Escalators are passenger-carrying equipment with high HS, quality-control and safety-inspection risks. Generic descriptions, insufficient technical dossiers or unclear complete/disassembled import conditions may lead to customs queries, delayed clearance and extra DEM/DET. This guide provides an E2E map for HS, taxes, C/O, QCVN, dossier control, customs clearance and pre-ETA risk blocking.

Review group	Reference information	Application note
Operational product name	Escalator for passenger use; may include handrail, steps, comb plate, drive motor, controller, safety sensors, balustrade and truss.	Do not automatically apply this file to elevators, freight conveyors or moving walkways with different construction.
Main reference HS	8428.40.00 – escalators and moving walkways.	Final HS must be confirmed against catalogue, drawings, import form and component list.
Reference taxes	MFN: 5%; ordinary duty: 7.5%; VAT: generally reviewed at 10%.	Special preferential duty may apply if a valid C/O is accepted; re-check tariff schedule on declaration date.
Main compliance policy	Quality inspection/conformity certification under QCVN 11:2012/BLĐTBXH; safety inspection before use.	For disassembled imports, control installation and post-installation conformity records.
Used equipment	May fall under Decision 18/2019/QĐ-TTg and amendments.	Do not confirm import plan without manufacturing year, applied standard and inspection certificate.

Legal note: This guide applies to passenger escalators. Review catalogue, datasheet, model, import configuration, new/used status, origin documents and actual purpose. Do not conclude that no permit/quality control is required without a complete technical dossier.

SCOPE OF APPLICATION

This article applies to passenger escalators for malls, stations, airports, buildings, factories and projects. Related products include elevators, escalators and passenger conveyors; however, this article does not automatically apply to electric elevators, hydraulic lifts, freight conveyors, lifting platforms, freight lifts or spare parts imported separately.

New goods, used/refurbished goods, samples, warranty goods, project imports or disassembled complete sets may trigger different policies. Motor, controller, speed-control module, safety sensors or electrical parts imported separately must be reviewed on their own dossier.

Review according to catalogue, datasheet, model and actual import purpose.

CLASSIFICATION & PRODUCT IDENTIFICATION

Technical identification

A passenger escalator normally includes truss, steps, handrail, comb plates, drive motor, gearbox, brakes, controller, safety sensors, protection panels and alarms. Lock model, manufacturing year, speed, angle, step width, rise height, transport capacity, drive type and applied standards.

Description warning

Generic naming may lead to incorrect HS, incorrect sectoral policy, wrong QCVN/TCVN, permit mistakes and labelling discrepancies.

TECHNICAL IDENTIFICATION CRITERIA TABLE

Criteria to check	Documents to compare	Risk if wrongly described	Suggested goods description
Nature of goods	Catalogue, drawings, datasheet, contract, photos.	Misclassification as elevator, freight conveyor or spare parts.	“Passenger escalator, model…, capacity…, speed…, rise height…, brand-new”.
Import condition	Packing list, model list, component list, installation drawings.	Disassembled complete set may be questioned if declared too generally.	State “complete set in CKD/SKD condition” where applicable.
Key specifications	Datasheet, general arrangement drawing, technical description.	Weak HS/QCVN dossier if speed, step width, rise and drive type are missing.	Show speed, angle, step width, drive and control system.
Controller, motor, sensors	Wiring diagram, accessory list, user manual.	Separate modules may need separate HS such as 8501, 8537, 8431/8483.	If imported separately, describe as component and its use.
Condition	Invoice, labels, serial, manufacturing year, certificates.	Refurbished/used status may trigger used machinery rules.	Clearly state new or actual condition.

HS CODE – DUTY – C/O

Passenger escalators are generally reviewed under heading 8428 for lifting, handling, loading or unloading machinery. Final HS must be based on the technical nature: passenger escalator/moving walkway, complete or disassembled set, and whether parts are imported separately.

