US tariffs on SPC flooring from Vietnam in 2026: what applies today

What duty applies to SPC flooring from Vietnam today?

Two layers, both charged on the same customs value: the 5.3% general rate for HTS 3918.10.10 and the 12.5% Section 301 duty on products of Vietnam. That is 17.8% before fees, as of 26 October 2026. Rigid-core vinyl tile normally sits at statistical line 3918.10.10.20.

The rate is the easy part. The harder questions are who carries the 12.5% if it changes, and what could hit a Vietnamese floor next. Most of this page is about those.

Layer	Rate	Applies to	Source	Confidence
General (MFN) duty, HTS 3918.10.10	5.3%	Vinyl tile, including rigid-core SPC	USITC HTS, Revision 21 (2026)	Confirmed
Section 301 forced-labour duty, heading 9903.05.84	+12.5%	All products of Vietnam, unless listed in an exemption	Federal Register, 91 FR 47318; USITC HTS	Confirmed
Exemption for heading 3918 from the 12.5%	None found	Not in the U.S. note 52 exemption lists	USITC HTS Chapter 99, Revision 21	Our reading; confirm with broker
Section 301 China duty, heading 9903.88.03 (List 3)	+25%	Chinese-origin goods only, including 3918.10.10	USITC HTS Chapter 99, note 20(f)	Confirmed
AD/CVD on vinyl flooring from Vietnam	None found	No order or petition found	Federal Register search, Jan 2024 to Oct 2026	Confirmed as of date (absence of a record)
2025 “reciprocal” (IEEPA) tariffs	Not in force	Voided by the Supreme Court, 20 Feb 2026	Court decision, as reported	Confirmed
Section 122 temporary surcharge	Ended	Replaced by the Section 301 action on 24 Jul 2026	USTR release, 23 Jul 2026	Confirmed

The 12.5%: what is settled and what is not

USTR announced the action on 23 July 2026 against 60 economies it found had not banned, or not enforced a ban on, imports made with forced labour. It applies to goods entered from 24 July 2026 and replaced the Section 122 surcharge. Vietnam is in the 12.5% tier, with exemptions only as listed in the annexes.

What is settled: U.S. note 52 says the new duty stacks on top of the normal rate and generally on top of other Chapter 99 duties, and it does not displace AD/CVD duties or fees. We read the exemption lists in Revision 21 (effective 9 October 2026) and heading 3918 is not in them. The listed exemptions cover things like certain raw materials, civil aircraft, pharmaceutical inputs and Section 232 metals.

What is not settled: the challenges were argued at the Court of International Trade on 30 September 2026. Trade press reports the court asked for more briefing in October. We found no ruling by 26 October, and CBP is still collecting.

How we would read the next 12 months

These are scenarios, not predictions. We do not know which one happens. The point is to decide in advance what each would mean for your price and your contract.

Scenario	What would trigger it	What it means for a Vietnam SPC buyer	What we would do now
12.5% stays	No ruling, or a ruling for the government	17.8% remains the working stack	Price on 17.8%. This is the base case for quoting
12.5% struck down	A court ruling against the action	The stack could fall to 5.3%, and past duty may be refundable; nobody can promise either	Keep entry records in full. Agree now who gets any refund
A new US action aimed at Vietnam	Our research indicates USTR opened a separate Section 301 investigation into Vietnam’s IP practices in May 2026 (graded probable)	A further layer is possible; its size is unknown	Keep a duty clause that covers new duties, not only changes to the 12.5%
A trade case on vinyl flooring	A petition on SPC or LVT from Vietnam; plywood from Vietnam already got final AD/CVD in July 2026	Case-specific deposits on top of the stack, possibly large	Check the Federal Register before each contract. Keep origin and cost records ready
A UFLPA hold on your container	Resin traced, or not disproved, to Xinjiang	No duty change, but the container can sit at the port	Get the resin file before shipment, not after detention

Our reading: the court result gets the attention, but the bottom two rows are the ones that can cost a buyer more than 12.5 points. A struck-down duty helps everyone at once. A trade case or a detention hits the buyers who were not ready.

How we would put tariff risk in a quote and a contract

In the quote. Show duty as its own line, with the rate, the HTS line and the date it was checked. Never fold it into a single “landed” figure. If a customer or a sales team sees one number, they will not notice when its biggest moving part changes.

