You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

May 22, 2026

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.

RELATED INSIGHTS​ 

October 20, 2025
Global trade has become an everyday issue with immense effects on trade and the economy. Today’s global trade climate sees countries around the world engaged in trade negotiations aspiring to eliminate trade barriers. Customs tariffs and associated privileges are among the issues that most impact global trade flows and the import-export sector. Thailand has negotiated customs tariff privileges as part of its 14 free trade agreements (FTAs) with 18 countries, including six bilateral and eight regional agreements. These FTAs set forth criteria for member states to comply with and adopt into national law. To achieve customs privileges, one of the most important criteria is rules of origin, which indicate the originating country of imported or exported goods and the accompanying duty rates or privileges for reduction or exemption. Rules of Origin Under FTAs The rules of origin mapped out in FTAs allow for duty exemptions or rate reductions based on the determination of goods’ country of origin. This largely includes two main categories: Wholly obtained (WO) means the product was entirely produced in a single originating country and does not include any foreign (non-originating) content or manufacturing process. Product specific rules (PSR) are detailed criteria that define how each product’s origin is determined. PSR criteria that are often found in FTAs include “change in tariff classification” (determining origin based on sufficient transformation of materials), “regional value content” (requiring a minimum percentage of value to be added locally), and specific manufacturing or processing operations (mandating particular production steps occur in the originating country). These criteria also extend to cover other subordinated methods of verification, such as accumulation rules and de minimis rules, to provide more flexibility for the establishment of origins and tariff privileges under such FTAs. Compliance Challenges Despite attempts to promote international trade and eliminate trade barriers through
October 17, 2025
The Department of Trade under Myanmar’s Ministry of Commerce (MOC) issued a schedule of revised service fees for trade-related services, effective October 15, 2025. The revised fees are contained in Newsletter of Export/Import 6/2025, which supersedes the previous rates set out in 2018 and 2020. Service Fees The revised fees include the following: Annual fee for TradeNet 2.0, the MOC online platform for trade submissions: MMK 50,000 (approx. USD 23.81) Online service application fee: MMK 10,000 (approx. USD 4.76) Import or export license renewal (including for all imported goods exempt from the license fees): MMK 50,000 (approx. USD 23.81) for initial renewal (two months) MMK 30,000 (approx. USD 14.29) for second renewal (one month) Amendment of license information: MMK 10,000 (approx. USD 4.76) per amendment Return of export/import license: MMK 30,000 (approx. USD 14.29) Late fees for renewal/amendment of import or export license: MMK 5,000 (approx. USD 2.38) if within one month of expiry MMK 10,000 (approx. USD 4.76) if later than one month after expiry Submission Schedule License renewal applications submitted more than 14 days after the license expiration date will not be processed. Applications for license amendment must be submitted in advance of the relevant goods’ arrival at Myanmar ports or airports. For more information on this announcement, or on any aspect of import and export matters in Myanmar, please contact Tilleke & Gibbins at [email protected].
August 21, 2025
On August 19, 2025, the Trade Competition Commission of Thailand (TCCT) released its draft Guidelines on the Consideration of Unfair Trade Practices and Conduct Constituting Monopoly, Reducing Competition, or Restricting Competition in Multi-Sided Platform Businesses in the Category of Digital Platforms for the Sale of Goods or Services (E-commerce). A public comment period on the guidelines is open until September 18. The draft provides the first detailed framework for how the TCCT will interpret and enforce the substantive provisions under the Trade Competition Act against digital platforms, which have a unique network effect and require complex competition analysis. This development will profoundly impact the operations of e-commerce platforms, sellers, and associated service providers in Thailand. The guidelines primarily target e-commerce digital platform business operators, which are defined as follows: E-commerce digital platform: A medium facilitating the sale, purchase, or exchange of goods or services, including any operations to create transactions or interactions between business operators via an electronic transaction system, regardless of whether service fees are charged. E-commerce digital platform business operator: A service provider of a digital platform for the sale of goods or services who acts as an intermediary facilitating the sale of goods or services, including any operations to create transactions or interactions through an electronic transaction system by receiving orders for goods or services transacted via an electronic system, whether in the form of an e-marketplace, a social marketplace, or any other form that connects purchase orders for goods or services with business operators through an electronic system. Prohibited Conduct The guidelines classify potentially anticompetitive conduct and unfair trade practices into two categories: price-related and non-price-related conduct. 1. Price-related conduct The TCCT is targeting pricing strategies that can harm competition. Key prohibited behaviors include: Price below cost: Setting prices below the average total cost without
August 19, 2025
On August 6, 2025, Myanmar’s National Defence and Security Council (NDSC) issued Order No. 20/2025, announcing a change in the composition of the country’s Foreign Exchange Supervisory Committee (FESC). The prime minister has been appointed committee chair of the FESC, and five other individuals were appointed to the committee. The order took immediate effect. Originally established in April 2022, the FESC is responsible for approving foreign currency conversion, granting exemptions to foreign exchange restrictions, and permitting overseas transfers of foreign currency. The FESC supervises the flow of foreign currencies for domestic and foreign investment, manufacturing, exports and imports, and service businesses (including education- and health-related initiatives). The FESC is specifically responsible for considering and approving the use of foreign currency for the following: Importing machinery, vehicles, equipment, and raw materials essential for foreign investment and manufacturing projects; Importing fuel, medicine, cooking oil, fertilizer, insecticide, and construction materials not readily available on the domestic market; Covering Myanmar citizens’ needs abroad, such as medical treatment, education, or religious activities; Facilitating imports of general goods, loan repayments, interest payments to foreign lenders, service payments, and profit repatriation from investments; and Importing luxury products, including brand-name goods, jewelry, sports cars, and watches. The FESC is empowered to carry out further duties related to foreign exchange management as assigned by the NDSC Importers, exporters, investors, and business owners are encouraged to consult the most current FESC guidelines and approval lists before conducting transactions in Myanmar. For more details on these FESC composition developments, or on any aspect of financial regulations in Myanmar, please contact Tilleke & Gibbins at [email protected].