REFERENCE HS CODE TABLE

Reference HS code	Application conditions	Reference taxes	Risk of wrong HS	Documents to compare
8428.40.00	Complete escalator/moving walkway for passenger use, imported as a complete unit or synchronized set.	MFN 5%; ordinary 7.5%; VAT generally 10%.	Wrong duty, wrong quality-control dossier and customs queries.	Catalogue, datasheet, drawings, contract, packing list, model list.
8431.xx or suitable parts heading	Parts imported separately and not forming a complete synchronized escalator.	Check by each 8-digit line.	Wrongly grouping parts as a complete machine or vice versa.	BOM, accessory list, position drawing.
8501 / 8537 / 8483…	Motor, control panel, gearbox or electrical/mechanical modules shipped separately.	Check individually.	Modules not proven as synchronized may be classified separately.	Line-item invoice, module catalogue, wiring/mechanical diagrams.
Special preferential C/O	Valid C/O under applicable FTA.	May be lower than MFN if origin criteria are met.	C/O rejection due to wrong form, origin criterion, description, HS or transport documents.	C/O, through B/L, invoice and transit documents if any.

REFERENCE TAX TABLE

Tax element	Reference level for HS 8428.40.00	Condition	Point to lock before declaration
MFN import duty	5%	When MFN treatment and correct HS are applicable.	8-digit HS, product name, exporting country, origin and condition.
Ordinary import duty	7.5%	Review where MFN/FTA treatment is not applicable.	Do not use ordinary rate if MFN/FTA is valid.
VAT	Generally 10%; review VAT policy on declaration date.	VAT reduction is not automatic.	Check HS, product description and effective VAT regulation.
FTA special preference	May be lower than MFN depending on FTA and origin.	C/O must be valid in form, origin criterion, description, HS and direct transport.	Review draft C/O before ETA.

C/O risk: Incorrect C/O form, origin criterion, goods description, HS code or direct transport/transit documents may result in rejection of FTA preference.

APPLICABLE SECTORAL POLICY

SECTORAL POLICY MATRIX TABLE

Goods situation	Possible policy	Documents to check	Authority/portal if identifiable	Recommended timing	Risk note
New complete escalator	Quality inspection/conformity certification under QCVN 11:2012/BLĐTBXH; safety inspection before use.	Catalogue, original technical dossier, CQ, CO, test report, drawings, manuals.	Designated certification/inspection body; customs; labour safety authority.	Before booking/ETA.	Do not state “no permit” without the technical dossier.
Disassembled synchronized set	May be temporarily cleared by set and completed after installation, subject to QCVN process.	Detailed packing list, BOM, GA drawing, installation plan.	Certification/inspection body and Customs.	Before ETA.	Missing BOM may trigger HS split or inspection hold.
Used/refurbished goods	Used machinery policy under Decision 18/2019/QĐ-TTg and amendments.	Manufacturing year, applied standards, inspection certificate, maintenance records.	Inspection body and Customs.	Before purchase/booking.	Do not book without age/standard confirmation.
Separate controller, motor or parts	Policy follows each component.	Line-item invoice, module catalogue, wiring/mechanical diagrams.	Customs and sectoral authority if applicable.	Before invoice issuance.	Wrong part description may lead to reclassification.
Sample/project/warranty goods	HS, label, value and used machinery policy still need review.	Purpose letter, project/warranty documents, technical dossier.	Customs; certification body if put into use.	Before ETA.	Sample/warranty status does not automatically exempt compliance.

