Linear fluorescent lamps should be reviewed by structure, wattage, tube dimensions, mercury content and import purpose. A generic description such as “lamp” may lead to incorrect HS classification, missing specialized compliance documents, energy-labelling issues or loss of C/O duty preferences.

This guide summarizes the key points to check before ETA: HS code, import duty, C/O, applicable QCVN/TCVN standards, customs dossier, product labelling and clearance risks that may cause cargo hold or additional storage charges.

QUICK FACTS

Item	Review point	Operational note
Product	Linear fluorescent lamps, normally hot-cathode straight fluorescent tubes for general lighting.	Do not apply this guide automatically to LED tube lamps, compact fluorescent lamps or ballasts.
Main reference HS	8539.31.20 – other straight tube lamps for other fluorescent lamps.	Confirm by catalogue, datasheet, product images, lighting technology, wattage, tube length and actual use.
Reference duties	MFN: 25%; ordinary duty reference: 37.5%; standard VAT: 10%.	VAT 8% may only be reviewed if the product meets the VAT-reduction policy at declaration time.
Specialized policy	Review QCVN 02A:2020/BCT on mercury content in fluorescent lamps; TCVN 8249:2013 on energy performance; and energy-labelling requirements under MOIT regulations.	LED tube replacements may follow different HS and QCVN rules.
Key documents	Invoice, Packing List, B/L or AWB, C/O if claiming FTA duty, catalogue/datasheet, original label, test report/conformity dossier if applicable.	Product name, model, wattage, length and origin must match across documents.

Legal note

HS, duty and specialized-policy information in this guide is for operational review. Businesses must cross-check the actual catalogue, datasheet, model, lighting technology, wattage, tube length, origin, C/O and tariff schedule effective at customs declaration time.

SCOPE OF APPLICATION

Applies to

Linear fluorescent lamps for general lighting.
Two-ended tube/linear fluorescent lamps.
Imports for trading, projects, maintenance replacement or factory supply.

Does not automatically apply to

LED lamps, LED tube replacements or LED lamps with integrated driver/ballast.
Compact fluorescent lamps and compact lamps with integrated ballast.
Ballasts, complete luminaires, UV lamps, medical/special-purpose lamps or decorative lamps.
Used/refurbished goods, samples, warranty goods or special project goods if separate import conditions apply.

Review must be based on the actual catalogue, datasheet, model and import purpose. If the shipment includes luminaires, starters, ballasts, power supply or accessories that alter product function, classify and review each component separately.

CLASSIFICATION & PRODUCT IDENTIFICATION

Linear fluorescent lamps should be identified by lighting technology, electrode type, tube dimensions, wattage, cap/base type, intended use and whether a ballast is integrated. Generic descriptions such as “tube light” or “fluorescent lamp” on the invoice are not sufficient for HS and policy determination.

Criterion to check	Documents to compare	Risk if misdescribed	Suggested declaration wording
Lighting technology	Catalogue, datasheet, product photos, technical specifications.	Confusion between fluorescent tube and LED tube; wrong HS and QCVN.	“Linear fluorescent lamp, hot-cathode, straight tube, model…, wattage…, length…”
Straight tube or compact type	Photos, packaging, model list, specification sheet.	Confusion between 8539.31.20 and 8539.31.10/8539.31.30.	State “straight tube” clearly.
Wattage, tube length, base type	Datasheet, original label, packing details.	Insufficient evidence for customs explanation.	Add W, mm and cap/base type where available.
Mercury-content policy	Test report, conformity certificate/declaration, manufacturer documents.	Request for additional conformity documents.	State whether the product is a mercury-containing fluorescent lamp.
Ballast/luminaire included	Invoice, packing details, bill of materials.	Wrong HS if the shipment is actually a complete lighting set.	Split product lines where components differ.

HS CODE – DUTIES – C/O

The classification basis is heading 85.39, discharge lamps other than ultraviolet lamps, specifically subheading 8539.31 for hot-cathode fluorescent lamps. The final HS must be determined by the actual product, not only by the commercial name.

