A child car seat should not be declared only as a “plastic chair” or “car accessory”. Once QCVN 123:2024/BGTVT applies to child restraint systems used in motor vehicles, importers should review HS classification, conformity certification, conformity declaration, product labeling, C/O and technical documentation before ETA to reduce storage, demurrage, document supplementation and market-release risks. 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.

QUICK SUMMARY

TERMINOLOGY AND WHY THIS PROCEDURE MATTERS

CRS – Child Restraint System

A system designed to restrain children in vehicles, including child seats, infant carriers, booster seats and related anchorage parts.

ISOFIX

A standardized anchorage system connecting the child seat to the vehicle body. ISOFIX bases, top tether and support legs should be checked against the manual and test documentation.

Conformity certification / declaration

Conformity certification and declaration are quality-control documents required when a product is subject to a Vietnamese technical regulation.

ETA

Estimated Time of Arrival. For products subject to conformity assessment, technical and compliance files should be reviewed before ETA.

SCOPE OF APPLICATION

This article applies to importers of child car seats, infant carriers, booster seats and child restraint systems used in motor vehicles for trading, distribution, e-commerce, automotive dealers, fleets or project supply.

Goods situation	Application scope	Separate review points
Complete child safety seat	Applies when the product is designed to be installed in a motor vehicle to restrain a child.	Review test standard, weight/height group, installation direction, ISOFIX/seat belt installation and warning labels.
Infant carrier	Applies if the product can be installed in a vehicle as a child restraint.	Review rear-facing use, handle, detachable base, age/weight group and test documents.
Booster seat / cushion	Applies when the product positions the child so the vehicle seat belt fits properly.	Review child height range, user manual, warnings and whether the booster has a backrest.
ISOFIX base, tether, spare part	May require different treatment if imported separately.	Review part HS code, compatibility with the main seat and market-release documentation.
High chair / indoor child seat	Not automatically covered if the product is not for motor-vehicle use.	Review as furniture/household goods rather than QCVN 123 if outside the technical-regulation scope.

PRODUCT IDENTIFICATION AND CLASSIFICATION

The product should be identified by catalogue, datasheet, user manual, model, label photos, restraint mechanism, anchorage type, material, weight/height group and testing standard, rather than by trade name only.

Product group / situation	Technical points to check	Example	Evidence	Possible policy	Files to compare	Application note
Seat-belt-installed CRS	Harness, buckle, belt path, installation direction.	Convertible car seat.	Catalogue, manual, test report, label photos.	QCVN 123, conformity certification/declaration, product labeling.	Invoice, packing list, B/L/AWB, C/O, labels, certificate.	Description should clearly state child restraint system for motor vehicles.
ISOFIX or i-Size seat	ISOFIX connector, top tether, support leg, detachable base.	ISOFIX child seat, i-Size seat.	Datasheet, manual, ISOFIX images, test report.	QCVN 123 and applicable UN R44/R129 documentation.	Model list, serial/lot, certificate, installation manual.	A base imported separately may not follow the same HS as a complete seat.
Booster seat	Raises the child so the vehicle seat belt is positioned correctly.	High-back booster, backless booster.	Catalogue, label, manual.	QCVN 123 if within scope.	Warning label, user manual, technical file.	Some products look like cushions but function as safety devices.
Smart child seat	Sensor, Bluetooth, app, electronics or lithium battery.	Seat with anti-left-behind warning.	Electronics datasheet, battery MSDS, RF specifications.	Additional battery/RF/electrical policies may be triggered.	MSDS, UN38.3, RF specs, labels.	Do not limit the review to QCVN 123 only.
Samples for testing	Small quantity and non-commercial purpose.	Sample for certification/testing.	PO, purpose letter, product images.	May still require market-release compliance later.	Sample invoice and test plan.	Separate import purpose from commercial sale.

HS CODE, DUTIES AND C/O REVIEW

The following HS codes are for operational reference. Final classification must be determined based on the actual product, material, function, import condition, technical documents and customs position at the time of declaration.

Reference HS code	Suitable description	Classification basis	Condition of use	Normal import duty	MFN duty	VAT	FTA/C/O to review	Documents to compare
9401.80.00	Other seats; commonly reviewed for removable child safety seats and boosters.	Heading 94.01 for seats and parts thereof.	The item is a removable seat/restraint, not a fixed vehicle seat or spare part only.	Reference 37.5% where normal rate is calculated at 150% of MFN.	Reference 25%.	Usually reviewed at 8%/10% depending on VAT policy at the import date.	ACFTA/RCEP for China; ATIGA for ASEAN; EVFTA/UKVFTA/CPTPP/RCEP depending on origin.	Catalogue, photos, structure, material, manual, C/O, invoice.
9401.20.00	Seats of a kind used for motor vehicles.	Motor-vehicle seat category.	Review only if product nature indicates a vehicle seat rather than a removable child restraint.	Check current tariff.	Check current tariff.	Current VAT policy.	Review by origin.	Technical file and installation photos.
9401.90	Parts of seats, possibly for separate bases or spare parts.	Parts of heading 94.01.	Do not use for complete child restraint systems.	Check current tariff.	Check current tariff.	Current VAT policy.	Review by origin.	Detailed packing list, part drawings and compatibility file.

