For machinery and electronic-component imports, document delays rarely begin with one missing paper. They usually begin with unclear ownership: who creates source data, who issues a document, who reviews it and who has final approval authority. A supplier may issue the commercial invoice but cannot decide which HS code the Vietnamese importer will declare. A forwarder may draft a customs declaration but cannot confirm product function, composition or customs value on behalf of the buyer. The buyer is legally accountable for import compliance only when it is also the importer/customs declarant, while an internal buyer approval role must not be confused with the legal declarant role. It cannot manufacture origin evidence controlled by the exporter. An effective allocation separates four roles: responsible, accountable, consulted and informed. This article provides a practical RACI matrix and document-locking workflow to reduce amendments, clearance delays and responsibility disputes.

Prepared by: B2B Logistics Content TeamUpdated: 20 July 2026Product group: Imported machinery and electronic components

QUICK FACTS

Supplier creates source data

Issues the invoice and packing list and provides catalogues, datasheets, BOMs, label images and origin information.

Separate Buyer and Importer roles

The Buyer approves the commercial transaction; the importer/customs declarant bears legal responsibility for customs data. Add a separate role when they are different entities.

Forwarder organises and warns

Coordinates booking, shipping instructions, transport documents and pre-alerts. It may directly conduct Vietnamese customs procedures only if it is an eligible customs agent or the filing is made by another legally qualified declarant under proper authorisation.

Incoterms does not replace RACI

Incoterms allocates selected delivery, cost and customs obligations; it does not assign every internal document approval.

Illustration for Document responsibility matrix for Buyer, Supplier and Forwarder — Illustration of the logistics topic, document or operation discussed in the article.

SCOPE OF APPLICATION

The matrix applies to Vietnamese imports of machinery, equipment, electronic modules and components under EXW, FCA, FOB, CFR, CIF, CPT, CIP, DAP or DDP, moved by sea, air, road or rail.

Buyer

The commercial purchaser. It is not automatically the importer or customs declarant; add the Importer/entrusted importer as a separate role when the entities differ.

Supplier

The seller, trading company, exporter or manufacturer. More than one export-side entity may appear in a shipment.

Forwarder

A freight forwarder or transport organiser, not automatically a customs agent. Its customs role depends on legal eligibility, the service contract and proper authorisation.

Additional controls

Dangerous goods, controlled products, letters of credit, entrusted imports and duty-exempt projects require extra parties and documents.

Principle: the person sending a file is not automatically the party ultimately accountable for it. Legal responsibility, issuance responsibility and review responsibility must be recorded separately.

KEY TERMS

Term	Meaning	Use in this article
Buyer	The purchaser under the commercial transaction; may or may not be the importer.	Approves purchase conditions, import information and budget.
Supplier	The vendor, which may be the seller, manufacturer, exporter or trading company.	Creates product source data and export-side documents.
Forwarder	A logistics service provider that arranges transport. It may directly perform customs procedures only if it qualifies as a customs agent or uses a legally qualified customs declarant under applicable rules.	Consolidates data, drafts documents, communicates cut-offs and flags discrepancies within scope.
RACI	Responsible – Accountable – Consulted – Informed.	Separates execution, final accountability, consultation and notification.
Document owner	The party controlling the approved version of a document.	Not necessarily the person who physically drafted the file.
Source data	Original product, transaction, transport or legal-entity data.	Used to prepare invoices, transport documents, origin documents, licences and declarations.

HOW THE RESPONSIBILITY MODEL WORKS

RACI is an internal governance tool, not a mandatory legal form. Each task should normally have only one Accountable party, although several parties may perform or support it.

Code	Role	Practical authority/duty	Common failure
R – Responsible	Performs the task	Drafts, collects, transmits or files the document as instructed.	Assigned the task without source data or authority.
A – Accountable	Final owner	Approves data, accepts the risk and confirms the version to be used.	Multiple “A” parties create decision paralysis.
C – Consulted	Provides input	Gives technical, tax, transport, banking or legal advice.	Advice is mistaken for final approval.
I – Informed	Receives status	Is notified of cut-offs, ETA, routing, customs channel and amendments.	Receives information only after the amendment deadline.