Main HS to review8539.31.20

MFN reference25%

Ordinary duty reference37.5%

Standard VAT10%

Reference HS	Description / condition	MFN duty	Ordinary duty reference	VAT	Risk of wrong HS	Documents to check
8539.31.20	Other straight tube lamps for other fluorescent lamps; main code if the product is a normal straight fluorescent tube.	25%	37.5%	10%; review 8% only if VAT-reduction conditions are met.	Confusion with LED tube or compact lamp affects duty and conformity obligations.	Catalogue, datasheet, photos, label, model list, wattage, length, technology.
8539.31.10	Tubes for compact fluorescent lamps.	25%	37.5%	10%	Wrongly using this code for straight tubes distorts product description.	Compact-lamp design and technical documents.
8539.31.30	Compact fluorescent lamps with integrated ballast.	25%	37.5%	10%	Confusion with CFL products.	Integrated ballast, shape and base information.
8539.31.90	Other hot-cathode fluorescent lamps.	25%	37.5%	10%	Use only when no more specific description fits.	Classification explanation and technical evidence.
8539.52.10 or LED heading	Only if the product is actually an LED tube or LED replacement for fluorescent tubes.	Check current tariff.	Check current tariff.	10% or applicable VAT policy.	Wrong technology changes both HS and QCVN requirements.	LED datasheet, driver, LED chip and QCVN dossier.

C/O and FTA matrix

Origin scenario	Typical C/O	Special preferential duty	Conditions	Key risk
ASEAN	Form D / accepted e-C/O.	May be lower than MFN, often 0% depending on ATIGA tariff schedule.	Correct HS, description, origin criterion and direct transport.	C/O description says LED lamp instead of fluorescent lamp.
China	Form E / RCEP if eligible.	Check ACFTA/RCEP tariff schedule; do not assume 0%.	Verify RVC/CTH/PSR and third-party invoice rules.	Wrong origin criterion or HS on C/O.
Korea/Japan/Australia-New Zealand	VKFTA/AKFTA, VJEPA/AJCEP, AANZFTA.	Review the relevant special preferential tariff schedule.	Correct form, validity, transport route and supporting documents.	Model or description mismatch.
EU/UK/CPTPP/EAEU	EVFTA, UKVFTA, CPTPP, VN-EAEU FTA.	Potentially significant preference if rules of origin are met.	Self-certification or origin document as required by the agreement.	Insufficient origin evidence during post-clearance audit.

APPLICABLE SPECIALIZED POLICIES

Goods scenario	Possible policy	Documents to check	Authority/portal	Timing	Risk note
Mercury-containing linear fluorescent lamps	Conformity certification/declaration under QCVN 02A:2020/BCT.	Test report, conformity certificate/declaration, catalogue, label.	MOIT / designated certification and testing bodies.	Review before ETA.	Missing mercury-control dossier may delay clearance or market release.
Products subject to energy labelling	Energy labelling / minimum energy performance under MOIT regulations, including Circular 52/2025/TT-BCT.	Energy-efficiency test result, labelling dossier, label artwork.	MOIT public service portal if applicable.	Before market distribution.	Clearance may be completed, but market circulation may be affected.
Goods shipped with ballasts/luminaires	Separate HS and QCVN review may arise.	BOM, packing details, catalogue.	Customs and relevant authority.	Before invoice finalization.	Grouping all items as “fluorescent lamp” can cause misclassification.
Used/refurbished goods	Review used-goods import conditions and environmental risks if any.	Condition, production year, technical documents.	Customs / specialized authority.	Before purchase.	Do not purchase first and review policy later.
Samples, warranty, project, EPE/FDI	Import purpose, tax treatment and customs regime may differ.	Contract, PO, warranty letter, internal use statement.	Customs branch of declaration.	Before ETA.	Wrong import purpose creates compliance risk.

LEGAL DOCUMENTS TO REVIEW

Group	Document	Issuer	Application time	Role	Key point	Review note
Law	Law on Customs 2014; Law on Export and Import Duties 2016; Law on Product and Goods Quality 2007.	National Assembly	Applicable, subject to amendments.	Basis for customs, duty and quality management.	Customs dossier, classification, valuation and quality control.	Review against the actual customs regime.
Decree	Decree 26/2023/ND-CP	Government	Effective from 15 July 2023.	MFN import tariff schedule.	Appendix II, Chapter 85, heading 85.39.	Check amendments at declaration time.
Decision	Decision 15/2023/QD-TTg	Prime Minister	Effective from 15 July 2023.	Ordinary duty rules.	Ordinary duty generally equals 150% of MFN if no separate rate applies.	Check if the HS has a specific ordinary rate.
Circular/QCVN	Circular 45/2020/TT-BCT and QCVN on mercury content in fluorescent lamps.	MOIT	Effective from 1 July 2022.	Mercury-content control.	QCVN 02A:2020/BCT and covered-product appendix.	Verify the exact QCVN symbol and product scope.
Prime Minister decisions	Decision 04/2017/QD-TTg; Decision 14/2023/QD-TTg	Prime Minister	Decision 04 effective from 25/04/2017; Decision 14 effective from 15/07/2023.	Energy labelling and phase-out of low-efficiency equipment.	Linear fluorescent lamps; TCVN 8249:2013; minimum energy performance.	Review energy test result before import for trading/circulation.
Circular	Circular 52/2025/TT-BCT	MOIT	Effective from 1 January 2026.	Energy-labelling list and roadmap.	Household group includes linear fluorescent lamps.	Review roadmap, test standard and labelling dossier.

