50 Commodities Under the Trade Defense Spotlight: When Market Share Must Go Hand in Hand with Capability

 02/11/2026

On October 22, the Ministry of Industry and Trade officially issued Official Letter No. 8744/BCT-PVTM accompanied by the list of 50 export commodities at high risk of being investigated for the application of trade defense measures, origin fraud, and illegal transshipment; just five days later, the Customs Department forwarded the directive through Official Letter No. 23535/CHQ-GSQL to regional customs branches to identify risks and tighten controls right at the border gate.

Why This Group of 50 Commodities Is Different

The warning list spans seven key industry groups, including: wood and wood products, iron, steel and metalworking, construction materials, industrial processed products, chemicals and plastic raw materials, fibers and textile-garment products, along with several other supporting groups — among which the wooden furniture and iron-steel segments always stand at the center of attention. The common thread that pulls these commodities into special control status stems from export turnover growing too rapidly and the market share held in the destination country being too large.

Actual data shows that, in just the first seven months of 2026, the upholstered wooden-frame seating category exported from Vietnam to the United States reached a turnover of USD 1.86 billion, accounting for up to 61.6% of total imports in this segment across the entire US market; similarly, rubber tires for trucks and buses exported to the European Union (EU) market reached USD 241.96 million, accounting for 19.2% of market share and establishing the position of the second-largest supply source. Establishing a dominant position in a key export market is itself the factor that triggers systemic suspicion from domestic manufacturing associations and investigating authorities in the destination country.

What are they suspecting? That Vietnam’s domestic production capability cannot grow at such lightning speed in a short period of time without importing semi-finished products or raw materials from countries subject to high trade defense tariffs (such as China), bringing them to Vietnam only to carry out simple processing operations, changing labels and packaging, and then exporting to evade anti-dumping (AD) and countervailing duties (CVD).

That is why, when an investigation into circumvention of trade defense measures is officially initiated, the subject that businesses must justify before international inspection delegations is not merely the quality specifications of the product, but the entire supply chain documentation:

• Clear origin of each batch of input raw materials (from plantation wood and hot-rolled steel coils to surface treatment chemicals);
• Technological processes and Substantial Transformation operations actually taking place at the production facility;
• Bill of Materials (BOM) of product components aligned with accounting records and the Customs Final Settlement Report;
• The percentage of Regional Value Content (RVC) created in Vietnam;
• The legality and continuity of the entire documentation flow: sales contracts, bills of lading, commercial invoices, warehouse receipts and release notes, and Certificate of Origin (C/O) issuance records.

This is no longer an equation inside the manufacturing plant. This is a major challenge to customs compliance management capability. As of mid-September 2026, Vietnamese exports have faced 327 trade defense investigation cases from global markets (with the United States accounting for the overwhelming share), while authorities continue to add 67 more commodities with high turnover growth rates to the US to the special review list. If supply chain transparency cannot be proven, businesses will face punitive tariffs reaching several hundred percent.

Customs Procedure Solution

The standard customs procedure solution framework for businesses requires being established right from the supply chain planning stage through an in-depth solution:

1. Standardizing HS codes and screening origin criteria

A distinction must be made between determining the origin of goods under preferential or non-preferential rules and assessing the circumvention of trade defense measures. Meeting the criterion of HS code transformation or regional value content does not automatically exclude the risk of being subject to a circumvention investigation. Businesses must separately cross-check the product scope and the legal criteria applied in each case at the importing market.