Price on the duty in force, not the hoped-for refund. We would not discount a contract on the chance of a court win. If the 12.5% goes, that is a margin gain you can share later. If you priced it out and it stays, you carry the loss on every container.

In the supply contract. On FOB or ex-works terms the factory pays no US duty, so a duty clause there is about price, not payment. We would write three things:

• A price review if a new US duty, an AD/CVD order or a change of more than an agreed amount to an existing duty takes effect on the floor in the contract.
• A cap on how long a quoted price holds, tied to shipment date, so a long programme is not frozen on today’s duty.
• A factory duty to supply the origin and resin records in the format your broker needs, as a condition of shipment.

In your own sales contracts. If you sell on to US retailers or contractors with duty baked into the price, decide now who owns a refund if the 12.5% is struck down. This is where we expect most arguments if the ruling goes against the government. A line in the contract today is cheaper than a dispute later.

On DDP offers. All-in DDP prices from Vietnam put the duty out of your sight. Buyers we have read describe DDP as hard to check. If you accept one, ask for the entry summary that shows what was declared and paid. You still want the floor entered at its real value and origin.

Worked example: what the 12.5% costs, and who carries it

This shows the method. It is not a quotation. It uses an example customs value of USD 20,000 for one container of SPC in 3918.10.10. Each duty layer is a percentage of the same customs value; you add them.

Line	Vietnam origin	China origin
Example customs value	USD 20,000	USD 20,000
General duty, 5.3%	USD 1,060	USD 1,060
Section 301 China, 25%	Not applicable	USD 5,000
Section 301 forced labour, 12.5%	USD 2,500	USD 2,500
Total duty	USD 3,560	USD 8,560
Duty as % of customs value	17.8%	42.8%

Now take a 12-month programme of 10 such containers from Vietnam. The 12.5% layer alone is USD 25,000 of duty. That is the amount that rides on the court case, and the amount your refund clause decides.

Per square metre, the same logic holds. At an example customs value of USD 8.00/m², the 12.5% is USD 1.00/m² and the full stack is about USD 1.42/m². If your sell price to a retailer was set before 24 July on a 5.3% basis, that is roughly the margin you lost per square metre.

Two errors we would look for in any landed-cost sheet. First, the 12.5% charged on value plus the 5.3%, which overstates the duty. Second, the duty charged on a CIF figure. US customs value is usually based on the price actually paid, with ocean freight and insurance generally excluded, though some costs such as assists or certain commissions can be added. Your broker confirms the value and adds the merchandise processing and harbor maintenance fees.

Vietnam versus China: what the 25 points really buy

Vietnamese origin pays about 25 percentage points less than the same floor of Chinese origin. China keeps the 25% List 3 duty that has applied to vinyl flooring since 2018 and 2019; an earlier click-vinyl exclusion has expired.

Origin	General duty	Section 301, China (List 3)	Section 301, forced labour	Total ad valorem duty
Vietnam	5.3%	Not applicable	12.5%	17.8%
China	5.3%	25%	12.5%	42.8%
Difference				25 points

The totals are our arithmetic from confirmed components. In our view, the 25 points are not a feature of the country. They are the value of the origin evidence behind your entry. A floor you cannot prove was made in Vietnam carries China-level risk, whatever the label says. Our guide to who owns Vietnam’s SPC factories covers the substantial transformation test and the records that support it.

Trade remedies, UFLPA and EAPA

We found no anti-dumping or countervailing order, petition or EAPA determination on vinyl, SPC or LVT flooring from Vietnam in Federal Register notices since January 2024. A search can miss a notice worded differently, so check again before a large contract. Two nearby cases matter: the July 2026 plywood orders on Vietnam, and the China multilayered wood flooring orders, which can reach a real wood veneer over a composite core (our research grades this as probable). A “hybrid” with a wood layer needs a scope opinion.

