For electrical and electronic products, customs risk is not limited to HS code or import duty. If RoHS compliance is not controlled, the shipment may face technical clarification, market inspection, post-clearance review or project handover issues. This guide provides an end-to-end review map for scope identification, technical dossiers, HS – duty – C/O, information disclosure and post-import record keeping before products are placed on the Vietnamese market.

Operational reference for importers and exportersPolicy group: RoHS / hazardous substance restrictionsModel, catalogue and actual dossier must be reviewed

TERMS AND OPERATIONAL SIGNIFICANCE

RoHS means restriction of hazardous substances. In Vietnam, it is mainly applied through the regulation on permissible limits of certain hazardous chemicals in electrical and electronic products circulated in the Vietnamese market.

Restricted substances

Pb, Cd, Hg, Cr6+, PBB and PBDE. Reference limits are 0.1% by weight for Pb/Hg/Cr6+/PBB/PBDE and 0.01% by weight for Cd.

Homogeneous material

A material that cannot be mechanically separated into different materials. RoHS review normally covers plastics, PCB, coatings, cables, soldering points and other component materials.

Operational impact

RoHS is generally not handled as a standalone import licence, but it is a market-compliance obligation requiring evidence and record keeping when inspected.

Operational note: one product may be subject to RoHS, product labelling, ICT conformity, energy efficiency, lithium battery transport, cybersecurity or civil cryptography controls. A trade name alone is not sufficient for conclusion.

DETAILED PRODUCT CLASSIFICATION AND IDENTIFICATION

This guide applies to electrical and electronic products whose hazardous substance limits must be reviewed before circulation in Vietnam, including large and small household appliances, ICT equipment, consumer equipment, lighting equipment, electrical tools, electronic toys and automatic monitoring instruments. Components, batteries, spare parts, exhibition goods, temporary imports or goods not placed on the market must be reviewed separately against the actual import purpose and legal exclusions.

The review should be based on catalogues, datasheets, model specifications, functions, material structure, BOM, import purpose and distribution channel.

Product group / scenario	Technical indicators to review	Example model / function	Supporting documents	Possible policy triggers	Dossiers to cross-check	Application notes
Household electrical and electronic appliances	Plastic housing, controller PCB, cable, motor, coating, solder	Refrigerators, washing machines, microwave ovens, electric cookers, fans	Catalogue, datasheet, manual, BOM, RoHS certificate or report	RoHS, product labelling, energy efficiency where applicable	Invoice, packing list, catalogue, original label, RoHS declaration/report	Separate the main unit, accessories, adapters, power cords and spare parts.
Information and communication technology equipment	PCB, cables, display, adapter, wireless modules, battery	Laptop, router, switch, server, camera, printer	Datasheet, model list, test report, applicable QCVN if wireless	RoHS; possibly ICT quality inspection and conformity	Catalogue, datasheet, test report, conformity dossier if applicable	RoHS does not replace ICT conformity obligations for wireless products.
Lighting and consumer equipment	LED chip, driver, metal/plastic housing, coating, cable	LED lamps, TV, monitor, speaker, audio equipment	Catalogue, RoHS declaration, material test report	RoHS, product label, possibly energy efficiency	Original label, datasheet, report, manufacturer information	Drivers, cables, coatings and plastics are common risk points.
Power tools, toys and electronic sports equipment	Battery, motor, controller, sensor, plastic housing	Electric drill, remote-controlled toy, electronic trainer	Catalogue, BOM, SDS if any, test report	RoHS; possibly safety or battery transport requirements	Technical file, product photos, warning labels	Battery-powered goods should be reviewed separately from plug-in goods.
Samples, warranty, project, EPE/FDI goods	Import purpose, quantity, circulation plan, place of use	Test samples, replacement goods, project equipment	Contract, PO, purpose statement, internal records	Treatment may differ for circulation, labelling and post-import use	Invoice, packing list, project documents, internal transfer records	Determine whether the goods will be circulated in Vietnam or used only internally.

HS CODE – DUTY – C/O

RoHS is not an HS classification criterion. HS classification must still be determined based on the main function, structure, operating principle, condition of the goods and accompanying parts/accessories. However, the correct HS code helps the importer identify whether the electrical or electronic product group is likely to require hazardous substance control before being placed on the Vietnamese market.

Control principle: Do not determine duties merely by commercial names such as “RoHS goods”, “electronic equipment” or “electronic components”. The importer should cross-check the catalogue, datasheet, label photos, model, function, material/structure and actual packing of each shipment.

