Vietnam vs China SPC flooring: what an importer should weigh

How do Vietnam and China compare for SPC flooring today?

For US buyers the market has already moved. Vietnam supplied 46.1% of US imports of vinyl floor coverings (HS 3918.10) by value in 2025 and China 14.0%, against 0.6% and 84.0% in 2019. Vietnam passed China in 2024. Elsewhere, China is still the default supplier.

UN Comtrade data for 2025 show how US-specific the shift is. China was the largest supplier of HS 3918.10 to every other market we checked: 41.5% of UK imports, 58.3% of Canada’s, 60.5% of Australia’s and 52.1% of Germany’s. Vietnam’s share in those markets ranged from 0.6% to 7.3%.

What each factor looks like for a US-bound SPC programme, as of November 2026. Sources: UN Comtrade, CBP rulings, USITC tariff schedule and our factory records.

Factor	Vietnam	China	What decides it for your order
US duty	12.5% Section 301 duty; no List 3 duty	12.5% Section 301 duty plus the 25% List 3 duty (heading 9903.88.03)	Where the core is made and the plank finished
Duty stability	The 12.5% duty applies from 24 July 2026	List 3 heading in place since the 2018 action; the 12.5% since 24 July 2026	Your contract’s duty clause
Origin risk	Exposed if the plant buys in finished board	Not an issue	Production records for your lot
Supply depth	Large in the US trade, thin elsewhere	Largest supplier to most other markets	Plant capacity and décor library
Published terms	1 of 13 records states an MOQ; none a lead time	Not covered by our records	A dated, written quotation

Next step: see what each Vietnamese plant publishes about its lines, ownership and documents.

How large is the duty difference, and how stable is it?

On US entries, Chinese-origin vinyl tile under 3918.10.10 pays an extra 25% Section 301 duty under heading 9903.88.03 that Vietnamese origin does not. Both origins pay the same 12.5% Section 301 duty (headings 9903.05.31 for China and 9903.05.84 for Vietnam). The List 3 gap is the whole duty case for Vietnam. Current rates, the stacking rules and what is being challenged in court sit on our US tariff monitor for Vietnam SPC.

The two duties differ in age. The List 3 heading comes from the September 2018 modification of the China Section 301 action (83 FR 47974). The 12.5% applies only to goods entered from 24 July 2026, under a USTR notice covering 60 economies (91 FR 47318) that found each had not imposed and enforced a ban on forced-labour imports.

So the extra China cost has been predictable for years, while the 12.5% both origins pay is new and has a shorter record. A buyer moving a range for duty should price with today’s rates and write a clause that says who carries a change in either direction.

What protects the Vietnam duty position?

Origin, decided by where the floor is made, not where it ships from. Under US rules, further work in another country changes origin only if it substantially transforms the goods. CBP’s SPC rulings turn on which steps happened where, and each binds only the facts it describes, so your process has to stand up on its own.

N323990 is the pattern most Vietnamese plants describe: imported layers, a core made in Vietnam from Vietnamese, Swiss and Chinese raw materials, then pressing, cutting and click profiling there. N350880 went further, accepting cutting, profiling and padding of imported sheets as enough. We would not build a programme on that second pattern without a ruling in the importer’s own name.

The risk runs to the importer. Under 19 U.S.C. 1592 a material false statement on entry can be penalised for negligence alone, not only fraud. Our origin evidence workflow sets out the records to collect before the order.

Do Chinese inputs or a Chinese parent change the comparison?

Neither decides origin on its own. Imported layers are common, and some Vietnamese SPC plants have Chinese parents, yet N323990 accepted Chinese layers inside a Vietnamese-origin plank. What matters is whether the core is made in the plant that ships your order, and whether the group can quietly move volume back to China.

Resin is one input where China does not dominate. Vietnam’s 2023 imports of PVC resin (HS 3904.10, all uses) came 27.5% from Taiwan, 19.2% from China, 16.4% from Indonesia and 13.5% from the US, by value. A plant’s own resin record still matters more than the national mix, for origin and for forced-labour checks.

Ownership matters for a different reason: in a group with plants in both countries, one sales team can quote either. The ownership grades for each plant are on our page on who owns Vietnam’s SPC factories.

Where is supply deeper, and what does that do to lead times and MOQ?

China has the deeper base: it still leads supply to most import markets outside the US. Vietnam’s US trade in vinyl flooring was built mostly since 2019, and few plants publish commercial terms. Lead time belongs in the quotation, plant by plant.

Of the 13 Vietnamese factory records we publish, reviewed between October and early November 2026, only ATT states a standard MOQ (generally one full container, in its September 2026 factory article). None publishes a lead time. We hold no comparable records for Chinese plants.

For a buyer this means MOQ per décor, sample approval time and production slots are negotiated, not looked up. Ask for them in writing with a date, and ask which décors are already in the plant’s film library, since a new décor adds film development before the first run.

