Circular 29/2025/TT-BKHCN is a key regulatory reference for importers and businesses dealing with ICT and telecommunications equipment in Vietnam. This operational note summarizes the document, compliance triggers, affected goods and logistics checkpoints before customs declaration or market circulation. This article places the regulation in the practical context of import-export operations, clarifying its scope, affected parties, and the checks required before it is relied on for a shipment dossier. Before implementation, businesses should verify the effective date, amendments, and relevant official guidance applicable to the transaction, while retaining the source and document version used for later explanation or audit.

DOCUMENT INFORMATION

Field	Details
Document title	Circular regulating the List of potentially unsafe products and goods in information technology and telecommunications under the management responsibility of the Ministry of Science and Technology.
Reference number	29/2025/TT-BKHCN
Issuing authority	Ministry of Science and Technology
Date of issuance	13 November 2025
Effective date	31 December 2025
Signer	Minister Nguyen Manh Hung
Validity status	The Ministry of Science and Technology portal shows the document as currently effective. Application should still be checked against the actual shipment file and timing.
Scope	Group-2 products and goods in IT and telecommunications; management principles; and selected cases of suspension/non-mandatory application of some technical regulations.
Applicable entities	Organizations and individuals manufacturing, trading, importing or involved in quality management of Group-2 goods in Vietnam.

Application note: A product should be assessed by both HS code and product description/technical characteristics in the appendices. Do not rely only on generic commercial names.

Illustration for Circular 29/2025/TT-BKHCN: Group-2 ICT and Telecommunications Goods List — Illustration of the legal document and affected subjects in import-export operations.

VALIDITY AND TRANSITIONAL PROVISIONS

This section should be checked before relying on existing conformity certificates, notices of receipt of conformity declarations or dossiers prepared before the Circular takes effect.

Item to check	Applicable information	Operational note
Effective date	The Circular takes effect on 31 December 2025.	Dossiers opened after this date should be reviewed against Circular 29/2025/TT-BKHCN and the relevant appendices.
Ceased document	Circular 02/2024/TT-BTTTT ceases to be effective from the effective date of Circular 29/2025/TT-BKHCN.	New dossiers should not continue to follow the old list without re-checking the new appendices.
Certificates/declarations issued before the effective date	Conformity certificates and notices of receipt of conformity declarations issued before the effective date remain valid until the expiry date stated therein.	Keep the original certificate/notice, issue date, expiry date, model and product scope for post-clearance review.
Future risk-classification list	The Circular applies until a product and goods list based on risk classification is promulgated under the law on product and goods quality.	Monitor later instruments if the dossier remains pending or imports are repeated periodically.

Operational note: For shipments in transit or close to ETA near the effective date, review existing certificate/declaration validity, test reports and applicable appendix before customs clearance.

KEY POINTS FOR BUSINESSES

Operational focus: Circular No. 29/2025/TT-BKHCN is not merely a product-name lookup list. For import compliance, enterprises should cross-check HS codes, appendix descriptions, technical functions, connectivity standards, frequency bands, models, applicable technical regulations and conformity status.

1. Scope of application

The Circular applies to Group 2 products and goods in the IT and telecommunications sector. Do not conclude based only on commercial names; verify against the HS codes and product descriptions in the appendices.

2. Two compliance layers

Appendix I covers products requiring both certification of conformity and declaration of conformity; Appendix II covers products requiring declaration of conformity.

3. Multi-QCVN principle

If a product is subject to several QCVNs or integrates another Group 2 product, obligations may apply to both the main product and the integrated component.

1. REGULATORY SCOPE: NOT ALL ICT PRODUCTS ARE TREATED THE SAME

The Circular focuses on products and goods likely to cause unsafety in the IT and telecommunications sector. For a real shipment, enterprises should avoid conclusions based only on generic names such as “network device”, “computer”, “router”, “camera”, “tablet” or “IoT device”.

Point to review	Operational meaning	Action required
HS code and product description	The goods should match the appendix description and the actual technical nature of the product.	Compare the proposed HS code with catalogue, datasheet, manual, label images and functional description.
Technical function	Products with the same commercial name may trigger different obligations if Wi-Fi/Bluetooth/4G/5G modules, transmission power or frequency bands differ.	Separate each model/SKU; do not apply one policy conclusion to the whole shipment.
Import purpose	Commercial goods, project goods, samples, warranty goods or goods imported for factories/EPEs may differ in dossier timing and document retention.	Clarify the import purpose at the documentation and RFQ stage.

2. APPENDIX I: PRODUCTS REQUIRING CERTIFICATION AND DECLARATION OF CONFORMITY

Appendix I should be reviewed before ETA because it usually covers radio transmitting/receiving devices, telecommunication equipment and equipment affecting safety, electromagnetic compatibility, radio frequency or connection quality.