Reference HS code	Relevant product group	Classification basis	Conditions for use	Ordinary import duty	MFN import duty	VAT	C/O or FTA to review	Documents to cross-check
8471	Automatic data processing machines, computers, servers, storage devices and relevant parts.	Data processing/storage function; CPU/RAM/storage configuration; complete machine or part.	Use only where the goods are ADP machines or ADP parts, not for all electronic devices.	To be checked under the ordinary tariff according to the final HS code.	Many IT lines may have MFN 0%; final subheading must be verified.	Generally 10% or 8% if a VAT reduction applies at the time.	RCEP, CPTPP, AKFTA, VKFTA, EVFTA if the route is relevant.	Catalogue, datasheet, invoice, C/O, model list and function description.
8517	Routers, switches, modems, gateways, transmission devices and telecom terminals.	Data transmission/reception function; connection standards; network ports; Wi-Fi/Bluetooth/4G/5G module.	If radio transmission is included, ICT conformity, QCVN and related specialized dossiers must be reviewed.	Tariff treatment must be checked under the specific 8517 subheading.	Many network devices may have MFN 0%; do not finalize without the 8-digit HS code.	Generally 10% or 8% if eligible.	ACFTA, RCEP, AKFTA, VKFTA, CPTPP, EVFTA.	Datasheet, wireless module information, C/O, label, test report if any.
8528	Monitors, TVs, display devices and specialized displays.	Display function; size; signal reception capability; operating system or tuner integration.	Distinguish monitors, TVs, standalone panels, industrial displays and specialized equipment.	Check tariff according to the final HS code and condition of goods.	MFN differs by product type; the current tariff must be verified.	Generally 10% or 8% if subject to reduction.	EVFTA, CPTPP, RCEP, ACFTA if origin rules are met.	Catalogue, display specifications, C/O, label and energy dossier if triggered.
8504	Power supplies, adapters, chargers and electrical converters.	Voltage/current conversion function; power rating; dedicated or standalone use.	If supplied with the main machine, determine whether it is declared as a set or separately.	Check duty according to power rating, type and intended use.	MFN depends on the subheading; final HS code must be verified.	Generally 10% or 8% if eligible.	ACFTA, RCEP, AKFTA, VKFTA, EVFTA depending on origin.	Datasheet, electrical specifications, label photos, safety/RoHS report if any.
8516 / 8418 / 8451 / 8422	Electrical household appliances: heating, cooling, washing, cleaning, drying or food processing appliances.	Main function; heating/cooling/washing/cleaning mechanism; structure and power rating.	Review RoHS, goods labeling, energy efficiency and electrical safety where applicable.	Check tariff by product group and actual model.	MFN may range around 0%–25% depending on HS; do not finalize without model data.	Generally 10% or 8% if eligible.	ATIGA, ACFTA, RCEP, EVFTA, CPTPP depending on the route.	Catalogue, energy label if any, C/O, technical specifications and RoHS declaration.

This table is for review orientation only. Ordinary duty, MFN duty, VAT and special preferential duty must be finalized based on the final HS code, customs declaration date and actual dossier.

Route/origin	FTA/agreement	C/O form or origin document	Special preferential duty if supported	Conditions for use	Documents to check	Application notes
ASEAN	ATIGA	Form D or valid origin document.	May be 0% if the PSR is satisfied.	Correct origin criterion, direct transport and matching goods description.	C/O, invoice, packing list, B/L, catalogue and origin criterion.	Check HS at 6 digits, issue date, country of origin, stamp/signature.
China	ACFTA / RCEP	Form E or RCEP C/O/statement where applicable.	May be 0% under the applicable HS roadmap.	Correct form, origin criterion and third-party invoicing if any.	C/O, third-party invoice, B/L, catalogue and model list.	Model, description and HS on C/O are frequent error points.
Korea	AKFTA / VKFTA / RCEP	Form AK, VK or RCEP C/O.	May be 0% under the preferential tariff schedule.	RVC/CTH/CTSH must satisfy the PSR of the final HS code.	C/O, BOM if needed for origin proof, invoice and packing list.	Select the most beneficial FTA only when the proof is complete.
Japan	VJEPA / AJCEP / CPTPP / RCEP	Form VJ/AJ or origin document under CPTPP/RCEP.	Review under each agreement’s preferential schedule.	Meet PSR, direct transport and valid origin documentation.	C/O/origin document, invoice, B/L and catalogue.	Do not use one C/O form for all agreements.
EU / UK	EVFTA / UKVFTA	EUR.1 or statement on origin where eligible.	May enjoy preferential duty under the HS roadmap.	Correct origin certification mechanism and valid EU/UK origin.	Statement on origin/EUR.1, invoice and transport documents.	Check third-party invoicing and direct transport requirements.
Australia – New Zealand	AANZFTA / CPTPP / RCEP	Form AANZ or relevant CPTPP/RCEP origin document.	Review by HS code and route.	Meet PSR and maintain proof of origin.	C/O, invoice, packing list, B/L and catalogue.	Use the most beneficial agreement while avoiding wrong forms.

