Passenger conveyors / moving walkways are continuous passenger-transport systems used in airports, stations, commercial buildings and public facilities. The key risk is not the commercial name but the correct classification under HS Code 8428.40.00, Group 2 quality inspection, applicable QCVN, technical dossier and safety control before use. This article provides an E2E map for pre-ETA review: HS code, duties, C/O, specialized policy, dossiers and control points.

Legal note: This article applies only to complete passenger conveyors / moving walkways. It must not be automatically used for elevators, escalators, cargo/material conveyors or separate spare parts. Review actual catalogue, datasheet, model, installation drawings, safety components and import purpose.

QUICK FACT

Criteria	Key review points
Product	Passenger conveyor / moving walkway; continuous moving surface for passenger transport.
Reference HS	8428.40.00 – escalators and moving walkways.
MFN import duty	Reference 5% for 8428.40.00; verify the tariff in force at declaration date.
Ordinary duty	Reference 7.5% where MFN/FTA conditions are not met; check the current ordinary tariff.
VAT	Common base rate 10%; review any VAT reduction only if still effective and not excluded.
Specialized policy	Falls under Section I, No. 9 of Circular 01/2021/TT-BLDTBXH: state quality inspection is required upon importation; key technical basis: QCVN 11:2012/BLDTBXH.
Processing authority/portal	The Department of Work Safety is listed as the inspection authority; the current filing portal/receiving mechanism must be checked at the time of import.
Labeling	Original label/Vietnamese sub-label should show product name, model, origin, key specifications and responsible entity.

SCOPE OF APPLICATION

Covered

Moving walkways/passenger conveyors.
New 100% complete or synchronized systems.
Systems for airports, stations, malls, public facilities, factories or projects transporting passengers.

Not automatically covered

Passenger elevators, freight elevators and escalators.
Cargo/material conveyors and industrial conveyors.
Separate parts such as brakes, safety gears, traction machines, motors or gearboxes.
Used/refurbished equipment or project-specific systems.

CLASSIFICATION & TECHNICAL IDENTIFICATION

The dossier must prove that the equipment transports persons, not materials. Review length, belt/pallet width, nominal speed, inclination, design load, braking system, emergency stop, safety sensors, traction machine, control cabinet and design standards.

Criterion	Documents to compare	Risk if misstated	Suggested description on documents/declaration
Main function	Catalogue, datasheet, general arrangement drawing	Misclassified as cargo conveyor or escalator	Passenger conveyor / moving walkway, brand, model, new 100%, for transporting passengers
Moving structure	Technical drawing, specification	Unable to distinguish flat/inclined moving walkway from escalator steps	Passenger conveyor, flat/inclined belt or pallet type, not cargo conveyor
Safety components	Manual, test report, component list	Insufficient basis for quality inspection/conformity assessment	State brake, safety gear and emergency stop where imported as complete system
Model/serial	Model list, nameplate, packing list	Mismatch between invoice and catalogue	Keep one model format across Invoice, Packing List, C/O and catalogue
Condition	Contract, photos, year of manufacture	Used goods may trigger different import conditions	State new 100%; if used/refurbished, review separately
Use purpose	Project contract, installation drawings	Wrong purpose may affect safety compliance	For installation at airport/building/station passenger transport area

HS CODE – DUTIES – C/O

HS classification should follow the nature of continuous passenger-moving equipment. The word “conveyor” alone must not lead to cargo conveyor codes.

Reference HS	Application condition	Risk if incorrect	Documents to compare
8428.40.00	Complete passenger conveyor / moving walkway; same HS line as escalators but description must be clear.	Incorrect tax and specialized policy if declared as material conveyor.	Catalogue, datasheet, installation drawings, manual, nameplate.
8431.31.10 / 8431.31.20	Only for separately imported safety components/parts where technically justified.	Parts declared as complete equipment or vice versa may be rejected.	BOM, component list, part number, function description.
Other HS codes	Only where documents prove the goods are not complete passenger conveyors.	Policy and C/O mismatch.	Technical explanation, actual photos, project documents.

Tax component	Reference level	Application note
MFN import duty	5%	For correct 8428.40.00 classification and MFN eligibility.
Ordinary import duty	7.5%	Reference only; verify if MFN/FTA is not available.
Import VAT	10%	Check VAT reduction policy at declaration date if any.
Special preferential duty	May be 0% or another FTA rate	Only with valid C/O, correct form, origin criterion and goods description.
C/O	Form E/D/AK/VJ/AJ/CPTPP/EVFTA/RCEP… depending on exporting country	Check HS, description, quantity, third-party invoice and direct transport.

