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Import procedures for machinery and equipment classified as Group 2 goods under specialized management
Machinery or equipment brought into a Group 2 goods list cannot be handled as ordinary mechanical equipment. Common risks include incorrect HS classification, missed state quality inspection registration, missing conformity certification, wrong applicable QCVN/TCVN, or model discrepancies among the invoice, packing list, catalogue and original label. If handled incorrectly, the shipment may be routed for document/physical inspection, held for supplementary dossiers, lose C/O preferential duty treatment, or incur DEM/DET charges. This article provides an E2E (End-to-End) map for pre-ETA review: model identification, HS–duty–C/O, Group 2 policy, customs dossier, clearance workflow and decision points to lock before arrival.
Quick fact
| Item | Operational direction | Pre-ETA checkpoint |
|---|---|---|
| Scope | Machinery/equipment whose model, HS code or QCVN is included in a Group 2 goods list issued by a specialized ministry. | Do not apply this automatically to all machinery; review the actual catalogue, datasheet, model and import purpose. |
| Main policy | State quality inspection; conformity certification/declaration where required by applicable QCVN. | Identify the competent ministry: MOST, MOLISA, MOT, MIC, MOIT, MOC or another sectoral authority. |
| HS and taxes | No single HS applies to all Group 2 machinery. HS depends on principal function, structure and operating principle. | Lock the 8-digit HS code, MFN duty, ordinary duty, VAT and C/O preferential treatment before declaration. |
| Core risk | The model is discovered to be Group 2 only after arrival, or test reports/conformity documents are not ready. | Check the sectoral list and QCVN as soon as PI/catalogue is available. |
Legal note: From 2026, Law 78/2025/QH15 and Decree 37/2026/ND-CP should be cross-checked when handling import quality-inspection obligations. The term “Group 2 goods” must still be reviewed against the sectoral list/QCVN issued by the competent ministry, but older decrees should not be used as a standalone legal basis if the file is governed by the new framework. This article is an operational review framework; it is not a binding HS ruling, quality-inspection conclusion or authority decision.
Scope of application
This article applies to a machinery or equipment model listed as a product/goods posing potential safety risks, commonly referred to as Group 2 goods. The scope may cover industrial machinery, electrical/electronic equipment, lifting equipment, pressure equipment, telecommunications devices, specialized machines, or factory machinery subject to QCVN/TCVN requirements.
Covered cases
- Models named in a sectoral Group 2 list.
- Models whose HS codes are listed but still require technical description matching.
- New machinery imported for trading, projects, factories, FDI/EPE use.
- Samples, testing goods or warranty goods if still controlled by sectoral rules.
Not automatically covered
- Ordinary mechanical machines not included in any Group 2 list.
- Used machinery governed by Decision 18/2019/QD-TTg.
- Machines with Wi‑Fi/Bluetooth/4G/5G, encryption, batteries, adapters, chargers or special control software.
- Integrated lines containing multiple equipment groups with different policies.
Review must be based on the actual catalogue, datasheet, model and import purpose.
Classification and technical identification
Generic names such as “machine”, “equipment”, “industrial device” or “parts for production line” are not sufficient. The dossier should prove the principal function, structure, operating principle, safety parameters, standards, model, serial number and accompanying accessories.
| Checklist criterion | Reference document | Risk if described incorrectly | Suggested declaration description |
|---|---|---|---|
| Principal function | Catalogue, datasheet, manual, photos | Wrong HS or wrong sectoral policy | Machine name + main function + industry/application if relevant |
| Model and serial | Model list, nameplate, packing list | Mismatch with quality/conformity dossier | State model, series, power, voltage and version |
| Applicable QCVN/TCVN | Group 2 list, QCVN, test report | Missing quality inspection or wrong certification body | Add standard/regulation if required by the sectoral dossier |
| Condition | Invoice, contract, photos, inspection certificate if used | Used machinery may trigger age/standard/inspection requirements | State “new 100%” or the actual condition clearly |
| Accessories | Packing list, controller, adapter, motor, sensor, wireless module | Accessories may trigger ICT, electrical safety or energy rules | Separate accessories where needed and clarify whether they change the machine’s nature |
HS code – Duties – C/O
Group 2 status is a sectoral policy layer; import duty still depends on the final 8-digit HS code. Classification must consider principal function, structure, operating principle, completeness, accessories and Chapter Notes of Chapters 84/85/90.