HS warning: declaring the product as a general car accessory under Chapter 87 may trigger classification queries if the product is actually a removable child safety seat. Prepare product photos, catalogue and explanatory notes before importing large volumes.

C/O AND FTA REVIEW BY IMPORT ROUTE

Origin route	FTA	C/O or origin document	Preferential rate	Conditions	Documents	Application note
China	ACFTA or RCEP	Form E or RCEP origin document	Check by final HS and annual tariff schedule.	Origin rule, direct transport and consistent goods description.	C/O, invoice, packing list, transport document.	Descriptions should align with declaration and invoice.
ASEAN	ATIGA or RCEP	Form D or RCEP document	Check by final HS.	Origin rule and direct transport.	C/O, invoice, packing list, B/L.	Review third-party invoicing if any.
EU / UK	EVFTA / UKVFTA	EUR.1 or permitted origin statement	Check by final HS.	Compliance with agreement-specific origin requirements.	Origin proof, invoice, transport document.	Review exporter eligibility and value threshold.
Japan / Korea	VJEPA, AJCEP, VKFTA, AKFTA, RCEP	Agreement-specific C/O	Check by final HS.	Origin rule and transport requirements.	C/O, invoice, packing list.	Choose the correct FTA rather than assuming one form works for all.

DOCUMENT SET AND SUBMISSION CONTROL

Document group	Required documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial documents	Commercial invoice, packing list, contract/PO, B/L or AWB, C/O if claiming preference.	Customs declaration, duty calculation and C/O review.	Supplier, importer, forwarder, documentation team.	Generic description; missing model; unclear quantity of seat/base/accessories.	Match goods name, model, quantity, value and origin across all files.
Technical documents	Catalogue, datasheet, user manual, label photos, model list, material, height/weight group.	HS classification and QCVN review.	Supplier, brand owner, importer.	No proof of motor-vehicle use or testing standard.	Request manual and label photos before pickup.
Conformity files	Test report, certificate of conformity, conformity declaration file.	Market release and quality compliance.	Importer, conformity body, compliance team.	Foreign test report does not match model; certificate scope is unclear.	Check certification body, scope, model/lot/serial.
Labeling documents	Original label, Vietnamese supplementary label, safety warnings and user instructions.	Market circulation and post-clearance review.	Importer, brand owner, distributor.	Missing Vietnamese content or local responsible party.	Prepare label draft before distribution.
Logistics documents	Booking, trucking plan, cargo photos, carton codes and warehouse data.	Shipment control and delivery.	Forwarder, warehouse, supplier.	Base/accessory cartons are missing or mixed.	Request carton photos and model/PO marks before export.

LEGAL BASIS AND POLICY MATRIX

Document group	Legal document	Authority	Effective / application date	Role	Key point	Review note
Law	Road Traffic Order and Safety Law 2024	National Assembly	Effective from 01/01/2025 with child-safety rule following the statutory date.	Creates demand for suitable child safety devices in cars.	Article 10 on children under 10 and under 1.35 m.	Relevant to market demand; not a customs document by itself.
Technical regulation	Circular 48/2024/TT-BGTVT and QCVN 123:2024/BGTVT	Ministry of Transport	Circular effective 01/01/2025; QCVN 123 effective 01/01/2026.	Core technical regulation for child safety devices.	QCVN 123 on inspection and conformity certification.	Main basis for import compliance and market release.
Guidance	MOC guidance on QCVN 123 conformity assessment	Ministry of Construction	2026 update.	Guides certification, declaration and conformity-assessment bodies.	Transition before and after 01/7/2026.	Monitor designated/recognized conformity bodies.
Quality law	Law on Product and Goods Quality and Law 78/2025/QH15	National Assembly	According to respective effective dates.	General quality-management framework.	Risk-based product management and conformity obligations.	Review according to product risk list at application date.
Labeling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	According to current validity.	Product labels and Vietnamese supplementary labels.	Product name, origin, responsible entity, warnings and instructions.	Important for child safety products.
VAT	Resolution 204/2025/QH15 and Decree 174/2025/ND-CP	National Assembly / Government	From 01/7/2025 to 31/12/2026.	VAT rate review.	Check reduction scope and exclusion appendices.	Confirm at import declaration date.