Recommended control chain: Supplier provides source data → Forwarder standardises and checks operational consistency → Buyer approves commercial data and Importer/declarant approves customs data → an eligible customs agent or lawful declarant executes → all changes are logged.

RESPONSIBILITY MATRIX BY DOCUMENT

Document/data	Buyer	Supplier	Forwarder	Mandatory lock point
Contract/PO	A/R: finalises parties, Incoterms, payment and document requirements.	R/C: confirms supply and seller-side obligations.	C/I: advises on transport, cut-offs and document practicality.	Legal names, named place, product description, origin and technical-document clauses.
Commercial Invoice	A/C: checks price, currency, parties, Incoterms and payment.	R: issues it for the transaction.	C/I: checks operational usability; does not alter commercial facts.	Invoice number/date, model, quantity, unit price, total, Incoterms and charges.
Packing List	A/C: checks against the PO and warehouse plan.	R: prepares it from actual packing.	C: checks packages, weights, CBM, marks and booking data.	Packages, net/gross weight, dimensions, model/SKU split and serials where relevant.
Catalogue/Datasheet/BOM/label images	A: approves the evidence used for HS and policy review.	R: supplies documents matching the shipped model and configuration.	C: flags gaps and prepares comparisons; does not certify product function.	Model, construction, operating principle, power, composition, use and set configuration.
Booking request	A/R or I: depends on Incoterms and transport appointment.	R or I: provides cargo-ready date, pickup address and export data.	R: secures space and communicates schedule and cut-offs.	Pickup/delivery point, cargo type, DG/OOG/reefer status, packages, weight, CBM and readiness.
Shipping Instruction	A: approves consignee, notify and release requirements.	R/C: provides shipper, cargo and export data.	R: prepares/submits the SI from approved data.	Shipper, consignee, notify, description, packages, weight, ports, freight term and release type.
Draft B/L or AWB	A: approves receiver data, routing and release.	C/A on export side: approves shipper and export data.	R: obtains, checks and circulates the draft.	No final issuance before written approval by authorised parties.
C/O or origin evidence	A/C: reviews form, criterion, data and preference eligibility.	R: prepares origin evidence; the competent authority or eligible exporter issues under the applicable scheme.	C/I: tracks progress, reviews the draft and forwards the issued document.	Exporter/producer, invoice, HS, description, origin criterion, transport and issue timing.
Vietnamese licences/specialised inspection	A/R: determines policy, signs, provides accounts and bears legal accountability.	R/C: provides certificates, test reports, composition and manufacturer documents.	R/C: prepares/files under authorisation and tracks deficiencies.	Correct importer, model, standard, receiving authority and validity.
Customs declaration	A: importer/declarant approves and is accountable for declaration data and evidence; Buyer is an internal A only when it is the same entity or is formally assigned approval.	C: explains product, price, origin and transaction data when required.	R/C: drafts and checks; directly files only when acting as an eligible customs agent or where filing is made by a lawful declarant under proper authorisation.	Customs regime, importer, partner, HS, description, value, tax, origin, licence and transport data.
Valuation/payment file	A/R: contract, payment, debt, royalties, assists and adjustments.	R/C: invoice, price list, discounts, transaction and beneficiary confirmation.	C: compiles evidence; does not certify cash flow.	Price paid/payable, discount conditions, freight/insurance and party relationships.
Arrival Notice/D/O	A/R: verifies, pays applicable charges and issues pickup authorisations.	I/C: assists where release or originals are blocked.	R: receives notices, obtains the order and coordinates delivery within scope.	Consignee, B/L/AWB, ETA/ATA, free time, charges, release status and pickup location.
Post-clearance file	A/R: retains the file, approvals, payments and audit trail.	R/C: supplies issued documents and later explanations.	R/C: hands over declarations, receipts, transport records and processing history.	Final version, issuer, receipt date, approver and cross-document references.

INCOTERMS AND SERVICE-SCOPE ADJUSTMENTS

Incoterms® 2020 allocates selected tasks, costs and risks between seller and buyer. The document matrix must still be written into the contract and operating procedure. Appointing a forwarder does not make it the owner of all shipment data.

