Refrigeration systems are technical imports that may involve HS classification, occupational safety rules, MOLISA Group 2/QCVN 21 safety management, controlled refrigerants and used-machinery restrictions. If the shipment is declared only as “cooling system”, “refrigeration unit”, “chiller” or “cold room equipment” without capacity, refrigerant type, charge quantity, component list and use purpose, customs may request additional catalogues, reclassify HS codes or require QCVN 21/conformity/safety-inspection clarification after ETA.

This article provides an E2E map for importing refrigeration systems: scope, technical identification, HS code, duty, C/O, occupational-safety policy, customs documents, pre-ETA checklist and decision points that may hold the shipment.

Key HS range8418.61 / 8418.69 / 8418.99

Reference MFN0%–10% depending on code and configuration

Main riskrefrigerant, charge quantity, Group 2 status, used goods and confusion with HS 84.15.

QUICK FACT TABLE

Item	Points to review	Operational note
Product	Refrigeration systems for cold rooms, factories, processing lines, storage, water/brine chilling or industrial cooling.	Do not automatically apply this article to household refrigerators, air conditioners, standalone compressors, separate pressure vessels or piping.
Reference HS	8418.61.00, 8418.69.41, 8418.69.49, 8418.69.50, 8418.69.90, 8418.99.10, 8418.99.90.	Final classification depends on function, cooling capacity, chiller/heat pump/ice machine/part status and import configuration.
Reference MFN duty	10% for many 8418.61/8418.69 items; 3% for flake-ice making equipment; 0% for certain parts under 8418.99.	Always check the tariff schedule on the declaration date.
Reference ordinary duty	Specific operational reference: 15% where MFN is 10%; 4.5% where MFN is 3%; 0% where MFN is 0% under the 150%-of-MFN principle, unless the current ordinary-duty schedule provides a separate rate.	Still verify Decision 15/2023/QD-TTg and the tariff schedule on the declaration date.
VAT	Standard review rate: 10%; during 01/07/2025–31/12/2026, 8% may be reviewed if the goods are not excluded under Resolution 204/2025/QH15 and Decree 174/2025/ND-CP.	Check exclusion appendices and the declaration date.
C/O	FTA preferential duty may reach 0% if the C/O is valid and origin criteria are met.	Check C/O form, origin criterion, goods description, HS code and direct consignment.
Specialized policy	If the system uses refrigerants in safety groups B1, B2L, B2, B3, A2, A3 or A2L with charge from 5 kg, review Circular 01/2021/TT-BLDTBXH, QCVN 21:2015/BLDTBXH, technical dossiers, conformity certification/declaration and pre-use safety inspection where applicable.	Review SDS, nameplate, refrigerant charge, catalogue and import configuration.
Used goods	As Chapter 84 equipment, used refrigeration systems imported for production in Vietnam may fall under Decision 18/2019/QD-TTg.	Do not ship used/refurbished units before confirming inspection and age requirements.

Legal note: This guide is for import-procedure planning. Actual policy depends on configuration, refrigerant type, charge quantity, capacity, new/used condition and whether the shipment is imported as a complete system or as separate parts.

Additional control point: Circular 01/2021/TT-BLDTBXH also lists several 8415 codes where the actual product is an air-conditioning system. This article focuses on industrial refrigeration systems under heading 84.18; if the catalogue shows an air-conditioning machine or central AC system, HS classification and policy must be reviewed under heading 84.15.

SCOPE OF APPLICATION

Covered goods

Industrial/cold-room refrigeration systems imported as complete or modular systems.
Chillers, water chillers, condensing units, evaporators, compressor-condenser-evaporator packages imported as refrigeration solutions.
Systems for factories, storage facilities, food-processing lines, cold-chain logistics or EPE/FDI projects.

Not automatically covered

Air conditioners under heading 84.15.
Household refrigerators/freezers classified in specific 8418.10–8418.40 subheadings.
Separate compressors, pressure vessels, gas tanks, electrical control panels or piping.
Refurbished goods, dismantled project equipment, samples, warranty goods or incomplete technical dossiers.

