COUNTRY OF ORIGIN — CHINA, CAMBODIA, VIETNAM
Your papers say Cambodia. The machines may still be in China.
The PI used to say China. Now it says Cambodia, sometimes Vietnam. The price dropped the week the tariffs got painful. Your broker filed the new country. You have not stood in either building.
Origin isn't where the invoice comes from. It's where the last real manufacturing happened. If that's still Dongguan, the entry is wrong — and the importer of record signed it, not the broker.
Here is how CBP decides, which of three setups you're actually in, what to do today, and what it costs if you're wrong. Then, if you want it, what we do.
How does CBP decide where my goods are from?
One test. Did the third country make a new article — with a new name, character, or use — or did it only pack, label, or lightly assemble a Chinese good?
That's substantial transformation, and it's the whole of origin law in a sentence. A Cambodian exporter on the bill of lading doesn't move origin out of China. A Cambodian chop on the invoice doesn't either. Only the process does, and CBP will ask where the process happened.
Two more things. Under 19 U.S.C. §1304 every article must be marked with its country of origin in English, and goods marked wrong carry an additional 10 per cent duty on top of whatever else is owed. And the duty of reasonable care on that declaration sits with you. A US court has already ruled that relying on the exporter and the broker does not remove it.
Source: DOJ/DHS Trade Fraud Guide, July 2026, pp.3, 5, 19.
Which of the three is your setup?
Almost every origin file we open is one of these. Find yours.
1. Paper route. Second letterhead. Same floor in China. Cambodian or Vietnamese exporter on the BL. Deposit still hits a Chinese account. Nobody you can visit without a week of excuses.
2. Real second building, cosmetic work. There is a gate in Phnom Penh or Binh Duong. People sew, pack, wipe, label, bolt two pieces together. The process that makes a new article — new name, character, or use — never left Dongguan or Ningbo. CBP can still call origin China. They already do this on Cambodia lanes.
3. Real move. Inventory, machines, process, and the step that changes the article actually live in the third country. That can be a clean origin. It still needs a file from both floors, not a slogan on an invoice.
Most buyers who book us are living in 1 or 2 and paying as if they were in 3.
Cambodia is the route that actually runs right now. Chinese capital, Chinese managers, Chinese process, Cambodian company chop. The owner can still be reached on WeChat at 11pm. Accountability to the China side stays soft, so the paperwork looks tidy and buyers believe the origin moved.
Vietnam is stricter — and watched. Harder to fake a whole factory. Also the country CBP has already burned. "Made in Vietnam" after a rented room and a label is a known pattern. We published one: buyer never visited, broker filed Vietnam, CBP called China, box sat 47 days.
What do we see on the floor? The tells.
Mandarin in the office, local staff on the line, WeChat QR on the gate
One owner, two licenses: Guangdong + Phnom Penh, or Guangdong + Binh Duong
PI from China, BL from Cambodia
Deposit to China, balance to the third country — or the whole wire still to China
Fabric, parts, or moulds leave China the week before the "Cambodian" PO
Claimed monthly output doesn't fit the room you can walk in twenty minutes
Vietnam version: few machines, no raw inventory, same Chinese exporter that used to be on your 7501
Transformation story falls apart when you ask for a BOM by country, not by supplier nickname
One of those is enough to look. Three is a live origin problem.
What should I do today?
In this order. None of it costs anything.
1. Follow your own money.
Pull the wires for your last three shipments. Which country did the deposit go to? Which country did the balance go to? If either landed in China, your file already disagrees with your invoice.
2. Get both legal names and both addresses.
The Chinese entity and the Cambodian or Vietnamese one. From business licenses, not from the PI. If the same person owns both, write that down too — it isn't disqualifying, but CBP will ask.
3. Ask for a bill of materials by country.
Not by supplier. Where was the fabric woven, the part moulded, the frame extruded. The answer tells you which of the three setups you're in before anyone visits.
4. If a CF-28 has arrived
read it for the entry number, the date and the officer's name, and call your broker. The deadline is on the letter. Don't let either factory write to CBP.
5. Do not relabel anything, and do not ask the supplier to "help with origin."
Origin is a fact about the process. Changing the label changes the marking violation into a fraud case.
6. Find out where the inputs came from.
A real move to Cambodia doesn't help if the cotton or the polysilicon came from Xinjiang. UFLPA follows the input, not the country on the BL. See the UFLPA page.