C/O review checklist: form, WO/RVC/CTH/CTSH criterion, third-party invoicing, direct transport, goods description, HS code, quantity, weight, country of origin, stamp/signature, issue date and validity period.

DOSSIER SET AND SUBMISSION METHOD

For RoHS goods, the core task is not only customs submission at the port but also building a technical compliance dossier proving that the product meets hazardous substance limits before market circulation.

Dossier group	Documents required	Used for which step	Typical preparer	Common error	Pre-ETA check
Commercial dossier	Commercial invoice, packing list, B/L or AWB, contract/PO, C/O if duty preference is claimed	Customs declaration, customs value and origin review	Importer, shipper, forwarder, docs team	Goods name or model differs from catalogue	Lock product name, model, quantity and origin before ETA.
Product technical dossier	Catalogue, datasheet, user manual, label photos, model/serial list	HS classification, product identification, RoHS and policy screening	Supplier, procurement, technical team	Marketing catalogue lacks material details	Request official datasheet, drawings and BOM where needed.
RoHS / hazardous substance dossier	RoHS declaration, IEC 62321 or equivalent test report, BOM, material control process	Evidence of Pb/Cd/Hg/Cr6+/PBB/PBDE limits	Manufacturer, laboratory, importer	Report does not match the model or homogeneous material	Check model, revision, part number and lab scope.
Related policy dossier	ICT conformity, energy efficiency, auxiliary label, lithium battery, cybersecurity or cryptography dossiers if triggered	Additional sectoral obligations beyond RoHS	Compliance, legal, logistics provider, certification body	RoHS exists but other licences/conformity dossiers are missing	Review wireless, encryption, battery, adapter and power functions.
Post-import records	Declaration, tax payment, C/O, RoHS dossier, information disclosure, product label	Post-clearance, market inspection and project audit	Importer, legal, compliance, accounting	Original evidence is not kept by shipment	File by customs declaration, PO, model, serial and supplier.

LEGAL BASIS AND SPECIALIZED POLICY MATRIX

Document group	Document number / title	Issuing authority	Effective date / application period	Role in procedure	Key articles / annexes	Review note
Sectoral circular	Circular 30/2011/TT-BCT	Ministry of Industry and Trade	Effective from 23 September 2011; applies until replaced by corresponding national technical regulation	Main regulation on hazardous substance limits in electrical and electronic products	Articles 1, 4, 5, 6, 9; Annexes 1, 2 and 3	Review product group and exclusions against actual dossier.
Correction decision	Decision 4693/QD-BCT	Ministry of Industry and Trade	Issued on 16 September 2011	Corrects certain contents and annexes of Circular 30/2011/TT-BCT	Corrections to Articles 5, 6, 9 and annexes	Use the corrected version for dossier citation.
Chemical law	Law on Chemicals 69/2025/QH15	National Assembly	Effective from 1 January 2026	Current chemical management framework to review for applications after 2026	Relevant provisions on chemical activities and management duties	Monitor implementing decrees/circulars where applicable.
Product quality law	Law on Product and Goods Quality 05/2007/QH12	National Assembly	Effective from 1 July 2008	General framework for product quality and circulation control	Relevant quality and inspection provisions	Does not replace product-specific RoHS evidence.
Test standard	IEC 62321 or equivalent standard	IEC / accredited laboratory	Applied where no corresponding Vietnamese technical regulation is available	Testing method for six restricted substances	Referenced by Circular 30/2011/TT-BCT and correction decision	Check lab scope and model/material coverage.
Tariff and FTA schedules	Current import-export tariff and special preferential tariff schedules	Government / Ministry of Finance	By each effective period	Determines import duty, VAT and FTA preference	Final HS code, origin and C/O form	Do not finalize duty without final HS and C/O.
Decree guiding the Law on Chemicals	Decree No. 26/2026/ND-CP	Government of Vietnam	Effective status must be checked against the official text at the application date	Provides detailed rules under the Law on Chemicals for chemical activities and hazardous chemicals in products and goods	Relevant annexes/lists should be reviewed where the goods contain hazardous chemicals or require information disclosure	This does not replace Circular 30/2011/TT-BCT for Vietnam RoHS limits; it is used as an additional review layer for hazardous chemicals in products/goods.
Circular guiding the Law on Chemicals	Circular No. 01/2026/TT-BCT	Ministry of Industry and Trade	Effective from 17 January 2026	Guides implementation of the Law on Chemicals and Decree No. 26/2026/ND-CP, including hazardous chemicals in products and goods	Article 1 and relevant annexes/lists, where applicable	Review for 2026 dossiers, especially where electrical/electronic goods contain hazardous chemicals beyond the RoHS scope.

