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IMPORT PROCEDURE GUIDE FOR USED PRODUCTION MACHINES
Used production machines carry high operational risk because commercial names are broad while HS classification, import conditions, inspection certificates and specialized policy depend on real function, year of manufacture, used condition, technical standards and import purpose. Wrong HS, missing inspection certificate, unclear equipment age, confusion between a standalone machine and a technology line, omission of Decision 18/2019/QD-TTg and its amendments, or inconsistent C/O may trigger customs inspection, additional documents, loss of preferential duty, DEM/DET, project delay and post-clearance exposure. This guide provides an E2E review map before ETA, covering HS, duty, specialized policy, dossier set, customs workflow and pre-arrival risks.
QUICK FACTS
| Item | Quick review content |
|---|---|
| Product | Used production machine imported for direct manufacturing activities in Vietnam; applicable to standalone machinery/equipment, not automatically to a synchronized used technology line. |
| Key HS | No single HS code exists for “used production machine”. HS must follow actual function, usually Chapter 84 or 85. |
| Reference duty | Duty depends on the final HS code. Many Chapter 84/85 machinery lines show MFN 0%, while some lines may be 3%, 5%, 10% or higher. Standard VAT is usually 10%. |
| Key policy | Decision 18/2019/QD-TTg, as amended by 28/2022/QD-TTg and 02/2026/QD-TTg; age, standards, inspection certificate; the inspection certificate for a used individual machine should be issued no more than 06 months before the machine arrives at the Vietnamese border gate; over-age machines must be reviewed under Article 9 of Decision 18 as amended. |
| Technical file | Catalogue/datasheet, manufacturing year, model/serial, function/capacity, used condition, inspection certificate, photos, applied standards and C/O if any. |
| Caution | Do not apply automatically to used packaging machines, used processing machines, synchronized lines, Group 2 potentially unsafe products/goods, specialized regulated machinery, prohibited imports or machinery discarded by exporting countries due to obsolescence, poor quality or pollution. |
Legal note: This article applies only to used production machines under the product category of used production, packaging, processing and industrial machines. It does not automatically apply to synchronized technology lines, other used machinery categories, Group 2 products/goods, specialized machinery regulated by sectoral rules, temporary import/re-export, transit or machinery not used directly for production in Vietnam. Review is required based on catalogue, datasheet, model and actual import purpose.
SCOPE OF APPLICATION
This guide applies to used production machines imported for direct manufacturing activities in Vietnam, usually a standalone machine or machine cluster with a specific production function, not a full synchronized technology line unless the dossier shows so.
- Do not combine with used packaging, processing or other industrial machines if function, HS and policy differ.
- New, used, refurbished, warranty, sample, project and EPE/FDI imports may require different customs regimes and dossiers.
- Control cabinets, inverters, PLC, robots, wireless modules, encryption, batteries, adapters, chargers or accessories must be reviewed separately.
- If the machine is prohibited, discarded due to poor quality/obsolete/polluting status, or fails safety, energy-saving or environmental requirements, import eligibility risk is high.
CLASSIFICATION & TECHNICAL IDENTIFICATION
| Checkpoint | Documents to review | Risk if described incorrectly | Suggested goods description |
|---|---|---|---|
| Main function | Catalogue, datasheet, photos, operating video | Wrong HS due to generic “used production machine” | Used [specific machine name], model…, serial…, used for… |
| Manufacturing year and age | Nameplate, manufacturer certificate, inspection certificate | Over-age machine without special approval | Year of manufacture…, age… years, used machine for production |
| Standalone or line | Layout, process flow, packing list, invoice breakdown | Wrong criteria applied to a line or to a machine | Used standalone machine / used production line – clarify configuration |
| Applicable standards | QCVN/TCVN, G7/Korea standards, CE/UL/ISO if any | Insufficient proof of safety, energy efficiency and environmental compliance | Manufactured according to… standard; inspection certificate attached |
| Remaining capacity/efficiency | Inspection certificate, performance test | Insufficient basis for special approval | Remaining capacity/efficiency…% of design capacity |
| Accessories/modules | Packing list, BOM, module catalogues | Accessories may trigger separate policy | Machine with control cabinet, inverter, PLC, spare parts… |
HS CODE – DUTY – C/O
There is no single HS code for a used production machine. HS must be determined by the principal function, structure and operating principle; used condition creates import conditions under Decision 18 but not a separate HS code.
