B11 and E62 may both accompany a sales contract, so the invoice or the fact that the exporter manufactures goods does not determine the procedure code. The key question is whether the output falls within the current export-manufacturing management scope. E62 is not limited to E31 or duty-exempt inputs: current Article 70 also covers products manufactured entirely from business-imported materials and products combining several input sources. Therefore, duty-paid A12 materials do not automatically make B11 correct. This article applies a decision matrix based on goods status, material origin, production evidence, import codes, tax treatment and the exclusion of other specialized procedures.

QUICK SUMMARY

B11 is a business export

Use it within the official B11 scope after excluding a more specific procedure code that better reflects the goods.

E62 is export-manufacturing output

It covers products made from all or part of imported materials, including certain business-imported inputs under current Article 70.

Duty-paid A12 does not automatically mean B11

Products made entirely from business-imported materials remain within the current export-manufacturing management scope.

Domestic-only output may point to B11

Where the product uses only domestic inputs and no other specialized regime applies, B11 is generally the direction to review.

The export code does not create tax relief

Exemption or refund depends on statutory conditions and evidence, not on E62 alone.

Illustration for Business export vs. export of export-manufacturing products: what is the difference? — Illustration of the logistics topic, document or operation discussed in the article.

SCOPE

This article applies mainly to Vietnamese domestic enterprises exporting abroad, to non-tariff zones, export-processing enterprises or under qualifying on-the-spot arrangements. It compares B11 and E62 only and does not replace the rules for processing exports E52, EPE products E42, re-export of imported goods B13 or temporary export procedures.

Note: The accurate Vietnamese term is “export of products manufactured for export” (E62), often shortened operationally to export manufacturing.

TERMS

Term	Operational meaning	Control point
B11 – Business export	Export procedure code used in the business-export cases stated in Decision 1357/QD-TCHQ.	Exclude E62, E52, E42, B13 and other specific codes before selecting B11.
E62 – Export-manufacturing product	Export code for products made from all or part of imported materials. Current Article 70 also includes products made entirely from business-imported materials.	Reconcile import declarations, source warehouses, production records, actual norms and outbound data.
Products managed as export manufacturing	Current Article 70 covers products from export-manufacturing inputs; mixed processing/export-manufacturing, business-imported and domestic inputs; and products entirely from business-imported inputs.	Duty exemption or payment status is not the sole classification test.
Business-imported materials	Materials imported under an appropriate business/production import procedure and taxed under that import regime.	When used to manufacture exports, review Article 70 and the separate refund rules.
Actual consumption norm	Actual quantity consumed per unit of output, including justified loss.	Key evidence for materials–output and finalization reconciliation.
Customs finalization	Providing or reporting imported-material and exported-product data under current Article 60.	Imported materials must be tracked by import procedure, including business import.

THE CORE DIFFERENCE: A COMMERCIAL EXPORT OR AN IMPORTED-MATERIAL MANAGEMENT CHAIN?

B11 records business exports within the official code table. Common cases include domestically purchased goods exported unchanged or products made wholly from domestic inputs, provided no processing, export-manufacturing, EPE, re-export or other specific code applies. In-house production does not exclude B11, but material tracing must come first.

E62 records products made from all or part of imported materials. Decision 1357 uses that broad test, while Article 70 as amended by Circular 121/2025/TT-BTC expressly includes products made entirely from business-imported materials. A duty-paid A12 input therefore does not automatically move the exported product to B11.

Control principle: determine the procedure code from the legal management scope and factual input chain; assess exemption, refund or duty paid as a separate layer.

B11–E62 COMPARISON

Criterion	B11	E62	Control question
Nature	Business export after excluding a more specific code.	Export of a product made from all or part of imported materials.	Was the item exported unchanged or manufactured with imported inputs?
Product source	Commonly domestic purchases or domestic-only manufactured products.	E31 inputs; combinations of processing/export-manufacturing, business-imported and domestic inputs; or entirely business-imported inputs.	Which import declarations and warehouse lots supplied the production order?
Related import codes	No fixed import code; duty paid does not itself justify B11.	May involve E31, A12 or another appropriate business-import procedure.	Do import purpose, warehouse source and production use align?
Import-duty treatment	B11 does not create material exemption or refund.	SXXK inputs may qualify for exemption; duty-paid business imports may be reviewed for refund under separate conditions.	Is the tax file based on exemption or refund?
Inventory records	Accounting, warehouse and other obligations applicable to the activity.	Imported inputs by procedure, finished goods, actual norms, scrap and exports must reconcile.	Do ERP, stock and declarations use matching codes and units?
Finalization	B11 alone does not create SXXK finalization.	E62 is an outbound dataset in the applicable finalization/reconciliation chain.	Were materials and output recorded in the correct fiscal period?
Misclassification risk	B11 may break the Article 70 output link and affect tax/refund evidence.	E62 may create an unsupported chain for domestic-only or unprocessed goods.	Would the entire import–production–export file remain coherent?