What happens if CBP decides the origin is China?
The entry gets re-rated. That means:
Section 301 duties, back-owed. The China-specific tariffs your new origin was avoiding — on this entry and, once CBP is looking, the ones before it.
Antidumping and countervailing duties, if the product sits in an order. The government's own guide says these can exceed 600 per cent of declared value. Applied to entries already liquidated and sold.
The marking duty. An additional 10 per cent for goods marked with the wrong country.
Section 592 penalties, scaled by how careless CBP decides you were. Negligence, gross negligence, or fraud. "My broker filed Cambodia" is the negligence argument at best.
And where the transshipment was deliberate, it stops being civil. The Trade Fraud Guide's own examples: a Charlotte distributor paid $54.4 million to settle claims it routed tungsten carbide through a third country and declared that country as origin. A Florida couple got 57 months in prison for a plywood scheme built on false origin and transshipment. A resin distributor paid $6.8 million for false origin declarations to dodge 25 per cent Section 301 duties, and an executive pleaded guilty.
Then the forced-labour overlay, which is separate. Even a real Cambodian transformation doesn't answer UFLPA if the input traces to Xinjiang or a listed entity. That's a detention on top of the origin question.
Source: DOJ/DHS Trade Fraud Guide, July 2026, pp.6, 10, 19–21; CBP Forced Labor Enforcement Operational Guidance, June 2026, p.9.
A file from both floors. Not from the invoice.
What does CBP want to see for origin?
Both entities. Business licenses for the Chinese company and the Cambodian or Vietnamese company. Ownership, if shared.
Both addresses, as floors. What's physically at each. Machines, people, inventory. Whether the room can produce the output on the invoice.
What enters each building, and what leaves. Import records into Cambodia or Vietnam — what came from China and in what state. Export records out. The gap between them is the transformation, or the absence of one.
The marking duty. An additional 10 per cent for goods marked with the wrong country.
A bill of materials by country. Every input, where it was made.
And where the transshipment was deliberate, it stops being civil. The Trade Fraud Guide's own examples: a Charlotte distributor paid $54.4 million to settle claims it routed tungsten carbide through a third country and declared that country as origin. A Florida couple got 57 months in prison for a plywood scheme built on false origin and transshipment. A resin distributor paid $6.8 million for false origin declarations to dodge 25 per cent Section 301 duties, and an executive pleaded guilty.
The money. Who was paid, in which currency, to which account, in which country — matched to the invoices.
The process, evidenced. Production records, dated photographs of your product on the line at the claimed address, and the step that makes a new article, shown happening there.
That's the same shape of file CBP's own guidance asks for on supply-chain questions generally. Origin is a supply-chain question.
Source: DOJ/DHS Trade Fraud Guide, July 2026, p.5; CBP Forced Labor Enforcement Operational Guidance, June 2026, Appendix E pp.56–57.
WHERE WE COME IN
What we do — and what we don't
We walk the buildings you already have and write down what's real.
Both legal entities. Both addresses against both floors. What enters China, what enters Cambodia or Vietnam, what actually changes between them. Who is paid, in which currency, to which account. Photographs on both lines. Chopped records from the building that does the work — China, Cambodia, Vietnam, or both. After the call, Asia Agent sends a person to the third-country floor, and the packet your counsel uses is built from both sides.
What we are not.
We are not US trade counsel — your broker and lawyer file and argue. We do not design a new origin, and we won't find you a Cambodian factory so you can change one — we never source and take no commission from any factory. We tell you what the operation you already have actually is, in which of the three setups it sits, and what the file can and can't support. If the honest answer is that origin is China, you'll hear it from us before you hear it from CBP.
No letter yet?
Mapping both floors before CBP asks costs you a visit. Mapping them after costs you the visit, the storage, the re-rated entry and the ones before it.
If your origin moved recently and nobody from your side has stood in the new building, you already have the file problem. You just haven't had the letter.
If your origin moved recently and nobody from your side has stood in the new building, you already have the file problem. You just haven't had the letter.
FAQs
Frequently Asked Questions
China Situation Call
Thirty minutes.
Tell us the country on the invoice and the city the factory claims. We tell you which building to walk first, and whether this looks like paper, cosmetic, or real.
Book
+86 15322086875
Where we are
Hong Kong, Guangzhou, Foshan, Shenzhen, Yiwu and Jinan.