Rule	What it targets	What it means for SPC from Vietnam
Uyghur Forced Labor Prevention Act (Public Law 117-78)	Goods made wholly or in part in Xinjiang, or by listed entities, presumed barred	Applies wherever the floor was finished. The risk sits in the PVC resin. Rebuttal needs clear and convincing evidence
Enforce and Protect Act (19 U.S.C. 1517)	Evasion of an AD or CVD order by false statement or omission	Only bites where an order covers the goods, so mainly wood-veneer products today
Country of origin rules (19 CFR 134)	The origin declared on the entry	Records of where the floor was made or substantially transformed

US and Vietnamese customs held a workshop on production checks in July 2026 (our research grades this as probable). For an honest buyer the answer does not change: the factory’s resin and production records are part of the product.

Checklist before the first order ships

• 10-digit HTS line for each product confirmed by the broker, with wall panels classified separately
• Chapter 99 headings: 9903.05.84 for Vietnam origin, plus 9903.88.03 for any Chinese-origin item
• Note 52 exemption lists checked against your headings at the date of contract
• Origin evidence and resin purchase records named as shipping documents in the purchase order
• Duty-change and price-validity clauses in the supply contract
• Refund ownership agreed in your own sales contracts
• Wood-veneer or hybrid products flagged for an AD/CVD scope check

Common mistakes

1. Quoting old rates. The 2025 “reciprocal” rates and the Section 122 surcharge no longer apply. Check the date on any rate you use.
2. Multiplying layers. The 12.5% is charged on the customs value, not on the value plus the 5.3%.
3. Pricing in the refund. Discounting on a hoped-for court win puts the whole risk on your margin.
4. Leaving refund ownership unwritten. If the duty goes, the money will be argued over by whoever did not write it down.
5. Taking origin on trust. The port of loading and the brand owner do not decide origin. Manufacture does.
6. Getting the resin file after detention. By then the container is already earning storage charges.

Our view

Quote on 17.8% for Vietnamese-origin SPC under 3918.10.10, as of 26 October 2026, with duty as its own dated line. Do not bet a contract on the court case. Spend the effort on the risks the court cannot fix: a new trade case, and a container held over resin.

The supplier choice is where most of that risk is decided. The factory directory shows the legal entity and production site behind each brand, for example NEO FLOOR, Huali Group Vietnam and AMY. Our team in Hanoi can help with factory selection and production management, including getting the origin and resin records written into the order.

Questions buyers ask

Who pays the US duty on an FOB order from a Vietnamese factory?

The importer of record, normally you. Under FOB or similar terms the factory never touches US duty. Under DDP the seller or its agent pays, and the cost sits inside the price, so ask to see the entry papers.

Does a Chinese-owned factory in Vietnam pay the China rate?

Not because of ownership. Origin follows where the floor was made or substantially transformed. A Chinese-owned plant that makes the floor in Vietnam can ship Vietnamese origin, with the records to prove it.

Is Thailand cheaper than Vietnam for US duty?

Not on our reading. Our research places Thailand in the same 12.5% tier of the same Section 301 action, so the stack is about 17.8% for both. Choose between them on the factory, not the duty.

Are SPC wall panels charged the same as floors?

Possibly not. Our research indicates the wall and ceiling lines of 3918.10 carry 4.2% or 6.5% rather than 5.3%, and some rigid slats may fall in 3925.90. Get a separate classification for each panel product.

Can the factory lower the invoice to reduce the duty?

No. Declaring less than the price actually paid is undervaluation, and the importer carries the penalty. We would treat that offer as a reason to walk away from the supplier.

Sources & further reading

• USITC Harmonized Tariff Schedule: heading 3918.10 (Revision 21, 2026), general rate 5.3% for 3918.10.10
• USITC Harmonized Tariff Schedule: heading 9903.05.84, products of Vietnam, +12.5%
• USITC HTS Chapter 99 (Revision 21, 2026): U.S. notes 20(f) and 52
• Federal Register, 28 July 2026 (91 FR 47318): Notice of actions in Section 301 investigations of 60 economies
• USTR, 23 July 2026: USTR takes action in forced labor Section 301 investigations
• Federal Register, 21 July 2026: hardwood and decorative plywood from Vietnam, final affirmative determination
• Uyghur Forced Labor Prevention Act, Public Law 117-78 (govinfo)
• 19 U.S.C. 1517, Enforce and Protect Act: investigations of evasion of AD/CVD orders (govinfo)
• CBP ruling N323990 (2022): country of origin of SPC flooring produced in Vietnam
• Sandler, Travis & Rosenberg: court schedule for litigation challenging Section 301 forced labor tariffs