Review must be based on catalogue, datasheet, model and actual import purpose. If the system includes charged refrigerant, separate refrigerant cylinders, wireless control modules, integrated electrical cabinets, pressure vessels or pressure piping, each component may trigger separate policy review.

CLASSIFICATION & TECHNICAL IDENTIFICATION

Technical identification

Main function: refrigeration, freezing, water/brine chilling or heat pump.
Components: compressor, condenser, evaporator, expansion valve, receiver, control cabinet, sensors and piping rack.
Cooling capacity, especially the 21.10 kW threshold for water-chilling equipment.
Refrigerant: NH3, CO2, HFC/HFO, Freon, hydrocarbons or blends; safety group under TCVN 6739:2015.
Charge quantity, particularly A2L systems from 5 kg.

Documents before HS finalization

Catalogue/datasheet showing cooling capacity, refrigerant, charge quantity and operating principle.
P&ID/layout if imported as a system.
BOM and detailed packing list for each module.
Nameplate photos of compressor, chiller, condensing unit, receiver and control cabinet.
SDS/MSDS if refrigerant is pre-charged or shipped together.

TECHNICAL IDENTIFICATION CRITERIA

Criterion	Document to verify	Risk if misdescribed	Suggested goods description
Main function	Catalogue, manual, technical description.	Confusion between refrigeration system, air conditioner, heat pump or parts.	“Industrial refrigerating system/chiller, model…, capacity…, refrigerant…”
Cooling capacity	Datasheet, nameplate.	Wrong HS branch, especially for water chillers above 21.10 kW.	State kW/RT capacity and operating temperature range.
Refrigerant and charge	SDS, catalogue, nameplate, charging record.	QCVN 21/conformity/safety-inspection dossier or controlled refrigerant policy may be missed.	State refrigerant type, safety group and pre-charged/not charged status.
Imported components	BOM, packing list, layout.	A single HS may be wrongly used for separate modules.	Separate lines for chiller, condenser, evaporator, receiver and control panel if imported separately.
New/used condition	Contract, invoice, photos, inspection certificate.	Used/refurbished goods declared as new.	State “brand new 100%” or the accurate actual condition.

HS CODE – DUTY – C/O

Refrigeration systems are commonly reviewed under heading 84.18. Classification must be based on function, structure, capacity, whether the shipment is complete or parts, and whether it is actually an air-conditioning machine of heading 84.15.

Reference HS	Application condition	Reference MFN	Reference ordinary duty	Reference VAT	FTA/C/O	Risk	Documents
8418.61.00	Heat pumps, excluding air-conditioning machines of 84.15.	10%	15%	10% or review 8% if eligible.	May be 0% under FTA.	Confusion with AC or chiller.	Catalogue, operating principle.
8418.69.41	Water chillers above 21.10 kW for air-conditioning machines.	10%	15%	10%/8%	Review FTA/C/O.	Purpose cannot be proven.	Datasheet, application note.
8418.69.49	Other water chillers above 21.10 kW.	10%	15%	10%/8%	May be 0% if C/O is valid.	Capacity or purpose unclear.	Datasheet, nameplate.
8418.69.50	Flake-ice making equipment.	3%	4.5%	10%/8%	Review by origin.	Confusion with water chillers.	Catalogue, process description.
8418.69.90	Other refrigerating/freezing equipment.	10%	15%	10%/8%	Many FTAs may be 0%.	“Other” code used without enough support.	Catalogue, P&ID, BOM.
8418.99.10	Evaporating or condensing equipment as parts of refrigeration systems.	0%	0%	10%8%	Review C/O by part code.	Part declared as a complete system or vice versa.	Packing list, BOM, part function, drawings.
8418.99.90	Other parts of refrigerating/freezing equipment not classified under a more specific part code.	0%	0%	10%8%	Review FTA/C/O by part code.	Failure to prove dedicated refrigeration part status.	Catalogue, part list, drawings, BOM.

