TEMPORARY EXPORT AND RE-IMPORT PROCEDURE FOR REPAIR AND WARRANTY GOODS
Sending defective machinery back to the manufacturer may look like a non-sale shipment, but the customs file is not simple. Without locked model and serial data, the re-import declaration may not reconcile with the temporary export. A whole-unit warranty replacement needs a different evidence path from the return of the same repaired unit, while repair charges and replacement parts can be omitted or misclassified in the declaration if the transaction is not documented clearly. The correct approach is to classify the transaction before selecting a procedure code, build an evidence chain from the pre-export condition to the post-repair item, register the period and control every change. This article sets out the dossier, procedure, tax-control points and risk matrix for machinery, equipment and parts sent abroad for repair or warranty and subsequently returned to Vietnam.
QUICK FACTS
Temporary export and re-import applies where the company sends its goods abroad for a limited period for repair, warranty or replacement and brings them back. It should not be automatically used for returned exports, overseas processing or an independent replacement shipment.
A generic name such as “machine part” is insufficient to link the temporary-export declaration with the re-import declaration. Use model, part number, serial number, nameplate photos, condition and the original import declaration where available.
For repair and warranty goods, the temporary-export period follows the agreement with the overseas party and is registered with Customs. Any extension should be filed before the registered period expires.
Duty exemption depends on the purpose, registered period and the conditions in Article 13 of Decree 134/2016. A whole-unit warranty replacement may still qualify where the replacement preserves the basic shape, function and characteristics of the replaced goods; a new serial number does not automatically disqualify it. Repair fees, parts, freight and insurance should be documented separately for declaration and review, but they are not automatically taxable merely because they appear on an invoice.
SCOPE
Mainly applies to production machinery, electrical/electronic equipment, measuring instruments, moulds, tools, parts and components controlled by a Vietnamese enterprise and sent overseas for fault inspection, repair, warranty or replacement before re-import.
KEY TERMS
| TERM | MEANING | OPERATIONAL ROLE |
|---|---|---|
| Temporary export – re-import | Goods leave Vietnam for a defined period and are subsequently re-imported under the permitted customs mechanism. | Creates one linked file covering temporary export, repair evidence and re-import. |
| Warranty | Seller or manufacturer obligation to remedy a defect under agreed warranty terms, often without a repair charge. | Supports the purpose and tax treatment. |
| Repair | Restoration of the goods; parts may be replaced, but the process should not be assumed to permit a new model, new function or a different product. | Determines whether the re-imported item remains the temporarily exported item. |
| Replacement | Replacement of a component or, under some warranties, the whole unit. A whole-unit replacement may have a new serial number. | Requires manufacturer confirmation and a separate review of duty, used-goods and sectoral rules. |
| RMA – Return Merchandise Authorization | Supplier/manufacturer authorization to receive goods for inspection, repair or warranty replacement. | Links the defect, model, serial, receiving location and expected timeline. |
| Repair Report | Report stating the defect, work performed, parts replaced, serial before/after and test results. | Core evidence for re-import and valuation review. |
NATURE AND OPERATING MECHANISM
A temporary export–re-import file is not two unrelated declarations. It is one control chain: company-controlled goods → actual temporary export → repair/warranty work → actual re-import → goods or parts that do not return.
THREE KEYS MUST REMAIN INTACT
- Legal key: repair/warranty purpose, agreement, registered period, licence and duty-exemption conditions.
- Identification key: technical name, model, part number, serial, nameplate photos, configuration and accessories.
- Value key: reference value, repair fee, replacement parts, freight, insurance and actual payment.
Under the procedure-code table and Customs operational guidance currently in use, domestic enterprises commonly use G61 – Temporary export and G51 – Re-import of temporarily exported goods. The procedure code does not by itself grant duty exemption; the legal purpose, period, evidence and conditions remain decisive.