LEGAL DOCUMENTS TO REVIEW

Document group	Document name/number	Issuing authority	Effective timing	Role in procedure	Key point	Review note
Technical regulation	QCVN 11:2012/BLĐTBXH under Circular 32/2012/TT-BLĐTBXH	MOLISA	Issued 19/12/2012; verify current validity.	Safety requirements for escalators/passenger conveyors; import, circulation, installation and use.	Original technical dossier, import conditions and safety inspection.	Review by actual dossier, especially disassembled imports.
Strict-safety equipment list	Circular 36/2019/TT-BLĐTBXH	MOLISA	Effective 01/03/2020.	Management framework for machinery with strict OSH requirements.	Attached list.	Compare actual goods and QCVN.
Safety inspection process	QTKĐ 25:2016/BLĐTBXH	MOLISA	Apply current inspection process.	Inspection procedure before use/periodic/extraordinary.	Dossier check, technical check, load test and result handling.	Use designated inspection body.
Used machinery	Decision 18/2019/QĐ-TTg; Decision 28/2022/QĐ-TTg	Prime Minister	Decision 18 effective 15/06/2019; Decision 28 effective 01/03/2023.	Used machinery import conditions.	Age, standards and inspection certificate.	Only relevant if not brand-new.
Goods labels	Decree 43/2017/NĐ-CP; Decree 111/2021/NĐ-CP	Government	Decree 111 effective 15/02/2022.	Original and Vietnamese supplemental labels.	Origin, responsible party, model and key specifications.	Labels must match documents and serial/model.
Tariff schedule	Decree 26/2023/NĐ-CP and amendments; current import tariff	Government/MOF	Review on declaration date.	Import duty, VAT and FTA preferences.	HS 8428.40.00 and parts HS if separate.	Do not finalize tax without HS and C/O.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises should search by document number on official legal portals or issuing authority websites. Always cross-check official sources before application.

Decision 18/2019/QĐ-TTg Decree 111/2021/NĐ-CP HS 8428.40.00

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order where available.
C/O if claiming duty preference.
Catalogue, datasheet, drawings, photos and model/serial list.

Sectoral dossier if applicable

Original technical dossier under QCVN 11:2012/BLĐTBXH.
Quality inspection/conformity certification dossier.
CQ, CO, test report, GA drawing and load test process.
Labelling dossier, safety manual and warnings.
Inspection certificate if used machinery.

Matching rule: Product name, quantity, model, serial, origin and specifications must match 100% across commercial documents, catalogue, labels, sectoral dossier and customs declaration.

OPERATIONAL DOSSIER CHECKLIST TABLE

Dossier group	Required documents	Used for	Usually prepared by	Common error	Pre-ETA check
Commercial documents	Invoice, Packing List, Contract/PO, B/L/AWB, C/O if claiming preference.	Declaration, tax and C/O review.	Shipper, importer, forwarder, Docs team.	Generic goods name, missing model, wrong packages/weight.	Compare each invoice line with packing list and catalogue.
Technical dossier	Catalogue, datasheet, GA drawings, installation drawings, manual, wiring diagram, model/serial list.	HS, compliance and customs explanation.	Manufacturer/supplier and technical team.	Missing speed, step width, rise height or drive type.	Prepare mandatory specification checklist before booking.
QCVN/quality dossier	CQ, CO, test report, conformity certification/quality registration if applicable, original technical dossier.	Quality inspection/conformity certification.	Importer, certification body, manufacturer.	Cannot prove synchronized set.	Check BOM and drawings before ETA.
Used machinery dossier if any	Manufacturing year, inspection certificate, applied standard, maintenance records, photos.	Used machinery eligibility.	Supplier, inspection body, importer.	Certificate missing key data.	Do not book without age/standard evidence.
Label dossier	Original label photos, draft Vietnamese sub-label, warning labels and safety manual.	Circulation/installation/use.	Importer, compliance and installer.	Missing origin, model or key specification.	Take label photos before shipment.

