Thailand's 2025 Trade Data Signals Transshipment Risk as US Customs Scrutiny Intensifies

Thailand's trade surplus with the United States surged to 51.3 billion US dollars in 2025, up from 35.6 billion dollars in 2024, while over the same period Thailand's trade deficit with China widened to 67.8 billion dollars, up from 45.3 billion dollars the year before. Reported together, as Bloomberg Law and other trade press outlets did in their 2025 coverage, those two figures moving in the same direction at the same time describe a pattern trade analysts associate with transshipment: Chinese-origin goods routed through Thailand with minimal local transformation, shipped onward to the US market under a Thai origin claim to access lower tariff treatment than a direct China-origin shipment would face. This is not a new legal action or a formal enforcement decision. It is a trade-data trend that has already prompted US Customs and Border Protection to intensify scrutiny of Thailand-routed imports, and it is a live compliance risk for any Thailand-based exporter relying on a certificate of origin to access preferential or standard US tariff treatment.

Reading the two numbers together

A rising Thai surplus with the US, on its own, could simply reflect genuine growth in Thai manufacturing and export capacity, and Thailand has real, substantial manufacturing sectors in electronics, automotive parts, food products, and industrial goods that have nothing to do with disguised Chinese origin. A widening Thai deficit with China, on its own, could simply reflect Thailand importing more raw materials, components, and intermediate goods from its largest single trading partner to feed genuine domestic manufacturing. It is the combination and the pace of both moving together, a nearly 45 percent jump in the US surplus in a single year alongside a nearly 50 percent jump in the China deficit, that trade analysts flagged as consistent with a transshipment pattern: goods entering Thailand from China, undergoing limited processing or repackaging, and departing for the US market under a Thailand-origin declaration.

Lexology's 2026 Thailand export outlook coverage and Kaohoon International's reporting both framed this data pattern as the basis for intensified US Customs and Border Protection review of imports suspected of being transshipped through Thailand specifically, rather than treating it as background noise. That enforcement posture is what turns a macroeconomic data point into an operational compliance risk for individual Thai exporters, because CBP's transshipment enforcement tools (including forced entry holds, requests for detailed supply chain documentation, and after-the-fact penalty actions) apply at the level of individual shipments and individual exporters, not at the level of national trade statistics.

The tariff gap that makes this pattern financially rational to exploit, and risky to be caught in

The trade data pattern matters as much as it does because of how large the tariff differential has become between genuine Thai-origin goods and goods that fail to meet rules-of-origin or local-content standards. Thailand's baseline US tariff rate has moved more than once since its October 2025 framework agreement first set it at 19 percent, down from an earlier 36 percent: after the Supreme Court struck down the underlying IEEPA tariff authority in February 2026 and a brief 10 percent Section 122 stopgap tariff was itself invalidated, Thailand has faced a 12.5 percent tariff since July 24, 2026 under a new Section 301 action tied to forced-labor enforcement. Whatever the current baseline rate, goods that cannot substantiate genuine Thai origin, and that US Customs and Border Protection determines were transshipped to disguise a higher-tariff country of origin, face a flat, additional 40 percent transshipment penalty tariff, a separate and non-negotiable enforcement mechanism that sits on top of, not in place of, the baseline rate. That roughly 27.5-percentage-point gap between the current 12.5 percent baseline a genuinely Thai-origin good receives and the 40 percent transshipment penalty is exactly the kind of tariff arbitrage opportunity that drives bad-faith transshipment activity in the first place, and it is also exactly why CBP has an incentive to scrutinize Thailand-routed trade more closely than it might a country without that kind of surplus-and-deficit signature.

The practical difficulty for a legitimate Thai exporter is that CBP's enforcement lens does not distinguish, at the moment a shipment is flagged for review, between a company deliberately laundering Chinese-origin goods through minimal Thai processing and a company that performs genuine, substantial manufacturing in Thailand but has never built the documentation to prove it quickly. Both companies get pulled into the same enforcement review process, and the burden of proof in that review falls on the exporter or importer to substantiate the origin claim, not on CBP to disprove it. A company with strong underlying manufacturing but weak paperwork can end up facing the same practical consequences, delayed shipments, tariff reclassification, penalty exposure, as a company genuinely engaged in transshipment fraud, simply because it cannot produce a bill-of-materials and value-content analysis fast enough during a review.

What this means for Thailand-based exporters right now

Any Thailand-based exporter shipping toward the US market, particularly in product categories where China is a major low-cost manufacturing base for similar goods (electronics, industrial components, textiles, and increasingly regulated products like medical device parts or cosmetic ingredients with Chinese-manufactured inputs), should treat the current environment as one where a US Customs review of Thailand-origin shipments is a real possibility, not a remote hypothetical. The trade data trend behind this update is not a one-time event with a fixed resolution date; it describes an ongoing condition through 2025 and into 2026 that shapes how aggressively CBP is likely to scrutinize Thailand-routed trade for the foreseeable future, independent of any single enforcement action.

The direct response to this risk is documentation, not a change in where or how a company actually manufactures, provided the manufacturing itself is genuine. A Thai exporter whose product legitimately qualifies as Thailand-origin under the applicable rule of origin needs a bill-of-materials and value-content analysis on file that can substantiate that claim quickly if a shipment is questioned, along with a clear understanding of whether its current certification approach (electronic Form D or self-certification, depending on the trade agreement involved) matches the strength of that underlying documentation. DeeMED has covered the mechanics of that documentation process in detail in its companion guide on rules of origin and certificate of origin procedures for Thai exporters; this update is meant to establish why that documentation discipline is not an abstract best practice but a response to a specific, currently escalating enforcement environment.

This is not a hypothetical risk: a named case and Thailand's own enforcement numbers

The trade-data pattern described above is not the only evidence behind this update. On May 13, 2025, US Customs and Border Protection preliminarily determined that Boly Pipe Co., Ltd., a Thai company, had transshipped Chinese-origin oil country tubular goods (OCTG, steel pipe used in oil and gas drilling) through Thailand specifically to evade existing antidumping and countervailing duties on Chinese OCTG, which stood at 99.14 percent antidumping and 27.08 percent countervailing. CBP's determination named two US importers, Commercial Steel Products LLC and JOL Tubular, Inc., with JOL identified as a Boly Pipe affiliate, and found that all of the entities involved traced back to a single Chinese OCTG producer. This is precisely the enforcement pattern the trade-data trend predicts: real duty evasion, using Thailand as the routing point, caught and acted on by CBP using exactly the kind of supply-chain and ownership analysis a Thai exporter now has to be prepared to survive if its own shipment is ever flagged for the same review.

Thailand's own customs authorities are responding to the same pressure from their side of the border, with Thai Customs and the Department of Foreign Trade jointly disclosing a substantial and growing body of false-origin enforcement cases at Laem Chabang port through 2026, detailed in DeeMED's companion update on that enforcement record. Read together, the CBP case against Boly Pipe and Thailand's own port-level enforcement numbers confirm that both the destination-country and origin-country customs authorities are actively working this exact fact pattern right now, not simply reacting to a data trend after the fact.

DeeMED's Global Trade compliance services help Thailand-based exporters build and maintain the origin documentation that stands up to exactly this kind of intensified US Customs review, so a legitimate Thailand-origin claim can be substantiated quickly rather than getting caught in the same scrutiny aimed at genuine transshipment activity like the Boly Pipe case.