Imported goods subject to specialised inspection may not qualify for immediate customs clearance. To reduce port storage and enable inspection at an inland site, certain shipments may be moved to an approved inspection or storage location. This is not customs clearance, unrestricted release or an automatic right. The goods remain under customs supervision, and the declarant must move them to the registered location, preserve their original condition, report arrival, present them for inspection and complete the specialised-inspection result. This article reflects the rules effective from 1 February 2026.

Operational update: 20 July 2026 · Based on Circular 121/2025/TT-BTC

QUICK FACTS

Nature

Goods leave the port to await inspection/results but are not freely usable or marketable.

Core condition

The location must have a clear address, be separated from surrounding areas and preserve the goods intact.

System filings

Submit the request under Form 18 and arrival notice under Form 19.

Main risk

Unauthorised use, sale, alteration, wrong storage location or late inspection result.

Illustration for Removal of Goods for Storage: Conditions and Business Responsibilities — Illustration of the logistics topic, document or operation discussed in the article.

SCOPE

Applicable mainly to imports subject to quality, food-safety, quarantine or other specialised inspection before clearance. The exact procedure depends on sectoral law, the inspection authority and National Single Window connectivity.

It must not be confused with goods release pending classification/value/tax or final customs clearance.

TERMS

Term	Meaning	Operational marker
Removal for storage	Permission to move goods awaiting specialised inspection to an approved location.	Not cleared; still supervised.
Specialised inspection site	Location where the specialised authority performs inspection.	Designated or accepted under sectoral law.
Storage location	Registered warehouse/yard preserving the shipment intact.	Clear address, separation and supervision conditions.
Original condition	No substitution, consumption, use or unauthorised alteration.	Seal, packages, models and quantities remain traceable.
Arrival notice	Electronic notice sent once the shipment reaches the registered destination.	Form 19.

OPERATING MECHANISM

The mechanism balances trade facilitation and state supervision. Goods may move inland, but the business cannot exercise unrestricted control over them.

Customs

Confirms permission, monitors movement, inspects the location and goods.

Specialised authority

Receives the file, samples/tests and issues or transmits the result.

Declarant

Moves, preserves, reports arrival and presents the goods.

Control principle: Goods may not be sold, consumed, used or unsealed without legal authority. Installation/operation solely for inspection requires prior customs notification and supervision as applicable.

STORAGE VS RELEASE VS CLEARANCE

Criterion	Removal for storage	Goods release	Customs clearance
Purpose	Await specialised inspection/result.	Await classification, value or tax completion.	Complete customs formalities.
Status	Not cleared; supervised.	Not all clearance conditions finalised.	Customs clearance decision issued.
Use	No unrestricted use/sale.	Depends on release conditions and other law.	Use/circulation only if sectoral and labelling rules are also met.
Main duty	Preserve, report arrival, submit result.	Finalise value/tax/file.	Retain records and maintain compliance.

ELIGIBILITY CONDITIONS

Condition	Requirement	Evidence to retain	Control point
Goods and scenario	Imported goods are subject to specialised inspection, and either the specialised authority designates an inspection site or the declarant requests a storage site.	Inspection registration, declaration and authority instruction/confirmation.	Assess by HS code, function and sectoral rules, not by trade name alone.
Business status	The declarant is not currently suspended or barred from using the procedure.	System status and violation history.	Check before dispatching the truck or reserving warehouse space.
Correct filing route	Inspection site: Form 18 plus inspection registration unless available through the National Single Window. Storage at the declarant’s request: Form 18.	System filing; for a paper customs declaration to an inspection site, Form 09/BQHH/GSQL plus inspection registration.	Form 09 is not a universal requirement for every storage request.
Location	Clear address, identifiable and separated storage area, intact preservation and customs-supervision capability.	Right-of-use evidence, layout, boundary photos, warehouse owner and custodian details.	Keep these records available for inspection; they are not automatically attachments to every electronic request.
Transport data	Correct site, vehicle, route and declared transport deadline.	Dispatch, GPS, driver data and warehouse receiving plan.	Failure to report arrival by the registered deadline can suspend subsequent removals until verification.
Intact control	No free sale or use. Installation/operation is limited to specialised inspection needs after prior customs notice.	Seal and package photos, handover records, CCTV, warehouse logs and written notice.	Segregate uncleared goods from goods released for use or sale.

