IMPORT PROCEDURE FOR MACHINERY SUBJECT TO QUALITY INSPECTION / CONFORMITY CERTIFICATION UNDER THE MACHINERY CATEGORY
For machinery subject to quality inspection or conformity certification, the main risk is usually not inland delivery but misidentifying the machine, applying the wrong HS code, lacking a proper catalogue/datasheet, failing to lock the applicable QCVN, or not separating new equipment, used equipment and integrated lines. A single mismatch may delay customs clearance, increase storage costs and affect installation schedules. This article provides an end-to-end review map so the importer can control HS code, duties, C/O, technical files and quality-inspection/conformity procedures before ETA.
OVERVIEW OF IMPORT PROCEDURES FOR MACHINERY SUBJECT TO QI / CONFORMITY
Not all imported machinery is subject to quality inspection. The procedure is triggered when the goods fall under Group 2 goods or under a specialized technical regulation requiring conformity certification, conformity declaration, inspection or state quality registration.
Industrial machinery, lifting equipment, pressure equipment, boilers, forklifts, elevators, refrigeration systems and machinery with technical safety requirements.
HS code, model, catalogue, QCVN/TCVN, quality certificates, test reports, C/O, new/used status and import purpose.
The same commercial name may lead to different policies depending on capacity, pressure, lifting mechanism, power source, operating environment and technical file.
TERMS AND WHY THE PROCEDURE MATTERS
| Term | Operational meaning | Why it matters |
|---|---|---|
| Quality inspection | State quality registration/inspection for imported goods with safety risks. | Customs may request it before clearance or before the goods are put into use. |
| Conformity certification/declaration | Evidence that the product complies with the applicable Vietnamese technical regulation. | It is not enough to rely on commercial catalogues. |
| Group 2 goods | Potentially unsafe products listed by specialized ministries. | Triggers quality registration, conformity assessment or technical inspection. |
| Technical safety inspection | Inspection before operation for equipment with strict occupational safety requirements. | Often applies to lifting equipment, pressure equipment, elevators and boilers. |
| Used machinery | Machinery already assembled and operated after manufacture. | May trigger Decision 18/2019/QD-TTg, unless excluded by Group 2 or specialized management rules. |
DETAILED PRODUCT CLASSIFICATION AND IDENTIFICATION
Machinery should be reviewed based on catalogue, datasheet, model, main function, load/pressure/power, operating principle, accessories, condition and import purpose.
| Product group/situation | Technical signs to check | Examples | Evidence | Potential policy | Documents to compare | Application note |
|---|---|---|---|---|---|---|
| Lifting and handling equipment | Load, lifting height, mechanism, control mode, safety standard. | Cranes, hoists, winches, lift tables. | Catalogue, drawings, nameplate. | Quality inspection, conformity and safety inspection if listed. | HS, model, load, serial, CO/CQ. | Do not use one conclusion for all lifting devices. |
| Forklifts and personnel lifting equipment | Power source, lifting height, rated load, operating scope. | Forklift, reach truck, aerial work platform. | Datasheet, battery/fuel spec, safety certificate. | Quality inspection/conformity; pre-use inspection if applicable. | Invoice, packing list, catalogue, C/O. | Used units require year and condition review. |
| Boilers and pressure equipment | Design pressure, volume, medium, temperature, manufacturing standard. | Boilers, air tanks, LPG tanks, pressure vessels. | Technical drawings, certificate, test report. | Group 2 quality inspection and technical safety inspection. | Pressure, volume, material, standard. | Wrong pressure/volume description may change the policy. |
| Used machinery | Year of manufacture, import year, operating history, purpose in Viet Nam. | Production machines, processing lines, packaging lines. | Inspection certificate, photos, technical records. | Decision 18/2019/QD-TTg if within scope. | HS chapters 84/85, age, remaining quality. | Group 2 and specialized machinery may be excluded from Decision 18. |
HS CODE – DUTIES – C/O
For machinery, the HS code should never be fixed based on generic trade names such as “machine”, “equipment” or “system”. The importer should first lock the nature of the goods by reviewing the principal function, drive mechanism, level of line integration, load/pressure/capacity, power supply, working medium, attached parts and new/used condition. Machinery with similar commercial names may still fall into different HS codes, quality-inspection triggers and technical-regulation paths.