Content group	Explanation	Impact on import dossiers
Radio transmitting and receiving/transmitting equipment	Includes transmitting and receiving/transmitting devices, excluding radio-only receivers unless otherwise specified.	Review frequency bands, transmission power, connectivity standards, radio modules, test reports and relevant QCVNs.
Short-range radio / DECT / radar equipment	Devices with short-range or specialised transmission functions may still be regulated if they match the appendix.	Avoid generic descriptions such as “electronic accessory” when technical documents show a radio transmission function.
Dual obligation	This group generally requires both certification and declaration of conformity before market circulation, subject to applicable conditions.	Plan time for testing, certification, dossier submission and receipt of declaration acceptance.

3. APPENDIX II: PRODUCTS REQUIRING DECLARATION OF CONFORMITY

Appendix II focuses on products requiring declaration of conformity. Importers should not assume that “declaration only” can be handled after shipment arrival; technical data, conformity assessment results where applicable, labelling data and consistent model information are still required.

Common product groups	Documents to compare	Risk if incomplete
Desktop computers, industrial computers, laptops, tablets	Catalogue/datasheet, model list, configuration, adapter, battery, Wi-Fi/Bluetooth module if any, original label and manufacturer information.	Incorrect model information or missing module details may lead to wrong QCVN mapping and delayed declaration.
TV decoders, set-top boxes, digital TV receivers	DVB-S/S2, DVB-T2 standards, interfaces, power supply, software/firmware and product labels.	Incorrect product description may cause confusion between IT equipment, broadcasting equipment and telecommunication equipment.
Multi-function integrated equipment	Detailed datasheet, block diagram if available, user manual, test report and manufacturer certifications.	Reviewing only the commercial name may miss obligations for radio modules or additional QCVNs.

4. INTEGRATED PRODUCTS MUST NOT BE REVIEWED AS SINGLE-FUNCTION GOODS

Situation	Correct approach	Documents to prepare before ETA
Main product integrates another Group 2 module	Review obligations for both the main product and the integrated component where the appendix/QCVN is triggered.	Module datasheets, model list, technical documents, test reports, label images and manufacturer information.
Product is subject to multiple QCVNs	Do not select only one QCVN if technical regulations require multiple applicable standards.	Mapping table: model – function – QCVN – certification/declaration method.
New QCVN replaces or supplements an existing one	Follow the legal instrument promulgating the new QCVN.	Monitor new regulations before each recurring import shipment, especially for ICT products with short model lifecycles.

5. DECISIONS TO LOCK BEFORE CUSTOMS DECLARATION

Do not determine policy by product name only: invoice descriptions should be technically sufficient and consistent with catalogues, test reports and customs declarations.
Do not apply one conclusion to all models: each model/SKU may differ in configuration, connectivity module, battery, adapter or production market.
Do not ignore the appendices: Appendix I and Appendix II determine certification/declaration obligations and must be checked separately.
Do not let conformity dossiers lag behind logistics timelines: if goods arrive before technical files are ready, storage, demurrage/detention and project delays may occur.
Do not overlook transitional provisions: certificates and declaration acceptance notices issued before the effective date should be checked for validity period, model coverage and applicable QCVNs.

Implementation recommendation: Prepare a pre-ETA review sheet covering proposed HS code, Vietnamese/English product name, model, connectivity standard, frequency band, transmission power, applicable QCVN, corresponding appendix, conformity status and dossier owner.

AFFECTED BUSINESSES / GOODS

Analysis group	Required review
Business groups	Importers/exporters, factories, EPE/FDI entities, trading companies, brand owners, distributors, logistics providers and ICT/telecom equipment sellers.
Product groups	IT equipment, telecom equipment, radio equipment, terminal equipment, networking devices, products with Wi-Fi/Bluetooth/4G/5G or data transmission functions if listed in the appendices.
Affected stages	Pre-import review, customs declaration, quality inspection registration, conformity certification/declaration, market circulation and post-clearance audit.
Documents to compare	Catalogue, datasheet, user manual, invoice, packing list, B/L/AWB, C/O, test report, original label and model/serial list.
Triggering conditions	HS code, product description, function, technical standard, frequency band, model and actual import purpose.

IMPACT ON IMPORT-EXPORT / LOGISTICS

Affected stage	Risk / control point
Customs declaration	Incorrect HS code or product description may lead to wrong commodity policy, additional files and inspection routing.
Commercial documents	Invoice, Packing List, B/L/AWB and contract/PO should match catalogue/datasheet in name, model, quantity, origin and technical specifications.
Specialized inspection	Goods in Appendix I/II may require conformity certification, conformity declaration, quality inspection or test reports.
Logistics timeline	Late preparation of technical files may cause storage, demurrage/detention or project delivery delay.
Post-clearance compliance	Shipment files, technical data, certificates, declarations and import documents should be retained for audit.
Cost control	Do not estimate testing/certification costs before confirming QCVN, product scope and testing method.

