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

The global trade environment for Thai exporters in 2026 has shifted significantly. Recent enforcement developments in both the United States and the European Union show a clear shift in trade policy: regulators are no longer focused solely on tariff levels, but also on whether products genuinely originate where exporters claim they do. Adding to this complexity, the US Supreme Court’s February 2026 decision striking down the use of the International Emergency Economic Powers Act (IEEPA) to impose tariffs has upended the legal basis for a major pillar of US tariff policy, creating significant legal and commercial uncertainty for exporters worldwide, including in Thailand. For Thai companies integrated into regional supply chains, this change carries material implications. Although the IEEPA-based US reciprocal tariffs have been struck down, intensified circumvention enforcement continues under separate legal authorities, and the administration has signaled its intent to reimpose tariffs under alternative statutory frameworks, while EU authorities are using anti-circumvention investigations where trade patterns shift. In both jurisdictions, the decisive issue is whether manufacturing in Thailand constitutes substantial transformation under applicable rules of origin. Such origin determinations increasingly drive duty exposure, audit risk and commercial disputes. In 2026, the ability to defend a product’s Thai origin is not merely a procedural step, it is central to preserving market access in the US and EU. Impact Of US Circumvention Enforcement and an Uncertain Tariff Landscape Following the 2025 Framework for an Agreement on Reciprocal Trade, Thailand saw a shift in its tariff relationship with the US. A substantial range of Thai-origin goods were subject to a 19% reciprocal tariff under the IEEPA. However, the Supreme Court’s ruling invalidating the use of IEEPA for tariffs has removed the legal basis for that rate. The Administration has indicated it intends to pursue replacement tariffs under other statutory authorities,

In March 2026, the United States Trade Representative (USTR) initiated two significant investigations under Section 301(b) of the Trade Act of 1974 that directly affect Thailand. The first investigation examines overproduction in manufacturing sectors caused by government support or policies that distort normal market conditions across 16 economies, including Thailand. The second investigation, launched the following day, targets 60 economies, also including Thailand, for alleged failures to impose and effectively enforce prohibitions on the importation of goods produced with forced labor. Taken together, these investigations represent a significant escalation in US trade enforcement and create substantial risk for Thai exporters, manufacturers, and businesses with supply chain connections to the United States. The investigations are moving on an accelerated timeline, with the USTR indicating that potential trade measures, including tariffs, could be imposed as early as July 2026. This article provides an overview of the investigations, highlights their specific implications for Thailand, and outlines practical considerations for affected businesses. Section 301 as a Trade Enforcement Tool Section 301 of the Trade Act of 1974 gives the USTR authority to investigate foreign acts, policies, or practices that are considered unreasonable or discriminatory and that burden or restrict US commerce. If the USTR concludes that such practices exist, the statute allows a wide range of remedial measures, including the imposition of tariffs, nontariff trade restrictions, and negotiated agreements with foreign governments. Unlike other trade authorities, Section 301 does not set limits on the level of tariffs or the duration of measures, giving the USTR considerable flexibility to address perceived trade imbalances or unfair practices. Historically, Section 301 investigations take up to a year to complete. In this instance, however, the USTR has indicated that the investigations will proceed on a much faster timetable, with an unofficial target of concluding by July 2026.

On March 30, 2026, Thailand’s Customs Department announced a strategy to raise import duties on a broad range of consumer goods—including plastic items and electronics accessories—to their maximum statutory ceilings, which often sit at 30% or 40%. Many of these goods currently benefit from promotional or incentive rates as low as 5%. For importers, e-commerce platforms, and logistics providers, this development demands immediate attention. While these increases generally require cabinet approval, they do not require full parliamentary amendment of the Customs Tariff Decree B.E. 2530, as the Customs director-general and the finance minister hold delegated authority to adjust rates within existing statutory bounds. Businesses should not assume that the legislative process will provide significant lead time before higher rates take effect. Death of the De Minimis: Abolishing the THB 1,500 Loophole This “ceiling-rate” policy, which is designed to equalize the landed cost of foreign goods with the domestic production costs of Thai manufacturers, builds on a sweeping set of customs reforms that have already begun to reshape Thailand’s trade environment. The foundation of this new regime was laid on January 1, 2026, when Thailand formally abolished the longstanding THB 1,500 duty exemption for small imported parcels under Customs Notification No. 219/2568. Every imported item is now subject to VAT and applicable import duties for its declared value, regardless of parcel size or transaction amount. By narrowing the scope of exemptions previously granted to low-value goods under the Customs Tariff Decree B.E. 2530, the government has made clear that the era of tax-free cross-border micro-imports is over. Three-Phased Strategy and Legal Modernization The March 30 announcement is the second phase of a three-part regulatory roadmap: Immediate enforcement: The removal of the THB 1,500 loophole and the imposition of VAT on all parcels, effective January 1, 2026. Tariff realignment: The current