On duties, three layers should be checked in parallel: ordinary import duty, MFN preferential duty and special preferential duty under C/O or FTA. In many cases, the ordinary import duty is determined at 150% of the MFN rate for the same code if no other rule applies. Machinery commonly falls under 10% VAT, but the actual VAT treatment should still be reviewed under the tax policy effective on the customs-declaration date.
PROPOSED HS CODE – DUTIES – C/O TABLE BY MACHINERY GROUP
| Reference HS code | Suitable description / machinery group | Classification basis | Application conditions | Ordinary import duty | MFN preferential duty | VAT | C/O / FTA to review | Supporting documents to review |
|---|---|---|---|---|---|---|---|---|
| 8426 | Cranes, overhead cranes, gantry cranes, electric hoists and other crane-type lifting equipment. | Classified by lifting/handling function, movement of loads and lifting mechanism; distinguish fixed, rail-mounted, tyre-mounted or line-integrated structures. | Applicable where the machine is a complete lifting system; review safe working load, span, lifting height, installation environment and whether it is a stand-alone machine or part of a line. | Usually 150% of MFN if the shipment is not eligible for MFN/FTA treatment; review the current tariff schedule at the 8-digit level. | Commonly 0%–5%, depending on the subheading. | Commonly 10%; review the VAT policy in force for the final HS code. | Review Form D, E, AK, VK, VJ, AJ, EUR.1, CPTPP and RCEP depending on origin. | Catalogue, nameplate, lifting capacity, structural drawings, CO/CQ, test report, C/O. |
| 8427 | Forklifts, reach trucks, pallet stackers and other self-propelled industrial trucks with lifting/handling equipment. | Classified by lifting/handling function, motive power and operating structure. | Separate electric forklifts, diesel/LPG forklifts, reach trucks, stackers and pallet trucks; review battery/charger or fuel specifications and lift height. | Usually 150% of MFN if not eligible for preferences. | Commonly 0%–5%. | Commonly 10%. | Check FTA eligibility based on actual origin; pay attention to PSR, origin criteria and product description on the C/O. | Datasheet, battery/fuel specs, serial list, invoice, catalogue, C/O. |
| 8428 | Elevators, escalators, conveyors and other lifting/handling machinery. | Used for lifting or moving persons/goods, but not falling under 8426/8427; distinguish passenger and cargo functions. | Review the equipment type, load, speed, number of stops, whether it carries persons, and whether the control cabinet is supplied together. | Usually 150% of MFN if not eligible for preferences. | Commonly 0%–5%. | Commonly 10%. | Review Form D/E/AK/VK/AJ/VJ/EUR.1/CPTPP/RCEP by import lane. | Catalogue, installation layout, load, speed, safety standards, CO/CQ, C/O. |
| 8422 | Packaging machines, filling machines, labelling machines, capping machines and other mechanical packing machinery. | Classified by the principal function of the equipment set: filling, packing, labelling, capping, shrink-wrapping or a combined line. | Review whether the shipment is a stand-alone machine or an integrated line; automation level, capacity, packaging material and processed product. | Usually 150% of MFN if not eligible for preferences. | Commonly 0%–5%. | Commonly 10%. | Check FTA eligibility based on actual origin; compare the product description on the C/O against the contract and technical documents. | Catalogue, line diagram, capacity, packaging material, manual, CO/CQ, C/O. |
| 8402 / 8419 | Boilers, thermal-oil heaters, industrial heating equipment, heat exchangers and thermal sterilisation equipment. | Classified by steam-generation/heating/heat-exchange function, pressure construction, working medium, fuel and heating method. | Review working pressure, capacity, working medium, manufacturing standard, fuel type and whether the equipment must undergo safety inspection before use. | Usually 150% of MFN if not eligible for preferences. | Commonly 0%–5%. | Commonly 10%. | Review applicable FTA by origin and the relevant tariff-shift rule. | Technical drawings, pressure certificate, material certificate, CO/CQ, test report, C/O. |
| 7311 / 8418 | Compressed-gas or liquefied-gas containers, pressure vessels and industrial refrigeration systems with pressure components. | Classification depends on material, capacity, refrigerant/gas, pressure, construction and end use. | Do not apply one rule to all tanks/vessels; separate pressure vessels, normal tanks, refrigeration assemblies and auxiliary equipment. | Usually 150% of MFN if not eligible for preferences. | Commonly 0%–10%. | Commonly 10%. | Review C/O/FTA only if the origin file is complete and the product description matches. | Nameplate, pressure data, material, refrigerant, test report, C/O. |
