Circular 52/2025/TT-BCT: Equipment Subject to Energy Labeling and Implementation Roadmap

Legal document • Ministry of Industry and Trade

CIRCULAR 52/2025/TT-BCT: ENERGY LABELING EQUIPMENT LIST AND OPERATIONAL NOTES FOR IMPORTERS

Misclassifying equipment, missing the applicable energy labeling milestone, or preparing technical dossiers too late may delay market circulation, create warehousing cost, and increase post-clearance compliance risk. This article summarizes Circular 52/2025/TT-BCT from a B2B logistics and compliance perspective. 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.

Issued: 14/11/2025Effective: 01/01/2026Category: MOIT

QUICK SUMMARY

Review pointOperational note
What does this Circular regulate?It sets out the list of products under MOIT management subject to energy labeling and distinguishes mandatory and voluntary milestones.
Effective / transition milestonesEffective from 1 January 2026; several products move from voluntary to mandatory labeling from 1 January 2027.
Products to reviewHousehold appliances, office/commercial equipment and industrial equipment, including air conditioners, refrigerators, washing machines, laptops, desktop computers, distribution transformers, electric motors and LED street lighting.
Immediate actionsReview HS codes, models, catalogues/datasheets, energy efficiency standards, labeling dossiers, product labels and market circulation plans.
Illustration for Circular 52/2025/TT-BCT: Equipment Subject to Energy Labeling and Implementation Roadmap
Illustration of the legal document and affected subjects in import-export operations.
Legal note This English version is an operational reference translation only and is not an official legal translation. For application, businesses should check the Vietnamese original and product-specific dossiers.

DOCUMENT INFORMATION

FieldContent
Document titleCircular providing the list of equipment and appliances subject to energy labeling under MOIT management and the roadmap for implementation
Number52/2025/TT-BCT
Issuing authorityMinistry of Industry and Trade
Date of issuance14 November 2025
Effective date1 January 2026
StatusIn force according to the official Government Portal and MOIT information at the time of review.
SignerDeputy Minister Nguyen Hoang Long
ScopeList of equipment and appliances subject to energy labeling and the implementation roadmap.
Affected businessesManufacturers, importers, distributors and traders of listed household, office/commercial and industrial equipment.

KEY POINTS TO NOTE

1. Scope

The Circular applies to manufacturers, importers, distributors and traders of products listed for energy labeling under MOIT management.

2. Product groups

The list is divided into three groups: household appliances, office/commercial equipment and industrial equipment. Review by product name, function, model, capacity and testing standard.

3. Roadmap

Some products are voluntary until 31 December 2026 and mandatory from 1 January 2027, notably induction cookers, infrared cookers, microwave ovens, LED road/street lighting and desktop computers.

  • Article 1 excludes certain defense/security, temporary import for re-export, transit/transshipment, diplomatic/consular and repair/replacement/testing cases.
  • Article 2 requires businesses to identify whether the product is household, office/commercial or industrial equipment.
  • Article 3 distinguishes mandatory energy labeling from voluntary energy labeling and transition dates.
  • Article 4 identifies MOIT’s Agency for Innovation, Green Transition and Industry Promotion as the guidance, inspection and supervision authority.

AFFECTED BUSINESSES / PRODUCT GROUPS

Business groupAffected stageDocuments to check
Importers / trading companiesBefore import, customs declaration, market circulationCheck whether the model falls within Article 2 and the relevant mandatory milestone under Article 3; prepare technical and energy labeling dossiers where applicable.
Distributors / brand ownersBefore placing products on the marketControl energy labels, Vietnamese labels, technical documents and retained compliance files for market surveillance.
Factories, EPE/FDI, projectsProcurement and import of project/production equipmentReview exclusions such as defense/security, temporary import for re-export, transit, diplomatic goods, repair/replacement or energy efficiency testing equipment.
Logistics providers / Docs / ComplianceBefore ETA and customs declarationCross-check product name, HS code, model, capacity, function, invoice, packing list, B/L/AWB, catalogue and specialized dossiers.

IMPACT ON IMPORT / LOGISTICS OPERATIONS

  • Goods classification: avoid generic descriptions; include model, function and relevant capacity where these support policy review.
  • Technical dossiers: catalogue, datasheet, test report, label artwork and energy performance data should align with commercial documents.
  • Timeline: delayed testing or labeling preparation may affect post-import sales, warehousing and project handover.
  • Compliance: keep dossier files by shipment/model for market surveillance and post-clearance explanation.

