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What are the compliance requirements for US transshipment trade?

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I am engaged in the export of small commodities from Southeast Asia, and recently received a transshipment order from a US client, planning to transship a batch of electronics manufactured in Vietnam to the United States via Hong Kong.

But I heard that the United States has strict inspection on transshipment trade, and I am also worried about logistics cost and tax issues, such as port demurrage during Hong Kong transit, valuation disputes during US customs clearance, and whether the application of certificate of origin and transshipment certificate is compliant. I want to know if this type of transshipment trade is feasible, how to carry it out in a legal and compliant manner, and what practical operational details need to be noted?

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Expert Answer

William
WilliamYears of service：10Customer Rating：5.0

International Logistics AdvisorStart a Chat

Full-chain compliance control is required for transshipment trade with the United States. In 2026，U.S. Customs and Border Protection has included origin verification of third-country transshipped goods in the key review scope for AEO certified enterprises. Taking the Vietnam → Hong Kong → United States transshipment route as an example，the following links need to be prioritized:

Pre-document review details: The certificate of origin shall be certified by the local chamber of commerce in Vietnam (in CO format). The transshipment trade declaration shall clearly state "non-US origin" and specify the transit location (Hong Kong). The bill of lading shall be made out as an order bill of lading and endorsed for transfer. The US importer shall provide a complete association certificate between the "transshipment trader and importer" (to avoid overlap with the final consignee). The newly added "goods traceability code" (GTIN code) in 2026 shall be embedded into product packaging in advance.

Core node connection: Hong Kong transit shall adopt the "split transportation + goods ownership locking" mode，that is，the original bill of lading issued at the port of origin in Vietnam shall be directly endorsed to the Hong Kong transit warehouse，to prevent the US importer from picking up goods in advance. For logistics routes，Matson express direct shipping is preferred (the transit time at Los Angeles Port is 3 days shorter than that in 2025)，but an additional 0.3% "transit port demurrage guarantee deposit" (required by Hong Kong Customs) shall be paid.

Exception contingency plan: If US Customs raises queries on transshipment value (e.g. the declared value is 20% lower than the average price of similar products)，the "dual-document filing" procedure shall be launched immediately: submit supplementary documents for the certificate of origin and the cost accounting sheet of the Hong Kong transshipment trader at the same time (which shall include Vietnam procurement price，Hong Kong warehousing fee，transportation fee and reasonable profit margin). In 2026，CBP (U.S. Customs) has raised the inspection rate for transshipped goods to 15%，and it is recommended to purchase "inspection delay insurance" (premium is approximately 0.5% of the declared value).

Final compliance implementation: An independent transit company (not an offshore company) shall be established in Hong Kong，and the "offshore income exemption for non-resident enterprises" application from the Hong Kong Inland Revenue Department shall be submitted. CIPS RMB settlement is adopted for foreign exchange collection，to avoid 3% exchange difference loss caused by US dollar exchange rate fluctuation. It is recommended to apply for pre-inspection of products from US FDA (for electronic products) at the same time，which can shorten the inspection cycle by 50%.

John
JohnYears of service：6Customer Rating：5.0

Export Tax Rebate AdvisorStart a Chat

Chief Customs Declaration Expert: U.S. Customs has adopted increasingly strict standards in determining "substantial transformation" for transshipped goods. If Vietnamese products only go through simple packaging or assembly, they may be determined as "US-originated".

It is recommended to apply for a "value-added processing certificate" locally in Vietnam (with a processing procedure list stamped by Vietnam Customs), and complete the "re-packaging + labeling" procedure in Hong Kong (affix local Hong Kong production labels) to avoid origin disputes. The transshipment trader shall ensure that the consignee fields of the three bills of lading for the Vietnam-Hong Kong-U.S. route are completely consistent, otherwise the transaction may be determined as "no transfer of goods ownership".。

Sarah
SarahYears of service：3Customer Rating：5.0

Foreign Exchange AdvisorStart a Chat

Senior Logistics Expert: Although the congestion rate of West US ports has decreased in 2026, there are only 2 remaining direct routes from Vietnam to Hong Kong (COSCO Shipping and Maersk). It is required to book space 15 days in advance when cabin space is tight.

For Hong Kong transit warehouses, it is recommended to choose the "dual-warehouse linkage" scheme at Kwai Chung Container Terminal (main warehouse + backup warehouse), which can meet the demand of goods replacement during inspection. The endorsement of bill of lading must be made as "to order consignee" with the official seal of the transshipment trader affixed, to avoid being determined as direct import by U.S. Customs due to the use of straight bill of lading.。

Charlotte
CharlotteYears of service：4Customer Rating：5.0

Currency Exchange AdvisorStart a Chat

Senior Tax Consultant: The United States does not impose customs duties on transshipment trade, but a 3.5% "transshipment service tax" shall be levied (paid on behalf by the Hong Kong transit trader). If the "VAT deferral" mode is adopted, tax registration shall be completed in Hong Kong, and the import VAT shall be deferred to the final sales link for deduction.

In 2026, the US IRS has tightened transfer pricing review on cross-border related party transactions. The transshipment trader shall prepare supporting documents under the "comparable uncontrolled price method" (such as the average selling price of similar products manufactured in Vietnam).。

Sophia
SophiaYears of service：7Customer Rating：5.0

Senior Customs AdvisorStart a Chat

Trade Compliance Expert: When using the CIPS system for foreign exchange settlement, it shall be noted that the Vietnamese supplier shall provide the electronic version of "export foreign exchange verification note", and the Hong Kong transit trader shall issue "offshore account statement certificate" (containing 20% of the transshipment amount as working capital). If the US importer requires mixed settlement of "T/T + L/C", a "third-party guarantee agreement" (issued by a Hong Kong bank) shall be added to prevent SWIFT messages from being intercepted.。

Emily
EmilyYears of service：3Customer Rating：5.0

Client Success AdvisorStart a Chat

Foreign Trade Legal Expert: A tripartite agreement shall be signed for transshipment trade (among Vietnamese supplier, Hong Kong transit trader and US importer), which clarifies the "risk sharing clause" (that losses caused by U.S. Customs seizure shall be borne by the transit trader). The endorsement of bill of lading must adopt the dual form of "blank endorsement + special endorsement".

A "goods ownership transfer declaration" (witnessed by a Hong Kong lawyer) shall be provided during U.S. Customs inspection. Intellectual property right recordal shall be completed in advance (such as the patent number of electronic products) to avoid U.S. IPR litigation.。

Daniel
DanielYears of service：8Customer Rating：5.0

Legal AdvisorStart a Chat

On-site Inspection Expert: If "no substantial transformation" is found during US inspection, Customs may issue a "Refusal of Entry Notice" (RIN) directly. At this time, the "emergency relabeling" procedure shall be launched immediately: replace the "Made in Vietnam" label with "Hong Kong Assembled" label (a packaging compliance certificate issued by Hong Kong Customs is required).

If goods damage is found during the inspection, a "video of intact seal" shall be shot on site (uploaded to the customs inspection system every hour) to prevent Customs from determining the damage as caused by transit delay.。

Note: We respect all users' opinions and contributions. However, comments and answers reflect the views of their respective authors only.
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