REPAIR AND WARRANTY CASE MATRIX
| CASE | NATURE | EVIDENCE | RISK | CONTROL |
|---|---|---|---|---|
| Same unit repaired, same serial | Same model, serial and function return. | RMA, nameplate photos, repair report and temporary-export declaration. | Lower risk if quantity, weight and accessories reconcile. | Perform one-to-one reconciliation and reference the temporary-export declaration. |
| Main unit repaired with parts replaced | Main machine remains but boards, motors, modules or parts are changed. | Parts list, part value, part numbers and technical report. | Value and sectoral compliance may change; removed parts need a disposition. | Separate repair service, replacement parts and items that do not return. |
| Whole unit replaced, new serial | Manufacturer sends another unit of the same or equivalent model. | Warranty replacement letter, old-to-new serial mapping and specifications. | Do not assume it is simply the same goods; used-goods, value, duty or licence issues may arise. | Declare it as a warranty replacement and retain the sales contract, warranty terms, replacement confirmation and old-to-new model/serial mapping. Review used-goods or licensing rules only where the actual configuration, condition or product group triggers them. |
| Goods cannot be repaired and do not return | Goods remain abroad, are destroyed or transferred. | Unrepairable statement, destruction/transfer evidence and company decision. | Temporary-export declaration remains unresolved and purpose may change. | Do not allow silent expiry; complete the appropriate closing procedure. |
| Paid repair outside warranty | Company pays service, parts and logistics charges. | Repair contract, service invoice, payment proof and repair report. | Duty exemption cannot be inferred only from the customs code; re-import value needs separate assessment. | Separate original-goods reference value from service, parts and transport costs. |
DOSSIER AND DATA TO CHECK
| DOSSIER GROUP | DOCUMENTS | PREPARER/ISSUER | CONTROL POINT |
|---|---|---|---|
| Ownership and origin | Original import declaration, purchase contract, old invoice, fixed-asset register or warehouse receipt. | Importer / Accounting | Prove control of the goods and identify the original shipment. |
| Defect and repair authorization | Defect report, photos, technical emails, RMA, warranty claim and repair quotation. | Technical team + supplier | Lock the defect, scope, fee status and expected period. |
| Identification list | Technical name, proposed HS, model, part number, serial, quantity, accessories and nameplate photos. | Engineering + Customs team | Reconcile export and re-import and detect a replacement unit. |
| Statutory and supporting temporary-export records | Declaration, pro forma/non-commercial invoice, packing list, repair/warranty agreement and licences/sectoral results where required. | Trade compliance / Forwarder | State the repair/warranty purpose, registered re-import period and no-sale nature where applicable. |
| Post-repair dossier | Repair report, replacement letter, repair/parts invoice, replaced-parts list, test result and post-repair serial photos. | Repairer / Manufacturer | Explain changes in serial, configuration, weight and value. |
| Re-import dossier | Re-import declaration linked to the temporary export, transport document where applicable, invoice, packing list, sectoral and tax records. | Trade compliance / Customs broker | Close the temporary-export cycle and confirm actual returned quantity. |
| Exception closure | Extension, unrepairable confirmation, destruction, change of purpose or non-return handling. | Legal + Trade compliance + Accounting | Avoid an expired declaration with no legally supported disposition. |
PROCEDURE
- STEP 1 – CLASSIFY THE CASE: determine whether this is company-owned equipment sent abroad for repair and return, a returned export, overseas processing, lease/loan or an independent replacement shipment.
- STEP 2 – SCREEN PRODUCT CONTROLS: check prohibitions, temporary-export licences, sectoral inspection, used-goods rules, encryption, chemicals, batteries, medical devices and project-asset conditions.
- STEP 3 – LOCK THE REPAIR AGREEMENT: identify the repairer, location, period, warranty status, expected charges, authority to replace parts/units, treatment of defective parts and the outcome if repair fails.
- STEP 4 – BUILD THE IDENTIFICATION MATRIX: model, part number, serial, configuration, accessories, condition, nameplate photos, weight and the original import declaration.
- STEP 5 – REGISTER TEMPORARY EXPORT: under the current operational code table, G61 is commonly used for temporary export for repair/warranty. Reconfirm the code on the system and with the filing Customs office; declare purpose, period, RMA and identification details.
- STEP 6 – CONFIRM ACTUAL EXPORT: retain declaration status, customs-supervision exit evidence, transport document, final packing list and proof of delivery to the repairer.
- STEP 7 – MONITOR REPAIR CHANGES: require prior notice of model changes, new serial, major parts and additional charges. Before the registered period expires, file a supplementary declaration and submit one copy of the agreement with the overseas party on the extension to the Customs office that handled the temporary export.
- STEP 8 – PREPARE RE-IMPORT: finalize the repair report, service/parts invoice, parts list, serial mapping, condition, transport document and any renewed sectoral approval.
- STEP 9 – REGISTER RE-IMPORT: G51 is commonly used for re-import of temporarily exported goods under the current code table. Reference the G61 declaration and accurately state whether the return is a repaired unit or a warranty replacement, the before/after model and serial, quantity differences and actual payments. Do not infer a tax liability merely from a repair or parts invoice.
