IMPORT PROCEDURE GUIDE FOR NAS
Problem: For NAS (Network-Attached Storage), incorrect HS classification, overly broad goods description, or missed Wi‑Fi/encryption/self-encrypted-drive features may trigger customs explanation, additional specialized dossier or DEM/DET costs. Agitate: A small mismatch among invoice, packing list, catalogue and model label can delay clearance, affect C/O treatment and create unplanned logistics costs. Solution: This guide provides an E2E (End-to-End) review map for HS code, duty, VAT, specialized policies, dossier, clearance workflow and pre-ETA risk control.
QUICK FACT
| Review item | Recommended approach for NAS | Operational note |
|---|---|---|
| Product scope | NAS (Network-Attached Storage) used to store, share and manage data over LAN/WAN. | Do not automatically treat NAS as SAN controller, storage security appliance or general-purpose server. |
| Reference HS code | 8471.70.90 – Other storage units; if the goods are only standalone hard disk drives, 8471.70.20 may need review. | Classification depends on actual structure: complete NAS, enclosure, controller, HDD/SSD included or imported separately. |
| MFN import duty | 0% for the relevant ADP/storage-unit heading in the preferential import tariff. | Re-check the tariff at customs declaration date. |
| Ordinary import duty | 5% reference for HS 8471.70.90 under the ordinary import tariff. | Used only where MFN/FTA eligibility is not available; recalculate if reclassified. |
| VAT | 10% standard; 8% from 1 July 2025 to 31 December 2026 if eligible under Decree 174/2025/ND-CP and not excluded. | Check the active VAT schedule at filing; if HS changes, VAT must be reviewed again. |
| Specialized policy | Standard NAS is usually handled through customs dossier and labelling; models with Wi‑Fi/Bluetooth, encryption, self-encrypted drives, network security or civil cryptography must be reviewed separately. | Do not conclude “no permit required” without datasheet, model and feature list. |
SCOPE OF APPLICATION
This article applies to NAS, a network-attached data storage device commonly equipped with drive bays, storage controller, Ethernet ports, storage firmware/OS, RAID, user access control and data sharing/backup functions over a local or wide-area network.
Directly covered
- NAS for file storage, backup and data sharing.
- NAS enclosure with or without HDD/SSD depending on shipment configuration.
- NAS used for offices, factories, server rooms, camera storage or enterprise backup.
Not automatically covered
- SAN controller.
- Storage appliance with DLP, database security or security monitoring function.
- General-purpose server, firewall/UTM, network monitoring appliance or dedicated encryption device.
Separate review required
- Used/refurbished/sample/warranty/RMA goods.
- Models with Wi‑Fi/Bluetooth/4G/5G, battery, adapter, encryption module or self-encrypted drive.
- Project, EPE/FDI or factory asset imports.
CLASSIFICATION & TECHNICAL IDENTIFICATION
NAS should be identified by its principal function: data storage and network access to stored data. It is not primarily a router/switch, and a standard NAS is different from a security appliance whose main function is monitoring, testing or protecting information systems.
Technical data to lock
- Brand, model, part number and serial list.
- Drive bays, supported drives, capacity, RAID, CPU/RAM if indicated.
- Ethernet, SFP/SFP+, USB, HDMI, Wi‑Fi/Bluetooth if any.
- Firmware/OS, backup, snapshot, virtualization and encryption features.
Risk of generic description
- Wrong HS code.
- Wrong specialized policy where wireless or encryption exists.
- Incorrect labelling for market circulation.
- Difficult customs explanation on main function and structure.