DOCUMENTS AND DATA

Record	Owner	Purpose	Data to reconcile
Customs declaration	Declarant	Identify goods, policy and processing status.	Declaration, line item, packages, weight and procedure type.
Specialised-inspection registration	Business/authority	Evidence of registration; attach for an inspection-site request where data are not available through the National Single Window.	Goods, model, quantity, authority and inspection site.
Form 18	Declarant	Request movement to an inspection or storage site.	Site, vehicle, route and expected transport deadline.
Form 09/BQHH/GSQL	Declarant	Paper-document route for moving goods to a specialised inspection site.	Declaration, inspection site and inspection registration.
Location file	Business/warehouse	Prove lawful use, boundaries and supervision capability when customs inspects the site.	Address, segregated area, owner, term of use and custodian.
Form 19	Declarant	Report arrival immediately after goods reach the registered site.	Arrival time, site, seal/package status and declaration.
Inspection result	Inspection authority/body	Basis for customs to continue clearance, release or other treatment.	Declaration, lot, model, quantity and conclusion.

Submission file vs retained file: A streamlined electronic request does not remove the need to retain warehouse evidence, seal photos, handover records and proof of lawful site use for a later customs check.

PROCESS

Determine policy: review HS code, function, model and sectoral rules.
Register specialised inspection: through the National Single Window or the authority’s mechanism.
Select the correct route: for an authority-designated inspection site, submit Form 18 and inspection registration if the system does not already hold it; for storage at the declarant’s request, submit Form 18. Form 09/BQHH/GSQL applies to the paper-declaration inspection-site route.
Receive customs response: no later than one working hour after customs completes document or physical inspection, if conditions are met.
Transport and hand over: control seals, packages, vehicle, route, deadline and receiving evidence.
Report arrival: send Form 19 immediately after arrival.
Support inspection: present goods and samples; notify customs in writing before installation/operation required for specialised inspection.
Complete the result: submit within 30 days from removal for storage if the authority has not electronically sent it, unless an extension is certified.
Return when required: where the specialised authority reports an incomplete file or failure to present goods and customs requires return, move the goods back to the original supervision area within five days of notice.

BUSINESS RESPONSIBILITIES

Duty	Action	Evidence	Risk
Correct transport	Move to the declared site using the declared vehicle and deadline.	GPS, dispatch, booking and handover.	Inspection and suspension of subsequent removals until verification.
Preserve intact	No substitution, sale, use or unauthorised change.	Seal photos, CCTV, warehouse log and count.	Administrative sanction and possible formal restriction period.
Report arrival	Send Form 19 immediately and no later than the Form 18 transport deadline.	System response and receiving timestamp.	No subsequent removals until customs verifies compliant storage.
Present goods	Arrange goods, personnel and files for customs or specialised inspection.	Inspection record, sampling record and visitor log.	Violation handling or an order to return goods to supervision.
Controlled installation/operation	Only for specialised inspection needs and after prior written customs notice.	Inspection request, notice and supervision record.	May be treated as unauthorised use or alteration.
Complete the result	Submit within 30 days where not electronically transmitted, unless extension is certified.	Result, Single Window data or extension confirmation.	Operational hold on subsequent shipments; a six-month restriction may apply only after the relevant inspection and sanction conditions are met.
Comply with return order	Return goods to the original supervision area within five days where legally required.	Notice, dispatch and customs receipt.	Violation exposure, cost and delay.
Bear costs	Pay transport, storage, holding and return costs.	Contracts and invoices.	Higher landed cost and clearance delay.