RELATED LEGAL DOCUMENTS TO REVIEW

GroupName/numberIssuing authorityTimingRoleReview note
LawLaw No. 50/2010/QH12 on Economical and Efficient Use of EnergyNational AssemblyIssued 17 Jun 2010; effective 1 Jan 2011Foundational legal basis for energy efficiency policy and obligations of manufacturers/importers of energy-using equipment.Use the consolidated version when applying.
Amending lawLaw No. 77/2025/QH15 amending the Law on Economical and Efficient Use of EnergyNational AssemblyIssued 18 Jun 2025; effective 1 Jan 2026Directly cited legal basis of Circular 52/2025/TT-BCT.Review amended provisions for internal compliance policies.
DecreeDecree 40/2025/ND-CPGovernmentIssued 26 Feb 2025; effective 1 Mar 2025Defines MOIT functions, powers and structure; basis for MOIT authority.Review when identifying the competent sectoral authority.
CircularCircular 36/2016/TT-BCTMOITIssued 28 Dec 2016; effective 10 Feb 2017Provides procedures for registration, implementation and withdrawal of energy labels.Review partial validity and the consolidated text before applying.
Consolidated textConsolidated Document 23/VBHN-BCT (2020)MOITIssued 24 Mar 2020Consolidates rules on energy labeling under Circular 36/2016/TT-BCT and amendments.Useful for procedure review; still compare with original texts.
DecisionDecision 04/2017/QD-TTgPrime MinisterIssued 9 Mar 2017; effective 25 Apr 2017Provides lists and roadmaps for energy labeling and minimum energy performance.Review interaction with Circular 52/2025/TT-BCT by product group.
DecisionDecision 14/2023/QD-TTgPrime MinisterIssued 24 May 2023; effective 15 Jul 2023Provides lists and roadmap for removal of low-efficiency energy-using equipment and generation units.Not identical to labeling obligations; review for MEPS-related import risk.
StandardsTCVN/QCVN by product groupCompetent authoritiesProduct-specificBasis for testing and energy efficiency parameters.Do not generalize; review by catalogue, model and capacity.

VIEW / DOWNLOAD ORIGINAL DOCUMENT

Use the official Government Portal and MOIT website as primary sources before applying the Circular to a shipment.

DOCUMENT CHECKLIST

Document groupRequired documentsUsed forTypical ownerCommon errorPre-ETA check
Commercial documentsCommercial Invoice, Packing List, B/L/AWB, Sales Contract/PO, C/O if preferential duty is claimedCustoms declaration and goods matchingSales/Docs/ImporterProduct name or model does not match catalogue/labelLock product name, model, quantity and origin before ETA.
Technical documentsCatalogue, datasheet, manual, original label image, model/serial listScope and milestone determinationProcurement/Technical/ComplianceGeneric product names cause wrong policy determinationSeparate function, capacity, product type and import purpose.
Energy labeling dossierTest report, energy labeling declaration, label artwork, applicable standardMarket circulation and inspectionCompliance/Importer/Brand ownerPreparing only after goods arrive delays market releaseReview from RFQ/PO stage or before ETA.
Product labelingOriginal label, Vietnamese supplementary label, energy label if applicableMarket circulation and surveillanceImporter/DistributorMissing mandatory data or mismatched energy labelCompare label with test report, catalogue, invoice and actual goods.
Legal reviewLaws, decrees, circulars, decisions, TCVN/QCVNDetermine obligations and timingLegal/Compliance/OperationConfusing energy labeling with minimum energy performance requirementsBuild a matrix by SKU/model, not one conclusion for all products.

TERMINOLOGY NOTES

  • Energy labeling: displaying regulated energy consumption or efficiency information on products.
  • Minimum energy performance: a threshold requirement that may apply under other regulations; it is not identical to energy labeling.
  • Test report: a report issued by a competent testing body, used to substantiate energy performance data.
  • ETA: Estimated Time of Arrival.