VIEW / DOWNLOAD ORIGINAL DOCUMENTS

Businesses should search official legal portals or websites of issuing authorities by document number before application.

Decree 26/2023/ND-CP QCVN 02A:2020/BCT Circular 52/2025/TT-BCT Decision 14/2023/QD-TTg

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading / Air Waybill.
Sales Contract / Purchase Order if any.
C/O if claiming preferential duty.
Catalogue, datasheet, model list, product photos and original label.

Specialized dossier if applicable

Mercury-content test report; energy performance test result under TCVN 8249:2013 if applicable.
Conformity certificate/declaration under QCVN.
Energy-labelling dossier and test result.
Vietnamese supplementary label.
Technical documents and user manual.

Product name, quantity, model, wattage, tube length, origin and technical specifications must match across commercial documents, technical documents, specialized dossiers and the customs declaration.

KEY DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question	Evidence	Consequence	Recommended handling
HS code	Is it a straight fluorescent tube, compact lamp, CFL with ballast or LED tube?	Catalogue, photos, datasheet.	Wrong duty and policy.	Confirm before invoice issuance.
Mercury QCVN	Is QCVN 02A applicable?	Test report, conformity documents.	Additional dossier request.	Check with certification body before ETA.
Energy label	Is the product within the list/roadmap?	Circular, test result, labelling dossier.	Difficulty in market distribution.	Prepare before sales release.
C/O	Does C/O match HS, description and origin criterion?	C/O, invoice, B/L.	Loss of preferential duty.	Review draft C/O.

PRACTICAL E2E PROCESS

Step 1 · Pre-ETA review

Confirm HS, duty, C/O, mercury QCVN, energy label, product label and goods condition.

Step 2 · Lock documents

Check invoice, packing list, B/L/AWB, catalogue and model list.

Step 3 · Specialized dossier

Prepare test reports, conformity and energy-labelling files if applicable.

Step 4 · Customs declaration

Manage green/yellow/red channels and be ready to explain HS, value, C/O and QCVN.

Step 5 · Clearance and delivery

Pay duties, release goods, deliver inland and complete labelling before distribution.

Step 6 · Post-clearance archive

Keep customs declaration, C/O, test report, conformity documents and labels.

PRE-ETA RISK CHECKLIST

C/O error: review draft C/O for HS, description and origin criterion.

LED/fluorescent confusion: require technical datasheet.

Missing QCVN dossier: check mercury-content requirements.

Generic product name: add technology, wattage and length.

Energy label not prepared: review roadmap and dossier.

Ballast/luminaire included: split product lines if needed.

FAQ – COMMON BUSINESS QUESTIONS

1. Is an import licence required?

Do not answer absolutely by product name. Review HS, mercury QCVN, energy labelling, product labels and import purpose.

2. What is the common HS code?

The main reference code is 8539.31.20 if the goods are hot-cathode straight fluorescent tubes.

3. What is the MFN rate?

MFN reference is 25%; ordinary duty reference is 37.5%; standard VAT is 10%.

4. Can C/O reduce duty?

Yes, if the C/O is valid and origin rules are satisfied.

5. Is conformity certification required?

If QCVN 02A:2020/BCT applies, conformity certification/declaration should be prepared; also review TCVN 8249:2013, energy labelling and minimum energy performance if imported for circulation/trading.

6. Is LED tube covered here?

No. LED tube lamps require separate HS and policy review.

EXECUTION SUPPORT FROM TGIMEX

This guide provides a map of HS, duty, C/O, dossier and specialized policies for linear fluorescent lamps. In real shipments, businesses should review the actual catalogue, datasheet, model, documents, origin and import purpose.

Support scope

Pre-ETA review: HS, policy, C/O, duty, labelling and technical documents.
Compliance dossier control: invoice, packing list, B/L/AWB, C/O, test report and labels.
International logistics coordination and ETA/pre-alert control.
Customs declaration and explanation for HS, value, origin and specialized policy.

Execution approach

Businesses should not wait until cargo arrival to review documents. Minor discrepancies among invoice, packing list, catalogue, datasheet, C/O or labels can lead to document supplementation, clearance delay or unplanned storage costs.

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