Practical guide for imported goods subject to Vietnam energy labeling: HS code, duties, C/O, test reports, registration dossier and post-clearance obligations.

Import Procedures for Goods Subject to Energy Labeling in Vietnam — Operational illustration supporting the article.

Quick facts

Item	Key point	Risk to control
Main procedure	Energy-labeling registration for products and equipment covered by Decision 04/2017/QD-TTg and MOIT implementing regulations.	Do not conclude by trade name only; verify product group, model, power rating, testing standard and import purpose.
Authority/portal	Agency for Innovation, Green Transition and Industrial Promotion – Ministry of Industry and Trade under the published procedure; dossiers may be submitted via the MOIT public service portal, directly or by public postal service.	Wrong submission route or missing test evidence may require supplementation and delay market release.
Operational outcome	After submitting the registration dossier, the enterprise self-affixes the energy label according to the declared dossier and remains responsible for accuracy.	Wrong label information, wrong efficiency level or model mismatch may trigger label recall or remedial action.
Recommended timing	Review before ETA; test report and label information should be prepared before cargo arrival.	Starting only after arrival may cause demurrage, detention or project/sales delay.
Duties & C/O	HS, MFN duty, VAT and FTA preferential duty depend on the exact product group: air conditioners, refrigerators, washing machines, fans, LED lamps, laptops, printers, transformers or electric motors.	Wrong C/O form, origin criterion or HS description may result in denial of preferential duty.

TERMS AND WHY THIS PROCEDURE MATTERS

Energy labeling

Affixing a label showing energy consumption, energy-efficiency performance and mandatory technical information.

Comparative label

A label comparing energy-efficiency levels, often displayed by star rating or efficiency scale.

Certification label

A label confirming that a product reaches or exceeds the applicable high-efficiency criteria.

MEPS

Minimum Energy Performance Standards; products below MEPS may not be permitted for circulation under the applicable roadmap.

Test report

The core evidence for registration and energy-label information, issued for the relevant model and testing standard.

ETA

Estimated Time of Arrival; the key milestone for locking documents and controlling compliance risk.

The energy-labeling procedure mainly affects the pre-market circulation stage, but for imports it should be managed before ETA because the test report, model list, catalogue and labels may also affect customs declaration, other specialized controls and sales planning.

PRODUCT CLASSIFICATION AND TECHNICAL IDENTIFICATION

This guide applies to imported goods that may fall under Vietnam’s list of equipment subject to energy labeling, including household appliances, office/commercial equipment, industrial equipment and certain energy-using electrical/electronic products. It must not be applied automatically to every product sharing the same commercial name. The importer must verify the catalogue, datasheet, model, function, power rating, testing standard and actual import purpose.

Operational warning: products named “LED lamp”, “air conditioner”, “refrigerator” or “printer” may have different policies depending on power rating, configuration, new/used condition, sample/project/warranty status and market-circulation purpose.

Product group / scenario	Technical signs to check	Examples	Evidence	Possible policies	Dossiers to compare	Application note
Household electrical appliances	Power, voltage, frequency, cooling capacity, volume, testing standard and original label.	Air conditioners, refrigerators, washing machines, rice cookers, electric fans, water heaters.	Catalogue, datasheet, manual, original label, model list, test report.	Energy labeling; goods labeling; conformity/quality inspection may apply by product.	Invoice, Packing List, B/L/AWB, C/O, test report, energy-label sample.	Check the exact model and standard; do not rely on the commercial name only.
Office/commercial equipment	Main function, print/copy speed, power source, energy-saving mode, commercial model.	Photocopiers, printers, monitors, laptops, commercial refrigerated cabinets.	Catalogue, datasheet, model documents, test report if covered.	Energy labeling; ICT compliance may apply if wireless modules are present.	Model/serial list, technical documents, import dossier.	Multifunction devices require clear identification of principal function for HS and policy.
Industrial / energy equipment	Rated power, efficiency, insulation class, use case and technical standard.	Electric motors, transformers, industrial lighting equipment.	Technical datasheet, nameplate, testing standard, project contract.	Energy labeling or MEPS; other quality controls may apply.	Catalogue, nameplate, test report, project dossier.	Project or replacement equipment requires clear proof of purpose and use scope.
Wireless-enabled goods	RF module, frequency band, output power and communication standard.	Smart air conditioners, smart refrigerators, Wi-Fi printers, smart displays.	Module datasheet, manual, RF certificates if any.	Telecom/ICT conformity may apply in addition to energy labeling.	Catalogue, test report, conformity dossier if covered.	Energy labeling and ICT conformity are separate compliance layers.
Samples / trial / warranty / replacement goods	Quantity, import purpose, commercial circulation, internal use.	Demo samples, spare parts, replacement equipment for projects.	Purpose letter, project contract, PO, technical documents.	Exemption or different treatment may apply depending on evidence.	Purpose letter, commercial documents, catalogue.	Do not assume exemption if the goods are sold or handed over commercially.
Used/refurbished goods	Year of manufacture, condition, purpose, technical compliance.	Used printers, used refrigerators, used industrial equipment.	Condition records, year of manufacture, inspection report if any.	Used-equipment import policy may apply in addition to energy labeling.	Invoice, images, inspection dossier, catalogue.	Review before purchase; detention risk is higher than for new goods.