POLICY MATRIX BY PRODUCT SITUATION

Goods situation	Legal basis	Possible policy	Authority / processing channel	Trigger condition
Complete CRS for commercial sale	QCVN 123, MOC guidance, quality laws.	Conformity certification, conformity declaration and labeling.	Local competent body, conformity assessment body, Vietnam Register where applicable.	Product is a child safety device for motor vehicles.
ISOFIX / i-Size / UN R129 product	QCVN 123 and technical files.	Model-specific testing and certification review.	Qualified testing/certification body.	Catalogue/manual indicates ISOFIX or i-Size/R129.
Electronic or battery-equipped seat	QCVN 123 plus battery/RF/electrical rules if applicable.	Additional battery or radio/electrical documentation may be required.	Relevant sectoral authority.	Product includes sensor, Bluetooth, battery or charger.
Separate base or spare part	HS parts rules, labeling and QCVN if safety-related.	May require separate HS and technical explanation.	Customs and quality authority if marketed.	Base, tether, buckle or spare part imported separately.
Testing samples	Customs rules and QCVN testing purpose.	Sample handling and later market-release compliance.	Customs and testing body.	Small quantity imported for testing/certification.

TIMELINE, FEES AND RISK COSTS

Step	Recommended timing	Time / cost to budget	Risk if delayed
HS, policy and labeling review	Before order confirmation or before supplier pickup.	Depends on documentation completeness.	Wrong duty estimation, unclear declaration name, insufficient explanation.
Conformity preparation	Before ETA and before market release.	Testing/certification costs depend on model range and body.	Goods may not be ready for market release.
Customs declaration	When commercial and transport files are complete.	Import duty, VAT and logistics charges.	Customs channel change, HS query, DEM/DET/storage.
Supplementary label and file retention	Before distribution.	Label printing, relabeling and warehousing costs.	Market surveillance or post-clearance explanation risk.

END-TO-END IMPORT PROCESS

Pre-order product review: identify whether the goods are CRS, booster or separate parts; request catalogue, manual, labels and test report.
Lock reference HS and tax treatment: compare function, structure, material and supporting files; prepare explanation for 9401.80.00/9401.20.00/parts if needed.
Review QCVN 123 compliance: check model, test standard, conformity body and declaration route.
Lock documents before ETA: ensure invoice, packing list, transport document, C/O, catalogue and labels use consistent names, models, quantities and origin.
Customs declaration: prepare clear goods description, product photos, catalogue and technical file; respond to green/yellow/red channel requirements.
Post-clearance and market release: complete Vietnamese labels, conformity files and shipment records for post-clearance or market surveillance.

OUTPUTS AND POST-CLEARANCE OBLIGATIONS

Customs output

Cleared import declaration, tax documents and retained commercial/transport files.

Quality output

Conformity certificate, declaration file or applicable conformity-assessment documents under QCVN 123.

Labeling

Vietnamese supplementary label, user instructions, safety warnings and responsible party in Vietnam.

Audit file

Catalogue, test report, certificate, declaration, C/O, invoice, packing list, customs declaration and label photos.

FAQ

1. Is conformity required?

If the product is a child safety device used in a motor vehicle, QCVN 123 should be reviewed and conformity documentation should be prepared before market release.

2. Can a foreign UN R44/R129 certificate be used directly?

It is useful technical evidence, but the importer still needs to compare it with QCVN 123, the model scope and Vietnam’s conformity procedures.

3. Is 9401.80.00 always correct?

No. It is a reference code for removable child safety seats. Separate bases, parts or special configurations may require another classification review.

4. Does ISOFIX change the policy?

ISOFIX increases the technical review requirement because anchorage, installation method and test standard must match the model.

5. Are samples exempt?

Samples should be declared with a clear purpose. If later sold or released to the market, quality and labeling obligations still need to be completed.

6. Is Vietnamese labeling required?

Imported products circulated in Vietnam must be reviewed under product-labeling rules, especially warnings and installation instructions.

7. Can China-origin products enjoy preferential duty?

Possibly, under ACFTA or RCEP if origin documents are valid and the goods meet origin rules. The rate must be checked by final HS code.

8. When should documents be prepared?

At the ordering stage and before ETA, especially HS, C/O, catalogue, test report, labels and conformity route.

ORIGINAL LEGAL SOURCES AND LOOKUP LINKS

Circular 48/2024/TT-BGTVT on the national legal database MOC guidance on QCVN 123 QCVN 123:2024/BGTVT – VSQI Road Traffic Order and Safety Law – MPS Vietnam Customs tariff lookup Decree 174/2025/ND-CP on VAT reduction

Priority sources include the national legal database, the Ministry of Construction, the Ministry of Public Security, VSQI and Vietnam Customs. Importers should reconfirm the position at the declaration date because conformity assessment capacity, sectoral rules and tariff treatment may change.

OPERATIONAL SUPPORT FROM TGIMEX

For child safety seats, importers should control compliance before ETA rather than waiting until cargo arrival. The priority is to reduce HS, test report, conformity, labeling, C/O and market-release risks.

Legal and policy review

Review QCVN 123, product scope, model, import purpose, sample/commercial status, labeling rules and product-quality obligations.

Document control

Cross-check invoice, packing list, B/L/AWB, C/O, catalogue, manual, test report, labels, model list and technical files.

Logistics coordination

Set a pre-ETA timeline, identify risk blockers and coordinate supplier, forwarder, customs, port/warehouse and domestic delivery.

Post-clearance file retention

Maintain declaration, C/O, conformity, label and technical records for audit, market surveillance and distributor control.

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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