The foundation for proving origin begins with precision in goods classification (HS Classification):

• Cross-checking HS codes of input raw materials and output finished products to accurately determine the corresponding rule of origin for each market: the HS code transformation criterion at the 2-digit (CC), 4-digit (CTH), or 6-digit (CTSH) level; or the Regional Value Content (RVC/VAC) criterion based on FOB price or Ex-works price.
• Controlling common documentation errors before transmitting the declaration:
  • Ensuring the HS code on the Export Declaration, the commercial contract, and in box 7/box 8 of the C/O is fully consistent.
  • Timely alerts when the proportion of foreign inputs exceeds the permitted threshold, accurately applying the De Minimis flexibility rule for auxiliary components.
  • Cross-checking the logic between the C/O and the actual Bill of Materials (BOM)

2. Establishing a traceability documentation set for each shipment

Rather than waiting until an investigation initiation notice is received to begin collecting documents, a professional management system must digitize and synchronously store the data of each export container, ready to serve on-site inspection:

• Raw material purchase contracts, VAT invoices (for domestic goods), import customs declarations (for foreign-imported goods), quality inspection records, and origin verification results.
• Production dispatch orders by lot, raw material release notes, machinery operation logs, and timesheets of workers directly involved in processing.
• Detailed calculation sheets of the proportion of domestic raw material costs, labor costs, depreciation of factory/machinery, and indirect management costs forming the ex-works price.
• Finished product warehouse receipts, port weighing slips, domestic transport bills of lading, and original C/O issuance records stored in parallel with periodic Customs Final Settlement Report data.

3. Proactive risk reconciliation:

Export businesses need to continuously review their commodity catalogs against:

• The list of 50 commodities at high risk of trade defense investigations and origin fraud warned by the Ministry of Industry and Trade (under Official Letter No. 8744/BCT-PVTM);
• The list of risk-controlled items at border gates by the Customs authority (Official Letter No. 23535/CHQ-GSQL);
• Developments in trade defense cases that destination markets (US, EU, Canada, etc.) are applying to neighboring countries, in order to proactively prepare justification scenarios when the business’s export turnover surges unexpectedly.

U&I Logistics — A Professional Customs Brokerage Agent with a risk management mindset — does not merely provide customs declaration services but establishes a transparent and tight compliance control system right from the moment of receiving shipment data, with:

• A team of in-depth experts directly appraising documentation.
• Standardized processes serving post-clearance audits.
• Accompanying businesses from the stage of preparing documents, responding to investigation questionnaires, through coordinating direct justification before domestic and foreign authorities.

Conditions for the Solution to Create Real Value

For a supply chain management structure to truly protect businesses, the model must satisfy three principle-based prerequisite conditions:

The first condition is the substantive nature of value added. Documentation is only valuable when it reflects a real production process, real technology, and value-added content actually created in Vietnam. A business that essentially only imports semi-finished components to carry out assembly operations, repackaging, or label changes to evade duties should not seek to legitimize this. Transparency and honesty in production capability is the principle of every sustainable export strategy.

The second condition is the continuity of the data chain. The percentage of Regional Value Content (RVC) or the HS code transformation criterion (CTC) can only hold up if the lower supply chain links (Tier-2 and Tier-3 suppliers) also maintain equivalent transparency. If input raw materials are purchased on a floating basis, without clear origin or lacking proper documentation, the Chain of Custody will be broken.

The third condition is the discipline of preparing documentation from the beginning, not acting in firefighting mode. A set of technical evidence documentation prepared in sync and accumulated naturally with each production order and each export declaration always carries far greater legal weight than a documentation set only built up after a foreign investigation authority has conducted inspection. Facing the extremely stringent deadline for responding to the questionnaires of international trade defense authorities (typically only 14 to 30 days), patched-together documentation reveals points of conflict, pushing businesses into the risk of being subject to punitive tariffs.

When a leading position in export market share itself becomes the factor triggering suspicion and defensive barriers from the destination market, the competitiveness of an exporting business lies not only in unit price or delivery schedule, but also in the ability to prove the lawful transparency of the supply chain faster and more accurately.

For manufacturing and exporting businesses that wish to proactively review the gaps in their documentation chain, an in-depth working session with U&I Logistics’ team of experts will help identify potential points of conflict early, standardize the evidence set, and establish a protective corridor for the business’s long-term export position.

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