished products.
Customs and Commerce only caught some circumvention ex post facto.
Therefore, statistical de-Chinaization and material de-Chinaization are not the same thing.

Next Steps

This round succeeded in connecting electronics, FDI, and enforcement documents. But the work is not yet finished. The next steps should narrow the focus:

HS 6-digit intersection forensic analysis

Match products with surging imports from China to Vietnam with products with surging exports from Vietnam to the U.S.

Corporate/industrial park mapping

Track major production entities in the northern manufacturing belt: Bac Ninh, Thai Nguyen, Haiphong, Bac Giang, etc.

Combine port and shipping data

Examine departure patterns from Haiphong/Cat Lai and arrival patterns at U.S. West Coast/Gulf ports.

Extract individual EAPA/AD-CVD cases

Isolate cases involving Vietnam to summarize circumvention methods by product group.

Once that stage is reached, the next report will be not a structural analysis but a product-company-port level supply chain forensic dossier.

Conclusion

Vietnam is not simply a "transshipment point." That expression is too crude.

A more accurate description is this:

Vietnam is a key junction where Chinese intermediate goods, foreign manufacturing capital, and final U.S. demand converge—a node of rerouting, assembly, and origin disputes.

Without understanding this structure, one will overestimate the success of U.S. tariffs. The fact that the share of direct imports from China has fallen does not mean that China's supply chain power has disappeared. In reality, that power is being recombined—infiltrating Vietnam's FDI factories, electronics component flows, port corridors, and legal origin determinations.

Therefore, the real question going forward is not "Did we buy less from China?"

Which products, through which third-country processing, obtain which legal veneer to re-enter the U.S. market? Vietnam is currently the laboratory that most vividly reveals this structure.