White House Transshipment Report: What U.S. Importers Need to Know

Article

August 18, 2026

The White House published a new report and guidance for importers on illegal transshipment.

The “Great Transshipment Scam” report highlights that over $75 billion in goods evade U.S. tariffs each year and that U.S. Customs and Border Protection (CBP) has deployed a new AI-powered “Detective Border” to target companies and shipments for trade fraud. The White House report calls on CBP to rapidly increase enforcement against companies and shipments. The report also extensively highlights Exiger and how 1Exiger.AI can be used to identify country of origin violators.

Key Takeaways

AI has expanded CBP’s ability to detect and investigate transshipment. The White House outlines greater use of AI, anomaly detection, shipment and routing data, ownership relationships, production-capacity indicators and computer vision to identify higher-risk entries and test country-of-origin claims at scale.
CBP is conducting more post-entry enforcement. Shipments identified with post-release discrepancies increased 245% across the periods compared by the White House, while associated revenue assessments rose 169%, signaling more aggressive follow-up on questionable entries.
Importers face tighter accountability requirements. New measures address importer-of-record requirements, bonding, ownership and business-affiliation disclosures, good standing, penalties and trade transparency.
Origin claims can increasingly be checked against the underlying supply chain. Components, facilities, production capacity, ownership, shipment timing and routing can reveal inconsistencies that customs paperwork alone may not show.
Higher-risk imports need stronger origin evidence before entry. Significant tariff differentials, AD/CVD exposure, recent sourcing shifts and China-linked upstream dependencies are useful places to focus review.

What Is Illegal Transshipment?

Illegal transshipment occurs when goods are routed through another country and falsely declared to have originated there to avoid tariffs, duties, or trade restrictions.

How Is CBP Transshipment Enforcement Changing?

Executive Order 14411 gives CBP additional enforcement leverage through tighter importer-of-record requirements, increased bonding and domestic-asset requirements, more ownership and business-affiliation disclosures, good-standing requirements, stronger penalties and greater customs transparency.

For importers, country-of-origin documentation now sits alongside a much broader factual record. Facility capabilities, components, manufacturing activity, shipment timing and routing can all be used to test whether an origin claim is supportable. Trade teams may own the entry, but procurement and supply chain teams often hold much of the information needed to substantiate it. 1Exiger.AI collapses these siloes so that organizations can proactively identify illegal transhipment prior to an enforcement action.

What Makes a Country-of-Origin Claim Supportable?

For an importer, the relevant evidence sits below the country name on the entry.

If a product is declared as originating in Vietnam, Mexico or another third country, the manufacturing activity should support that claim. The production facility should have the equipment and capacity required to make the product. Components and inputs should be consistent with the reported manufacturing process. Shipment timing should allow the claimed work to occur.

A supplier certificate records an origin representation. Supporting production records establish why that representation is credible.

Which Imports Face Higher Transshipment Risk?

The White House identifies more than 40 countries associated with elevated transshipment risk. Several are major U.S. trading partners with substantial legitimate manufacturing, so a country’s inclusion should be used to prioritize review rather than judge an individual shipment.

Specific Indicators

Large tariff differences between the declared country and an upstream source country
Products subject to antidumping or countervailing duties
Recent sourcing shifts from China or another higher-tariff jurisdiction
Significant China-linked components or upstream manufacturing dependencies
Limited evidence of meaningful production in the declared country
Facilities whose equipment or capacity do not support the reported manufacturing activity
Shipment timing that conflicts with the production process described by the supplier
Supplier, ownership or intermediary relationships missing from existing records

AD/CVD exposure deserves particular attention. The White House notes that these duties can stack on top of ordinary tariffs and can reach very high levels in some product categories, substantially increasing the financial consequences of an incorrect origin determination.

What Evidence Should Importers Have to Support Country of Origin?

For higher-risk products, the origin record may need to extend beyond the documents traditionally collected at entry. A bill of lading can show where goods traveled, and a supplier certificate can state an origin claim. Neither, by itself, establishes where a product originated.