TECHNICAL IDENTIFICATION CRITERIA
| Technical criterion | Documents to cross-check | Risk if misdescribed | Suggested customs/commercial description |
|---|---|---|---|
| Main function | Catalogue, datasheet, user manual, technical brochure | May be reclassified as server, network equipment, security appliance or parts. | Network-Attached Storage (NAS), model…, brand…, new 100%. |
| Storage configuration | Bay number, HDD/SSD included or not, RAID, maximum capacity | Wrong distinction between complete NAS and standalone drive. | NAS enclosure without HDD / NAS with …TB HDD depending on actual shipment. |
| Network interface | LAN, SFP/SFP+, Wi‑Fi/Bluetooth/4G/5G if any | Wireless modules may trigger ICT conformity/quality control. | State Ethernet/LAN interface; avoid generic “network equipment”. |
| Security/encryption | Encryption specifications, security whitepaper, firmware feature list | May trigger civil cryptography/network security review. | NAS for data storage, with/without encryption depending on actual model. |
| Power/accessories | Packing list, labels, product photos, accessory catalogue | Adapter/power supply/accessories may require separate labelling/policy review. | Set includes NAS, power adapter, LAN cable, standard accessories. |
| Condition | Invoice, contract, new-goods statement, serial photos | Used/refurbished goods may follow a different policy. | New 100%, unused, for enterprise data storage. |
HS CODE – DUTY – C/O
For standard NAS, classification review usually starts from heading 8471 for automatic data-processing machines and units. Where the product is essentially a network-attached data storage unit, and routing, switching, cybersecurity or general-purpose server processing is not the principal function, the practical reference code should be reviewed as 8471.70.90 – Other storage units. If the imported goods are standalone HDD/SSD, drive trays, controller modules, server appliances, network devices or security appliances, the NAS tax table should not be applied mechanically.
| HS option to review | When applicable | Ordinary import duty | MFN duty | VAT | Control note |
|---|---|---|---|---|---|
| 8471.70.90 Other storage units |
Complete NAS/NAS enclosure with controller, LAN ports and storage OS; principal function is data storage, sharing and management. | 5% | 0% | 10% standard; 8% from 1 Jul 2025 to 31 Dec 2026 if eligible for VAT reduction and not excluded. | Priority reference for standard NAS; storage must be evidenced as the principal function. |
| 8471.70.20 Hard disk drives |
Only where the imported goods are standalone hard disk drives, not complete NAS appliances. | 5% | 0% | 10% standard; 8% may apply during the reduction period if eligible. | Do not use HDD classification where the goods are NAS enclosure or NAS appliance. |
| 8471.50.90 Other processing units |
Review only where the product is closer to a processing/server unit with CPU/RAM/OS for broader data processing. | 5% | 0% | 10% standard; 8% may apply during the reduction period if eligible. | If shifted to server/processing-unit classification, re-check technical policy and goods description. |
| 8471.80.10 / 8471.80.90 Controllers/other ADP units |
For separate import of controllers, adaptors, expansion cards or functional modules of storage systems. | 5% reference | 0% reference | 10% standard; 8% may apply during the reduction period if eligible. | Do not use for complete NAS appliances. |
| 8517.xx / 8543.xx / other codes | Where the principal function is network transmission, switching/routing, security, dedicated encryption or another electrical function. | Depends on final HS | Depends on final HS | Depends on final HS/VAT policy | Restart classification; do not use the NAS tax table. |
| Tax item | Reference treatment for NAS HS 8471.70.90 | Basis/application condition | Declaration control note |
|---|---|---|---|
| MFN import duty | 0% | Applicable where the goods qualify for the preferential import tariff; review Decree 26/2023/ND-CP and amendments in force at filing date. | 0% MFN does not remove HS risk. If HS changes, duty, VAT and specialized policy may change. |
| Ordinary import duty | 5% | Decision 15/2023/QD-TTg provides the ordinary tariff; the appendix shows 8471.70 storage units, 8471.70.90 other at 5%. | Used only where MFN or FTA preferential treatment is not available. |
| Import VAT | 10% standard for goods otherwise subject to 10%; 8% from 1 Jul 2025 to 31 Dec 2026 if eligible under Decree 174/2025/ND-CP. | Decree 174/2025/ND-CP reduces VAT for 10% goods/services except the groups listed in Annexes I and II; it applies consistently at import, production, processing and trading stages. | Check HS, exclusion annexes and customs VAT schedule at filing date; do not lock 8% if reclassified into an excluded group. |
| Special preferential duty under C/O | Often 0% under many FTAs if HS, origin and C/O are valid. | Relevant FTA tariff: ACFTA, ATIGA, AKFTA, VKFTA, AJCEP, VJEPA, CPTPP, EVFTA, UKVFTA, RCEP… depending on origin/exporting country. | Where MFN for 8471.70.90 is already 0%, C/O may not reduce duty further but remains important for origin records, procurement compliance and post-clearance audit. |
| Common origin/export route | FTA/tariff to review | Common origin document | Pre-ETA check |
|---|---|---|---|
| China | ACFTA or RCEP | Form E or RCEP C/O | Check origin criterion, direct consignment, goods description and HS. |
| ASEAN | ATIGA | Form D | Check exporting country, origin country and transport route. |
| Korea | AKFTA, VKFTA or RCEP | Form AK, Form VK or RCEP C/O | Select the valid form for the transaction; avoid mixing agreements. |
| Japan | AJCEP, VJEPA, CPTPP or RCEP | Form AJ, Form VJ or CPTPP/RCEP origin document | Review origin rule and transit conditions. |
| EU/UK | EVFTA or UKVFTA | EUR.1 or origin statement/certification as provided by the agreement | Check exporter eligibility, origin wording and goods description. |
| No FTA or no valid C/O | MFN or ordinary duty depending on eligibility | No special preferential C/O | Review MFN eligibility; ordinary 5% may arise if MFN/FTA is not available. |
C/O risk points: wrong form, wrong origin criterion, inconsistent goods description, HS mismatch, missing through B/L or failure to prove direct consignment may result in denial of special preferential treatment.