Rule group	Typical transport allocation	Buyer should lead	Supplier should lead	Record separately
EXW	Buyer commonly organises pickup and main carriage.	Forwarder appointment, pickup data, import licences and import clearance.	Invoice/PL, delivery at premises and agreed export information support.	Export-clearance feasibility in the origin country; do not assume Buyer can act as exporter.
FCA/FOB	Buyer commonly appoints main carriage; Supplier delivers and clears export as applicable.	Booking instructions, consignee/notify, insurance where required and import clearance.	Export documents, delivery, shipper/cargo SI data and delivery notice.	Exact delivery point, cut-offs, origin charges and B/L approval.
CFR/CIF/CPT/CIP	Supplier contracts and pays carriage to the named destination.	Import clearance, transport-document review, origin evidence and receipt.	Booking, carriage and delivery documents; insurance under CIF/CIP as required.	Seller-paid freight does not mean seller bears risk to destination under every “C” rule.
DAP/DDP	Supplier organises carriage to the named destination; import obligations differ.	Import data coordination; under DAP, Buyer handles import clearance and taxes under the rule.	Carriage and delivery documents; under DDP, Seller has import obligations subject to local feasibility.	Do not accept DDP mechanically where legal entity, declarant and tax arrangements are not workable.

DATA TO LOCK

Data group	Source	Main reviewer	Required consistency
Parties and transaction	Contract, PO, registration data, invoice, bank account	Buyer/Finance/Legal	Seller, buyer, beneficiary, address, tax number and relationships.
Technical information	Catalogue, datasheet, manual, BOM, labels, drawings	Buyer/Engineering/Compliance	Model, construction, function, power, material, composition and use.
Quantity and packing	PO, invoice, packing list, actual packing record	Supplier + Buyer + Forwarder	Quantity, packages, net/gross weight, CBM, marks, serials and split shipment.
Transport	Booking, SI, B/L/AWB draft, manifest/pre-alert	Forwarder; parties approve their data	Shipper, consignee, notify, routing, freight term, packages, weight and release.
Customs and tax	HS work file, value, origin, licences, draft declaration	Importer/declarant; Buyer participates when it is the same importing entity or is assigned approval; Forwarder supports	Description, HS, origin, value, adjustments, regime and conditions.
Version control	Email, workflow, system log, meeting record	Buyer-appointed document owner	Filename, timestamp, editor, approver, reason for change and filing version.

IMPLEMENTATION WORKFLOW

Milestone	Buyer	Supplier	Forwarder	Output
Before PO signing	Defines document needs, import policy and approval owner.	Confirms technical, origin and delivery-document capability.	Advises route, Incoterms, cut-offs and RFQ data.	Document requirement list attached to the PO/contract.
Before cargo ready	Reviews HS/policy, licences, importer data and budget.	Sends draft invoice/PL, catalogue, BOM, labels and packing data.	Opens shipment file and issues the deficiency list.	Draft file with owners and deadlines.
Before booking/SI cut-off	Approves consignee/notify, routing, freight term and release.	Locks shipper, description, package and weight data.	Books space, submits SI and checks transport consistency.	Confirmed booking/SI.
Before document issuance	Approves invoice/PL, B/L/AWB and origin drafts as relevant.	Corrects and issues export-side documents.	Tracks cut-offs, manifest and document circulation.	Approved final document set.
Before customs filing	Approves HS, value, tax, licence and declaration data.	Resolves open product/transaction questions.	Drafts, checks and files after approval and within authorisation.	Declaration with approval audit trail.
After clearance	Retains file, reconciles payment and landed cost.	Provides later evidence or explanations.	Hands over operational records, charges and history.	Completed shipment file for audit.