CLEARANCE DECISION POINTS

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended action
Is HS supported?	Complete escalator, moving walkway or parts?	Catalogue, drawings, BOM, packing list.	Reclassification and duty/compliance mismatch.	Confirm 8-digit HS before documents are issued.
Is QCVN 11 applicable?	Does it carry passengers as an escalator/passenger conveyor?	Datasheet, manual, drawings, use purpose.	Quality inspection delay.	Review QCVN 11 at inquiry stage.
Complete or disassembled?	Are all components synchronized for one system?	BOM, installation drawing, packing list.	HS split or post-installation dossier request.	State complete set and package mapping.
New or used?	Can 100% new status be proven?	COC/CQ, label, manufacturing year, photos.	Used machinery policy may apply.	Lock condition in contract and invoice.
Is C/O acceptable?	Are form, origin criterion, HS, description and transport correct?	C/O, B/L, invoice, packing list.	FTA preference rejected.	Review draft C/O before ETA.

PRACTICAL E2E PROCEDURE

Step 1 – Pre-ETA review: HS, QCVN, taxes, C/O, labels, new/used status and quality-control route.

Step 2 – Lock documents: Invoice, Packing List, B/L/AWB, catalogue, BOM, drawings and model/serial list.

Step 3 – Sectoral registration if required: prepare quality/conformity dossier and select suitable certification/inspection body.

Step 4 – Customs declaration: handle Green/Yellow/Red channel and explain HS, value, C/O, catalogue and policy.

Step 5 – Clearance and delivery: move goods to project/site, control labels and installation records.

Step 6 – Post-clearance/use: retain lot dossier, arrange safety inspection, acceptance minutes and maintenance records.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents to check
Generic description such as “machinery equipment”	HS and compliance queries.	Describe as passenger escalator with model and specifications.	Invoice, packing list, catalogue.
Missing original technical dossier	Insufficient QCVN/conformity basis.	Request drawings, manual, test/loading process from manufacturer.	Datasheet, drawing, manual, CQ/test report.
Disassembled set not proven synchronized	HS split or physical inspection hold.	Prepare BOM and package mapping.	BOM, packing list, installation drawing.
C/O errors	FTA duty preference rejected.	Review draft C/O before issuance.	C/O, invoice, B/L, transit docs.
Used/refurbished status not controlled	Used machinery policy issue.	Confirm condition, manufacturing year and inspection report before booking.	Photos, serial, certificate, inspection report.
No post-installation inspection plan	Cannot put equipment into legal use.	Book designated inspection body before handover.	Installation record, acceptance minutes, technical dossier.

FAQ

1. Does importing an escalator require quality inspection?

It may be subject to quality inspection/conformity certification under QCVN 11:2012/BLĐTBXH. Review actual dossier and import condition.

2. What is the HS code?

Reference HS is 8428.40.00. Parts, motors or controllers imported separately may require different HS codes.

3. What taxes apply?

Reference: MFN 5%, ordinary duty 7.5%, VAT generally 10%. Check on declaration date.

4. How to handle disassembled imports?

Prepare BOM, detailed packing list and installation drawings to prove a synchronized complete set.

5. Can used escalators be imported?

Used/refurbished goods may be subject to Decision 18/2019/QĐ-TTg and amendments.

6. When is safety inspection needed?

Before being put into use, then periodically or extraordinarily as required by the safety inspection procedure.

IMPLEMENTATION SUPPORT FROM TGIMEX

This guide provides the map for HS, taxes, dossier and sectoral policy for passenger escalators. Real shipments still require review against catalogue, datasheet, model, documents, origin, condition and import purpose.

Coordination capability

Agent network in over 60 countries; WCA, WCA China Global, VLA and HNLA membership; sea, air, road/rail, warehouse and inland delivery capability.

Scope of support

Pre-ETA review: HS, QCVN, C/O, taxes, labels and technical dossier.
Compliance control: Invoice, Packing List, B/L/AWB, C/O, test reports and labels.
International logistics, pre-alert, customs declaration, channel handling and inland delivery.

For shipments that may trigger sectoral inspection, C/O or labelling requirements, enterprises should not wait until cargo arrival to review documents. Small discrepancies between Invoice, Packing List, catalogue, datasheet, C/O or labels may lead to document supplementation, clearance delay or unplanned storage costs.

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