APPLICABLE SPECIALIZED POLICIES
| Goods scenario | Potential policy | Dossier to check | Authority/portal if identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Standard NAS with Ethernet only, main function is data storage | Normal customs procedure; import labelling; HS and duty review. | Invoice, Packing List, B/L/AWB, catalogue, datasheet, original label, model list. | Customs authority at the declaration place. | 5–7 working days before ETA. | Avoid broad wording such as “network equipment”. |
| NAS with Wi‑Fi/Bluetooth/4G/5G or wireless module | May fall under ICT Group 2 conformity/quality control if both HS and description match the list. | Wireless datasheet, RF test report, applicable QCVN, label photos, model/module list. | Relevant ICT quality authority/service portal/NSW if applicable. | Before ETA, preferably before booking. | Conclude only after checking the model against the annexes. |
| NAS with self-encrypting drive, hardware encryption or key management | Review potential civil cryptography import permit. | Security whitepaper, encryption algorithm, key management, HS, model. | Government Cipher Committee/Ministry of National Defence regime. | Before contract signing or before shipment departs. | Civil cryptography list applies when HS, goods description and cryptographic technical features all match. |
| Storage security appliance / DLP / ATTT product | May trigger network information security product management if the main function is security monitoring, testing or protection. | Datasheet, security features, software licences, intended use, model. | Relevant network security authority. | Before ETA or purchase order. | Ordinary NAS and security appliance must not be grouped together. |
| Used/refurbished/warranty goods | May trigger used-goods, RMA or re-import/re-export policy. | Warranty/RMA documents, condition statement, serials, previous export docs if any. | Customs and relevant authorities. | Before shipment. | Do not use the “new goods” approach for refurbished goods. |
| Goods imported by EPE/FDI/factory/project | Customs regime, asset/project management and tax treatment depend on import type. | Contract, PO, import purpose, asset/project list, enterprise dossier. | Customs authority managing the regime. | Before declaration. | Wrong declaration type may affect tax, finalization and post-clearance audit. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document number/name | Issuing authority | Effective/application timing | Role in procedure | Key article/annex to note | Review note |
|---|---|---|---|---|---|---|
| Law | Customs Law 54/2014/QH13 | National Assembly | Core legal framework; check amendments if any. | Customs declaration, inspection, supervision and clearance. | Rules on customs dossier, inspection and risk management. | Review by actual import regime. |
| Law | Foreign Trade Management Law 05/2017/QH14 | National Assembly | Applies to import/export goods management. | Basis for prohibited, restricted and conditional goods. | Management principles and lists. | Do not conclude before checking wireless/encryption/security features. |
| Decree | Decree 69/2018/ND-CP | Government | Effective from 15 May 2018; check amendments. | Guides the Foreign Trade Management Law. | Lists of prohibited/conditional goods. | Important for used/refurbished goods. |
| Tariff | Decree 26/2023/ND-CP; Decree 144/2024/ND-CP; Decree 199/2025/ND-CP | Government | Decree 26 effective from 15 July 2023; later decrees amend/supplement. | Preferential import tariff and duty basis. | Chapter 84, heading 8471; reference code 8471.70.90. | Re-check at declaration date. |
| VAT | Resolution 204/2025/QH15 and Decree 174/2025/ND-CP | National Assembly/Government | VAT reduction from 1 July 2025 to 31 December 2026. | Determines 8% or 10% VAT. | Article 1 and exclusion annexes. | Check HS and VAT schedule at filing. |
| ICT quality | Circular 29/2025/TT-BKHCN | Ministry of Science and Technology | Effective 31 December 2025; replaces Circular 02/2024/TT-BTTTT. | ICT Group 2 goods list and conformity/quality principles. | Articles 1, 3, 4 and annexes. | Applies only when HS and description match. |
| Civil cryptography | Decree 211/2025/ND-CP | Government | Issued 25 July 2025, effective 9 September 2025. | Civil cryptography business/import/export and sanctions. | Licensed import/export product annex. | Review carefully for dedicated encryption/storage protection features. |
| Labelling | Decree 43/2017/ND-CP; Decree 111/2021/ND-CP | Government | Current labelling framework; check validity. | Original label and Vietnamese supplementary label. | Mandatory import label information. | Check origin, model and responsible importer information. |
VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS
Enterprises should search by document number on official legal databases, the Government portal or the issuing authority’s website. Always cross-check the current validity before application.
