Customs clearance, warehouse receipt or market release does not end the obligation to prove conformity. During post-market quality control, specialised inspection, complaint handling or recall, the business must be able to retrieve the Test Report, conformity declaration dossier, surveillance records and evidence linking them to the correct product, model or shipment lot. In a post-clearance audit, these records are relevant where they relate to the customs file, specialised-control policy or the circulation conditions of the shipment.

TGIMEX professional content · Updated 20 July 2026

QUICK FACTS

Do not discard records after clearance

Circular 14/2026/TT-BKHCN requires the declarant to establish and retain conformity declaration records for inspection and audit.

A Test Report must match the actual product

The report is useful only when the tested sample can be traced to the model, configuration, manufacturer, factory and applicable technical regulation.

There is no single retention period for all goods

Retention depends on sector rules, the technical regulation, certificate validity, customs records and the product risk lifecycle.

The five-year customs period is not a universal cap

Five years applies to customs records under Customs Law; it must not automatically be treated as the maximum period for quality records.

Changes may trigger reassessment

A change to the regulation, declaration, functions, intended use or product characteristics may require a new declaration.

Illustration for Responsibility for Retaining Test Reports and Conformity Records After Products Enter the Market — Illustration of the logistics topic, document or operation discussed in the article.

SCOPE

This article applies to manufacturers, importers and entities named in conformity declarations for products subject to national or local technical regulations, especially medium- and high-risk goods or products under specialised management. It focuses on the period after customs clearance and market placement in Vietnam.

Limit: The exact dossier and retention period depend on the applicable QCVN, sector regulations, conformity assessment method, certificate term and product characteristics. This article is not a substitute for a product-specific legal review.

KEY TERMS

Term	Meaning	Operational role
Test Report	A report issued by a testing body showing test results.	Evidence of sample performance against a standard or regulation; scope and sample identification must be verified.
Conformity declaration dossier	The records supporting registration that an object conforms to a technical regulation.	The declarant must retain and provide it when requested by competent authorities.
Conformity certification	Third-party assessment that the object conforms to a QCVN/QCDP.	Supports declaration where third-party assessment applies and normally includes surveillance.
Self-assessment	The business makes its own conformity conclusion based on technical records and valid test results.	The business bears direct responsibility for the assessment, control plan and periodic surveillance.
Post-market surveillance	Quality monitoring and inspection after products enter the market.	May cover labels, CR marks, conformity evidence, traceability and additional testing.
Change control	Formal control over product and technical-file changes.	Determines whether an existing Test Report remains representative or new testing/declaration is needed.

HOW THE OBLIGATION WORKS

1. Quality responsibility continues after market placement

The amended product and goods quality framework adopts risk-based management and stronger post-market control. A business must continuously maintain conformity, quality control, testing and periodic surveillance while the product is marketed or used.

2. A Test Report is only one part of the evidence chain

A standalone PDF does not prove the full compliance case. Inspectors may verify sample origin, model equivalence, test methods, laboratory accreditation/designation scope and whether the marketed product changed after testing.

3. There is no universal period: build a record-specific retention schedule

Circular 14/2026/TT-BKHCN imposes a retention duty but does not set one universal number for every product. “Retain until the later supported endpoint” is a prudent control rule, not a single statutory period created by Circular 14. Businesses should map QCVN and sector rules, certificate validity, customs records, warranty, contracts and any open inspection, complaint or recall matter.

RETENTION RESPONSIBILITY MATRIX

Record group	Primary owner	Retention approach	Control point
Registration and database confirmation	Entity named in the declaration	Circular 14 sets no universal period; retain under QCVN/sector rules and while conformity must still be demonstrated.	Confirmation code, QCVN version, legal entity and declared object.
Certificate and certification file	Certificate/declaration holder	At least through certificate validity and the related post-market evidence period; do not destroy solely because it expired.	Product scope, factory, scheme and surveillance.
Test Report	Declaration holder or technical-file owner	Retain with the declaration/self-assessment file; close under the retention schedule and relevant sector/customs rules.	Report number, sample, model, serial/lot, date, method and laboratory scope.
Self-assessment and quality-control plan	Self-assessing business	Maintain during the declaration and retain under the schedule for inspection and audit.	Assessment report, test frequency, acceptance criteria and surveillance evidence.
Import and customs records	Customs declarant/cargo owner	Five years from customs declaration registration, unless another law requires otherwise.	Declaration, invoice, packing list, technical and specialised-control documents.
Change, nonconformity, recall and corrective-action records	Manufacturer/importer/declarant	Retain until the matter is closed and all legal, sector, contractual or dispute-related periods end.	Root cause, affected lots, notices, CAPA and recall evidence.

Validity is not retention: A report or certificate may no longer support new production, while it must still be retained as evidence for goods already placed on the market.

