When a declaration is selected for physical examination, businesses often hear “5% inspection”, “10% inspection” or “100% inspection”. These figures are not the probability that a declaration will be inspected, nor do they automatically mean Customs will open exactly that percentage of cartons and stop. Operationally, they describe scope within the shipment; current law does not establish a rigid statutory 5%–10%–100% schedule for every declaration. The electronic instruction and handling customs unit’s requirements take priority. This article explains the limits of the terminology and the records businesses should prepare.

Operational reference for Importers, Exporters, Customs, Compliance and Operations | Updated: 17 July 2026

QUICK FACTS

5% AND 10%

Partial examination scopes applied under the actual instruction; they are not 5% or 10% of the company’s declarations.

100%

Examination of the full goods scope stated in the instruction. A 100% scope does not necessarily mean manually opening every package where scanning or technical means are used.

WHO SELECTS PACKAGES?

Customs determines the units and locations to be examined. The trader must present the requested goods and may not self-select convenient packages.

SCOPE MAY EXPAND

Differences in description, quantity, model, origin, classification or other risk indicators may lead from a partial to a wider or full examination.

SCOPE OF APPLICATION

This article applies to exported or imported goods selected for physical examination during customs clearance, commonly described operationally as a red-channel declaration. It is relevant to cartons, pallets, containers, LCL cargo, multiple-SKU/model shipments and goods requiring verification of quantity, type, labels, origin or technical specifications.

It does not replace the inspection instruction on the electronic customs data-processing system, a decision of the competent customs unit, or separate specialised inspection rules. For bulk cargo, liquids, homogeneous goods, oversized cargo, perishables or specially preserved goods, a 5% or 10% scope may not be calculated simply by carton count.

Core caution: 5%, 10% and 100% are best treated as operational descriptions of examination scope within a shipment, not a statutory three-level schedule. If the electronic instruction does not state a percentage, the trader must not infer one merely from a red-channel result.

KEY TERMS

Term	Meaning	Operational role
Physical inspection	Comparison of actual goods with the declaration and supporting records through direct examination, scanning or other technical means.	Supports verification of description, quantity, weight, type, HS classification, value, origin and import/export policy compliance.
Inspection scope/rate	An operational description of a relatively limited partial scope where the actual instruction states a corresponding level.	Performed by the packages, positions or units indicated; it cannot be presumed to mean 5% of value, weight or total cartons.
Partial examination	Examination of selected packages, units or representative positions under Customs instruction; the trader does not choose the sample.	Allows an initial compliance assessment without opening the whole shipment at the outset.
Expanded examination	An operational description of a broader partial scope where the actual instruction states a corresponding level.	Selection remains with Customs; the trader provides package, pallet, line-item and position maps for presentation.
Non-intrusive inspection	Use of container scanners or other technical means, limiting direct opening where suitable.	It is an examination method, not a separate rate; abnormal images may require direct opening.

NATURE AND OPERATING MECHANISM

1. DISTINGUISH THE RATE OF DECLARATIONS INSPECTED FROM THE SHARE OF GOODS EXAMINED

The red-channel rate indicates how many declarations out of all declarations are physically examined. A 5%, 10% or 100% inspection, by contrast, is an operational description of scope within a shipment already selected for examination. A Customs Q&A has explained that an examined declaration may be checked in full or at 5% or 10% depending on the shipment; that Q&A helps explain usage but does not replace the current electronic instruction.

Keep a third percentage concept separate: risk-management percentages calculated over the total number of declarations — for selecting declarations for documentary or physical checks — are entirely different from a “5%/10% goods scope” within one shipment. Declaration-selection rates cannot be used to calculate how many packages must be opened.

2. THE DENOMINATOR IS NOT ALWAYS THE NUMBER OF CARTONS

Current rules do not provide a universal denominator that a trader may independently apply to cartons, value, weight or SKUs. For homogeneous packaged cargo, an actual instruction may be implemented by package count; for multi-line, bulk or complex cargo, the trader should provide a cargo map so Customs can identify the goods to be presented. “5%” must therefore not be assumed to mean 5% of all cartons.

