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As global brands look to diversify their supply chains away from China, Vietnam and India have become top alternatives for manufacturing. However, one major challenge arises: How do you ensure your product qualifies as “Made in Vietnam” or “Made in India,” even if some materials or components originate from China?
The answer isn’t as simple as assembling the product in a different country. To legally and strategically claim Vietnamese or Indian origin, your product must meet strict rules of origin (ROO) under international trade laws. Getting this right is essential to:✅ Avoid tariffs and trade restrictions (like U.S. tariffs on Chinese goods)✅ Access free trade agreements (FTAs) for lower duties✅ Ensure compliance with customs regulations✅ Protect your brand from mislabeling penalties
This guide breaks down how to legally and strategically manufacture in Vietnam or India while meeting the origin requirements for global trade.
1. What Determines a Product’s Country of Origin?
The country of origin (COO) is not simply where the final assembly happens. Customs authorities use three primary criteria to determine whether a product qualifies as “Made in Vietnam” or “Made in India.”
A. Substantial Transformation Rule
A product is considered “Made in Vietnam” or “Made in India” if it undergoes a substantial transformation that results in a different product than its raw materials or components.
✅ Example:

• A steel rod imported from China is cut, machined, and turned into a bicycle frame in Vietnam → This qualifies as “Made in Vietnam” because the final product is fundamentally different.
• A laptop assembled in India using Chinese components but with locally manufactured casing and software integration → Could qualify as “Made in India” if enough value is added.

⛔ What does NOT qualify?

• Simply repackaging a product in Vietnam or India
• Assembling pre-manufactured parts without significant processing

B. Regional Value Content (RVC) Rule – Local Value Addition
For a product to be considered Vietnamese or Indian-made, a significant percentage of its value must come from within the country. This percentage is known as the Regional Value Content (RVC).
🔍 Typical RVC Requirements:

• 35% to 50% of the product’s total value must come from Vietnam or India.
• This includes local labor, materials, and processing costs.

✅ Example:

• A garment factory in Vietnam imports raw cotton from China but dyes, weaves, cuts, and stitches the fabric into finished jeans. Since most of the production value is added in Vietnam, it qualifies as “Made in Vietnam.”
• A furniture company in India imports raw wood from Malaysia but processes, assembles, and finishes the furniture in India—this qualifies as “Made in India.”

⛔ What does NOT qualify?

• Importing fully-made products from China and just adding minor touches (e.g., adding packaging or a label).
• Buying semi-finished goods from China and doing minimal processing in Vietnam or India.

C. HS Code (Harmonized System Code) Change Rule
Each product has a unique Harmonized System (HS) Code, which customs authorities use to classify goods.If the final product has a different HS Code from its imported raw materials or components, it may qualify as “Made in Vietnam” or “Made in India.”
✅ Example:

• Electronic components (HS Code 8542) are imported into Vietnam and transformed into a complete laptop (HS Code 8471) → This qualifies as “Made in Vietnam” due to the HS Code change.

⛔ What does NOT qualify?

• Assembling a product in Vietnam or India but keeping the same HS Code as its Chinese components.

2. How to Ensure Your Product is Truly “Made in Vietnam” or “Made in India”
If you’re shifting production from China to Vietnam or India, follow these five key strategies to ensure compliance:
1️⃣ Source More Materials Locally
The easiest way to meet RVC requirements is to source more raw materials and components within Vietnam or India.
✅ Example: Garment Manufacturing

• Instead of importing fabric from China, work with Vietnamese or Indian textile mills to produce the fabric locally.
• Vietnam has strong textile manufacturing, while India has a well-developed cotton industry.

✅ Example: Electronics Manufacturing

• Instead of importing all electronic components from China, source PCB boards, casings, and batteries from Vietnamese or Indian suppliers.

Pro Tip: Work with a local sourcing expert to find factories that can produce the components you need.
2️⃣ Increase Local Processing & Manufacturing
The more value-added processing that happens in Vietnam or India, the stronger the case for origin compliance.
✅ Focus on:

• Raw material processing (e.g., turning raw steel into finished parts)
• Component manufacturing (e.g., producing plastic casings instead of importing them)
• Final assembly and testing (critical for electronics and machinery)

3️⃣ Document Everything for Customs Compliance
To avoid customs disputes, keep detailed records of:✅ Bills of materials (BOM) showing where each component comes from✅ Manufacturing invoices proving value addition in Vietnam/India✅ Worker and factory labor costs✅ Any HS Code changes during production
Having these documents ready will protect your shipments from being flagged as Chinese-origin by U.S. or EU customs.
4️⃣ Register for Free Trade Agreement (FTA) Benefits
Vietnam and India have strong free trade agreements (FTAs) that allow products to be exported duty-free to the U.S., EU, and other key markets.
✅ For Vietnam:

• EU-Vietnam Free Trade Agreement (EVFTA)
• Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP)

✅ For India:

• India-U.S. Generalized System of Preferences (GSP)
• India-EU Free Trade Agreement (under negotiation)

To qualify, products must meet the ROO criteria, so plan your supply chain accordingly.
5️⃣ Work with Local Experts for Factory & Compliance Support
Shifting production without expert guidance is risky. To ensure full compliance, work with:✅ Local supply chain specialists to verify factories✅ Legal experts to confirm your country-of-origin status✅ Inspection teams to ensure manufacturing follows trade regulations
Final Thoughts: The Key to “Made in Vietnam” or “Made in India” Success
Manufacturing outside China isn’t just about setting up a factory elsewhere—it’s about building a compliant supply chain that meets trade regulations.
✅ Step 1: Plan your supply chain to maximize local value addition✅ Step 2: Ensure your product undergoes substantial transformation✅ Step 3: Keep detailed records to pass customs inspections✅ Step 4: Take advantage of FTAs to reduce export costs✅ Step 5: Work with local experts to stay compliant and competitive
Shifting production is a strategic move—get it right, and you’ll enjoy lower costs, fewer trade risks, and stronger market positioning.
👉 Need help verifying a supplier in Vietnam or India?👉 Want an expert to map out your supply chain?
Let’s talk. Asia Agent helps brands secure their manufacturing across Asia with on-the-ground expertise, supplier verification, and compliance support.
No middlemen, no hidden risks—just direct factory access with full support.
Ensure your products qualify as ‘Made in Vietnam’ or ‘Made in India’—avoid costly mistakes.
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