HS CODE – DUTY – C/O

Energy labeling does not determine HS code. HS classification is based on principal function, structure, operating principle, technical specifications, condition and accessories/parts shipped with the goods. The table below is a practical reference and must be finalized against the 8-digit HS code, tariff schedules and actual dossier at customs declaration date.

Indicative HS code	Suitable product group	Classification basis	Application condition	Ordinary duty	MFN import duty	VAT	C/O/FTA to review	Documents to compare
8415.10.xx	Air-conditioning machines.	Cooling/air-conditioning function, compressor structure, indoor/outdoor unit, cooling capacity.	Depends on model, capacity and configuration.	Indicatively 37.5% if MFN is 25%; verify tariff.	Indicatively 25%.	Usually 10%.	ATIGA, ACFTA/RCEP, AKFTA/VKFTA/RCEP, AJCEP/VJEPA/CPTPP/RCEP, EVFTA, UKVFTA.	Catalogue, datasheet, original label, C/O, energy-efficiency test report.
8418.10/8418.21/8418.30/8418.40	Refrigerators, freezers and refrigeration equipment.	Cooling function, volume, door type, compression system, household/commercial use.	Separate household and commercial equipment.	Indicatively 37.5% if MFN is 25%; verify HS.	Indicatively 25%.	Usually 10%.	Form D, E/RCEP, AK/VK/RCEP, VJ/AJ/CPTPP/RCEP, EUR.1, UKVFTA.	Catalogue, nameplate, volume, power, test report, C/O.
8450.11/8450.12/8450.19	Washing machines.	Washing function, washing capacity, automatic/semi-automatic structure.	Do not apply automatically to industrial washing machines.	Indicatively 37.5% if MFN is 25%; verify tariff.	Indicatively 25%.	Usually 10%.	ASEAN, China, Korea, Japan, EU, UK, Australia-New Zealand.	Datasheet, model list, original label, C/O, test report.
8414.51.xx	Electric fans.	Airflow function, electric motor, power rating and fan type.	Separate household fan, industrial fan and parts.	Indicatively 37.5% if MFN is 25%; verify HS.	Indicatively 25%.	Usually 10%.	Review FTA by origin and applicable origin criterion.	Catalogue, motor power, original label, C/O.
8539.52.xx	LED lamps or LED light sources.	LED light-emitting principle, voltage, wattage and lamp/source type.	Distinguish luminaire, bulb, LED module and parts.	May be 0%–7.5% depending on HS; verify tariff.	May be 0%–5%.	Usually 10%.	Review C/O route; also check QCVN/TCVN if quality control applies.	Catalogue, datasheet, test report, applicable standard, C/O.
8516.10.10	Electric instantaneous/storage water heaters.	Electro-thermal function, heating element, power, capacity and use.	Apply by actual structure and description.	Indicatively 30% if MFN is 20%; verify tariff.	Indicatively 20%.	Usually 10%.	Review preferential duty by C/O and FTA schedule.	Datasheet, nameplate, power rating, C/O, test report.
8471.30.xx	Laptops / portable data-processing machines.	Data-processing function, display, keyboard, weight and configuration.	Separate laptop, tablet, mini PC, monitor and parts.	Often 0% if HS is correct; verify.	Often 0%.	Usually 10%.	C/O may still be required for origin proof or other preferences.	Catalogue, configuration, model/serial, C/O if any.
8443.xx	Printers, photocopiers and multifunction machines.	Printing/copying technology and main function.	Wireless models require separate ICT review.	May be 0%–15% depending on HS.	May be 0%–10%.	Usually 10%.	Review CTH/CTSH/RVC if preferential treatment is claimed.	Catalogue, manual, model list, C/O, test report if covered.

