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.

Issued: 14/11/2025Effective: 01/01/2026Category: MOIT
Legal noteThis 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.

QUICK SUMMARY

Review point Operational 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 milestones Effective from 1 January 2026; several products move from voluntary to mandatory labeling from 1 January 2027.
Products to review Household 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 actions Review HS codes, models, catalogues/datasheets, energy efficiency standards, labeling dossiers, product labels and market circulation plans.

DOCUMENT INFORMATION

Field Content
Document title Circular providing the list of equipment and appliances subject to energy labeling under MOIT management and the roadmap for implementation
Number 52/2025/TT-BCT
Issuing authority Ministry of Industry and Trade
Date of issuance 14 November 2025
Effective date 1 January 2026
Status In force according to the official Government Portal and MOIT information at the time of review.
Signer Deputy Minister Nguyen Hoang Long
Scope List of equipment and appliances subject to energy labeling and the implementation roadmap.
Affected businesses Manufacturers, 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 group Affected stage Documents to check
Importers / trading companies Before import, customs declaration, market circulation Check 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 owners Before placing products on the market Control energy labels, Vietnamese labels, technical documents and retained compliance files for market surveillance.
Factories, EPE/FDI, projects Procurement and import of project/production equipment Review exclusions such as defense/security, temporary import for re-export, transit, diplomatic goods, repair/replacement or energy efficiency testing equipment.
Logistics providers / Docs / Compliance Before ETA and customs declaration Cross-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

Group Name/number Issuing authority Timing Role Review note
Law Law No. 50/2010/QH12 on Economical and Efficient Use of Energy National Assembly Issued 17 Jun 2010; effective 1 Jan 2011 Foundational legal basis for energy efficiency policy and obligations of manufacturers/importers of energy-using equipment. Use the consolidated version when applying.
Amending law Law No. 77/2025/QH15 amending the Law on Economical and Efficient Use of Energy National Assembly Issued 18 Jun 2025; effective 1 Jan 2026 Directly cited legal basis of Circular 52/2025/TT-BCT. Review amended provisions for internal compliance policies.
Decree Decree 40/2025/ND-CP Government Issued 26 Feb 2025; effective 1 Mar 2025 Defines MOIT functions, powers and structure; basis for MOIT authority. Review when identifying the competent sectoral authority.
Circular Circular 36/2016/TT-BCT MOIT Issued 28 Dec 2016; effective 10 Feb 2017 Provides procedures for registration, implementation and withdrawal of energy labels. Review partial validity and the consolidated text before applying.
Consolidated text Consolidated Document 23/VBHN-BCT (2020) MOIT Issued 24 Mar 2020 Consolidates rules on energy labeling under Circular 36/2016/TT-BCT and amendments. Useful for procedure review; still compare with original texts.
Decision Decision 04/2017/QD-TTg Prime Minister Issued 9 Mar 2017; effective 25 Apr 2017 Provides lists and roadmaps for energy labeling and minimum energy performance. Review interaction with Circular 52/2025/TT-BCT by product group.
Decision Decision 14/2023/QD-TTg Prime Minister Issued 24 May 2023; effective 15 Jul 2023 Provides 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.
Standards TCVN/QCVN by product group Competent authorities Product-specific Basis 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 group Required documents Used for Typical owner Common error Pre-ETA check
Commercial documents Commercial Invoice, Packing List, B/L/AWB, Sales Contract/PO, C/O if preferential duty is claimed Customs declaration and goods matching Sales/Docs/Importer Product name or model does not match catalogue/label Lock product name, model, quantity and origin before ETA.
Technical documents Catalogue, datasheet, manual, original label image, model/serial list Scope and milestone determination Procurement/Technical/Compliance Generic product names cause wrong policy determination Separate function, capacity, product type and import purpose.
Energy labeling dossier Test report, energy labeling declaration, label artwork, applicable standard Market circulation and inspection Compliance/Importer/Brand owner Preparing only after goods arrive delays market release Review from RFQ/PO stage or before ETA.
Product labeling Original label, Vietnamese supplementary label, energy label if applicable Market circulation and surveillance Importer/Distributor Missing mandatory data or mismatched energy label Compare label with test report, catalogue, invoice and actual goods.
Legal review Laws, decrees, circulars, decisions, TCVN/QCVN Determine obligations and timing Legal/Compliance/Operation Confusing energy labeling with minimum energy performance requirements Build 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 area Operational approach Business value
Product scope review under Circular 52/2025/TT-BCT Cross-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 review Compare 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 standardization Review 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 setup Create 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 retention Organize 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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