Goods scenario	Legal basis to review	Possible policy	Processing authority / portal if identifiable	Trigger condition
Electrical/electronic products under the annex	Circular 30/2011/TT-BCT and corrected annexes	Hazardous substance limits, information disclosure and record keeping	MOIT / Vietnam Chemicals Agency; market surveillance authority	Goods are circulated in Vietnam and fall within regulated product groups.
Wireless or ICT goods	RoHS circular plus ICT/QCVN regulations	RoHS plus possible ICT quality inspection and conformity	ICT authority, certification body, customs	Wi-Fi, Bluetooth, 4G/5G, radio module or telecom function.
Goods with battery/adapter/charger	RoHS plus transport, labelling or safety rules if any	Review main equipment and separate battery/adapter obligations	Carrier, customs and sectoral authority if triggered	Lithium battery, separate adapter, charger or replacement battery included.
Components, spare parts or exhibition goods	Article 1 of Circular 30/2011/TT-BCT	May fall under exclusion depending on facts	Customs / market authority by scenario	Not circulated as a complete product or falls into exclusion.
Project, EPE or FDI factory imports	RoHS plus customs/investment/project rules	Review internal use, circulation and project handover	Customs, internal compliance, project owner	Goods are installed or used internally but may still need evidence.

View Circular 30/2011/TT-BCT Download official gazette PDF View Law on Chemicals 69/2025/QH15

PROCESSING TIME, FEES AND RISK COSTS

Step	Recommended timing	Expected output	Fees / cost notes	Risk if delayed
RoHS scope screening	Before order placement or before ETD	Product scope and possible exclusions identified	No separate state fee for internal screening	Goods purchased without material evidence or test reports.
Collect RoHS evidence from supplier	At least 7-15 working days before ETA for complex goods	RoHS declaration, test report, BOM or material control process	Testing/report fee may arise if new testing is needed	Goods arrive without compliance evidence.
Review HS, duty, C/O and related policies	Before customs declaration	Consistent customs and technical dossier	Consulting/checking cost if outsourced; taxes by HS	Wrong HS, rejected C/O or tax reassessment.
Customs declaration and channel handling	Upon ETA/arrival schedule	Valid declaration and explanation package	Port, warehouse, tax and service charges as applicable	DEM/DET and storage if technical questions take time.
Information disclosure and post-import filing	Before market circulation	Disclosure evidence and shipment file	Record management and label/document printing costs	Market inspection without sufficient evidence.

PRACTICAL END-TO-END PROCEDURE

For RoHS / hazardous-substance restricted goods, the workflow should operate as a control chain from pre-shipment review to post-clearance circulation. The key point is not to wait until cargo arrives at port before requesting RoHS documents.

Step	Stage	Actions required	Risk control points	Expected output
1	Pre-ETA review	Identify whether the product is an electrical/electronic product subject to RoHS control; separate main unit, adapter, cable, accessory, battery, spare part and component.	Do not generalize all models; review exclusions such as batteries, components, samples, exhibition goods or goods not placed on the market.	Model-based RoHS applicability matrix.
2	Technical data lock	Request catalogue, datasheet, BOM, model list, serial list, label photos and material-composition data where available.	The model in the RoHS dossier must match invoice, packing list, product label and catalogue.	Model list, datasheet and BOM/material documents.
3	RoHS dossier review	Review RoHS declaration, IEC 62321/equivalent test report, test scope and restricted substances.	Check Pb, Hg, Cd, Cr6+, PBB, PBDE and verify the 0.1% / 0.01% limits.	Valid RoHS declaration/test report by model.
4	Commercial document lock	Synchronize invoice, packing list, B/L/AWB, C/O, contract/PO, goods description and technical data.	Prevent discrepancies in goods name, quantity, model, origin, HS, accessories and new/used condition.	Commercial document set matched at 100%.
5	Parallel policy review	Review RoHS together with Vietnamese labeling, ICT conformity, energy efficiency, lithium battery rules and hazardous chemicals in products.	RoHS does not replace other permits or conformity requirements.	Specialized policy matrix by model.
6	Customs declaration and channel handling	Prepare explanations for HS, customs value, C/O, goods name, model, function and specialized dossier in case of Yellow/Red channel.	Catalogue, label, model list and RoHS dossier should be ready before customs questions arise.	Declaration, HS/policy explanation and supplement dossier if required.
7	Delivery and market circulation	Move cargo to warehouse, complete labeling/disclosure where applicable, and organize documents by PO, declaration, model/serial and supplier.	Maintain records by shipment for post-clearance audit, market inspection or project-owner requests.	Market circulation and post-clearance dossier by shipment.