PREFERENTIAL C/O/FTA ROUTES TO REVIEW

Origin route	FTA	C/O or origin document	Special preferential duty if supported	Conditions	Documents to compare	Application note
ASEAN	ATIGA	Form D	Many products may be 0% if rules are met.	Valid C/O, direct transport, matching description and HS.	C/O, invoice, packing list, B/L, catalogue, declaration.	Check WO/RVC/CTH/CTSH and third-party invoice if any.
China	ACFTA or RCEP	Form E or RCEP C/O	May be 0% or reduced by HS.	Origin rule and direct transport must be met.	C/O, contract, invoice, packing, bill, catalogue.	Form E is commonly scrutinized for HS, description and origin criterion.
Korea	AKFTA, VKFTA or RCEP	Form AK, VK or RCEP	Deep preferences may apply depending on HS.	Select the FTA matching the dossier and best tariff.	C/O, transport documents, catalogue, final HS.	Do not mix forms or schedules.
Japan	VJEPA, AJCEP, CPTPP or RCEP	VJ, AJ, CPTPP or RCEP origin proof	Preferences vary by HS and route.	Origin criterion and transport documents must match.	Origin proof, invoice, B/L, model list.	Review multi-country components carefully.
EU	EVFTA	EUR.1 or valid origin statement	May decrease under EVFTA staging.	Valid origin proof and product-specific rule.	EUR.1/origin statement, invoice, packing, B/L.	Check self-certification conditions if used.
UK	UKVFTA	EUR.1 or UKVFTA origin proof	May apply by UKVFTA tariff schedule.	UK origin and valid proof.	Origin proof, transport documents, catalogue.	Do not assume the same evidence as EVFTA.
Australia / New Zealand	AANZFTA or CPTPP	AANZ C/O or CPTPP origin document	May apply by tariff schedule.	Origin rule and transport requirements.	C/O/origin document, invoice, B/L, packing.	Choose the form by actual origin route.
India / Hong Kong	AIFTA / AHKFTA	Form AI / AHK	May apply if HS is covered.	Valid C/O, correct origin criterion and transport.	C/O, invoice, packing, B/L, catalogue.	Not every HS has the same preference.

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

DOSSIER AND SUBMISSION METHOD

The importer should separate the dossier into commercial documents, technical/specialized documents and the authority-submission dossier. The key control rule is a 100% match of goods description, quantity, model, serial number, origin and technical specifications across commercial documents, catalogue, label, energy-labeling dossier and customs declaration.

Dossier group	Required documents	Used for	Prepared by	Common errors	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 valuation, origin and quantity control.	Importer, shipper, forwarder, Docs/Ops.	Generic description, model mismatch, missing origin, wrong C/O form.	Lock documents before ETA and compare line-by-line with catalogue.
Technical dossier	Catalogue, datasheet, manual, product images, original label, nameplate, model/serial list.	HS classification, energy-labeling scope and testing standard.	Supplier, procurement, engineering, compliance.	Catalogue lacks wattage, volume or standard information.	Request technical files before booking.
Testing dossier	Energy-efficiency test report; evidence of laboratory competence if using foreign test results.	Energy-labeling registration.	Manufacturer, laboratory, importer.	Wrong model, wrong standard or unsuitable laboratory scope.	Check model, standard, report date and laboratory accreditation.
Registration dossier	Energy-labeling declaration, test result, projected label and supporting documents.	Submission via MOIT portal/direct/post.	Importer or authorized representative.	Missing Vietnamese translation/notarization; label sample inconsistent with test report.	Standardize model name and values before submission.
Goods labeling dossier	Original label, Vietnamese supplementary label, importer details, origin and mandatory specifications.	Market circulation and post-market inspection.	Importer, compliance, warehouse, sales.	Supplementary label inconsistent with original label.	Review goods label and energy label before warehouse release.

