特朗普关税语境下,“转运”成"欺诈"的代名词,但阻挡不住其他国家发展自由贸易
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原标题:"转运"成为国际贸易的新敏感词
来源:《国际航运新闻》
2025年7月28日
"货物原产地是哪里?"——这是海关官员必须核查的三大核心问题之一,另外两个是货物种类和价值。而唐纳德·特朗普发动的贸易战,可能让针对3.3万亿美元美国进口商品的"原产地追问"变成一场泥潭。
这位美国总统对美国贸易伙伴实施的令人眼花缭乱的关税政策——从英国争取到的10%基础关税,到威胁对巴西进口商品征收50%惩罚性关税——创造了巨大的套利空间。出口商(尤其是中国企业)有强烈动机虚报货物原产地。
特朗普试图通过一项新规来应对这种风险:经低关税国家"转运"(transshipped)的货物将面临更高税率。例如,美国对原产越南的商品征收20%进口税,但若货物仅是途经越南转运,税率将翻倍至40%。
"转运"并非新词,在贸易中本指货物在飞机、火车、卡车等运输工具间的中转。但特朗普将其作为"逃税"或"欺诈"的代名词。
他的担忧不无道理。回顾2018年特朗普对华加征关税后的变化:2017至2024年间,美国从中国进口的份额下降8个百分点至13.4%,但同期中国占全球商品出口总额的比重却上升1.5个百分点至14.2%。一个重要原因是,部分中国制造商通过墨西哥、越南等国中转电子产品、鞋类等商品以规避美国关税。
颠倒的关税体系
经济学家们对这一问题的实际规模争论不休,而特朗普的新贸易政策让情况更加复杂。现行全球贸易体系基于"标准关税+特定国家优惠"模式,但特朗普新政废除了美国的非优惠标准关税(曾是全球最低之一),转而实行最大相差40个百分点的差异化国别税率。此外,美国拟对半导体和药品单独征税,将进一步加剧混乱。
这对海关判定货物原产地提出了更高要求。"原产地规则"最初用于统计目的,过去30年因双边和区域自贸协定激增而繁复化,也被用于反倾销等政策。经典规则基于"最后实质性改变"原则——即关税取决于产品最终发生质变的所在国。
听起来简单,实则不然。以服装为例:若中国企业将衬衫运至河内贴上"越南制造"标签再出口美国,显然构成欺诈;但若耐克、Lululemon或优衣库在越南生产的服装使用中国染料、棉花或拉链,原产地判定就变成一场动态谜题。美国商务部试图用"混合冷冻蔬菜"和"饼干"案例说明差异:前者需标注所有原料原产地,后者则以烘焙地为原产国。
全球化供应链的困境
当今供应链远比过去全球化且复杂。以福特、通用等车企为例:要符合《美墨加协定》,其70%的钢材和铝材必须采购自北美。关税还会因"美国成分"含量变化——若进口商品价值至少20%来自美国,这部分可豁免互惠关税。
原产地核查需要国际合作。马来西亚、泰国和韩国正加大打击赤裸裸的"改标签"行为,因为廉价中国商品正威胁其本土产业。但若特朗普真要彻底将中国挤出供应链,这些国家的配合度可能下降。野村证券研究显示,中国占美国从柬埔寨进口增值部分的29%,越南进口的19%。中国投资者还是东南亚工厂的重要所有者。
与全球背道而驰
尽管原产地规则激增,世贸组织数据显示74%全球贸易仍适用"最惠国待遇"(即平等对待所有进口)。当前其他经济体正与美国反向而行:欧盟与印尼即将达成自贸协定,中国对53个非洲国家实行零关税,欧盟与印度谈判也定于9月重启。
特朗普本可通过"对中国高关税+其他国家统一低税率"实现缩减逆差、增加收入和孤立中国的目标。7月24日他透露将向150多个"较小国家"发送10%-15%的关税通知,但仍有40多国面临巨大税率差异。可以预见,"转运"这个贸易领域的新敏感词,未来会被更频繁地提及。
英文原文
Transshipment is the new dirty word of trade
in International Shipping News28/07/2025
Where is it from? It’s one of the top questions customs officials must ask of every shipment, alongside what it is and how much it is worth. Donald Trump’s trade war could turn this inquiry on the origin of $3.3 trillion of U.S. goods imports into a quagmire.
The dizzying spread of tariffs the U.S. president is imposing on American trading partners – ranging from a baseline duty of 10% secured by the United Kingdom to the threat of a punitive 50% charge on imports from Brazil – opens up a large arbitrage. Exporters, particularly in China, have a big incentive to misrepresent where their goods are from.