PROCEDURE-CODE DECISION MATRIX

Fact pattern	Review direction	Do not assume
Domestically purchased goods exported unchanged	Generally review B11 unless another specialized regime applies.	A factory owned by the exporter does not make E62 necessary.
Product made entirely from domestic inputs	B11 may be appropriate if no processing, EPE or other specific code applies.	In-house production does not automatically mean E62.
Product uses E31 inputs and domestic inputs	Review E62 under current Article 70.	A low imported-input ratio does not justify B11.
Product made entirely from duty-paid A12/business-imported inputs	Review E62 under Article 70(3)(a.3); assess any refund separately.	Duty paid does not automatically make B11 correct.
Product combines business-imported and domestic inputs	Review E62 against Decision 1357, Article 70 and actual production evidence.	Do not classify by material-value percentage alone.
Imported goods re-exported without processing	Review B13.	Do not use E62 without a manufacturing process.
Processed goods or EPE products	Review E52 or E42 respectively.	Imported inputs alone do not make E62 correct.

DOCUMENTS AND DATA TO VERIFY

Record	Issuer/source	Fields to reconcile	Why it matters
Export contract and invoice	Exporter and buyer	Parties, goods, quantity, value and delivery terms.	Supports the transaction but does not decide B11/E62.
Import declarations	Customs system	Procedure code, HS, quantity, unit, import purpose and duty status.	Identifies E31, business-imported or other sources; duty paid does not mean B11.
BOM, production order and actual norm	Engineering and production	Input code, output code, quantity consumed and loss.	Proves that imported materials formed the E62 product.
Warehouse and lot records	Warehouse/ERP	Date, lot, source warehouse and quantity.	Traces physical flow by import procedure.
Detailed accounting ledger	Accounting	Quantity, value, account, import evidence and source.	Article 60 requires imported materials to be tracked by procedure code.
Exemption/refund file	Enterprise and customs	Import entries, exported output, material use and claim evidence.	Keeps tax entitlement separate from procedure-code selection while maintaining consistency.
Export and delivery records	Customs, carrier and warehouse	Output code, quantity, weight, container and export date.	Records the correct B11/E62 output and reporting period.

TAX AND MANAGEMENT OBLIGATIONS

Issue	B11	E62	Warning
Export duty	Determined by HS and export policy.	The same; E62 does not automatically mean zero duty.	The procedure code does not replace HS classification.
Duty-exempt imported inputs	B11 does not create SXXK exemption.	SXXK inputs may be exempt where statutory conditions, production facilities and use records are met.	E62 is evidence of output, not the only exemption condition.
Duty-paid business imports	Duty paid does not automatically justify B11.	Products entirely from business-imported inputs remain within Article 70; any refund is determined under separate rules.	Separate the export code from refund entitlement.
Export VAT	Governed by VAT law and transaction evidence.	The same; E62 does not guarantee zero rating.	Do not infer VAT treatment from the customs code.
Finalization	B11 alone does not create SXXK reporting.	E62 output is tracked with imported inputs by procedure. Where annual reporting is selected, the basic deadline is day 90 after fiscal year-end.	Confirm the Article 60 reporting method selected by the enterprise.

PROCESS FOR SELECTING B11 OR E62

Identify the goods status

Determine whether the goods are unchanged imports/purchases or manufactured output.

Trace every input source

Separate domestic, E31, duty-paid business imports and processing inputs.

Apply current Article 70

Check whether the product falls into one of the three SXXK-managed groups.

Reconcile BOM and stock flow

Confirm the materials actually issued to the exported production lot.

Exclude specialized codes

Review B13, E42, E52 and other specific procedures.

Assess tax separately

Determine exemption, refund or duty-paid treatment without reversing the code decision.

Document and approve

Retain the factual/legal basis, stock evidence and approval trail.

Reconcile after clearance

Match customs, ERP, warehouse, accounting, tax and finalization data.