COMMON RISKS AND ERRORS

Error	Cause	Impact	Control
“Forwarder handles everything”	No document owner is appointed and Buyer versus Importer/declarant approvals are not separated.	HS, value or policy is based on assumptions; responsibility becomes unclear.	The Importer/declarant retains legal responsibility for customs data; Buyer is an internal A only when assigned; Forwarder remains R/C within scope and legal capacity.
Supplier issues invoice/PL before review	No internal cut-off or version control.	Party, model, Incoterms, value or package errors cascade across documents.	Approve drafts and lock the change log before issuance.
Manufacturer is confused with Seller/Exporter	Trading structure is not mapped.	Invoice, origin, transport and payment records cannot be reconciled.	Map each legal entity to each document.
C/O is delegated entirely to the Forwarder	Supplier origin data is not requested early.	Origin criterion, producer, HS or supporting evidence is missing.	Put origin requirements in the PO; Supplier owns source data, Buyer reviews, Forwarder tracks.
Approval exists only in chat	No formal workflow or email record.	No proof of the approved version or decision-maker.	Use naming rules, approval log and one official shipment folder.
RACI is not adjusted for Incoterms	One generic matrix is reused for all shipments.	Booking, export clearance, insurance and charges are unclear.	Lock the Incoterms rule and named place, then update RACI before PO signing.

LEGAL BASIS AND REFERENCE SOURCES

Instrument/source	Issuer	Status/role	Application
Customs Law 54/2014/QH13	National Assembly of Vietnam	Effective 1 January 2015; read with amendments.	The customs declarant is responsible for the truthfulness of declarations and submitted/presented documents and for consistency of retained records.
Decree 167/2025/ND-CP	Government of Vietnam	Effective 15 August 2025.	Amends Decree 08/2015 on customs procedures, inspection and supervision.
Circular 121/2025/TT-BTC	Ministry of Finance	Effective 1 February 2026.	Amends customs-procedure circulars and should be used to review the current document set.
Circular 83/2026/TT-BTC	Ministry of Finance	Effective 1 July 2026.	Sets current operating standards and management rules for customs agents and their employees, distinguishing an ordinary forwarder from an entity eligible to conduct customs procedures.
Incoterms® 2020	International Chamber of Commerce	Trade rules incorporated by reference into contracts.	Allocates selected tasks, costs and risks between Seller and Buyer; does not replace the Forwarder contract or internal approvals.

Sources reviewed on 20 July 2026. This English version is for operational reference and is not an official legal translation of Vietnamese law.

VIEW CIRCULAR 83/2026 VIEW CIRCULAR 121/2025 VIEW INCOTERMS® 2020

FAQ

1. Is the Forwarder liable when the HS code is wrong?

First distinguish an ordinary Forwarder from an eligible customs agent and identify the legal declarant. Liability depends on contract, supplied data, professional fault and authority; the importer/declarant still controls and bears the legal responsibilities assigned to it for the declaration.

2. Must the Supplier obtain a C/O for every shipment?

No. The obligation must be agreed in the PO/contract and depends on the origin scheme. The Supplier/Exporter prepares source evidence; the document may be issued by a competent authority or an eligible self-certifier.

3. Who approves the draft B/L?

The Forwarder normally coordinates the draft. Buyer/Importer approves consignee, notify, routing and release; Supplier/Shipper approves export-side party and cargo data. Written approval should be retained.

4. Do Incoterms decide who files customs?

Incoterms allocates export/import formalities between Seller and Buyer but does not create customs-declarant status. The actual filer must satisfy local law; in Vietnam, distinguish the customs declarant from an eligible customs agent and confirm the authorisation scope.

5. May the Forwarder download a catalogue from the internet?

It may assist with research, but documents used for classification and declaration should be confirmed by the Supplier/Manufacturer as matching the shipped model, configuration and version. Buyer approves their use.

6. Can two parties both be “A” for one task?

Avoid it by splitting the task: Supplier is A for export-side source data/issuance; Buyer is A for the commercial decision; Importer/declarant is the legal A for using data in the customs file. The last two roles merge only when they are the same entity.

APPLICATION NOTE: This matrix is a reference framework. Adapt it to Incoterms, payment method, product policy, entrusted-import structure, Forwarder scope and internal approval workflow. It cannot transfer legal responsibility contrary to law or contract.

TGIMEX IMPLEMENTATION SUPPORT

TGIMEX helps businesses turn the article into a shipment-ready checklist, covering input-data review, dossier preparation, milestone control, and coordination with the relevant parties.

Convert guidance into checks

Assign an owner and deadline to every operational control point.

Reconcile shipment data

Compare booking, transport, commercial, customs, and delivery evidence.

Manage operational risk

Record discrepancies, actions, and decision evidence to prevent recurrence.

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