Since April 2025, US trade policy toward Vietnam has shifted dramatically — from an initial 46% reciprocal tariff threat, down to a 20% rate in effect since August 2025, and now compounded by two new Section 301 investigations opened in 2026 covering intellectual property protection and forced labor in supply chains. For Vietnamese exporters, this is no longer a background policy risk to monitor occasionally — it is a set of overlapping, fast-moving legal exposures that directly affect landed cost, sourcing decisions, and market strategy. This article outlines the current landscape and the advisory services ISC Global provides to help exporters respond.

1. The Current State of US Tariff Exposure for Vietnam

As of mid-2026, goods exported from Vietnam to the United States can be subject to several overlapping duty layers:

• 20% reciprocal tariff, in effect since 7 August 2025, currently grounded in the President’s Section 122 balance-of-payments authority — a statutory authority capped at 150 days, with no automatic extension absent Congressional action;
• 40% duty on transshipped goods — products determined to originate from a third country (commonly China) but routed through Vietnam to circumvent duties;
• Section 232 national-security tariffs of 50% on steel and aluminum, which stack on top of the reciprocal tariff for products with significant metal content;
• Potential additional Section 301 duties arising from two active investigations: an IP protection and enforcement investigation (initiated 29 May 2026, final determination expected by 29 November 2026) and a forced-labor supply chain investigation (findings released 2 June 2026, proposing a 12.5% additional tariff on Vietnam).

2. Why This Requires Immediate Attention, Not Wait-and-See

1. The legal basis for the current 20% rate is temporary by statute. Section 122 authority expires after 150 days (around 24 July 2026) and cannot be unilaterally extended by the President. The rate is likely to migrate to a Section 301 legal basis once the IP investigation concludes — meaning the number itself, not just the underlying facts, could change materially before year-end;
2. Duty stacking distorts landed cost in ways that are easy to miscalculate. A metal-content product shipped to the US can face the 20% reciprocal tariff plus the 50% Section 232 duty on the metal-derived value simultaneously — errors here compress margins far more than either rate suggests in isolation;
3. Exposure to the proposed 12.5% forced-labor tariff and IP-related measures is a live, near-term risk, particularly for labor-intensive export sectors (textiles, footwear, solar), requiring exporters to review labor supply chain documentation and IP compliance now rather than after a final determination is issued.

3. ISC Global’s US Trade Policy Advisory Services

ISC Global, together with its Vietnam-based partners Duc Luong Services and STC VN Co., Ltd. (Staunchly Vietnam), provides an integrated advisory package to help exporters manage this multi-layered exposure:

• Effective duty rate modeling for each product line exported to the US, combining the reciprocal tariff, applicable Section 232 metal-content duty, and base MFN tariff by HS code, so pricing decisions reflect true landed cost;
• Transshipment risk assessment across the upstream supply chain, particularly for sectors with raw material sourced from China (steel, aluminum, solar cells, textiles), to reduce exposure to the 40% transshipment duty;
• Labor supply chain compliance advisory, aligned with the standards under review in the Section 301 forced-labor investigation, helping exporters prepare documentation demonstrating supply chain transparency down to Tier 1 and Tier 2 suppliers;
• IP compliance review, reducing exposure tied to the ongoing Section 301 IP investigation for companies handling branded goods, industrial designs, or licensed products;
• Real-time policy monitoring and client alerts, so exporters can adjust pricing and sourcing strategy promptly as the legal basis and rate structure evolve;
• Market diversification strategy, reducing over-reliance on the US market by better leveraging Vietnam’s existing FTA network (EVFTA, CPTPP, RCEP, UKVFTA) to expand into the EU, Japan, Korea, and other markets.

4. Frequently Asked Questions

Is the current 20% reciprocal tariff likely to change? Quite possibly. Its legal basis (Section 122) is time-limited by statute, negotiations toward a full US-Vietnam Agreement on Reciprocal, Fair, and Balanced Trade are ongoing, and the pending Section 301 IP determination (due by November 2026) could shift the rate in either direction depending on how negotiations and findings develop.

Do small and mid-sized exporters face the same Section 301 exposure as large exporters? Yes. Unlike anti-dumping or countervailing duties, which are typically calculated per company, Section 301 tariffs (if implemented) generally apply broadly to imports from the investigated country, regardless of exporter size — meaning smaller exporters cannot assume they are below the radar.

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