What changes in the quote when you move from China to Vietnam?

The product price is only one line. A Vietnam quote should also name the producing plant and address, the origin documents the plant will supply per shipment, and the duty clause. Clauses that a long-standing Chinese supplier never needed become essential once the duty saving depends on origin.

Fields to add or tighten when the same SPC range is requested from a Vietnamese plant. Our purchasing checklist, not a legal requirement.

Quote field	China programme (typical)	Vietnam quote should add
Producing site	Often the supplier’s only plant	Named plant and address; no site change without approval
Core	Rarely questioned	Confirmation the core is extruded in that plant
Origin documents	Certificate of origin	Bill of materials, resin records and lot production records
Duty change	Long-settled	Who carries a change in the Vietnam rate
MOQ and décors	Known from past orders	MOQ per décor and which films are in stock

Worked example: splitting a range between the two countries

Illustrative figures only. A US importer buys 12 containers a year of one SPC range in 8 décors from a Chinese plant. A Vietnamese plant offers the same construction with a one-container MOQ per décor and extrudes its own core.

Illustrative décor group	Containers a year	Decision
5 best-selling décors	9	Move to Vietnam after a trial container per décor family
3 slow décors	3	Stay in China for now; below one container each per order
First Vietnam order	2 of the 9	Two décors, approved against the current China reference sample

Outcome: 9 of 12 containers carry the duty advantage, the slow décors avoid forced MOQ stock, and the buyer keeps a working Chinese supplier. The Vietnam purchase order names the plant and requires lot records for every shipment.

Our view

For US-bound SPC we would move the high-volume part of a range to a Vietnamese plant that extrudes its own core and can show resin and lot records, and keep a smaller Chinese line running. Dropping China entirely trades a known duty for an unknown supply risk. Outside the US, we would stay with the best plant, wherever it is.

Two things would change our mind on a given plant: a refusal to name the producing site in the order, or a core bought in from another factory. The wider country decision is set out in our China plus one flooring guide.

If Thailand is also on your list, read how Vietnam and Thailand compare for SPC.

Common mistakes when comparing Vietnam and China

Most mistakes come from treating a country as a supplier. The duty saving, the MOQ and the lead time belong to one plant and one product, and the comparison breaks when any of them is assumed from the country label.

Mistake	What it costs	How to avoid it
Assuming a Vietnamese invoice means Vietnamese origin	China duty layers, plus possible penalties	Get lot production records and the plant address
Relying on someone else’s CBP ruling	No cover for your process	Compare your process to the ruling, or ask for your own
Moving every décor at once	MOQ stock on slow décors	Move high-volume décors first
Pricing with the duty saving built into the factory price	Hidden origin risk	Keep factory price and duty as separate lines
Dropping the Chinese supplier on day one	No fallback if the new plant slips	Keep a smaller line running until repeat orders are stable

More plant-level research is collected under find factories.

If you want a shortlist of Vietnamese plants that extrude their own core, with the origin questions already asked, our factory selection support works on that basis.

Questions buyers ask

Can I ask the factory to apply for a CBP origin ruling?

The factory can supply the process description, but the request usually comes from the importer side. In N323990 it was filed by counsel for the importer. Agree with your broker who files, and get the factory to sign off the process facts first.

What happens if CBP treats a Vietnamese shipment as Chinese origin after entry?

The China duty layers apply to that entry, and a false origin statement can also bring a penalty claim against whoever entered the goods. Your contract should say who pays in that case and which records the factory must hand over.

Is SPC from Vietnam cheaper than SPC from China?

We do not publish prices. Ask both plants to quote the same written construction on the same Incoterm, then add duty for each origin separately. A factory price comparison that already includes an assumed duty saving hides the origin risk.

Does the comparison change if I sell in Europe or Australia?

Yes. The Section 301 layers are US measures. In other markets the duty difference between the two origins depends on that country's tariff and any trade agreement, so the case for Vietnam may rest on supply alone. Check with your broker before moving.

What if a Chinese-owned plant in Vietnam fills my order from its China factory when busy?

Then the goods are Chinese origin, whatever the invoice says. Name the producing plant and address in the purchase order, ask for production records for your lot, and treat any change of site as a new approval.

Sources & further reading

• UN Comtrade: imports of HS 3918.10 by partner (US, UK, Canada, Australia, Germany), annual 2019 to 2025, checked November 2026
• CBP ruling N323990 (22 February 2022): country of origin of SPC flooring made in Vietnam
• CBP ruling N350880 (15 July 2025): country of origin of SPC planks finished in Panama
• Federal Register 91 FR 47318 (28 July 2026): Section 301 actions on 60 economies
• USITC Harmonized Tariff Schedule, Chapter 99, U.S. notes 20(f) and 52 (2026)