| Reference HS code | When applicable | Reference MFN | Reference ordinary duty | VAT | Risk of misclassification | Dossier to review |
|---|---|---|---|---|---|---|
| 8479.82.10 | Electric mixing, stirring, crushing, grinding, kneading or mechanical material-processing machinery not more specifically covered elsewhere. | 0% | 5% | 10% | Confused with food-processing machinery under 8438 or heating equipment under 8419. | Catalogue, operation principle, power rating, mixing chamber/blade photos. |
| 8479.82.20 | Non-electric or differently powered mixing/stirring/crushing/kneading machinery. | 0% | 5% | 10% | Wrong power source changes HS and duties. | Datasheet, nameplate, transmission diagram. |
| 8479.89.xx | Machines with individual functions not specified elsewhere; final 8-digit code must be locked. | Check by 8-digit HS | Check under Decision 15/2023/QD-TTg | 10% | Overusing “other machines” when the product belongs to 8422, 8438, 8419, 8428 or 9031. | Functional explanation, operation video, catalogue. |
| 8422.xx | Washing, filling, closing, labelling or packaging machinery if the model is placed in Group 2. | Check detailed code | Check detailed code | 10% | Declaring as ordinary machinery while sectoral quality inspection applies. | Catalogue, machine layout, packing/filling/labelling function. |
| 8438.xx | Food or beverage industry machinery when the principal function fits heading 8438. | Check detailed code | Check detailed code | 10% | Confusing general material-processing machines with specialized food machinery. | Production process, output product, catalogue. |
| 8419.xx | Equipment for material treatment by temperature change: heating, drying, cooling, sterilizing, heat exchange. | Check detailed code | Check detailed code | 10% | Missing pressure/thermal/refrigeration policy where relevant. | Thermal diagram, pressure/temperature data, material and safety documents. |
| 8501 / 8537 / 8504 | Motors, electrical cabinets, controllers, inverters, power supplies/adapters when imported separately or materially relevant. | Check detailed code | Check detailed code | 10% | Electrical accessories may trigger quality, electrical-safety or energy requirements. | Accessory list, wiring diagram, catalogue of each module. |
| 8517 / 8526 / 8528 / 9031 | ICT, measuring, display, transmitting or smart-control devices where the actual model has such functions. | Check detailed code | Check detailed code | 10% | May trigger ICT conformity, quality inspection, information security or civil cryptography rules. | Wireless module datasheet, test report, user manual and encryption/software functions. |
C/O: Preferential C/O may reduce import duty only when the correct FTA form, origin criterion, product description, HS code and transport route are accepted. It does not replace quality inspection, conformity certification/declaration or labelling dossiers.
Specialized policy matrix
| Goods situation | Potential policy | Dossier to check | Authority/portal where identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Model included in a Group 2 list | State quality inspection; conformity certification/declaration where QCVN requires. | Group 2 list, QCVN, catalogue, test report, contract, invoice, packing list. | Sectoral ministry; National Single Window if connected. | Before ETA, from draft documents. | Do not wait until arrival to check the list. |
| Equipment with motor/controller/adapter | Possible electrical safety, energy efficiency or sectoral QCVN rules. | Electrical datasheet, voltage, power, adapter/motor model. | Competent ministry by list. | Before HS and declaration are locked. | Accessories may change the policy layer. |
| Lifting, pressure, boiler, refrigeration or pressure-piping equipment | Occupational safety/technical safety inspection may apply. | Catalogue, factory certificate, pressure/load rating, year of manufacture. | Relevant occupational safety/sectoral authority. | Before import and before use. | Post-clearance use requirements may be the main risk. |
| Wi‑Fi/Bluetooth/4G/5G or radio module | ICT conformity, radio, information security or related controls may apply. | Wireless module datasheet, test report, user manual, label photos. | MIC/sectoral authority where within scope. | Before ETA. | Do not treat as pure mechanical equipment if radio functions exist. |
| Used/refurbished machinery | Decision 18/2019/QD-TTg and amendments; inspection certificate may be required. | Year of manufacture, standards, inspection certificate, technical dossier. | Customs and eligible inspection organization. | Before purchase commitment. | Check age and standard before buying. |
| Sample/testing/warranty/project goods | May differ from commercial goods but is not automatically exempt. | Purpose letter, warranty contract, testing documents, quantity. | Customs/sectoral authority case by case. | Before declaration. | Review based on the actual dossier. |