BUSINESS CHECKLIST

File group	Documents	Used for	Common error
Product identification	Catalogue, datasheet, user manual, label photos, model/serial list	Determine whether goods fall under Appendix I/II	Using generic names such as “router”, “camera” or “network device” without model/connectivity details.
HS and product description	Proposed HS code, technical description, principal function	Compare with Group-2 list	Checking only commercial name, not HS/technical function.
Technical regulations	Applicable QCVN and test reports where available	Determine certification/declaration obligations	Not checking multiple QCVNs for multifunction products.
Customs files	Invoice, Packing List, B/L/AWB, contract/PO, C/O where applicable	Customs declaration and document control	Mismatch of product name, model, origin or quantity.
Specialized files	Quality inspection registration, conformity certification/declaration, test report	Quality management compliance	Preparing specialized documents only after ETA.

Document group	Document	Authority	Role	Review note
Law	Law on Product and Goods Quality 2007	National Assembly	Foundation for quality management of Group-2 goods.	Check obligations of importers, traders and distributors.
Law	Law on Standards and Technical Regulations 2006	National Assembly	Basis for QCVN/TCVN and conformity assessment.	Compare with applicable technical regulations.
Law	Law on Telecommunications 2023	National Assembly	Basis for telecom equipment management.	Pay attention to terminal, radio and network equipment.
Law	Law on Radio Frequencies 2009 and 2022 amendments	National Assembly	Basis for radio-frequency equipment.	Check frequency band, transmission power and wireless standards.
Decree	Decree 132/2008/ND-CP; 74/2018/ND-CP; 13/2022/ND-CP	Government	Detailed implementation of product and goods quality law.	Review amended/consolidated versions at filing time.
Circular replaced	Circular 02/2024/TT-BTTTT	Ministry of Information and Communications	Previous Group-2 list for MIC-managed products.	Review effective date and transitional provisions.
Circular / HS schedule	Circular 31/2022/TT-BTC	Ministry of Finance	Promulgates Vietnam’s import-export goods nomenclature; the HS basis referenced in the appendices of Circular 29/2025/TT-BKHCN.	Final HS classification must be reviewed against actual description, function, structure and technical documents.
Appendices / QCVN	Appendix I and Appendix II of Circular 29/2025/TT-BKHCN	Ministry of Science and Technology	Defines certification/declaration control measures.	Check HS, product description, QCVN and control measure together.

VIEW / DOWNLOAD ORIGINAL DOCUMENT

Businesses should verify the official Vietnamese text before applying it to a specific shipment.

Government document portal View / download official PDF Ministry portal Official Gazette

FULL OFFICIAL TEXT

FULL TEXT PREVIEW — CIRCULAR 29/2025/TT-BKHCN

Reference translation only. The official Vietnamese PDF from the Government document portal / Official Gazette / Ministry of Science and Technology remains the controlling legal text.

FAQ

1. When does Circular 29/2025/TT-BKHCN take effect?

It takes effect on 31 December 2025. Transitional provisions should be checked for existing files.

2. Are all ICT devices Group-2 goods?

No. Assessment must be based on HS code, product description, function, model and the appendices.

3. What is the difference between Appendix I and Appendix II?

Appendix I requires conformity certification and declaration; Appendix II requires conformity declaration.

4. What should be checked for wireless devices?

Frequency band, transmission power, connectivity standard, integrated module and applicable QCVN should be reviewed.

5. Does the Circular change import duty?

The Circular governs quality management. Import duty, VAT and FTA preferences must be checked separately by final HS code and C/O file.

6. When should documents be prepared?

Preferably before ETA, once catalogue/datasheet and model information are available.

TGIMEX OPERATIONAL SUPPORT

Legal screening: Review the original text, appendices, effective date, technical regulations and compliance triggers by product model.

Document control: Compare Invoice, Packing List, B/L/AWB, PO/contract, catalogue, datasheet, labels, C/O, test reports and specialized files.

Operational coordination: Build a pre-ETA timeline, identify risk checkpoints, coordinate customs declaration, specialized procedures, international transport, trucking, port/warehouse handling and incident response.

Post-clearance readiness: Organize shipment records, supplementary labels, certificates/declarations, test reports and audit data for post-clearance review or market circulation.

Need to apply this regulation to a specific shipment? TGIMEX can review validity, scope, documents and pre-ETA execution milestones.

Discuss an implementation plan

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