Tiếng Việt
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IMPORT PROCEDURE GUIDE FOR ROHS / RESTRICTED HAZARDOUS SUBSTANCE GOODS IN VIETNAM
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.
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.
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.
A material that cannot be mechanically separated into different materials. RoHS review normally covers plastics, PCB, coatings, cables, soldering points and other component materials.
RoHS is generally not handled as a standalone import licence, but it is a market-compliance obligation requiring evidence and record keeping when inspected.
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.
| 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. |
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. |
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. |
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.
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.
Review RoHS declaration, IEC 62321/equivalent test report, model list, test scope, issue date, manufacturer name and hazardous substance limits.
Classify HS based on main function, structure and accessories; review C/O by route, goods description, 6-digit HS, origin criterion and direct transport.
Review labeling, ICT conformity, energy efficiency, lithium battery, hazardous chemicals in products and project requirements where relevant.
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.
Archive documents by PO, customs declaration, invoice, model/serial, supplier and shipment for post-clearance audit, market inspection or project-owner requests.
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.
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