Legal documents to review
| Group | Document | Issuing body | Effective/applicable timing | Role in procedure | Key points | Review note |
|---|---|---|---|---|---|---|
| Law | Law on Product and Goods Quality 05/2007/QH12 and Amending Law 78/2025/QH15 | National Assembly | Law 78/2025/QH15 takes effect from 01 January 2026. | Legal basis for product and goods quality management; shifts the review toward risk-based control and appropriate traceability/inspection obligations. | Review provisions on potentially unsafe goods, import quality inspection and importer responsibilities. | Use as the legal baseline; it does not replace sectoral lists/QCVN issued by competent ministries. |
| Decree | Decree 37/2026/ND-CP | Government | Issued and effective from 23 January 2026. | Current decree to review for import quality inspection, inspection exemption/reduction, handling during inspection and traceability. | Review provisions on import quality inspection for medium/high-risk goods and any appendices/transitional rules. | Do not rely on Decree 132/2008, 74/2018 and 13/2022 as the main basis for files governed by Decree 37/2026. |
| Legacy / transition | Decrees 132/2008/ND-CP, 74/2018/ND-CP, 154/2018/ND-CP and 13/2022/ND-CP | Government | Amended multiple times; check legal status/transitional effect at declaration date. | Historical basis for Group 2 goods, quality inspection and conformity procedures; may still appear in older dossiers or sectoral references. | Do not use independently where new regulations govern the same issue. | Use only for historical explanation or transitional files. |
| Conformity framework | Circular 28/2012/TT-BKHCN, Circular 02/2017/TT-BKHCN and amendments where applicable | Ministry of Science and Technology | Review current status/amendments. | Framework for standards/regulations conformity declaration and conformity assessment methods. | Conformity certification/declaration method and dossier. | If a sectoral ministry has separate rules, review the sectoral document and applicable QCVN first. |
| ICT / telecom if applicable | Circular 02/2024/TT-BTTTT | Ministry of Information and Communications | Effective from 15 May 2024. | Relevant where the machine/equipment includes modules or functions under MIC-managed potentially unsafe goods. | List appendices, HS, product descriptions, QCVN and any exemption/suspension provisions. | Apply only if the actual model has ICT/telecom functions or is listed by MIC. |
| Civil cryptography if applicable | Decree 211/2025/ND-CP | Government | Effective from 09 September 2025. | Relevant where the model has civil-cryptography functions subject to import/export licensing. | List of civil-cryptography products and licensing dossier if applicable. | Do not attach automatically to every Group 2 machine; review only where the catalogue/datasheet shows encryption/security functions within scope. |
| Decision | Decision 18/2019/QD-TTg; Decision 28/2022/QD-TTg | Prime Minister | Decision 18 effective 15 June 2019; Decision 28 effective 01 March 2023. | Management of used machinery, equipment and technological lines. | Age of equipment, standards and inspection certificate. | Only applicable to used/refurbished goods. |
| Tariff | Decree 26/2023/ND-CP; Decision 15/2023/QD-TTg | Government; Prime Minister | Both effective from 15 July 2023; check amendments on declaration date. | Determine MFN and ordinary import duty by final 8-digit HS code. | Tariff schedule under Chapter 84/85/90 or actual relevant chapter. | Do not use one tax rate for all Group 2 machinery; finalize by actual HS. |
| Sectoral documents | Potentially unsafe goods lists/QCVN issued by competent ministries | Sectoral ministries | Depends on each list and QCVN. | Determine whether quality inspection, conformity certification/declaration or a sectoral permit is required. | List appendices, HS, goods description, QCVN and management method. | Further review is required based on the actual dossier/product group. |
View / download original legal texts
Enterprises may search the legal instrument number on the official legal document portal, the Government portal or the issuing authority website. The buttons below prioritize the main references for machinery/equipment subject to sectoral inspection.
Law 78/2025/QH15Decree 37/2026/ND-CPDecree 26/2023/ND-CPDecision 15/2023/QD-TTgDecision 18/2019/QD-TTgDecree 211/2025/ND-CPCircular 02/2024/TT-BTTTT
Enterprises should also cross-check the legal portal or the issuing authority website before application.
Customs clearance dossier
Commercial documents
- Commercial Invoice.
- Packing List.
- Bill of Lading/Air Waybill.
- Sales Contract/Purchase Order where available.
- C/O where preferential duty is claimed.
- Catalogue, datasheet, user manual, machine photos, original label, model/serial list.
Specialized dossier if applicable
- State quality inspection registration.
- Conformity certificate/declaration.