Trade, procurement and supply chain teams should be able to connect what is declared at import with the production facts behind it:

What appears on the entry:

Declared country of origin
Exporter and importer
Product description and classification
Invoice and entered value
Shipment timing and routing

What supports the declaration:

Actual manufacturer and production facility
Major materials and components, including their countries of origin
Manufacturing and processing steps performed at each facility
Production dates and sequence
Relevant supplier, facility and ownership relationships
Bills of material, production records and other supplier evidence supporting the origin claim

Procurement often controls access to much of this underlying information. If a supplier cannot identify where production occurred, explain what work was performed there or provide records supporting its origin representation, trade and compliance teams may have little evidence available when CBP asks them to substantiate the claim.

What Should Importers Do Now?

The White House findings point to several areas importers should examine more closely, particularly where tariff exposure or sourcing changes increase the risk of an origin challenge.

1. Prioritize Imports With the Highest Origin Risk

Prioritize imports with significant tariff differentials, AD/CVD exposure, recent sourcing shifts or China-linked upstream dependencies. These conditions can increase both the financial incentive for origin shifting and the consequences of an incorrect determination.

2. Verify Where Manufacturing Actually Occurs

Confirm the facility producing the goods and whether its equipment, capacity and manufacturing activity support the country of origin being claimed. The White House highlights facility capabilities and required manufacturing processes as important evidence for distinguishing genuine production from pass-through trade.

3. Trace Major Components and Upstream Production

Review the origin of significant components and the suppliers and facilities involved upstream. A change in final assembly location may leave important production dependencies elsewhere, which can affect whether the declared origin is supportable.

4. Confirm Shipment Timing Supports the Production Claim

Compare the movement of inputs and finished goods with the manufacturing steps reported by the supplier. Exiger’s analysis considers shipment timing and dwell time alongside components, manufacturing requirements and facility capabilities to identify potential pass-through trade.

5. Ensure the Origin Record Can Withstand CBP Scrutiny

For higher-risk imports, confirm that supplier records, facility information, component data, shipment history and the basis for the origin determination tell a consistent story. Where the evidence conflicts or remains incomplete, resolve the discrepancy before entry and involve customs counsel when the legal determination is unclear.

How Can Importers Prepare for CBP Transshipment Enforcement?

The White House’s transshipment findings point to a more evidence-intensive enforcement environment. CBP has stronger importer requirements, more analytical tools and more supply chain information available to test country-of-origin claims.

Companies do not need the same depth of review for every shipment. Risk-based screening can identify the products and suppliers where tariff exposure, sourcing changes or gaps in production evidence warrant closer examination.

For higher-risk imports, companies should be able to substantiate how the declared origin was determined and resolve inconsistencies before entry.

Finding a discrepancy internally leaves time to investigate and correct it. Once CBP identifies the problem, the consequences can include additional duties, penalties, detention, exclusion and supply disruption.

How Exiger Tests Country-of-Origin Claims Against the Supply Chain

Exiger connects supplier, product, component, facility, ownership and shipment data to assess whether a country-of-origin representation is consistent with the production network behind it.

That analysis can flag:

Suppliers whose production claims need additional evidence

Facilities whose capabilities do not align with reported output

Unexpected upstream country dependencies

Routing or timing inconsistent with reported manufacturing

Relationships among suppliers, manufacturers and intermediaries that tier-one records may not reveal

Trade teams can use those findings to strengthen the evidence supporting customs declarations. Procurement can investigate origin and production claims before sourcing decisions are finalized. Supply chain teams can determine whether an apparent sourcing shift reflects a real change in production or leaves important upstream dependencies in place.

The same types of product, facility and shipment signals highlighted in the White House analysis can help companies identify their own exposure before it becomes a customs enforcement issue.

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Exiger provides the only purpose-built illegal transshipment detection capability used by CBP — which is now available to importers who need to find the same risks before enforcement agencies do. Don’t wait for a CF-28 to indicate your exposure.