Customs channel note: Green channel generally allows system-based clearance; Yellow channel checks documents; Red channel checks documents and physical goods. Common questions relate to HS, model, C/O, catalogue, wireless function, battery/adapter, label and RoHS dossier.

FAQ

1. Is RoHS a separate import licence in Vietnam?

It should not be treated as a standalone import licence. The key obligations are hazardous substance limits, information disclosure and record keeping before market circulation. Other licences or conformity obligations may still arise by model and function.

2. Is a manufacturer RoHS declaration enough?

Not always. It should match the exact model, scope and product revision. For project or high-risk goods, a test report or material control process is recommended.

3. Are electronic components covered?

Some components and spare parts are excluded under the regulation, but the actual import condition must be reviewed: loose components, spare parts, complete products and bundled accessories may lead to different conclusions.

4. Do goods with lithium batteries need RoHS review?

The main equipment may still require RoHS review. Batteries may be excluded from RoHS scope but can trigger transport, SDS, UN38.3, packaging or safety requirements.

5. Does RoHS replace ICT conformity?

No. Wireless or ICT group-2 products may still require quality inspection, certification and declaration of conformity under separate regulations.

6. What about samples and exhibition goods?

They may be excluded if they are genuinely samples, gifts, exhibition goods, temporary imports or non-commercial goods. Purpose, quantity and post-import treatment must be documented.

7. Which test standard should be used?

Where no corresponding Vietnamese technical regulation exists, IEC 62321 or an equivalent standard may be used. Lab scope, tested materials and model coverage must be checked.

8. What should be kept after customs clearance?

Keep declaration, invoice, packing list, transport document, C/O, catalogue, datasheet, RoHS declaration, test report, BOM/material process, label evidence and disclosure evidence by shipment.

OUTPUT RESULTS AND POST-CLEARANCE OBLIGATIONS

The output is not necessarily an import licence at the border. It is a compliance dossier proving that the electrical or electronic product meets hazardous substance limits when circulated in Vietnam.

Technical dossier: catalogue, datasheet, model list and BOM or equivalent material evidence.
RoHS dossier: declaration, test report and material control process or equivalent evidence.
Information disclosure: disclosure via website, user manual, electronic document, package or product depending on the chosen method.
Shipment records: file by customs declaration, PO, model/serial and supplier for post-clearance and market inspection.

TGIMEX SOLUTIONS

For RoHS / hazardous-substance restricted goods, the focus is not limited to customs clearance. The more important task is to establish a robust compliance dossier before ETA, capable of proving technical origin, hazardous substance limits, model consistency and post-clearance record-keeping obligations.

1. Model-by-model applicability review

Cross-check catalogue, datasheet, BOM, accessories, adapter, battery, cable, goods condition and import purpose to determine whether the goods fall under RoHS, an exclusion or another specialized policy.

2. Supplier RoHS dossier standardization

Review RoHS declaration, IEC 62321/equivalent test report, model list, test scope, issue date, manufacturer name and hazardous substance limits.

3. HS – duty – C/O review with technical files

Classify HS based on main function, structure and accessories; review C/O by route, goods description, 6-digit HS, origin criterion and direct transport.

4. Parallel specialized policy control

Review labeling, ICT conformity, energy efficiency, lithium battery, hazardous chemicals in products and project requirements where relevant.

5. Logistics and customs coordination

Monitor ETA, pre-alert, delivery order, trucking plan, warehouse/port option and Yellow/Red channel response scenario to reduce storage, DEM/DET and late supplementary-dossier risks.

6. Post-clearance record organization

Archive documents by PO, customs declaration, invoice, model/serial, supplier and shipment for post-clearance audit, market inspection or project-owner requests.

Coordination checklist: HS code, C/O, label, catalogue, datasheet, BOM, RoHS declaration, test report, model list, label photos, transport documents, customs declaration and post-clearance obligations.

Discuss shipment dossier View specialized procedure topics

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