The president is attempting to counter this risk by saying goods that are “transshipped” through lower-tariff countries will face higher charges. For example, the U.S. has imposed a 20% import duty on products originating in Vietnam, but will charge double that figure for goods routed via the Southeast Asian country.
Transshipment is not a new word or concept. In trade, it simply means moving goods between vehicles such as airplanes, trains and lorries. Trump, however, is using it as a shorthand for tariff evasion or fraud.
He has good reasons to be concerned. Just look at what happened when the president slapped duties on China in 2018. The share of U.S. imports arriving from the People’s Republic fell by 8 percentage points to 13.4% between 2017 and 2024. However, China’s total share of total global merchandise exports rose about 1.5 percentage points to 14.2% over a similar period. One reason is that some Chinese manufacturers dodged U.S. duties by re-routing everything from electronics to footwear through other countries, in particular Mexico and Vietnam.
UPSIDE DOWN
The exact size of the problem is a subject of intense debate and study among economists. Trump’s new trade regime makes it even more complicated. The existing global trading system is based on applying a standard tariff on imports, and then granting goods from certain countries, or groups of countries, preferential access.
Under Trump’s new system, however, the U.S. will no longer have a standard non-preferential tariff, nor one of the world’s lowest tariff regimes. Instead, the charges on goods arriving from different countries could vary by as much as 40 percentage points, depending on where U.S. tariffs end up. Separate levies that Washington intends to apply on semiconductors and pharmaceuticals will add further complexity.
This raises the stakes for customs officials trying to determine where a product is from. So-called “rules of origin” were first introduced to help countries collect statistical data, and have proliferated over the past 30 years to support bilateral and regional free trade agreements. These rules are also supposed to help countries implement other policies, such as anti-dumping measures.
The classic rule of origin is based on the concept of “last substantial transformation”. This means the correct tariff depends on the country where the character of the product was last changed.
This principle sounds simple but is anything but. Take clothing. Say a company sends a Chinese-made shirt to Hanoi, adds a “Made in Vietnam” label, and then ships it to the United States while paying the lower Vietnamese tariff. Most trade lawyers would agree that is fraud. But what if brands making clothing in Vietnam like Nike NKE, Lululemon Athletica LULU and Fast Retailing’s 9983 Uniqlo, use dye, cotton, buttons or zips from China? Determining a product’s true origin becomes a complex and ever-changing mystery.
The U.S. Department of Commerce tries to clarify the difference using the example of mixed frozen vegetables and cookies. Vegetables which are grown in various places and taken to another country to be mixed and frozen were not substantially transformed, so the mixture must be labelled with the origin of each ingredient. But if sugar, dairy products, and nuts from different countries are made into a cookie, the country of origin is the location where the ingredients are baked or processed.
Today’s supply chains are much more globalised and complicated. For motor vehicles produced by Ford Motor F, General Motors GM and Stellantis STLAM, origin depends on the value of the contents. To qualify for the United States-Mexico-Canada Agreement, for example, at least 70% of a vehicle producer’s steel and aluminum purchases must originate in North America.
Tariffs can also vary depending on a product’s American content. U.S. Customs and Border Protection says for imports where at least 20% of the value is from the United States, the reciprocal tariff will not apply to the U.S. components.
Verifying the origin of goods requires cooperation. U.S. customs officials will get some help from countries including Malaysia, Thailand and South Korea, which are stepping up their effort to crack down on blatant re-labelling of goods. This is in their interest because cheap Chinese products are threatening to hollow out local industries.
Support for the U.S. measures will drop, however, if Trump is serious about trying to squeeze China out of supply chains. The People’s Republic accounts for nearly 29% of value added in U.S. imports from Cambodia, and almost 19% of those originating in Vietnam, according to research by Sonal Varma and Si Ying Toh at Nomura. Chinese investors are also big owners of factories across Southeast Asia.
OWN GOAL
Despite the proliferation of rules of origin, the World Trade Organization estimates that 74% of global trade still flows under its “most favoured nation” terms, a principle whereby member countries treat imports equally regardless of their origin. For now, it looks like other economies are moving in the opposite direction from the United States. The European Union and Indonesia are moving ahead on finalising a free trade deal; China has extended zero-tariff treatment to 53 African countries; while talks over an EU-India trade pact are slated to continue in September.
Trump could have satisfied some of his stated goals of reducing U.S. trade deficits, raising money and isolating China by imposing high duties on the world’s second-largest economy, and a single lower tariff on the rest of the world. Indeed, that may yet be where the president’s tariffs end up: On Wednesday, he said he would send letters to more than 150 “smaller” countries notifying them their tariff rates could be 10% or 15%. But that would still potentially leave more than 40 countries facing wildly diverging rates. Expect the new dirty word in trade – transshipment – to be used much more often in future.
Source: Reuters
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