APPLICABLE SPECIALIZED POLICIES

SPECIALIZED POLICY MATRIX

Goods situation	Possible policy	Documents to check	Authority/portal	Timing	Risk note
System using B1/B2L/B2/B3/A2/A3 refrigerants or A2L from 5 kg	Group 2 goods under MOLISA; review Circular 01/2021/TT-BLDTBXH, QCVN 21:2015/BLDTBXH, technical dossier, conformity certification/declaration and safety inspection before use if applicable.	Catalogue, SDS, charge quantity, nameplate.	Department of Work Safety / provincial labor authority if applicable.	Before ETA.	Missing charge quantity may delay registration.
System whose technical nature is air conditioning or a central AC chiller	Do not automatically use heading 84.18. Review heading 84.15; Circular 01/2021/TT-BLDTBXH also lists 8415.81.91, 8415.81.94, 8415.81.99, 8415.82.91, 8415.82.99, 8415.83.91, 8415.83.99 for relevant refrigerating systems.	Catalogue, system diagram, air-conditioning/cooling function, temperature range, refrigerant and charge.	Department of Work Safety / provincial labor authority or applicable portal.	Before HS finalization and before shipment.	Confusing 84.15 and 84.18 may cause wrong HS, duty and specialized policy.
System with controlled refrigerants or separate refrigerant cylinders	Review ozone-layer and controlled greenhouse gas rules.	SDS, CAS number, gas quantity, cylinder documents.	Environment authority/portal if applicable.	Before ordering.	High risk if gas is not declared separately.
System with pressure receiver or pressure piping	Review occupational-safety rules for pressure equipment and inspection before use.	P&ID, pressure rating, test certificate.	Safety inspection body/provincial labor authority.	Before customs clearance and before operation.	Pressure components may need separate treatment.
Used/refurbished equipment	Decision 18/2019/QD-TTg for used machinery under Chapters 84/85.	Inspection certificate, production year, technical standard.	Designated inspection body and customs.	Before signing and shipping.	Non-compliant used machinery may not be importable.
EPE/FDI/factory project import	Review use purpose, project documents, possible tax treatment and installation dossier.	Contract, PO, layout, technical dossier.	Customs / industrial-zone authority if relevant.	Before declaration.	Requires coordination between logistics, technical and compliance teams.

LEGAL DOCUMENTS TO REVIEW

Document group	Document	Issuing authority	Effective/application time	Role	Key point	Review note
Decree	Decree 44/2016/ND-CP	Government	Effective 01/07/2016.	Technical safety inspection of machinery/equipment.	Review if the system or pressure components require strict safety management.	Mainly relevant to installation/use but affects import planning.
Circular	Circular 01/2021/TT-BLDTBXH	MOLISA	Effective 18/07/2021.	Group 2 goods list; distinguish goods subject/not subject to state import quality inspection while still reviewing applicable QCVN requirements.	Refrigeration systems using B1/B2L/B2/B3/A2/A3 refrigerants or A2L with charge from 5 kg; listed HS codes include 8415.81.91, 8415.81.94, 8415.81.99, 8415.82.91, 8415.82.99, 8415.83.91, 8415.83.99, 8418.69.41, 8418.69.49, 8418.69.50, 8418.69.90, 8418.99.10.	Refrigeration systems are listed in Section II of the list; do not conclude exemption or applicability without checking QCVN 21 and the actual handling mechanism. This article prioritizes heading 84.18; if the file falls under 84.15, review separately.
QCVN/Circular	Circular 50/2015/TT-BLDTBXH issuing QCVN 21:2015/BLDTBXH	MOLISA	Effective 25/01/2016.	National technical regulation for refrigeration-system safety.	Technical and management requirements.	Review with TCVN 6104 and inspection dossier.
Environment	Decree 06/2022/ND-CP and Decree 119/2025/ND-CP	Government	07/01/2022 and 01/08/2025.	Ozone-layer and controlled greenhouse gas rules.	Review if controlled refrigerants are imported or contained.	Not automatically applicable to all equipment.
Tariff	Decree 26/2023/ND-CP; Decree 108/2025/ND-CP	Government	15/07/2023; 19/05/2025.	Preferential import tariff schedule.	Heading 84.18.	Check on declaration date.
Used machinery	Decision 18/2019/QD-TTg	Prime Minister	Effective 15/06/2019.	Used machinery/equipment under Chapters 84/85.	Age, inspection and import purpose.	Only if goods are used/refurbished and within scope.
VAT	Resolution 204/2025/QH15; Decree 174/2025/ND-CP	National Assembly; Government	Both effective from 01/07/2025; VAT reduction applies during 01/07/2025–31/12/2026.	Basis to review 8%/10% VAT upon import.	Exclusion appendices and declaration date.	Do not apply 8% automatically; verify actual goods and exclusions.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Businesses should search the legal documents by document number on official legal portals or the issuing authority’s website before applying them to a real shipment.

