08/19/2026
🏭 A US TARIFF IS NOW PRICED ON YOUR SUPPLIER'S LABOUR PRACTICES, NOT ON YOUR PRODUCT.
For eight years, duties on Chinese goods were priced against what you imported. The 12.5% duty that took effect on 24 July is priced against how it was made.
Read that alongside UFLPA, which applies a rebuttable presumption to goods containing inputs from Xinjiang regardless of where final assembly happened, and the question changes shape. It stops being about your factory and starts being about your factory's suppliers.
The gap most brands have not closed: a company that moved assembly to Vietnam in 2024, kept the same component suppliers, and now calls itself diversified has changed its country of origin and little else. The presumption follows the input, not the assembly line. A detention rarely ends in a penalty. It ends in cargo sitting at port while you assemble documentation you never collected.
What component-level mapping requires:
- A written declaration of origin for each input, not for the finished goods
- Tier-2 suppliers named and located, in writing. A refusal is itself information about how much of the process your factory controls
- Traceability documents for the three highest-risk inputs: textile or yarn, electronic components, metals and minerals
- A contractual right to audit those inputs, agreed before the first PO. After a detention you have no leverage
You cannot map a full catalogue at once. Rank SKUs by import value, by how much of the bill of materials is textile, electronics or minerals, and by whether the origin changed in the last two years. Start with the top five.
How far down your supply chain can you go? Comment 1, 2 or 3.
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