| 8479 / other specialised machinery | Machinery having individual functions, special industrial machinery not more specifically described elsewhere, and special equipment sets or lines. | Classify by principal function, operating principle, completeness, integrated components and technical explanatory documents. | Use this screening route only when the goods do not fit a more specific heading; for production lines, decide whether the shipment should be declared as a complete line or broken into modules/equipment. | Usually 150% of MFN if not eligible for preferences; the tariff schedule must be reviewed very carefully against the actual configuration. | Commonly 0%–10%. | Commonly 10%. | Review all potentially relevant FTAs depending on origin; pay special attention to product description and HS code on the C/O. | Full catalogue, principle diagram, line layout, equipment photos, model/serial list, CO/CQ, C/O. |
SPECIAL PREFERENTIAL C/O / FTA TABLE TO REVIEW BY IMPORT LANE
This table is a quick screening tool for possible special preferential duty treatment for machinery. Preferential duty should only be applied when the final HS code, origin criterion, goods description, direct transport and C/O file are all consistent.
| Origin / lane | FTA / agreement | C/O form or origin document | Special preferential duty if supported | Application conditions | Documents to review | Application note |
|---|---|---|---|---|---|---|
| ASEAN | ATIGA | Form D | Many machinery groups may reach 0% if the origin rules are met; confirm against the final HS code. | Meet PSR, direct transport and consistent description across invoice/customs declaration. | C/O, invoice, packing list, B/L, catalogue, HS code, country of origin. | Review RVC/CTH/CTSH criteria and manufacturer information carefully. |
| China | ACFTA or RCEP | Form E or RCEP origin document | Preferential duty may apply under ACFTA/RCEP if the final HS code is covered. | Correct form, origin criterion, direct transport or transit proof. | C/O, third-party invoice if any, B/L, catalogue, model/serial list. | Watch for mismatched description, HS code or third-party invoice details. |
| Korea | AKFTA, VKFTA or RCEP | Form AK, Form VK or RCEP origin document | Duty benefit depends on the selected FTA and final HS code. | Compare AKFTA/VKFTA/RCEP schedules to select the optimal lane. | C/O, invoice, packing list, transport document, catalogue, origin criterion. | Do not assume the best treaty before checking the current tariff schedule. |
| Japan | VJEPA, AJCEP, CPTPP or RCEP | Form VJ, Form AJ, CPTPP/RCEP origin document | May enjoy preferential treatment if PSR and origin documents are satisfied. | Check origin criterion, direct transport, machinery description and HS code. | C/O/origin document, invoice, B/L, catalogue, CO/CQ if any. | For modular machinery, review descriptions and origin of major modules. |
| EU | EVFTA | EUR.1 or origin statement if eligible | EVFTA treatment depends on the final HS code and proper origin document. | Correct origin mechanism, direct transport and EVFTA-compliant documents. | EUR.1/origin statement, invoice, packing list, B/L, catalogue. | Check shipment value, eligible exporter status and product description. |
| UK | UKVFTA | EUR.1 or origin statement if eligible | UKVFTA treatment applies if HS code and origin file meet the rules. | Similar to EVFTA but applied separately for the UK lane. | Origin document, invoice, B/L, catalogue, HS code. | Do not mix EU and UK origin documents unless the file supports it. |
| Australia / New Zealand | AANZFTA or CPTPP | Form AANZ or CPTPP origin document | Special preferential treatment may apply if origin rules are satisfied. | Review PSR, goods description, direct transport and origin document. | C/O/origin document, invoice, B/L, catalogue. | Compare AANZFTA and CPTPP under the final HS code. |
| India / Hong Kong | AIFTA or AHKFTA | Form AI or eligible AHKFTA origin document | Duty benefit depends on final HS code and relevant concession schedule. | Correct form, origin criterion and transport documents. | C/O, invoice, packing list, transport document, technical description. | Apply only when the actual import lane and origin file fully support the claim. |
DOSSIER AND SUBMISSION METHOD