LEGAL BASIS AND SPECIALIZED POLICY MATRIX

Document group	Document	Issuing authority	Effective timing	Role	Key points	Review note
Law	Law No. 50/2010/QH12 on economical and efficient use of energy.	National Assembly	Effective from 01 Jan 2011; check partial validity.	Foundation for energy-efficiency control.	Energy-using equipment and energy labeling.	Use as the legal basis for labeling obligation.
Decree	Decree 21/2011/ND-CP.	Government	Effective from 15 May 2011.	Details implementation of Law 50/2010/QH12.	Lists and controls energy-using vehicles/equipment.	Check amendments where relevant.
Decision	Decision 04/2017/QD-TTg.	Prime Minister	Effective from 25 Apr 2017; replacing Decisions 51/2011 and 03/2013.	Core list of equipment subject to energy labeling and MEPS roadmap.	Household, office-commercial and industrial equipment groups.	Primary document for scope assessment.
Circular	Circular 36/2016/TT-BCT.	MOIT	Effective from 10 Feb 2017; partially amended.	Procedures for energy labeling, testing, registration and enterprise responsibilities.	Scope, exemptions, testing, registration dossier, self-labeling and label recall.	Check the consolidated/current version before filing.
Amending circular	Circular 42/2019/TT-BCT.	MOIT	Effective from 05 Feb 2020.	Amends periodic reporting obligations.	Annual reporting on energy labeling.	Track post-market obligations.
Administrative procedure	Circular 38/2025/TT-BCT.	MOIT	Effective from 01 Jul 2025.	Updates MOIT administrative procedures.	Review the current procedure on the MOIT public service portal.	Check the portal at filing date.
Goods labeling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP.	Government	Decree 43 effective from 01 Jun 2017; Decree 111 from 15 Feb 2022.	General goods labeling and Vietnamese supplementary labels.	Mandatory labeling contents for imported goods.	Energy label and goods label are separate layers.
Tariff schedules	Current import tariff and FTA tariff schedules.	Government / Ministry of Finance	At customs declaration date.	Ordinary duty, MFN duty, VAT and special preferential duty.	8-digit HS, description, origin and C/O.	Confirm by final HS and route.

SPECIALIZED POLICY MATRIX

Goods scenario	Documents to check	Possible policy	Authority/portal	Trigger condition
Goods listed under Decision 04/2017/QD-TTg	Decision 04/2017, Circular 36/2016 and amendments.	Energy-labeling registration, efficiency testing and self-labeling after dossier submission.	MOIT public service portal / relevant MOIT unit.	Covered model and market circulation in Vietnam.
Potentially exempt or outside scope	Circular 36/2016 and import-purpose dossier.	Different treatment may apply for certain non-commercial, transit, temporary or special-purpose goods.	Customs / specialized authority depending on case.	Evidence of purpose and no normal commercial circulation.
Goods also subject to quality/conformity control	Quality law, Decree 107/2016, applicable QCVN/TCVN.	Quality inspection, certification/declaration of conformity, CR mark where applicable.	Specialized authority / designated certification body.	Product is in Group 2 goods or mandatory QCVN.
Goods with Wi-Fi/Bluetooth/4G/5G	ICT/telecom regulations.	Telecom/ICT conformity may arise in addition to energy labeling.	MIC-related authority/portal if applicable.	Wireless module, frequency band or radio function.
Goods with encryption/security features	MMDS/Information security regulations if applicable.	Civil cryptography / cyber-security product review may arise.	Relevant specialized authority.	Encryption/security beyond ordinary operational functions.
Used/refurbished goods	Used machinery/equipment import regulations.	Used-goods import conditions, inspection or technical explanations may apply.	Customs / specialized authority.	Goods are not brand-new or have prior use history.

VIEW ORIGINAL LEGAL SOURCES

Decision 04/2017/QD-TTg Circular 36/2016/TT-BCT Energy-labeling procedure Consolidated Circular 49/VBHN-BCT

TIME, FEES AND COST RISKS

Step	Recommended timing	Indicative timing/fee	Cost risk if delayed
Scope and HS review	Before purchase or at least before ETA.	Depends on catalogue/datasheet completeness; no state fee for internal review.	Wrong HS or missed policy may cause amendment and customs explanations.
Test report preparation	Before cargo arrival.	Testing timeline depends on laboratory, standard and number of models.	Missing test report may delay registration and market release.
Registration submission	Before market circulation.	The public procedure does not prescribe a fixed processing time/fee; check portal at filing date.	Late filing may cause inventory delay and operating cost.
Customs clearance and delivery	Upon arrival and complete documents.	Depends on customs channel and dossier quality.	DEM/DET and storage may arise if documents are held.
Reporting and file retention	Periodically and upon technical/model change.	Follow MOIT reporting requirements.	Poor retention may create post-market inspection risk.