WHEN THE PROCEDURE IS NOT AVAILABLE

The formal restriction in amended Article 32(6) applies where a business has been inspected and administratively sanctioned for a listed violation, or where a competent authority issues a written request. A customs violation record is the starting date for certain restriction periods, but the mere preparation of a record should not be described as automatically triggering every bar.

Situation	Mechanism	Period/consequence	Key distinction
No arrival report by the Form 18 deadline	Operational suspension for subsequent shipments.	Until customs checks and confirms compliant storage.	Not automatically a one-year formal restriction.
Over 30 days without result or certified extension	No subsequent removals while the matter is checked and handled.	Depends on resolution with customs and the specialised authority.	Different from the six-month post-sanction restriction.
Inspected and sanctioned: goods not intact, wrong/ineligible site or unauthorised consumption	Formal Article 32(6) restriction.	One year from the customs violation record.	Apply to the specific sanctioned conduct.
Inspected and sanctioned: late specialised-inspection result	Formal Article 32(6) restriction.	Six months from the customs violation record.	Retain any certified extension.
Failure to present goods or written authority request	Management restriction.	For the period required by the relevant authority.	Read the scope of the specific written request.

COMMON RISKS

Treating storage as clearance: releasing goods to production or sale.
Combining two filing routes: treating Form 09 as universal or omitting inspection registration where Single Window data are unavailable.
Assuming electronic filing eliminates warehouse evidence: failing to retain site-use, boundary, seal and custody records.
Missing the arrival report: Form 19 is absent or sent after the Form 18 deadline.
Broken chain of custody: missing seal photos, receipt, vehicle history or responsible person.
Confusing the 30-day hold with a six-month bar: the immediate hold and the post-sanction restriction are legally distinct.
Installation or trial operation without notice: goods are run before written customs notification.
Ignoring a return order: missing the five-day return deadline where applicable.

LEGAL BASIS AND SOURCES

Instrument	Authority/effect	Relevance	Application point
Consolidated Customs Law 54/VBHN-VPQH (2026)	Office of the National Assembly; issued 23 Mar 2026.	Article 35 on specialised inspection and the customs-supervision framework.	The law sets principles; detailed conditions require the implementing decree and circular.
Decree 08/2015/NĐ-CP, amended by 59/2018/NĐ-CP and 167/2025/NĐ-CP	Government; Decree 167 effective 15 Aug 2025.	Article 33 on inspection/storage sites, supervision conditions and responsibility until clearance or release.	Read the instruments as an amended chain.
Circular 38/2015/TT-BTC, amended by 39/2018/TT-BTC and 121/2025/TT-BTC	Ministry of Finance; Circular 121 effective 1 Feb 2026.	Article 1(17) of Circular 121 amends Article 32: Forms 18/19, one-hour response, 30-day result, storage checks, five-day return and restrictions.	Separate an operational hold on subsequent shipments from a formal post-sanction restriction period.

Customs Law 2026 Decree 167/2025 Circular 121/2025

FAQ

1. Is removal for storage the same as customs clearance?

No. The goods remain uncleared and under customs supervision.

2. May the goods enter production?

Not freely. Installation or operation required for specialised inspection is permitted only within the applicable procedure and after prior written customs notice.

3. Can a third-party warehouse be used?

Potentially, if lawful use, identifiable boundaries, supervision capability and intact preservation can be demonstrated. The location file must be available for inspection.

4. When must arrival be reported?

Immediately after goods reach the inspection or storage site, and no later than the transport deadline registered in Form 18.

5. When is the specialised-inspection result due?

Where the authority has not transmitted it to customs, the declarant submits it within 30 days from removal for storage, unless an extension is certified.

6. Does passing 30 days automatically create a six-month bar?

No. Subsequent removals are first suspended while the matter is handled. The six-month restriction applies only where the business meets the separate inspected-and-sanctioned condition for late submission.

7. When must goods return to the original supervision area?

Where the specialised authority reports an incomplete file or failure to present goods and customs issues the applicable request, return is required within five days of notice.

APPLICATION NOTE: The English translation is for operational reference and is not an official legal translation. Apply the Vietnamese instruments to the actual goods, site and compliance status.

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