- Test report, type approval or inspection certificate if required.
- Labelling/supplementary labelling dossier.
- Technical documents, QCVN/TCVN, factory certificate.
- Used machinery dossier if applicable.
| Dossier group | Required documents | Process use | Usual preparer | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO | Declaration, customs value, quantity | Importer, exporter, purchasing | Generic goods name, missing model | Check model, quantity, origin and value |
| Transport | B/L, AWB, Arrival Notice, pre-alert | D/O, declaration, delivery | Forwarder, carrier/airline | Wrong consignee, weight/package discrepancy | Check pre-alert before ETA |
| Technical | Catalogue, datasheet, manual, nameplate | HS and Group 2 policy | Supplier, engineering, compliance | Catalogue does not match imported model | Compare model across documents |
| Specialized | Quality registration, conformity certificate/declaration, test report | Clearance/market circulation condition | Importer, certification body, compliance team | Late filing, wrong QCVN, wrong model | Confirm authority and certification body before ETA |
| C/O | FTA C/O, transport document, invoice | Preferential duty review | Exporter, importer, broker | Wrong HS, description or origin criterion | Check draft C/O where possible |
Control rule: Goods name, quantity, model, serial, origin and technical parameters must match across commercial documents, catalogue, labels, specialized dossiers and the customs declaration.
Decision points that may hold the shipment
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended action |
|---|---|---|---|---|
| HS basis | Is the principal function proven? | Catalogue, datasheet, photos, HS explanation | Inspection channel, explanation request | Lock HS before ETA |
| Group 2 status | Is the model/HS/description in a sectoral list? | Group 2 list, QCVN, technical description | Missing quality registration | Check list from PI/catalogue stage |
| Applicable QCVN | Which technical regulation applies? | QCVN, test report, certificate | Rejected specialized dossier | Identify QCVN and certification body |
| New or used | Is it used/refurbished? | Invoice, photos, year, inspection certificate | Decision 18 risk | Verify before purchase |
| C/O eligibility | Are form, origin criterion, description and HS aligned? | C/O, invoice, B/L, declared HS | No preferential duty; tax recovery | Review draft C/O and transport route |
Practical E2E workflow
Step 1 — Pre-ETA review
Lock HS, Group 2 status, QCVN, taxes, C/O, labelling and goods condition.
Step 2 — Lock documents
Match Invoice, Packing List, B/L/AWB, catalogue, model list, serial list and original label.
Step 3 — File sectoral procedures
Quality inspection/conformity dossier if the model falls within scope.
Step 4 — Customs declaration
Green channel: conditional clearance; Yellow: document check; Red: document and physical inspection.
Step 5 — Clearance and delivery
Take delivery, move to warehouse, complete sectoral dossier and supplementary labels where required.
Step 6 — Post-clearance archive
Archive declaration, C/O, Group 2 dossier, conformity documents, test reports and transport records.
Pre-ETA risk checklist
| Risk | Consequence | Pre-ETA control | Documents to review |
|---|---|---|---|
| Overly generic goods name | Wrong HS/policy | Standardize description by function and model | Invoice, packing list, catalogue |
| Group 2 model missed | No quality/conformity dossier at declaration | Check sectoral list | Group 2 list, QCVN, datasheet |
| Missing test report/certificate | Specialized dossier held | Request scanned copies in advance | Test report, certificate, declaration |
| Wrong C/O form or HS | Preferential duty denied | Review draft C/O | C/O, invoice, B/L, HS |
| Used machine declared as new | Used machinery policy risk | Verify year and condition | Photos, nameplate, inspection certificate |
FAQ
1. Does Group 2 machinery require an import permit?
Do not conclude generally. Many cases require quality inspection/conformity procedures; some special models may require additional permits or conditions.
2. Is quality inspection required?
If the model/HS/description is in a Group 2 list and applicable QCVN exists, quality inspection should be reviewed under the competent ministry.
3. Can C/O reduce duty?
Yes, where the FTA form, origin criterion, description, HS and transport route are accepted. C/O does not replace Group 2 dossiers.
4. Are samples exempt?
Not automatically. Samples, testing goods and warranty goods still require review against sectoral lists and import purpose.
5. What if invoice model differs from catalogue?
Correct documents or prepare explanation before declaration. Model discrepancies are a common reason for specialized dossier rejection.
6. How to handle used machinery?
Review Decision 18/2019/QD-TTg and amendments; check year of manufacture, standards and inspection certificate requirements.
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