For steel products, "Made in Vietnam" on the carton is only part of the story. US authorities increasingly look at where the steel itself was produced.
Two different origin questions
| Question | Why it matters |
|---|---|
| Country of origin of the finished product | Determines general tariffs and marking |
| Country where the steel was melted and poured | Used for Section 232 administration and monitoring of steel flows |
Circumvention findings involving Vietnam
The US Department of Commerce has previously found that certain corrosion-resistant and cold-rolled steel processed in Vietnam from Chinese substrate circumvented AD/CVD orders on China. Products made from such inputs can face the same duties as Chinese goods, and importers must certify the origin of the substrate.
Practical risk areas for rack and shelving makers
- Using imported coated coil without documenting its mill and country.
- Buying from traders who cannot provide mill certificates.
- Simple cutting, punching and painting of imported steel components.
Building a compliant file
- Mill test certificates for every steel lot, linked to purchase orders.
- Production records showing the transformation in your factory.
- A steel-origin declaration per shipment for your buyer or broker.
- Records retained for at least five years.
Trade measures on steel change often. Treat the rules described here as general guidance and confirm current rates, product lists and filing requirements for your HTS codes before each shipment.
Related: US customs compliance · Section 232 steel.