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US-Thailand Trade Meetings Increase Focus on Trade Enforcement

Thailand recently concluded the latest round of high-level trade discussions with its US trade counterparts. In addition to addressing concerns over claimed human rights abuses, forced labor, and the current trade imbalance with the US, one critical area of focus was US allegations of transshipment in Thailand’s import-export sector.

Transshipment is the practice of routing goods through a third country to circumvent duties or tariffs on goods exported to the receiving country. Specifically, the US alleges that many Thai exporters declare a Thai origin for goods to qualify for preferential duties or exemptions without meeting the legal standards for establishing Thai product origin—an act that it claims masks the goods’ true origin. This is a particular matter of concern for US authorities, since transshipment is perceived to be a means by which Thai origin is claimed for many Chinese goods exported abroad. This perception affects a wide range of otherwise legitimate Thai-origin goods.

The Thai trade delegation, led by Deputy Prime Minister and Commerce Minister Suphajee Suthumpun, met with counterparts from the Office of the United States Trade Representative (USTR) on May 3–6. A subsequent team of Thai trade representatives, led by the Thai Ministry of Commerce vice minister, met with the USTR on May 13–14. These discussions directly impact the trade enforcement environment in Thailand, potentially affecting numerous business operators involved in the manufacture, import, or export of goods and components.

Thailand’s position is that it strictly adheres to and enforces the legal standards for determining qualifying origin and that allegations of transshipment are largely unjustified. Nonetheless, it has agreed to increase its focus on trade compliance and enforcement in Thailand in return for commitments on reciprocal trade benefits with the US, including consideration of tariff exemptions on certain critical Thai imports into the US.

Notable Outcomes

There are two key takeaways for Thailand-based manufacturers, importers, and exporters:

  • Thailand agrees to increase cooperation with US Customs on origin verification: Thailand’s Department of Foreign Trade (DFT) confirmed that it is working closely with US Customs to monitor and prevent false claims of Thai origin on exports to the US. This amounts to a commitment to tighten audit scrutiny of certificates of origin and transshipment risk. This follows an already observed increase in origin scrutiny by Thai officials. It also involves more exercise of discretion in the conduct of origin investigations by the DFT and related authorities. It is important to note that his increased enforcement attention is not limited only to goods exported from Thailand to the US.
  • Thailand to upgrade certification standards for goods exported to the US: Thai officials confirmed that there is a commitment to upgrade standards for origin certification for exports to the US. While Thai authorities had already increased attention to the origin certification process and review, especially those involving Chinese inputs or business ties, the Thai delegation agreed to focus on an even more rigorous review of origin claims and supporting documents before exports are cleared.

The latest discussion with the USTR follows Thailand’s 2025 commitments on trade compliance during the tariff negotiation process. Thailand has been moving toward a stricter origin verification system since 2025, including strict evaluation of non-preferential certificates of origin, increased factory inspections, and greater scrutiny for products considered at risk of origin circumvention. In short, recent trade negotiations between the US and Thailand reinforce and, in fact, influence the increased enforcement trend observed in Thailand.

By Tilleke & Gibbins, Thailand, a Transatlantic Law International affiliated firm. 

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