CUSTOMS CLEARANCE DOSSIER
Commercial documents
- Commercial Invoice.
- Packing List.
- Bill of Lading/Air Waybill.
- Sales Contract/Purchase Order if any.
- C/O if preferential treatment or origin proof is needed.
- Catalogue, datasheet, user manual, product photos, original label, model/serial list.
Specialized documents if applicable
- Civil cryptography/network security import permit if applicable.
- Quality inspection registration, conformity certificate/declaration if in Group 2.
- Test report, technical documents, security whitepaper, encryption description if any.
- Labelling dossier and Vietnamese supplementary label.
OPERATIONAL DOSSIER CHECKLIST
| Dossier group | Required documents | Used for | Prepared by | Common error | Pre-ETA control |
|---|---|---|---|---|---|
| Commercial | Commercial Invoice, Packing List, Sales Contract/PO | Value, quantity, Incoterms, customs declaration | Importer/Procurement/Supplier | Generic product name, missing model, wrong accessory set. | Match every line with catalogue and packing reality. |
| Transport | B/L or AWB, Arrival Notice, Pre-alert | D/O, declaration and ETA tracking | Forwarder/Carrier/Agent | Wrong consignee, package number or weight. | Match transport docs with invoice/packing before arrival. |
| Technical | Catalogue, datasheet, user manual, model/serial list | HS classification, policy and customs explanation | Supplier/Technical team | Datasheet does not show NAS/security/wireless/encryption clearly. | Request official PDF and actual label photos. |
| Origin | C/O if preferential treatment or origin proof is needed | FTA duty and origin control | Supplier/Exporter/Docs | Wrong form, HS, description or origin criterion. | Review draft C/O before issuance. |
| Specialized if any | Permit, quality registration, conformity certificate/declaration, test report | Supplement customs and market circulation dossier | Compliance/Importer/Advisor | Prepared after ETA, missing test report, wrong QCVN/model. | Lock policy when datasheet is available. |
| Labelling | Original label, Vietnamese sub-label, serial/model photos | Market circulation and inspection | Importer/Warehouse/Compliance | Wrong origin, missing responsible party, model mismatch. | Prepare sub-label before ETA. |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended action |
|---|---|---|---|---|
| HS code | Is the goods a storage unit under 8471.70.90 or a server/network/security product? | Catalogue, datasheet, configuration, photos | Classification query, duty reassessment, clearance delay. | Fix technical description and HS position before ETA. |
| Model match | Does invoice model match catalogue, label and serial? | Invoice, packing, label photos, model list | Document amendment and clearance delay. | Lock model list before final documents are issued. |
| Wireless | Does the NAS include Wi‑Fi/Bluetooth/4G/5G? | RF datasheet, label, certificates/test reports | Missed ICT quality/conformity obligation. | Separate wireless and non-wireless models. |
| Encryption | Does it include hardware encryption/key management/self-encrypted drive? | Security whitepaper, manual, firmware feature list | Civil cryptography or security explanation may be required. | Review before purchase/shipment. |
| C/O | Is it eligible for FTA preferential treatment? | Draft C/O, B/L, invoice, origin criterion | C/O rejection or verification delay. | Check form, criterion, description, HS and direct transport. |
| Goods condition | New, refurbished, warranty or sample? | Contract, invoice, RMA, photos | Wrong policy/value/declaration type. | State condition clearly and use correct customs regime. |
E2E IMPORT PROCEDURE FOR NAS
Step 1 · Pre-ETA review
- Lock HS, MFN duty, VAT and C/O.