| Dossier group | Required documents | Used for | Usually prepared by | Common errors | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial documents | Invoice, Packing List, B/L/AWB, contract/PO, C/O. | Customs declaration, value and origin. | Importer, shipper, forwarder. | Mismatch of name, model, quantity or origin. | Compare line by line with catalogue. |
| Technical documents | Catalogue, datasheet, manual, drawings, nameplate photos, model/serial list. | HS, quality inspection and technical explanation. | Supplier, engineering team. | Missing load, pressure, power or year. | Lock the correct model file before shipment. |
| Quality/conformity documents | Quality registration, conformity certificate/declaration, test report, CO/CQ. | Specialized authority, customs and post-clearance file. | Importer, certification body, logistics provider. | Wrong model, wrong QCVN, incomplete evidence. | Check QCVN and scope of certificate. |
LEGAL BASIS – SPECIALIZED POLICY MATRIX
1. LEGAL BASIS TABLE TO REVIEW
| Document group | Document | Issuing authority | Effective timing | Role | Key point | Review note |
|---|---|---|---|---|---|---|
| Law | Law on Product and Goods Quality 05/2007/QH12 | National Assembly | Effective from 01/07/2008; partly expired. | Foundation for quality management and Group 2 goods. | Importer responsibilities and quality control. | Review current consolidated status. |
| Decree | Decree 132/2008/ND-CP as amended by 74/2018/ND-CP, 154/2018/ND-CP and related documents. | Government | Current quality-control framework to review. | Imported goods quality and Group 2 mechanism. | Articles 7/8 on imported goods and Group 2 goods. | Check current version at declaration time. |
| Specialized circular | Circular 01/2021/TT-BLDTBXH | MOLISA | Effective from 18/07/2021. | List of Group 2 goods under MOLISA, HS codes and import control measures. | Appendix and quality-inspection measures. | Check current receiving authority due to administrative restructuring. |
| Used machinery | Decision 18/2019/QD-TTg | Prime Minister | Effective from 15/06/2019. | Controls import of used machinery/equipment/technological lines. | Scope, criteria, inspection and exclusion rules. | Do not use it to replace Group 2 procedure. |
| Special case | Circular 30/2025/TT-BKHCN | Ministry of Science and Technology | Effective from 01/01/2026. | Criteria for used technological lines, equipment, machinery and tools directly serving semiconductor manufacturing/packaging/testing projects and training/R&D of digital technology products/services. | Articles 4 and 5 on criteria for used technological lines and used equipment/machinery/tools. | Review only when the goods fall within this special scope; it does not replace Decision 18/2019/QD-TTg or Group 2 procedures. |
2. SPECIALIZED POLICY MATRIX BY GOODS SITUATION
| Goods situation | Documents to review | Possible policy | Handling authority/portal | Trigger condition |
|---|---|---|---|---|
| New machinery not in Group 2 list | Quality law, decrees and specialized lists. | Normal customs procedure; still review label, HS, tax and C/O. | Customs and specialized authority if triggered. | No applicable QCVN/Group 2 listing. |
| Machinery in Group 2 list | Circular 01/2021/TT-BLDTBXH or relevant ministry list. | Quality registration, conformity certification/declaration. | National Single Window or assigned authority. | HS/model/function is listed. |
| Equipment with strict occupational safety requirements | Occupational safety regulations and inspection rules. | Technical safety inspection before operation. | Safety authority/appointed inspection body. | Lifting, pressure, elevator, boiler or similar high-risk equipment. |
| Used machinery | Decision 18/2019/QD-TTg and specialized regulations. | Age/quality inspection or specialized rule. | Customs and appointed inspection body. | Previously operated machinery for production use in Viet Nam. |
PROCESSING TIME, FEES AND RISK COSTS
| Step | Recommended timing | Indicative timing/fee | Risk cost if delayed | Control point |
|---|---|---|---|---|
| HS/QCVN/Group 2 review | Before ordering or before ETD. | Depends on technical file completeness. | Wrong policy and document shortage at port. | Model, function, purpose. |
| Quality inspection registration | Before ETA or when documents are available. | Public procedures show confirmation within about 01 working day and fee 0 VND. | Storage, DEM/DET and installation delay. | Correct form, authority, HS and model. |
| Conformity/inspection | Depending on QCVN and assessment method. | Depends on testing/certification/inspection body. | Cannot circulate or operate equipment. | Certificate scope must match model. |
END-TO-END OPERATIONAL PROCESS
HS, Group 2 list, QCVN/TCVN, C/O, label, new/used status and import purpose.