INTERNAL RESPONSIBILITY MATRIX

Function	Responsibility	Required output	Avoid
Customs/EXIM	Review inbound and outbound codes, policies and documents.	Procedure-code assessment sheet and declaration file.	Copying the previous shipment code.
Production/engineering	Confirm process, BOM and actual material use.	Production order, applicable BOM and actual norms.	Using planning BOM instead of actual data.
Warehouse	Segregate stock by source and customs status.	Lot and warehouse movement records.	Mixing exempt and duty-paid stock without traceability.
Accounting/tax	Reconcile quantity, value, import duty and finalization.	Detailed ledgers and reconciliation statement.	Checking value only and ignoring quantity/unit.
Compliance/legal	Review eligibility and cross-document consistency.	Control opinion for borderline cases.	Assuming E62 is always more tax-efficient.
Declaration approver	Approve the code based on documented evidence.	Approval trail and document version.	Approving after declaration transmission.

RISKS AND COMMON ERRORS

Error	Cause	Impact	Control
Selecting B11 because A12 duty was paid	Confusing import-duty status with the export procedure.	Incorrect Article 70 treatment and broken refund/finalization evidence.	Select the code from product origin first; assess tax separately.
Using B11 without tracing imported inputs	Reviewing only the invoice or product name.	No defensible import–production–export link.	Block filing until BOM, production order and stock evidence are available.
Using E62 for every in-house product	Equating manufacturing with export manufacturing.	Domestic-only goods enter an unsupported management chain.	Confirm whether imported materials form part of the product.
Assuming E62 requires 100% E31 inputs	Ignoring Decision 1357 and amended Article 70.	Misclassification of mixed or business-imported material products.	Review all three Article 70 product groups.
Selecting the code for a preferred tax result	Reversing the legal sequence.	Assessment, denied refund, penalties and post-clearance risk.	Separate code and tax approval records.
Not tracking materials by import procedure	ERP uses one undifferentiated source.	Finalization differences and uncertain tax eligibility.	Use source codes, lots and controlled mappings.
Ignoring other specialized procedures	Comparing B11 and E62 only.	B13, E42, E52 or another code may be missed.	Use a complete procedure-code decision tree.

LEGAL BASIS AND SOURCES

Instrument/source	Authority/effect	Role
Decision 1357/QD-TCHQ	General Department of Customs; effective 1 June 2021	Defines B11 and E62; E62 covers products made from all or part of imported materials.
Circular 121/2025/TT-BTC	Ministry of Finance; effective 1 February 2026	Amends Articles 60 and 70 on SXXK product scope, source tracking and finalization.
Customs guidance on B11	Vietnam Customs	Operational reference for business-export cases.
Customs guidance on E62	Vietnam Customs	Operational reference for SXXK products and material sources.
Decree 167/2025/ND-CP	Government; effective 15 August 2025	Amends customs procedures, inspection and supervision rules.
Law 90/2025/QH15	National Assembly; effective 1 July 2025	Amends customs and export-import duty legislation.
Decree 18/2021/ND-CP; Decree 182/2025/ND-CP	Government; effective 25 April 2021 and 1 July 2025	Import-duty exemption/refund conditions for export production.

FAQ

Must every in-house manufactured export use E62?

No. Domestic-only output may point to B11, but any imported material in the product requires an E62 and Article 70 review.

Can B11 be used when imported inputs are only 10%?

The percentage alone does not exclude E62. Decision 1357 covers products made from all or part of imported materials.

What if the product is made from duty-paid A12 inputs?

If it is made entirely from business-imported materials, Article 70(3)(a.3) places it in the SXXK-managed scope; E62 is the code to review. Refund entitlement is separate.

Does E62 guarantee exemption or refund?

No. Tax treatment depends on the import procedure, statutory conditions, production facility and evidence of actual use/export.

Can E62 cover business-imported and domestic inputs together?

Potentially yes. Review Decision 1357, Article 70, the BOM and actual stock flow.

Can a B11 declaration be amended to E62?

It depends on declaration status, amendable fields, goods status and customs instructions. Stop downstream posting and assess tax impact promptly.

Do B11 and E62 determine export VAT?

No. VAT treatment follows VAT law and transaction evidence, not the customs procedure code alone.

APPLICATION NOTE: Select B11 or E62 from the goods status, actual material sources and current Article 70. In particular, duty-paid business-imported materials do not automatically make B11 correct. A case-specific conclusion requires import declarations, BOM, stock records, production evidence and the intended tax treatment. Sources reviewed on 17 July 2026. Vietnamese legal translations are for operational reference only.

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