Colombia is on the US Risk Map Over Trade Triangulation Linked to China

One way for Chinese goods to reach the United States is for producers from the Asian giant not to do so directly, but rather to use third countries in a process known as transshipment. In this way, some Chinese exporters evade U.S. taxes.

The White House Office of Trade and Manufacturing Policy published the report The Great Transshipment Scam last August, identifying more than 40 economies associated with a high risk of illegal transshipment of goods linked to China. And Colombia appears there.

The document explains that operations to evade U.S. duties may include relabeling, repackaging, reinvoicing, minor processing or false declarations of origin so that goods subject to higher tariffs enter the North American country from jurisdictions with more favorable treatment.

For this reason, according to an analysis by the Colombian American Chamber of Commerce (AmCham) on this issue, Washington is moving from focusing solely on imposing higher tariffs on China to more closely monitoring how goods reach the U.S. market and where their productive transformation actually takes place.

“It is not simply a matter of a Chinese product passing through a third country,” AmCham warns. “The problem arises when that country is used to conceal or artificially modify the economic origin of the merchandise in order to access a more favorable tariff. Therefore, the United States seeks to differentiate between legitimate production and operations in which the documentation, packaging or a minor stage of the production process is primarily changed.”

Classification of countries in illegal transshipment

The report classifies countries at risk of illegal transshipment into three levels. The first is the one with the greatest exposure to trade linked to China. These include the economies of Canada, the European Union, India, Israel, Japan, Mexico, South Korea and Taiwan.

Regarding them, the report says they are economies with large absolute volumes of goods linked to China, diversified industrial bases and important export platforms to the United States. The risk of transshipment appears mixed with large flows of legitimate trade.

The second level includes manufacturing hubs integrated with China, and these are Brazil, Indonesia, Malaysia, Thailand, Turkey and Vietnam. For the United States, these economies present significant volumes of potential transshipment and deeper integration with supply chains, inputs, manufacturing and logistics linked to China.

Then there is the third level, with smaller destinations and opportunities for redirection. It includes Argentina, Azerbaijan, Bangladesh, Cambodia, Chile, Colombia, Costa Rica, the Dominican Republic, Georgia, Jordan, Kazakhstan, Kenya, Laos, Morocco, Myanmar, Oman, Panama, Peru, the Philippines, Singapore, Sri Lanka, Switzerland, the United Arab Emirates and Uzbekistan.

The report considers these to be economies with lower absolute volumes of potential transshipment, but they have advantages that could be used to redirect Chinese goods, such as lower-cost labor, free trade zones, port or border access, customs warehouses, assembly capacity, preferential access to the United States or more limited customs capabilities.

The case of Colombia draws attention because, according to AmCham, in addition to being at level three of the report, it also appears alongside Argentina, Brazil, Chile and Peru within the so-called “Latin American corridors,” associated with routes through the Pacific and Atlantic, customs storage and regional assembly.

U.S. attention to logistics and production

“This shows that U.S. attention is not limited to the volume of trade with China, but also to the logistical and productive role that these countries can play before merchandise reaches the United States,” AmCham points out. “[…] The classification indicates that Washington identifies conditions that could facilitate this type of operation and, therefore, that certain supply chains could receive greater scrutiny, especially when they involve goods or inputs originating in China.”

But AmCham is clear in warning that this does not mean that the United States is accusing Colombia of carrying out illegal transshipment or that its exports are automatically under suspicion. “Nor does it imply that they are subject to the 40% surcharge, which only applies to merchandise that CBP determines was transshipped to evade tariffs,” it emphasizes.

Colombia’s trade relationship with China increases the relevance of the issue, according to AmCham, because, according to DANE, China was the main source of Colombian imports in the first half of 2026, accounting for 28.5% of the total and purchases worth US$10.8372 billion, that is, 23.3% more than a year earlier. The United States ranked second, with 23.0%.

“In June alone, purchases from China grew 35.0%,” AmCham notes. “A large part of those imports corresponds to manufactured goods, machinery and other goods that can later be incorporated into local production processes. In the first five months of the year, the increase was driven mainly by vehicles for transporting people and laptop computers.”

And it warns again: “This does not constitute transshipment, but it expands the number of supply chains in which Chinese inputs, processing in Colombia and subsequent exports to the United States can coexist, increasing the importance of clearly demonstrating where the added value was generated.”

The analysis warns that Colombian companies that could face greater exposure are mainly those that import Chinese goods or components and carry out limited processes in Colombia before exporting them to the United States.

Likewise, operations based on simple assembly, repackaging, labeling, storage or re-exporting could receive greater attention if there is insufficient evidence of substantial productive transformation. “The report even proposes using installed capacity, suppliers, routes, length of stay and production data to assess the authenticity of the declared origin,” AmCham highlights.

Under these circumstances, the best thing companies can do is be able to demonstrate the origin of their components, the processes carried out in Colombia, the local added value and the transformation supporting the Colombian origin of the product.

Recommendations for Colombian exporters

The U.S. strategy proposes strengthening this analysis through artificial intelligence tools that make it possible to cross-reference trade data, routes, production capacity and relationships among suppliers. This issue could gain relevance in the negotiation of the Reciprocal Trade Agreement that Colombia and the United States agreed to accelerate in August.

Faced with this scenario, AmCham recommends that exporting companies review the following areas:

• Supplier map. Identify the origin of inputs not only from the direct supplier, but also from the second and third levels of the supply chain.

• Origin file. Document, before shipment, the production processes carried out in Colombia, the local added value and the traceability of the components.

• Contracts. Review declarations of origin, guarantees and indemnity clauses with suppliers and buyers.

• Operations in free trade zones. Verify the traceability of merchandise entering free trade zones or warehouses and leaving destined for the United States.

• Regulatory monitoring. Monitor the negotiation of the Reciprocal Trade Agreement and possible changes in rules of origin.