APPLICABLE SPECIALIZED POLICY

Goods scenario	Possible policy	Documents to check	Authority/portal if identifiable	Recommended timing	Risk note
Complete passenger conveyor	Group 2 quality inspection and conformity review under QCVN 11:2012/BLDTBXH.	Quality inspection registration, catalogue, test report, certificate, manual, drawings, labels.	Current occupational safety authority/NSW or relevant portal.	Before ETA or once pre-alert is available.	Late dossier preparation may delay clearance.
Safety components imported together/separately	Review No. 9 components: braking/control systems, safety gear and traction machine.	Component list, part number, function description.	Specialized authority or designated assessment body if applicable.	Before final invoice issuance.	Safety components may require separate evidence.
Cargo conveyor wrongly named as passenger conveyor	Do not apply passenger conveyor policy if actual use is only materials transport.	Catalogue, video/photos, layout drawing.	Customs and specialized authority if challenged.	Before declaration.	Wrong name may cause wrong HS and policy.
Used/refurbished equipment	Review import conditions for used machinery/refurbished goods if applicable.	Year, inspection certificate, condition, standards, maintenance records.	Customs/competent authority.	Before purchase contract.	Do not buy used equipment before confirming import eligibility.
Project/EPC imports	Import dossier plus project design, installation and safety acceptance dossier.	Project contract, BOM, installation drawing, method statement.	Customs, specialized authority and inspection body.	From procurement/booking stage.	Project mismatches can affect acceptance.
Sample/display equipment	Policy may still apply if operating or safety-related.	Sample invoice, purpose statement, catalogue.	Customs/specialized authority if applicable.	Before shipment.	Sample status does not automatically exempt policy.

LEGAL DOCUMENTS TO REVIEW

Document group	Document name/number	Issuing authority	Effective/application timing	Role in procedure	Key article/appendix	Review note
Law	Law on Product and Goods Quality 05/2007/QH12	National Assembly	Review current validity.	Basis for Group 2 quality management.	General quality inspection principles.	Framework document.
Decree	Decree 132/2008/ND-CP, amended by 74/2018/ND-CP and 154/2018/ND-CP	Government	Review consolidated/current version.	Detailed quality inspection mechanism for imported goods.	State quality inspection procedures.	Read with sectoral list.
Sectoral circular	Circular 01/2021/TT-BLDTBXH	MOLISA	Effective from 18/07/2021.	Group 2 list under MOLISA management.	Section I, No. 9; HS 8428.40.00; safety parts 8431.31.10 / 8431.31.20.	Check current receiving authority/portal.
QCVN	QCVN 11:2012/BLDTBXH	MOLISA	Issued with Circular 32/2012/TT-BLDTBXH dated 19/12/2012.	Safety regulation for escalators and passenger conveyors.	Technical and management requirements.	Compare with original QCVN.
Inspection procedure	QTKD 25:2016/BLDTBXH issued with Circular 54/2016/TT-BLDTBXH	MOLISA	Circular effective from 01/06/2017.	Safety inspection after installation/use.	Inspection process for escalators and passenger conveyors.	Does not replace import quality inspection.
Tariff	Decree 26/2023/ND-CP	Government	From 15/07/2023, subject to amendments.	MFN import tariff basis.	Heading 84.28, code 8428.40.00.	Verify latest tariff.
Labeling	Decree 43/2017/ND-CP and 111/2021/ND-CP	Government	Check at release/use date.	Original label and Vietnamese sub-label.	Name, origin, responsible entity and specifications.	Apply to actual equipment.
Used machinery	Decision 18/2019/QD-TTg and Decision 28/2022/QD-TTg	Prime Minister	Review only if not new.	Conditions for used machinery imports.	Age, standards, inspection.	Not applied to proven new 100% goods.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Circular 01/2021 QCVN 11:2012 Tariff heading 84.28

Enterprises should cross-check legal documents on official legal portals or websites of competent authorities before application.

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
C/O where preferential duty is claimed.
Catalogue, datasheet, installation drawing, manual, model/serial list.

Specialized dossiers if applicable

Import quality inspection registration.
Conformity certificate/assessment under QCVN 11:2012/BLDTBXH.
Manufacturer test report/certificate.
Labeling dossier and Vietnamese sub-label.
Post-installation safety inspection dossier before use.

OPERATIONAL DOSSIER CHECKLIST

Dossier group	Required documents	Used for	Usually prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO	Declaration, value and quantity	Buyer/Procurement/Supplier	Generic “conveyor” description	Specify passenger conveyor/moving walkway, model, new 100%.
Transport	B/L or AWB, Arrival Notice, pre-alert	D/O, manifest, declaration	Forwarder/Carrier/Agent	Wrong packages/weight	Match Packing List with B/L/AWB.
Technical	Catalogue, datasheet, manual, drawings, nameplate photos	HS, policy, quality inspection	Supplier/Technical team	No proof of passenger transport function	Request full technical file before booking.
Specialized	Quality inspection registration, conformity certification/inspection, test report/certificate if any	Quality inspection, customs clearance and post-clearance record retention	Importer/Compliance/Assessment body	Started after ETA	Prepare once draft documents are available.
C/O and duties	C/O draft, invoice, B/L, direct transport proof	FTA duty claim	Supplier/Docs/Forwarder	Wrong HS/description/model	Review C/O draft before issuance.
Labeling	Original label, proposed Vietnamese sub-label	Market release/use	Importer/QA/Warehouse	Missing origin/model/specs	Prepare sub-label based on final documents.