FULL TEXT

View English reference translation of Circular 52/2025/TT-BCT
MINISTRY OF INDUSTRY AND TRADE
——-
SOCIALIST REPUBLIC OF VIETNAM
Independence – Freedom – Happiness
—————

No.: 52/2025/TT-BCT
Hanoi, November 14, 2025

CIRCULAR

PROVIDING THE LIST OF EQUIPMENT AND APPLIANCES SUBJECT TO ENERGY LABELING UNDER THE MANAGEMENT OF THE MINISTRY OF INDUSTRY AND TRADE AND THE ROADMAP FOR IMPLEMENTATION

This English version is a full operational reference translation prepared from the Vietnamese text for business review purposes only; it is not an official legal translation.

Pursuant to the Law on Economical and Efficient Use of Energy dated June 17, 2010; and Law No. 77/2025/QH15 dated June 18, 2025 amending and supplementing a number of articles of the Law on Economical and Efficient Use of Energy;

Pursuant to Decree No. 40/2025/ND-CP dated February 26, 2025 of the Government defining the functions, tasks, powers and organizational structure of the Ministry of Industry and Trade;

At the proposal of the Director General of the Agency for Innovation, Green Transition and Industry Promotion;

The Minister of Industry and Trade hereby promulgates this Circular providing the list of equipment and appliances subject to energy labeling under the management of the Ministry of Industry and Trade and the roadmap for implementation.

Article 1. Scope and regulated entities

1. This Circular provides the list of equipment and appliances subject to energy labeling under the management of the Ministry of Industry and Trade and the roadmap for implementation.

2. This Circular applies to organizations and individuals engaged in the manufacture, import, distribution and trading of products included in the list of equipment and appliances subject to energy labeling under the management of the Ministry of Industry and Trade.

3. This Circular does not apply to organizations and individuals engaged in the manufacture, import, distribution and trading of the following products:

a) Equipment and appliances manufactured, assembled or imported for direct use for national defense and security purposes, or imported under separate regulations of the Prime Minister;

b) Equipment and appliances temporarily imported for re-export; in transit; transshipped; diplomatic and consular goods;

c) Equipment and appliances used for repair, replacement or testing of energy efficiency levels.

Article 2. List of equipment and appliances subject to energy labeling

The list of equipment and appliances subject to energy labeling is divided into the following groups:

1. Household equipment, including: linear fluorescent lamps, compact fluorescent lamps, electromagnetic and electronic ballasts for fluorescent lamps, air conditioners, refrigerators, household washing machines, rice cookers, electric fans, television sets, LED lamps, storage water heaters, induction cookers, infrared cookers and microwave ovens;

2. Office and commercial equipment, including: photocopiers, printers, computer monitors, laptop computers, desktop computers, commercial refrigerated cabinets and commercial air conditioners;

3. Industrial equipment, including: distribution transformers, electric motors, and LED luminaires for road and street lighting.

Article 3. Roadmap for energy labeling implementation

1. For household equipment and industrial equipment:

a) Mandatory energy labeling shall apply to the following household equipment and industrial equipment: linear fluorescent lamps, compact fluorescent lamps, electromagnetic and electronic ballasts for fluorescent lamps, air conditioners, refrigerators, household washing machines, rice cookers, electric fans, television sets, LED lamps, storage water heaters, distribution transformers and electric motors;

b) Voluntary energy labeling shall apply until the end of December 31, 2026 to: induction cookers, infrared cookers, microwave ovens, and LED luminaires for road and street lighting;

c) Mandatory energy labeling shall apply from January 1, 2027 to: induction cookers, infrared cookers, microwave ovens, and LED luminaires for road and street lighting.

2. For office and commercial equipment:

a) Mandatory energy labeling shall apply to laptop computers and commercial refrigerated cabinets;

b) Voluntary energy labeling shall apply to: photocopiers, computer monitors, printers and commercial air conditioners;

c) Voluntary energy labeling shall apply until the end of December 31, 2026 to desktop computers;

d) Mandatory energy labeling shall apply from January 1, 2027 to desktop computers.

3. Voluntary energy labeling is encouraged for equipment and appliances not included in the list prescribed in Article 2 of this Circular where national standards on energy efficiency levels are available and domestic testing capability exists.

Article 4. Implementation organization

1. The Agency for Innovation, Green Transition and Industry Promotion under the Ministry of Industry and Trade shall guide, inspect and supervise energy labeling for the groups of equipment and appliances subject to energy labeling prescribed in Article 3 of this Circular.

2. Provincial-level People’s Committees shall direct relevant specialized agencies to inspect and supervise the implementation of energy labeling for equipment and appliances in their localities according to the list and roadmap prescribed in this Circular.