Circular 50/2015 Decree 44/2016 Circular 01/2021 Decree 26/2023 Decree 119/2025 Resolution 204/2025/QH15 Decree 174/2025/ND-CP

CUSTOMS CLEARANCE DOCUMENT SET

Commercial documents

Commercial Invoice.
Packing List, preferably separated by module.
Bill of Lading / Air Waybill.
Sales Contract / Purchase Order if any.
C/O if preferential duty is claimed.
Catalogue, datasheet, product photos, nameplate, model/serial list.

Specialized documents if applicable

QCVN 21 dossier: technical files, system diagram, conformity certification/declaration where applicable.
Quality inspection/registration or certification dossier under the actual handling mechanism if requested by the authority/certification body.
Pre-use technical safety inspection dossier where the system falls within QCVN 21.
SDS/MSDS, CAS number and charge quantity for refrigerants.
Pressure equipment dossier, pressure test certificate and P&ID.
Inspection certificate for used machinery.
Vietnamese import label dossier.

OPERATIONAL DOCUMENT CHECKLIST

Group	Documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO.	Value, quantity, Incoterms and description.	Buyer/Seller/Docs.	Generic description and no module breakdown.	Match line items with BOM and planned HS codes.
Transport	B/L/AWB, arrival notice, pre-alert.	D/O, manifest and customs declaration.	Forwarder/Carrier/Agent.	Incorrect package/weight/OOG details.	Compare pre-alert with packing list and booking.
Technical	Catalogue, datasheet, P&ID, BOM, nameplate.	HS and policy review.	Supplier/Technical/Procurement.	Missing capacity, refrigerant or charge data.	Request official PDF before ETD/ETA.
Refrigerant	SDS/MSDS, charging record, CAS, safety group.	Environment and Group 2 review.	Supplier/HSE/Compliance.	Unclear pre-charged or cylinder status.	Obtain nameplate photos and gas documents before shipping.
Origin	C/O and transport proof.	FTA preferential duty.	Seller/Exporter.	Wrong description, HS or origin criterion.	Check draft C/O before issuance.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question	Evidence	Consequence	Recommended action
HS basis	Is it a chiller, heat pump, ice machine, complete system or parts?	Catalogue, datasheet, BOM, P&ID.	Reclassification, tax adjustment or line split.	Prepare a function/component explanation table.
Refrigerant group	Does it fall into B1/B2L/B2/B3/A2/A3 or A2L ≥ 5 kg?	SDS, nameplate, charging record.	Late quality-inspection registration.	Confirm before departure.
Gas/cylinder included	Is refrigerant pre-charged or shipped in separate cylinders?	Invoice, packing list, MSDS.	Possible chemical/environment issue.	Declare separately when applicable.
New/used status	Brand-new, refurbished or dismantled project equipment?	Contract, invoice, inspection certificate.	Decision 18 risk.	Do not ship used units before inspection planning.
C/O eligibility	Do description, HS, origin criterion and consignment comply?	C/O, B/L, invoice, packing list.	FTA preference denied or origin verification.	Check draft C/O per HS line.