CLEARANCE DECISION POINTS

Decision point	Question	Evidence	Consequence if unclear	Recommended handling
HS code	Is it correctly 8428.40.00?	Catalogue, datasheet, photos, drawings	Reclassification, wrong duty/policy.	Finalize HS and technical description pre-ETA.
Group 2 policy	Is it under Section I, No. 9 of Circular 01/2021/TT-BLDTBXH?	List, catalogue, operating data	Missing quality inspection/conformity dossier.	Prepare specialized dossier before arrival.
Applicable QCVN	Is the file sufficient for QCVN 11:2012/BLDTBXH?	Certificate, test report, manual, drawings	Inspection or acceptance delay.	Request full technical dossier from manufacturer.
C/O	Is C/O form, HS, description and transport rule correct?	C/O draft, B/L, Invoice	FTA preference rejected.	Review C/O per FTA.
New/used condition	New 100% or used/refurbished?	Invoice, photos, serial, year	Used machinery conditions may apply.	Fix condition in contract.
Labeling and acceptance	Are labels and post-installation safety inspection ready?	Original label, sub-label, inspection file	Cannot put equipment into use on time.	Prepare during clearance stage.

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Finalize 8428.40.00, Group 2 policy, QCVN, duties, C/O, labels and new/used status.

Step 2: Lock documents

Cross-check Invoice, Packing List, B/L/AWB, catalogue, datasheet, manual, model list, serial list and nameplate photos.

Step 3: Specialized registration if applicable

Prepare import quality inspection/conformity assessment under QCVN 11:2012/BLDTBXH before cargo arrival.

Step 4: Customs declaration

Green channel permits conditional clearance; Yellow checks documents; Red checks documents and physical goods. Typical questions: HS, value, model, C/O and specialized dossier.

Step 5: Clearance and post-clearance

Release cargo, deliver to site, complete sub-labeling, arrange safety inspection after installation and archive shipment records.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents
Generic conveyor description	Wrong HS and policy.	Specify passenger conveyor/moving walkway.	Invoice, catalogue, datasheet.
Missing Group 2 dossier	Delayed clearance.	Check No. 9 and prepare quality inspection.	Circular 01/2021, QCVN 11.
Wrong C/O HS/description	FTA preference rejected.	Review C/O draft.	C/O, Invoice, B/L.
Missing certificates/test reports	Insufficient conformity/inspection basis.	Request before booking.	Certificate, test report, manual.
Used goods declared as new	Used machinery conditions may apply.	Fix condition in contract.	Invoice, serial, year.
Incorrect sub-label	Problem at release/use stage.	Prepare from final documents.	Original label, model, origin, specs.

FAQ

Is import quality inspection required?

Likely yes if the goods fall under Section I, No. 9 of Circular 01/2021/TT-BLDTBXH. Confirm against the actual dossier and current receiving mechanism.

What is the main HS code?

Reference HS is 8428.40.00 for escalators and moving walkways.

Does QCVN 11:2012 apply?

Review the scope of QCVN 11:2012/BLDTBXH; it is the core safety regulation for escalators and passenger conveyors.

Is VAT 8% or 10%?

The common base rate is 10%; reduced VAT, if any, must be checked at declaration date.

Can C/O reduce duty?

Yes, if the C/O is valid, correct in form, origin criterion and goods description.

What if safety parts are imported separately?

Do not apply the complete equipment code automatically. Review 8431.31.10, 8431.31.20 or other codes by function and technical documents.

IMPLEMENTATION SUPPORT FROM TGIMEX

This article provides a map of HS code, duties, dossiers and specialized policy for passenger conveyors. For actual shipments, enterprises should still review catalogue, datasheet, model, documents, origin, condition and import purpose.

Pre-ETA review

HS, Group 2 policy, QCVN, C/O, duties and labeling.
Compare catalogue, datasheet, model, safety components and project dossier.

Compliance dossier control

Cross-check Invoice, Packing List, B/L/AWB, C/O, catalogue, test report, labels and technical documents.
Support identification of quality inspection/conformity dossier where triggered.

Logistics & customs

Coordinate agents, carriers/airlines, ETA and pre-alert.
Prepare declaration dossier and handle Green/Yellow/Red channels.

Post-clearance records

Archive shipment dossier, review sub-label and post-installation inspection dossier.
Prepare explanations on HS, value, origin and specialized policy.

For shipments that may trigger specialized inspection, C/O review or labeling requirements, enterprises should not wait until cargo arrival to start dossier review. Small inconsistencies across Invoice, Packing List, catalogue, datasheet, C/O or labels may lead to document supplementation, delayed clearance or unplanned storage costs.

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