| Reference HS code | Application condition | Risk if incorrect | Documents to review |
|---|---|---|---|
| Chapter 84 | Mechanical production, processing, packaging or industrial machinery. | Wrong chapter affects duty, policy and inspection. | Catalogue, principle of operation, function and specifications. |
| Chapter 85 | Electrical/electronic equipment or machines where electrical function is principal. | May trigger energy efficiency, electrical safety or ICT review. | Electrical datasheet, control diagram, nameplate. |
| 8422.xx | Only if the machine is for washing, bottling, packaging or labeling. | Over-classifying general production machines as packaging machines. | Packaging process, output and package handled. |
| 8456–8466 | Machine tools and metal-working machines. | Wrong duty/C/O and used machine policy. | Machining process, CNC/controller data. |
| 8477.xx | Machinery for rubber/plastic processing. | Confusion with general machinery. | Material processed and process description. |
| 8479.89.xx | Machines with individual functions not elsewhere specified; use only after excluding more specific headings. | Overuse of “other machines” may trigger HS query. | Exclusion analysis, catalogue and operating principle. |
REFERENCE DUTY TABLE BY HS FINALIZATION
| Tax scenario | Ordinary duty | MFN duty | VAT | FTA preference with valid C/O | Control note |
|---|---|---|---|---|---|
| Final HS confirmed under Chapter 84/85 | According to the ordinary tariff at declaration date. | According to final HS; many lines 0%, some 3%, 5%, 10% or higher. | Usually 10%. | May be 0% or preferential if C/O is valid. | Do not calculate duty before final HS is confirmed. |
| Machine with separate accessories/modules | By final HS of each line if declared separately. | May differ for main machine, spare parts, control cabinet or robot. | Usually 10%. | Depends on origin of each declared line. | Decide whether to declare as complete set or separate lines. |
| Over-age machine requiring approval | Tax nature unchanged, but clearance risk increases if approval is not ready. | By final HS. | Usually 10%. | Only if C/O is valid. | C/O does not replace used machinery import conditions. |
Duty note: Rates are for pre-checking only. Always verify the tariff at customs declaration date. C/O does not replace used machinery eligibility.
APPLICABLE SPECIALIZED POLICY
| Goods scenario | Possible policy | Documents to check | Authority / portal if identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Standalone used machine under Chapters 84/85 for direct production | Decision 18/2019/QD-TTg and amendments; age, standards and inspection certificate. | Catalogue, year, inspection certificate, standards, invoice, packing. | Customs; Ministry of Science and Technology for special cases. | Before ETA, ideally before contract. | Must prove direct production use. |
| Machine age within 10 years or sector-specific age list | Allowed if safety, energy and environmental standards are met. | Nameplate, year, certificate, standards. | Customs and designated/recognized inspection bodies. | Before arrival. | Age is counted from manufacture year to arrival year at Vietnam border gate. |
| Over-age machine needed to maintain production | Special approval mechanism; usually remaining capacity/efficiency at least 85% and consumption not exceeding 15% over design. | Request letter, business registration, inspection certificate, necessity explanation. | Ministry of Science and Technology; direct, postal or online submission under 2026 amendment. | Before declaration or purchase decision. | High risk if cargo arrives before approval. |
| Specialized machinery regulated by sectoral rules | Sectoral policy may apply in parallel. | Sectoral QCVN/TCVN, permits, quality inspection. | Relevant ministries and Customs. | Before ETA. | Decision 18 does not replace sectoral permits. |
| Machine with electrical, ICT, battery or security modules | Electrical safety, energy efficiency, ICT, civil cryptography/information security or lithium battery rules may arise. | BOM, module datasheets, labels, test reports. | Relevant authority if applicable. | Before HS and booking. | Accessories may change policy. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document name/number | Issuing authority | Effective timing | Role in procedure | Key points | Review note |
|---|---|---|---|---|---|---|
| Law | Foreign Trade Management Law 05/2017/QH14 | National Assembly | Effective 01 Jan 2018 | General basis for import/export management. | Review by actual goods. | Does not replace used machinery policy. |
| Decree | Decree 69/2018/ND-CP | Government | Effective 15 May 2018 | Details foreign trade management, prohibited and conditional imports. | Annexes on prohibited/conditional goods. | Check before applying Decision 18. |
| Decision | Decision 18/2019/QD-TTg | Prime Minister | Issued 19 Apr 2019, effective 15 Jun 2019 | Core criteria, dossier, procedure and inspection for used machinery/technology lines. | Articles 1, 4, 6, 8, 9, 10; Article 5 is for used technological lines, not for individual machines. | Core document. |
| Amending decision | Decision 28/2022/QD-TTg | Prime Minister | Effective 01 Mar 2023 | Amends Decision 18. | Dossier, procedure and inspection points. | Read with Decision 18. |
| 2026 amendment | Decision 02/2026/QD-TTg | Prime Minister | Effective 08 Jan 2026 | Simplifies certain procedures under MOST, including Decision 18 related procedures. | Article 2 and new form if applicable. | Important for over-age/special cases. |
| Tariff | Decree 26/2023/ND-CP, 199/2025/ND-CP and FTA schedules | Government | Check at declaration date | MFN, ordinary and FTA duty. | Chapters 84, 85. | Final HS required. |
VIEW / DOWNLOAD ORIGINAL LEGAL TEXTS
Decision 18/2019/QD-TTgDecision 28/2022/QD-TTgDecision 02/2026/QD-TTgDecree 69/2018/ND-CPDecree 26/2023/ND-CP
Enterprises should additionally verify the documents on official legal document portals or issuing authority websites before applying them.
