Following the release of the "2026 Special 301 Report" by the Office of the United States Trade Representative (USTR) on April 30, 2026, which listed Vietnam as the first "most serious concern" country in 13 years, on May 29, U.S. Trade Representative Jamieson Greer officially announced an investigation into Vietnam's actions, policies, and practices regarding intellectual property protection and enforcement under Section 301 of the "Trade Act of 1974".
This is the third U.S. 301 investigation Vietnam has faced since 2026; previously, the U.S. side initiated investigations against Vietnam citing "overcapacity in manufacturing" and "failure to prohibit imports of forced labor products".
Focusing on the intellectual property field this time, the scope of review covers five major issues including online piracy, counterfeit goods, and border enforcement. According to legal provisions, the USTR must make a decision within 6 months of the investigation launch, no later than November 29, 2026, with a possible extension to the end of February 2027 under exceptional circumstances.
Vietnam Tire Exports Face Dual Pressure
Vietnam's tire industry has become the focal point of this trade friction. In 2024, Vietnam's tire production ranked sixth globally, with approximately 90% used for export, totaling about 4 billion USD in annual export value, with North America being the most important market.
However, in July 2025, the U.S. Department of Commerce launched an annual administrative review of anti-dumping and countervailing duties on five categories of exported products from Vietnam, covering light truck tires.
Since 2021, the U.S. has implemented "double anti" policies on passenger car and light truck tires from South Korea, Thailand, Vietnam, and the Taiwan region of China. Vietnam is the least affected region, with some enterprises having a tax rate of 0%, while others are at 22.30%.
Once the new round of 301 investigations take effect, this relatively favorable situation may be disrupted, leading to Vietnam's tires exported to the U.S. facing additional high tariffs.
Chinese-Invested Tires Face "Origin" Look-Through Review Risks
Currently, several top Chinese tire enterprises including Sailun, Guizhou Tire, Jinyu Tire, Haohua Tire, and Zhongce Rubber have established factories in Vietnam and continued capacity expansion.
Since 2026, Guizhou Tire's Phase III PCR project has completed its first container shipment, Haohua Tire increased its Phase II investment by 400 million USD, and Zhongce Rubber also announced an investment of 1.041 billion yuan to build a new factory in Ho Chi Minh City.
However, the core risk of the 301 investigation lies in the possibility that the U.S. may significantly tighten the criteria for "Vietnam Origin" certification, especially targeting enterprises that heavily rely on Chinese imports for key raw materials (such as rubber additives, cord fabric, and semi-finished tire blanks).
If insufficient processing depth is determined, the U.S. may retroactively levy anti-dumping duties originally targeting Chinese tires. This will directly weaken the tariff advantage of "Made in Vietnam," and even lead to the risk of past years' profits being reversed.
Forcing Vietnam Tire Supply Chain "De-Chinaization"
After the investigation enters the procedure phase, Chinese-invested tire enterprises in Vietnam will face the practical impact of "customs clearance suspension" and order contraction. U.S. importers, to avoid capital occupation and legal risks, may suspend purchases, leading to finished goods inventory backlog at Vietnam factories, decreased capacity utilization, and pressure on cash flow.
In the long term, to pass origin review, enterprises must significantly increase the local procurement rate of Vietnam factories and reduce parts imports from China. This means reconstructing an independent supply chain system in the short term, involving substantial capital expenditure and management costs, posing a severe test for SMEs with tight cash chains.
Global Leaders with Layout Have Stronger Risk Resistance
This 301 investigation will profoundly reshape the competitive landscape of tire enterprises in Vietnam. Small tire factories that only use Vietnam as a "simple assembly point" and lack full-process production lines and complete traceability management systems will face the risk of being cleared out of the U.S. market.
Conversely, top enterprises with a layout at multiple points globally can alleviate losses to Vietnam factories by flexibly allocating orders and transferring supply tasks for the U.S. market to bases not subject to investigation.
Overall, the U.S. 301 investigation on Vietnam is essentially an extension of its trade friction against China in the Southeast Asia region. For Chinese tire enterprises investing in Vietnam, this is no longer a question of "whether it will be affected," but an urgent topic of "how deep the impact is" and "how to respond"!
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