Invoice, Packing List, B/L/AWB, catalogue, datasheet, model/serial list and nameplate photos.
Quality inspection, conformity, safety inspection, used machinery or integrated line.
Submit registration/certification/inspection or technical explanation dossier.
Handle Green/Yellow/Red channel questions on HS, value, C/O and policy.
Move goods to plant, complete inspection/conformity, label and archive file.
Operational output control by step
| E2E step | Required output | Risk control point | Suggested coordination |
|---|---|---|---|
| Pre-ETA review | HS/QCVN/Group 2 conclusion, C/O review note and technical risk memo. | Do not ship before confirming policy triggers. | Importer, procurement, technical team, customs broker. |
| Document lock | Commercial and technical documents aligned by model, serial, origin and parameters. | Prevent mismatches between invoice, packing list, catalogue and declaration. | Shipper, importer, forwarder, docs team. |
| Specialized dossier | Quality registration/conformity/safety inspection dossier where applicable. | Submit to the correct authority/portal and correct product scope. | Importer, certification/inspection body, logistics provider. |
| Customs declaration | Declaration, supporting documents and channel-response file. | Control HS, value, C/O and specialized management questions. | Customs broker, importer, warehouse/port team. |
| Delivery and post-clearance | Delivery plan, conformity/inspection completion and archived shipment file. | Avoid operating or circulating equipment before required obligations are completed. | Importer, warehouse, plant/EHS, compliance team. |
FAQ
1. Is all imported machinery subject to quality inspection?
No. It depends on HS, model, function, technical parameters and specialized lists.
2. Can Group 2 machinery be cleared before conformity certification?
It depends on the applicable QCVN and assessment method. Some cases may proceed based on quality registration while the importer continues post-clearance obligations.
3. Does used machinery require Decision 18 review?
Possibly, but Group 2 or separately regulated machinery may be excluded. Review the actual scope carefully.
4. Is catalogue mandatory?
It is operationally critical because HS, QCVN and safety parameters cannot be reliably reviewed without it.
5. Can C/O reduce import duty?
Yes, if the final HS is eligible and the origin document satisfies the relevant FTA rules.
6. What about EPE/FDI projects?
Customs type and asset management may differ, but specialized quality requirements still depend on the machinery itself.
7. What must be done after clearance?
Conformity, safety inspection, labeling, technical file archiving and handover to plant/EHS where applicable.
8. When should the policy be reviewed?
Before ETD/ETA, not after goods arrive at the port.
OUTPUTS AND POST-CLEARANCE OBLIGATIONS
Quality registration receipt, quality inspection result, conformity certificate/declaration, inspection certificate and technical explanation file.
Labeling, conformity/technical safety inspection, lot file archiving, serial management and preparation for post-clearance audit.
TGIMEX SOLUTIONS
For machinery subject to quality inspection/conformity, the key is to control technical, legal, customs and post-clearance operation at the same time.
Review HS, model, QCVN, Group 2 list, new/used status and import purpose before shipment.
Check catalogue, datasheet, nameplate, load, pressure, power, CO/CQ and test reports.
Prepare checklist, registration and coordination with certification/inspection bodies.
Review C/O form, origin criteria, MFN/FTA duty and VAT.
Monitor ETA, pre-alert, D/O, customs declaration and delivery to warehouse/plant.
Set up customs, technical, conformity and safety inspection archive by shipment.
Support flow by stage
| Stage | Core tasks | Business output |
|---|---|---|
| Before purchase | Review HS, policy, QCVN, new/used status, C/O and import feasibility. | Risk memo and supplier document request list. |
| Before ETA | Lock documents, prepare quality/conformity registration, check C/O and label. | Submission-ready dossier and clearance plan. |
| At arrival | Customs declaration, channel handling, specialized dossier submission/supplement and delivery coordination. | Customs handling file, declaration records and delivery plan. |
| After clearance | Complete conformity/safety inspection, archive technical/customs documents and hand over operation files. | Post-clearance file and controlled obligations. |
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