In response to the increasingly stringent U.S. rules of origin compliance requirements, the Thailand's Commerce Ministry recently issued new guidelines for Certificates of Origin (C/O) and anti-circumvention measures.

Under the new regulations, effective December 1, all high-risk goods exported to the U.S. - including explicitly named photovoltaic modules - must possess a C/O exclusively issued by Thailand's Department of Foreign Trade (DFT).

This measure aims to prevent foreign products from using Thailand as a conduit for "origin circumvention" to bypass U.S. tariff controls, while cracking down on nominee structures and other evasion tactics. It seeks to increase local content requirements, combat counterfeit "Made in Thailand" products, and ensure authentic origin verification.

According to relevant provisions, companies found guilty of origin fraud or transshipment violations will face punitive tariffs of up to 40%.