- Review wireless, encryption, security and used/refurbished status.
- Check labelling and post-clearance circulation conditions.
Step 2 · Lock documents and technical dossier
- Finalize Invoice, Packing List, B/L or AWB.
- Finalize catalogue, datasheet, model and serial list.
- Check name, quantity, origin and specifications.
Step 3 · Prepare specialized dossier if any
- Quality/conformity dossier if the model is in Group 2.
- Permit if civil cryptography or network security applies.
- Do not wait until after ETA to review policy.
Step 4 · File customs declaration
- Green channel: system clearance subject to conditions.
- Yellow channel: documentary check.
- Red channel: document and physical inspection.
- Prepare explanation on value, HS, C/O, catalogue and policy.
Step 5 · Clearance, delivery and warehouse receipt
- Release and move goods to warehouse.
- Check condition, serials and packages.
- Apply supplementary label/conformity mark if required.
Step 6 · Post-clearance records
- Store declaration, commercial docs, C/O, catalogue, permits/certificates if any.
- Prepare for post-clearance audit.
- Review reporting obligations for EPE/FDI/project regime.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA prevention | Documents to check |
|---|---|---|---|
| Generic name “storage/network equipment” | Customs explanation; possible policy mismatch. | Use NAS name, model and main function. | Invoice, catalogue, datasheet. |
| Model mismatch | Document amendment, clearance delay, storage cost. | Lock model/serial list before arrival. | Invoice, packing, original label. |
| Missing wireless/encryption review | Missing specialized dossier if applicable. | Feature checklist before ordering. | Datasheet, manual, security whitepaper. |
| C/O error | Preferential treatment denied or verification delay. | Review draft C/O. | C/O, invoice, B/L, packing. |
| No Vietnamese sub-label plan | Market circulation and inspection risk. | Prepare sub-label before ETA. | Label photos, catalogue, importer information. |
| Refurbished/RMA treated as new goods | Wrong policy, value or regime. | Obtain written condition confirmation. | Contract, invoice, RMA/warranty docs. |
FAQ – COMMON QUESTIONS
1. Does NAS require an import permit?
Standard NAS normally does not follow a separate permit regime. However, models with dedicated encryption, self-encrypted drives, network security functions or wireless features must be reviewed before conclusion.
2. Does NAS require quality inspection/conformity?
Only when the product matches both HS code and description in the ICT Group 2 list. Wireless-enabled NAS requires careful review.
3. Is HS 8471.70.90 certain?
It is a reference code for other storage units. Official classification depends on actual function, structure, imported condition and technical documents.
4. Is VAT 8% or 10%?
From 1 July 2025 to 31 December 2026, eligible goods may apply 8% if not excluded. Otherwise or after expiry, the standard rate should be reviewed as 10%.
5. Is C/O still needed when MFN is 0%?
It may not reduce duty if MFN is already 0%, but it remains useful for origin control, procurement compliance and audit records.
6. Should NAS with HDD be classified separately?
It depends on packing, sales configuration, document description and the essential character of the goods.
7. Are warranty/RMA goods treated like commercial imports?
No automatic assumption should be made. RMA goods need warranty documents, serial proof and correct customs regime.
8. Is “storage appliance” enough on invoice?
It is safer to state “Network-Attached Storage (NAS)” with model, brand, condition and key configuration.
RELATED ARTICLES
IMPLEMENTATION SOLUTION FOR ENTERPRISES
This guide provides a map for HS code, duty, dossier and specialized policy. For actual shipments, enterprises should still review catalogue, datasheet, model, documents, origin and import purpose.
Pre-ETA compliance review
- HS, duty, C/O and labelling.
- Wireless, encryption, network security and civil cryptography if any.
- Cross-check invoice, packing, B/L/AWB and catalogue.
E2E execution
- Coordinate agents, carriers and pre-alert.
- Prepare declaration dossier and handle customs channels.
- Domestic delivery and post-clearance records.
For shipments that may involve specialized inspection, permits, C/O or labelling requirements, enterprises should not wait until arrival to review documents. A minor mismatch can trigger additional documents, delayed clearance or unplanned storage costs.
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