3. THE RATE DOES NOT GIVE THE TRADER THE RIGHT TO CHOOSE SAMPLES

Customs selects the package, position or product group based on system instructions, records, risk indicators and actual conditions. The trader must arrange personnel, equipment and access to the requested goods. A detailed Packing List and loading map materially reduce retrieval and repacking time.

4. PARTIAL FINDINGS MAY CHANGE THE SCOPE

If the examined portion is consistent and supports a conclusion, the result is processed under the applicable rules. Where discrepancies, violation indicators or insufficient evidence arise, Customs may require further examination, direct opening, sampling or expert assessment. A 5% instruction is therefore not an absolute legal cap on the goods that may have to be presented.

COMPARISON OF 5%, 10% AND 100% EXAMINATION

Common label	Correct meaning	Selection basis	Business preparation	Expansion risk
5%	A relatively limited partial examination to compare the declaration and identify risk.	Customs may select packages, positions, line items, SKUs/models or suitable units; it is not automatically 5% of shipment value.	Loading map, package numbers, seals, pallet positions, model/serial list and retrieval labour.	May expand where irregularities, discrepancies or insufficient evidence are found.
10%	A broader partial examination, generally involving more packages, positions or product groups.	Selection remains with Customs; multi-SKU cargo may require coverage of several material groups.	Additional retrieval time, labour, handling equipment, examination area and repacking materials.	May likewise move to a higher or full scope.
100%	Examination of the entire goods scope stated in the customs instruction.	May use scanning, direct opening, weighing, counting or technical means; it does not automatically require manual opening of every package.	Full labour and handling plan, preservation controls, safety equipment and repacking arrangements.	The scope is already full, but sampling, expert assessment, verification or enforcement action may still follow.

Integrated example: For 1,000 homogeneous cartons, the nominal scope is 50 cartons only where the actual instruction defines 5% by package count. This is an operational illustration, not a universal legal formula. Customs determines which packages and whether additional examination is required.

DOCUMENTS AND DATA TO REVIEW

Document/data	Typical issuer/preparer	Use during examination	Fields that must align
Customs declaration and inspection instruction	Declarant/customs system	Defines declared data, channel and required checks.	Description, HS code, quantity, weight, value, origin and customs regime.
Commercial Invoice	Seller/exporter	Supports transaction, description, unit price and total value checks.	Goods, model, quantity, price and Incoterm.
Packing List and loading map	Shipper/factory/packing warehouse	Locates packages, container positions, weight and packing method.	Package count, gross/net weight, dimensions, marks, pallet-box mapping.
Bill of lading, arrival notice, container/seal data	Carrier/forwarder/agent	Links the goods to the transport unit and seal condition.	Container, seal, bill number, ports, shipper and consignee.
Catalogue, datasheet, label photos, model-serial list	Manufacturer/supplier/importer	Substantiates technical identity, function and models.	Model, specifications, brand, origin, function and serials where applicable.
Licence, specialised-inspection registration, C/O and other evidence	Competent authority/exporter/importer	Supports import conditions, origin and product-policy checks.	Description, HS code, quantity, model, origin and referenced declaration/document.

APPLICATION PROCESS FOR A SHIPMENT

RECEIVE THE CHANNEL AND INSPECTION INSTRUCTION

Read the required method, place and extent where stated. Do not infer 5%, 10% or 100% solely from a red-channel result.

RECONCILE RECORDS AND MAP THE CARGO

Cross-check declaration, Invoice, Packing List, bill, catalogue and licences; map container, pallet, box, SKU/model and position data.

REGISTER TIME/PLACE AND ARRANGE RESOURCES

Coordinate the port/warehouse, handling equipment, opening labour, authorised representative and customs broker. Special goods require preservation and safety controls.

PRESENT THE PACKAGES OR POSITIONS REQUESTED BY CUSTOMS

Do not substitute packages, self-select samples or break original condition before instruction. Record seals, packaging condition and the opened scope.

EXAMINE, RECORD AND PROCESS THE RESULT

Consistent results proceed to the applicable clearance/release step. Discrepancies may require explanation, permitted amendment, expanded inspection, sampling or expert assessment.

