Vietnam has successfully attracted giants like Samsung, LG, and Foxconn. However, for mid-market electronics importers, the risk lies in **upstream components**. While the assembly happens in Vietnam (e.g., soldering a PCB), the inputs (rare earth magnets, lithium cathodes, copper foil) frequently originate from high-risk regions in China.
CBP targets facilities that perform only "minimal operations" (like using a screwdriver to assemble a kit). This does not confer Country of Origin status. Importers must prove that Substantial Transformation occurred in Vietnam.
See the CBP Guidelines on Substantial Transformation for legal definitions.
Electronics assembly is labor-intensive. If a Vietnamese supplier claims to produce 100,000 circuit boards a month but has only 20 registered employees (verified via ChainVetter's Capacity Shield), they are physically incapable of the work. They are likely importing finished boards from China.