PRACTICAL E2E PROCESS

1. Pre-ETA review

Confirm preliminary HS, check whether the goods are in the energy-labeling list and review additional conformity/ICT/MMDS triggers if any.

2. Lock documents and technical files

Match invoice, packing list, B/L/AWB, C/O, catalogue, datasheet, model list, original label and test report.

3. Prepare testing evidence

Check that the test report covers the exact model, applicable standard and acceptable laboratory scope.

4. Submit energy-labeling registration

Submit via MOIT portal, directly or by post; retain proof of submission and the full dossier.

5. Customs declaration

Green channel is generally lighter; Yellow means document check; Red means document and physical inspection. HS, model, C/O, catalogue and policy are common query points.

6. Delivery and post-clearance completion

Deliver to warehouse, affix supplementary/energy labels where applicable, retain files by lot and prepare for reporting/inspection.

FAQ

1. Which goods require energy labeling?

Goods listed under Decision 04/2017/QD-TTg and relevant MOIT guidance, subject to model, rating, testing standard and import purpose.

2. Can labeling be handled after arrival?

It should be prepared before ETA. Covered goods should have a compliant dossier and label before market circulation.

3. Is an import license required?

Energy labeling is not an import license for all goods, but other specialized policies may apply depending on model and features.

4. Can a foreign test report be used?

It may be considered if the laboratory, standard and evidence meet the applicable requirements. Review by model and report scope.

5. Can one report cover multiple models?

Only where the models are within the same type/specification/origin/manufacturer scope and the report supports such use.

6. Are samples exempt?

Do not answer absolutely. Samples or non-commercial imports require evidence of purpose and scope review.

7. Does C/O replace energy-labeling documents?

No. C/O affects duty preference; energy labeling depends on product list, testing standard and registration dossier.

8. What should be retained after clearance?

Import documents, registration dossier, test report, label sample, catalogue, model/serial list, C/O and reporting records.

OUTPUTS AND POST-CLEARANCE OBLIGATIONS

Output / obligation	Control point	Files to retain	Operational note
Submitted energy-labeling dossier	Declaration, test report, label sample, technical file and submission evidence.	Electronic and internal file by model/lot.	Create file code by model and customs declaration number.
Energy label on goods	Label information must match model, manufacturer/importer, standard and test result.	Label images and design files.	Do not use another model’s label.
Vietnamese supplementary label	Goods name, origin, specifications, importer and mandatory contents.	Label sample and product photos.	Supplementary label and energy label are separate layers.
Reporting / model changes	Track reporting duties and re-register where technical changes affect energy performance.	Periodic reports and updated test reports.	Review any model or design change before the next shipment.
Post-clearance/post-market readiness	Prepare explanations for HS, C/O, label, test report and specialized policy.	Complete import and technical dossier.	Distribute file ownership among Ops, Docs, Compliance, warehouse and sales.

GIẢI PHÁP TỪ TGIMEX

For goods potentially subject to energy labeling, businesses should not wait until cargo arrival to start compliance review. A small mismatch among invoice, packing list, catalogue, datasheet, C/O, test report or labels may lead to document supplementation, clearance delay or unplanned storage costs.

Pre-ETA review

Check HS, energy-labeling scope, C/O, duties, goods labels, catalogue, datasheet, model/serial and import purpose before arrival.

Compliance dossier control

Match invoice, packing list, B/L/AWB, C/O, catalogue, test report, energy-label sample, supplementary label and technical explanations.

Logistics coordination

Monitor booking, ETA, pre-alert, transport documents, customs declaration, customs channel handling and port/warehouse delivery.

Post-clearance file retention

Build lot/model-based dossiers for reporting, post-clearance inspection, post-market inspection and future shipments.

Discuss shipment dossier View more procedures

ENERGY LABELING, HOUSEHOLD GOODS SUBJECT TO ENERGY LABELING

Import Procedures for Goods Subject to Energy Labeling in Vietnam

Import Procedures for Goods Subject to Energy Labeling in Vietnam

QUICK SUMMARY

TERMS AND WHY THIS PROCEDURE MATTERS

PRODUCT CLASSIFICATION AND TECHNICAL IDENTIFICATION