RECORDS AND DATA TO VERIFY

Document	Issued/prepared by	Fields that must align	Risk if missing
Conformity registration	Declarant	Legal entity, product, model, QCVN/QCDP and assessment basis.	Declared scope cannot be demonstrated.
National database confirmation	Receiving authority/system	Confirmation number, date and dossier version.	Completion of registration is difficult to prove.
Conformity certificate	Certification body	Model, manufacturer, factory, regulation and validity.	Certificate may not cover marketed goods.
Test Report	Testing body	Sample, parameters, methods, results, units and authentication.	Insufficient or non-representative evidence.
Technical file	Manufacturer/business	Design, specifications, BOM, photos, label, packaging and instructions.	Actual goods cannot be matched to the tested sample.
Surveillance records	Business/certification body	Frequency, method, lots, results and actions.	Continuous conformity cannot be demonstrated.
Lot traceability	Warehouse, sales, ERP and logistics	Lot/serial, import date, channels, sold and remaining quantities.	Recall scope cannot be identified.
Change-control record	R&D, engineering, procurement and QA	Date, component/material, factory and impact assessment.	Old evidence is used for a changed product.

RECORD-CONTROL PROCESS

Open a master file for each declared object

Assign a unique file to each product/model/factory/QCVN combination; do not mix non-equivalent configurations.

Build an evidence linkage table

Connect the Test Report, certificate, declaration, label, customs entry and lot numbers.

Build the retention schedule and choose a defensible closing date

Review QCVN and sector rules, certificate terms, Customs Law, warranty and open dispute/recall records. Where several periods apply, use the later endpoint or obtain legal review and document the basis.

Control versions and access

Keep records in the form required by law and by the dossier. Electronic retention must preserve legal validity, accessibility, integrity and provenance; an ordinary scan is generally only a copy.

Define reassessment triggers

Assess the impact of changes to QCVN, model, intended use, specifications, critical components, factory or process.

Maintain post-market surveillance

Collect complaints, periodic test results, market samples and nonconformity records.

Close records under approval

Destroy only after all mandatory and approved internal periods end, no inspection, dispute, complaint or recall remains open, and Compliance/Legal approves.

COMMON RISKS AND ERRORS

Error	Cause	Impact	Control
Deleting files after clearance	Compliance is treated as an import-only step.	No evidence during post-market or post-clearance review.	Separate clearance date from retention end date.
Keeping only the Test Report	Files are managed in isolation.	The report cannot be linked to the marketed product.	Retain photos, model, serial/lot, BOM, label and sampling records.
Using one report for non-equivalent models	No product-family assessment.	Evidence may be rejected.	Maintain a model matrix and sample-representativeness rationale.
Laboratory outside the required scope	Only the laboratory name is checked.	Results may not be accepted for mandatory parameters.	Retain accreditation/designation scope valid at the test date.
No change control	Engineering or procurement changes are not escalated.	Marketed goods differ from the tested/declarated object.	Require Compliance approval in the change workflow.
Records stored in personal email	No central repository.	Data is lost when staff or accounts change.	Use DMS/ERP, role-based access and backups.
Applying five years mechanically	Customs retention is confused with all compliance retention.	Records may be destroyed too early.	Use a retention schedule; where several periods apply, use the later endpoint or obtain legal review and document the basis.

LEGAL BASIS AND OFFICIAL SOURCES

Instrument/source	Effective date/date	Relevance
Law 78/2025/QH15	Effective 1 January 2026	Introduces risk-based product quality management and stronger post-market control.
Decree 37/2026/ND-CP	Effective 23 January 2026	Details implementation of the amended product and goods quality law.
Circular 14/2026/TT-BKHCN	Effective 25 May 2026	Defines conformity dossiers, retention, surveillance, document provision and re-declaration triggers.
Consolidated Customs Law 54/VBHN-VPQH	Issued 23 March 2026	Basis for five-year customs-record retention from declaration registration.
Law on Electronic Transactions 20/2023/QH15	Effective 1 July 2024	Basis for legal validity, original-form requirements and retention of records as data messages.
National Standards, Metrology and Quality Committee	Guidance dated 2 May 2026	Official guidance on continuing conformity responsibility and dossier retention.

Translation note: English legal descriptions are for operational reference only and are not official legal translations.

FAQ

1. Can the Test Report be destroyed after all stock is sold?

Not based on inventory alone. Check the retention schedule against sector rules, customs records, warranty/use periods and any open inspection, complaint or recall. Where several periods apply, use the later endpoint or obtain legal review before destruction.

2. Must paper originals be retained?

Circular 14/2026/TT-BKHCN requires an “original” for certain dossier components. An electronic record can substitute only when it satisfies Vietnam’s e-transaction law and the applicable sector requirements; an ordinary scan is not automatically an original.

3. How long is a Test Report valid?

There is no universal period. Usability depends on the QCVN, sector rules, certification scheme, product changes and authority/certification-body requirements.

4. Is a foreign manufacturer report sufficient?

Only where the applicable framework accepts it and the testing body/result is accredited, designated or recognised as required, with a representative sample.

5. Does a minor component change require retesting?

An impact assessment is required. Changes affecting safety parameters, function, intended use or declared characteristics may trigger retesting, recertification or re-declaration.

6. When does the customs five-year period start?

From the customs declaration registration date. It is not automatically the maximum period for conformity records.

7. Who should own the dossier?

A clearly designated owner—typically QA/Compliance or product legal—should coordinate with customs, R&D, procurement, warehouse and sales.

APPLICATION NOTE: For declarations or certificates completed before 25 May 2026, review the transition provisions of Circular 14/2026/TT-BKHCN and the stated certificate term. A new filing is not required solely because the circular changed where the transition rule applies, but changes to the regulation, declaration or product characteristics may still trigger re-declaration.

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.

Discuss your shipment dossier

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