Article 5. Effect and implementation responsibility

1. This Circular takes effect from January 1, 2026.

2. During implementation, if any difficulties or issues arise, agencies, organizations and individuals shall promptly report them to the Ministry of Industry and Trade for study, amendment and supplementation of this Circular.

Recipients:

– Office of the General Secretary;
– Office of the President;
– Office of the National Assembly;
– Government Office;
– The Prime Minister and Deputy Prime Ministers;
– Committees of the National Assembly;
– Ministries, ministerial-level agencies and Government-attached agencies;
– Supreme People’s Procuracy;
– Supreme People’s Court;
– State Audit Office of Vietnam;
– Office of the Party Central Committee and Party Commissions;
– Central Committee of the Vietnam Fatherland Front;
– Vietnam Chamber of Commerce and Industry;
– People’s Councils and People’s Committees of provinces and centrally run cities;
– Department of Examination of Legal Documents and Management of Administrative Violation Handling – Ministry of Justice;
– Leaders of the Ministry of Industry and Trade;
– Units under the Ministry of Industry and Trade;
– Departments of Industry and Trade of provinces and centrally run cities;
– Government Portal;
– Portal of the Ministry of Industry and Trade;
– Official Gazette;
– Archives: VT, DCK.

FOR THE MINISTER
DEPUTY MINISTER

Nguyen Hoang Long

FAQ

1. When does Circular 52/2025/TT-BCT take effect?

It takes effect from 1 January 2026.

2. Does energy labeling have to be completed at customs clearance?

Do not assume this based only on product name. Review customs requirements, energy efficiency standards, labeling procedure and market circulation obligations by model.

3. Which products become mandatory from 1 January 2027?

Induction cookers, infrared cookers, microwave ovens, LED road/street lighting and desktop computers move to mandatory energy labeling from 1 January 2027.

4. Should HS codes be reviewed?

Yes. HS codes are not the only basis, but they are important for customs policy, duty, specialized controls and declaration consistency.

5. What if the model also has wireless, encryption, batteries or adapters?

Additional specialized policies may apply. Review radio, cybersecurity, battery, adapter and safety-related regulations separately.

6. What should be done when product scope is unclear?

Prepare a matrix by catalogue, datasheet, model, capacity, purpose of import and testing standard; check official sources before booking or market launch.

SOLUTIONS FROM TGIMEX

For products subject to energy labeling, TGIMEX approaches the shipment not merely as a transport movement, but as a coordinated control of technical dossiers, commercial documents, legal milestones and post-import market circulation. Businesses should review these checkpoints before booking confirmation or before ETA to avoid goods arriving while the labeling basis, model consistency or post-clearance files are still incomplete.

Support areaOperational approachBusiness value
Product scope review under Circular 52/2025/TT-BCTCross-check product name, function, model, capacity/power and catalogue against Article 2; separate household, office/commercial and industrial equipment.Reduces the risk of incorrectly determining whether a model is subject to energy labeling, especially where commercial names are similar.
Implementation roadmap reviewCompare mandatory/voluntary milestones under Article 3; pay attention to products moving to mandatory labeling from 1 January 2027, including induction cookers, infrared cookers, microwave ovens, LED road/street lighting and desktop computers.Helps procurement, sales and logistics teams plan import, warehousing and market release by effective milestone.
Pre-ETA document standardizationReview invoice, packing list, B/L or AWB, C/O if any, catalogue, datasheet, original label images, model/serial list and test dossiers where applicable.Limits mismatched product names, model discrepancies, missing technical parameters and late requests for supplementary evidence.
Compliance checkpoint setupCreate checklists before export departure, before ETA and before market release; assign responsibility among Procurement, Docs, Operation, Compliance and warehouse teams.Reduces storage risk, project delivery delay, sales delay and extra costs caused by late dossier handling.
Model/SKU-based record retentionOrganize files by model/SKU: commercial documents, technical documents, labels, test reports, applicable legal texts and review results.Supports market inspection, post-clearance review, internal reconciliation and future repeat imports.

Operational recommendation: before finalizing an import plan, businesses should provide product name, model, catalogue/datasheet, power or capacity, import purpose, country of origin and market circulation plan for scope review. Products with Wi-Fi/Bluetooth, batteries, adapters, chargers or special functions should also be reviewed for other sectoral policies beyond energy labeling.

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