CUSTOMS CLEARANCE DOCUMENT SET
Commercial documents
- Commercial Invoice
- Packing List
- Bill of Lading/Air Waybill
- Sales Contract/Purchase Order if any
- C/O if preferential duty is claimed
- Catalogue/Datasheet, photos, original label, model/serial list
Used machinery dossier
- Inspection certificate for used machinery
- Manufacturing year, model and serial evidence
- Applicable standards
- Remaining performance/consumption file for over-age cases
- Approval letter if special case applies
Specialized dossier if any
- Permit/quality inspection/conformity if applicable
- Energy/electrical/ICT dossier for related modules
- Goods labeling dossier
- Accessory technical documents
- Project/EPE/FDI file if applicable
| File group | Required documents | Used for | Usually prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO, B/L/AWB | Declaration, value, quantity and transport | Docs/Procurement/Forwarder | Generic name, missing model/serial/year | Match with catalogue, nameplate and inspection certificate. |
| Technical | Catalogue, datasheet, photos, video, layout if line | HS and policy review | Engineering/Importer/Supplier | No principal function described | Confirm function and configuration before booking. |
| Used machinery | Inspection certificate, year, standards and condition | Eligibility under Decision 18 | Inspection body/Supplier/Importer | Certificate lacks age/standards/performance | Approve draft certificate before ETD/ETA. |
| HS–tax–C/O | HS analysis, draft C/O, tariff | Duty and FTA preference | Compliance/Broker/Supplier | C/O HS differs from declaration | Check C/O after final HS. |
| Specialized | Permit/quality inspection/conformity/energy if applicable | Policy handling | Compliance/Legal/QA | Assuming Decision 18 replaces all sectoral rules | Review each module and accessory. |
Control principle: Goods name, quantity, model, serial, origin, manufacturing year and technical specifications must match across commercial documents, catalogue, label, inspection certificate, specialized dossier and customs declaration.
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended handling |
|---|---|---|---|---|
| Scope of Decision 18 | Is the machine under Chapter 84/85 and directly used for production in Vietnam? | HS analysis, purpose letter, catalogue | Wrong policy or additional explanation | Confirm scope before contract. |
| Age | Does age exceed 10 years or a sector-specific threshold? | Nameplate, certificate | Import ineligibility or special approval required | Calculate age before purchase. |
| Inspection certificate | Does certificate include required criteria? | Inspection certificate | Additional dossier or delay | Use designated/recognized inspection body. |
| HS and C/O | Does C/O match declared HS and description? | C/O, invoice, B/L/AWB | FTA preference denied | Check draft C/O after HS. |
| Standalone or line | Is it a standalone machine or synchronized line? | Layout, packing, invoice | Wrong criteria and certificate | Clarify configuration. |
PRACTICAL E2E WORKFLOW
Pre-ETA review.
Finalize HS by function, review Decision 18 and amendments, duty, C/O, label, equipment age, inspection certificate and special approval need.
Lock documents and technical files.
Finalize Invoice, Packing List, B/L/AWB, catalogue/datasheet, model/serial list, manufacturing year, standards, photos/nameplate and specifications.
Register/finalize specialized dossier if any.
Prepare inspection certificate; for over-age or special cases, handle approval before arrival; review sectoral policy for modules.
Lodge customs declaration.
Green channel: system clearance subject to conditions. Yellow: document check. Red: document and physical inspection. Common queries include value, HS, goods name, model, C/O, catalogue, inspection certificate and used machinery policy.
Clear, deliver and archive records.
Move cargo to factory, verify model/serial, apply supplementary label if required and archive dossiers for post-clearance review.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA prevention | Documents to check |
|---|---|---|---|
| HS not determined by real function | Wrong duty, C/O and policy | Prepare HS analysis by catalogue and operation | Catalogue, datasheet, photos. |
| Missing/incorrect inspection certificate | Clearance delay and additional dossier | Approve certificate before ETD | Inspection certificate, standards. |
| Over-age machine without approval | Import ineligibility or re-export risk | Calculate age and handle special approval early | Nameplate, year certificate. |
| Generic goods name | HS/policy query | State exact machine name, function, model and serial | Invoice, packing, catalogue. |
| Accessories not reviewed | Missed sectoral policy | Separate BOM and review each module | BOM, module datasheets. |
| C/O discrepancy | Preferential duty denied | Check draft C/O after HS finalization | C/O, invoice, B/L/AWB. |
FAQ
| Question | Short answer |
|---|---|
| Does a used production machine require a permit? | Not always as a generic permit. It must satisfy Decision 18 and amendments; over-age/special cases or specialized machines may require approval or sectoral dossiers. |
| Must used machines be under 10 years old? | The general rule is not over 10 years, except sector-specific age limits or special approval cases. |
| When should the inspection certificate be prepared? | Before ETA. Waiting until arrival increases storage and clearance risk. |
| Can C/O reduce duty? | Potentially, if form, origin criterion, goods description, HS and direct transport are compliant. |
| Is refurbished machinery treated as used? | Usually yes if it was operated after manufacture; check original year, serial and inspection certificate. |
| What if invoice model differs from catalogue? | Correct documents or provide explanation before ETA; model discrepancies affect HS, inspection and customs queries. |
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
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