Vietnam's food and agricultural sector is navigating two regulatory environments simultaneously, and the margin for error in both is shrinking.
On the US side, the picture is more complicated than most headlines suggest. The US and Vietnam announced a framework agreement on reciprocal trade in October 2025, and a 20% baseline tariff currently applies to most Vietnamese exports. But "framework" is the operative word — final tariff rates and rules of origin are still being negotiated, and the March 11 Section 301 investigations add a further variable: if those proceedings result in new tariffs, they could potentially replace the current baseline rates entirely. Coffee, tea, tropical fruits, and roughly 200 other agricultural products are explicitly exempted from the 20% rate under a November 2025 executive order. Seafood, including shrimp, is a different story: the US Department of Commerce recently finalized the 19th anti-dumping review, and VASEP is warning of increased risk. Jan-Feb 2026 data confirms the trend — total shrimp exports are up 20% overall, but the US share declined about 3% as China and Japan absorbed the growth instead.
And on March 11, the Trump administration formally launched Section 301 investigations into 16 trade partners, Vietnam among them — the same legal mechanism used to impose tariffs on China beginning in 2018. The Federal Register notice, published March 17, defines the investigation scope as manufacturing sectors facing structural excess capacity, explicitly including processed food and beverages alongside steel, electronics, chemicals, and others. Written comments are due April 15; public hearings begin May 5. One day later, on March 12, USTR separately initiated Section 301(b) investigations into forced labor compliance across 60 trading partners, also including Vietnam. These are parallel tracks, not one investigation. Vietnam's Ministry of Foreign Affairs responded on March 19, with spokesperson Phạm Thu Hằng stating that Vietnam "consistently respects international regulations and works toward a stable, long-term, mutually beneficial economic cooperation framework." Calibrated language: not confrontational, but not indifferent. What matters for food and agricultural buyers specifically: processed food and beverages is now explicitly in the Section 301 scope, and if investigations result in new tariffs, those could supersede the current IEEPA-based baseline rates. The trans-shipment exposure hasn't changed — a 40% tariff still applies to goods suspected of Chinese-origin routed through Vietnam — but the broader tariff picture is more unsettled than it was a week ago.
On the EU side, the compliance clock is running, even if it just got reset. The EU Deforestation Regulation now requires large and medium operators to comply by December 30, 2026, with small and micro operators getting until June 30, 2027. The good news for Vietnam: the EU has classified Vietnam as a low-risk country, meaning a 1% inspection rate rather than the scrutiny applied to Brazil or Indonesia. The practical challenge remains at the farm level — roughly 95% of Vietnam's coffee is grown by smallholders, most of whom don't yet have the geolocation data and traceability documentation EUDR requires. The Central Highlands pilot programs are expanding, but coverage is still partial.
The connection between these two pressures is what makes the current moment worth paying attention to. Vietnamese coffee exporters are having a record year — exports to the EU are up over 70% in value year-on-year, driven partly by EVFTA tariff preferences and partly by tight global supply from Brazil. Companies that built EU market access are insulated from the US uncertainty. Those that concentrated on the US are running triage.
The strategic question — for buyers and exporters alike — is what the destination mix looks like in 24 months, and whether the compliance infrastructure being built now determines which markets remain accessible.
WHAT I'M WATCHING
I'll be on the floor at Food & Hotel Vietnam starting March 24, and this is exactly the policy backdrop I'll be walking in with. The question I'm most interested in: how much of this is actually landing in sourcing conversations yet. The Section 301 investigation was announced ten days ago, and most procurement cycles run on longer timelines than that — so my expectation is that a lot of buyers are still operating on pre-March assumptions. The exporters who've been quietly diversifying into Japan, the UAE, and the EU over the past two years are in a fundamentally different position than those who concentrated on the US market. That gap, I suspect, will be visible on the show floor. I'll have more in the next issue.
TL;DR: The US-Vietnam trade framework is live at a 20% baseline tariff, but that number may not hold — Section 301 investigations launched March 11 cover processed food and beverages and could replace current rates if they result in new tariffs. A separate forced labor compliance probe launched March 12. Vietnam's MFA responded, calibrated but not dismissive. On seafood: shrimp exports to the US are down ~3% while overall shrimp export value is up 20% — China and Japan are absorbing the growth. On the EU side, nothing has changed since December: Vietnam is "low risk" under EUDR, but traceability infrastructure at the farm level is still catching up. The companies with the most options right now are the ones that didn't put all their eggs in the US basket.
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