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Peng Delei, a professor specializing in international trade law at the East China University of Science and Technology in Shanghai, said such actions may constitute "circumvention of rules of origin". If discovered, companies involved could face retroactive tariffs, criminal charges, or inclusion on trade blacklists.
In addition to certificates of origin, US Customs and Border Protection requires exporters to provide production records, invoice chains, material sourcing information and other related data.
In 2023, key targets for enforcement included countries such as Vietnam, Malaysia, Cambodia and Mexico, according to information released by the Beijing-based China Council for the Promotion of International Trade, or the CCPIT.
Shi Xianjin, an assistant researcher at the Chinese Academy of Social Sciences' Institute of World Economics and Politics, said there is no real advantage in taking such risks when legitimate channels remain viable, especially after China and the US agreed in mid-May to temporarily lower tariff rates.