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Confirm HS, duty, VAT, C/O, refrigerant, charge quantity, Group 2 status, new/used condition and labeling.

Step 2: Lock documents

Match Invoice, Packing List, B/L/AWB, catalogue, datasheet, P&ID, BOM, nameplate and SDS.

Step 3: Specialized registration if required

Prepare QCVN 21, conformity, safety-inspection or specialized dossier before ETA if the shipment falls within specialized management.

Step 4: Customs declaration

Green channel may release conditionally; Yellow checks documents; Red checks both documents and physical goods.

Step 5: Clearance and post-clearance

Move goods to warehouse/site, check labels, arrange safety inspection if required and retain shipment records.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Prevention	Documents
Refrigerant and charge quantity not identified.	Group 2 or environment obligations missed.	Request SDS, nameplate and charge record.	SDS/MSDS, catalogue, nameplate.
Using HS 8418.69.90 for every configuration.	Reclassification or tax adjustment.	Prepare function/component matrix.	BOM, P&ID, datasheet.
Confusion with air conditioner heading 84.15.	Wrong HS and policy.	Check actual function and application.	Catalogue, application note.
Used/refurbished equipment without inspection.	Decision 18 risk.	Check age and condition before contract.	Contract, inspection certificate, photos.
C/O does not match modular shipment.	FTA preference may be denied.	Review draft C/O per HS line.	C/O, invoice, packing list.

FAQ – COMMON BUSINESS QUESTIONS

1. Does importing a refrigeration system require a permit?

Not always. Depending on refrigerant, charge quantity, safety classification, used status and configuration, QCVN 21/conformity/safety-inspection or other specialized review may arise.

2. What HS codes are commonly reviewed?

Heading 84.18, especially 8418.61.00, 8418.69.41, 8418.69.49, 8418.69.50, 8418.69.90 and parts under 8418.99.

3. When is it Group 2?

When the system uses specified refrigerant groups such as B1, B2L, B2, B3, A2, A3 or A2L from 5 kg, review Circular 01/2021, QCVN 21 and the applicable conformity/safety-inspection mechanism.

4. Is VAT 8% or 10%?

The standard review rate is 10%. During 01/07/2025–31/12/2026, 8% may apply if not excluded.

5. What if the system is used?

Review Decision 18/2019/QD-TTg, inspection certificate, production year and import purpose before shipping.

6. Does C/O reduce duty?

It may, if the C/O is valid and origin criteria are met. Modular systems require line-by-line checking.

7. Does the system with a gas receiver or pressure piping require separate handling?

Possibly. Pressure vessels, pressure piping or separate refrigerant cylinders may require separate HS and safety/chemical dossiers.

8. Is Vietnamese labeling required?

Yes. Imported goods placed on the Vietnamese market must review Vietnamese labeling requirements, including technical specifications and responsible party information.

IMPLEMENTATION SUPPORT FROM TGIMEX

This guide provides an overview of HS code, duty, documents and specialized policy. For a real shipment, the importer must still review catalogue, datasheet, model, documents, origin, refrigerant and charge quantity.

TGIMEX supports E2E import execution: pre-ETA policy review, document checking, international logistics coordination, customs declaration, clearance handling, inland delivery and post-clearance record retention.

Pre-ETA review

HS, duty, C/O, labels, refrigerant, charge quantity and Group 2 status.

Compliance documents

Invoice, Packing List, B/L/AWB, C/O, catalogue, SDS, labels and technical dossier.

International logistics

Agent/carrier coordination, ETA tracking, pre-alert and OOG/technical cargo planning.

Customs clearance

Declaration preparation, green/yellow/red channel handling and HS/origin/policy explanation.

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