REPACK AND RETAIN EVIDENCE

Recount, photograph, reseal/repack and retain inspection records, minutes, costs and communications for reconciliation and post-clearance review.

RISKS AND COMMON ERRORS

Error	Cause	Impact	Control
Treating 5% as a 5% chance of inspection	Confusing declaration-channel statistics with shipment scope.	Incorrect labour and timeline planning.	Separate the two metrics in SOPs and status reports.
Self-selecting packages	Preparing convenient or pre-checked samples.	Failure to present requested goods and additional delay.	Open only packages/positions selected by Customs.
Packing List lacks pallet-box-SKU mapping	Only aggregate quantities are shown.	Container shifting, search time and extra handling.	Obtain a packing map before ETA.
Assuming a 5% scope cannot expand	Treating the initial percentage as a hard cap.	No contingency for labour, time or costs.	Maintain a full-examination contingency.
Mixed models/origins in actual cargo	Co-packed cargo is not split by line item.	Difficulty with HS, duty, C/O and specialised policy checks.	Separate line items, label packages and maintain model-serial records.
No preservation plan after opening	Cold-chain, clean, fragile or dangerous cargo not considered.	Damage, quality loss or safety exposure.	Prepare examination area, PPE, repacking materials and preservation controls.

LEGAL BASIS AND OFFICIAL SOURCES

The sources below establish the framework for risk management, documentary checks and physical examination. For a specific declaration, use the current consolidated text and the electronic inspection instruction.

Instrument/source	Authority	Status/date	Relevance
Customs Law 54/2014/QH13	National Assembly	Effective 1 January 2015; read with amendments.	Core rules on customs control, responsibilities and inspection.
Law 90/2025/QH15	National Assembly	Effective 1 July 2025.	Amends selected provisions of the Customs Law and related laws.
Decree 08/2015/ND-CP, Decree 59/2018/ND-CP and Decree 167/2025/ND-CP	Government	Decree 167/2025 effective 15 August 2025.	Detailed and updated implementation measures for customs procedures and control.
Circular 38/2015/TT-BTC, as amended	Ministry of Finance	Read with Circulars 39/2018 and 121/2025.	Article 29 and related provisions cover methods, organisation and processing of physical-inspection results. Risk-management percentages over total declarations are a separate concept from goods scope within one shipment.
Circular 121/2025/TT-BTC	Ministry of Finance	Effective 1 February 2026.	Updates customs procedural rules and must be reviewed for current application.
Customs authority Q&A on examination scope	Vietnam Customs	Operational Q&A; not a normative legal instrument.	Illustrates how Customs has explained full, 5% or 10% examination; it does not replace the current electronic instruction.

CUSTOMS LAW SOURCE
CIRCULAR 121/2025 SOURCE

FAQ

1. Does 5% always mean 5% of all cartons?

No. Current rules do not prescribe one denominator for every shipment. Carton count applies only where the actual instruction uses package count; the trader must follow the stated instruction.

2. Does a 10% inspection always take twice as long as 5%?

No. Time depends on cargo position, SKU count, retrieval capability, handling equipment, technical records, sampling and any discrepancy.

3. Is scanned cargo considered 100% inspected?

That cannot be inferred from scanning alone. Scanning is a method; scope and any direct opening depend on the instruction and image-analysis result.

4. May the trader suggest convenient packages?

The trader may provide a loading map and operational assistance, but Customs determines the packages or positions to be examined.

5. If one package is discrepant, must the whole shipment be opened?

Not automatically, but Customs may expand the examination, sample, seek expert assessment or require explanations depending on the discrepancy.

6. Does every red-channel notice immediately state 5%, 10% or 100%?

Do not assume so. Read the electronic instruction and coordinate with the handling customs unit to confirm the method, place and scope.

APPLICATION NOTE: This is general operational guidance. The actual examination scope depends on risk instructions, documents, cargo characteristics, examination method, location and findings at the time of examination. It does not replace a customs decision or instruction for a specific declaration.

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