- STEP 10 – RECONCILE AND CLOSE: compare temporary-export quantity, re-import quantity and non-returned items; finalize tax, accounting, fixed-asset serials and the post-clearance file.
COMMON RISKS AND ERRORS
| ERROR | CAUSE | IMPACT | CONTROL |
|---|---|---|---|
| Generic goods description | No model, serial or nameplate photo. | Cannot prove the re-imported goods are the temporarily exported goods. | Create a serial list and photographs before packing. |
| “Free warranty” without evidence | Expired purchase warranty or RMA does not state warranty terms. | Customs asks for tax and value explanation. | Retain purchase contract, warranty terms, accepted claim and no-charge confirmation. |
| Replacement unit declared as the old unit | Serial and possibly model change is not disclosed. | Misdeclaration, used-goods, licence and duty risks. | Use old-to-new serial mapping and warranty replacement letter. |
| Repair or parts fee omitted | A “no commercial value” invoice is used for the entire shipment. | Insufficient customs valuation basis and payment mismatch. | Separate goods reference value, service, parts, freight and insurance. |
| Extension requested after expiry | No deadline monitoring. | Open declaration, possible enforcement and financial consequences. | Set alerts and supplement before expiry. |
| Function or main configuration changes | The repair becomes an upgrade to a different product. | HS code, sectoral policy and procedure may change. | Reassess the goods and procedure before re-import. |
| Non-returned goods not closed | Goods are destroyed or retained abroad with no customs closure. | Temporary export and asset records do not reconcile. | Retain disposition evidence and complete the appropriate procedure. |
LEGAL BASIS AND SOURCES
| INSTRUMENT/SOURCE | ISSUER – STATUS | ROLE | NOTE |
|---|---|---|---|
| Consolidated Customs Law 54/VBHN-VPQH | Office of the National Assembly; consolidated 23 Mar 2026 | Customs declaration, dossier, inspection, supervision and record responsibility. | Applied together with current implementing instruments. |
| Consolidated Decree 46/VBHN-BTC – Article 50 | Ministry of Finance; consolidated 24 Nov 2025 | Covers repair, warranty and replacement cases; basic statutory dossier, filing office, procedure, registered period and extension. | Before expiry: supplementary declaration plus one copy of the extension agreement submitted to the Customs office handling the temporary export. |
| Circular 121/2025/TT-BTC | Ministry of Finance; effective 1 Feb 2026 | Updates customs dossiers, data fields and record retention. | Article 50 does not list a repair or warranty contract as a universal mandatory item for every declaration. It is important supporting evidence for purpose, period, replacement and exemption conditions, and is submitted or produced when the applicable case or authority requires it. |
| Consolidated Export and Import Duties Law 96/VBHN-VPQH | Office of the National Assembly; consolidated 31 Mar 2026 | Point c Clause 9 Article 16 provides the duty-exemption basis for qualifying warranty, repair and replacement goods. | Exemption depends on conditions, evidence and the registered period. |
| Decree 134/2016/ND-CP – Article 13 | Government; direct source for exemption conditions | Repair/warranty goods must not change basic shape, function or characteristics or create other goods. A warranty replacement must preserve those basic characteristics of the replaced goods. | A new serial is not an automatic exclusion; prove replacement under the sales-contract warranty. |
| Decision 1357/QD-TCHQ and Customs Letter 14828/CHQ-GSQL dated 3 Apr 2026 | Vietnam Customs; fact-specific operational guidance | Code reference: the 2026 letter records G61/G51 for the delivering party in a repair/recycling scenario that does not change code, name, nature or function. | Do not extend mechanically to EPEs, returned exports, processing or a transaction of a different legal nature. |
FAQ
Must re-import use the same border checkpoint as temporary export?
Article 50 allows filing at a convenient Customs office. The re-import dossier must still clearly link to the temporary export and meet transport, supervision and licence requirements.
Which procedure codes are commonly used?
For a domestic enterprise, G61 is commonly used for temporary export and G51 for re-import of temporarily exported goods under the current code table. EPE, returned exports and processing cases may use different codes.
Can a no-charge warranty shipment be declared at zero value?
No-charge does not mean no customs value. The declaration needs a reasonable customs value, while goods reference value, service, parts, freight and insurance are separated according to the actual case.
Can a replacement unit with the same model but a new serial be linked to the temporary export?
Yes, potentially. Clause 2 Article 13 of Decree 134/2016 expressly addresses replacement under the warranty terms of a sales contract, provided the replacement preserves the basic shape, function and characteristics of the replaced goods. A new serial does not automatically remove the exemption, but the company should retain the contract/warranty terms, replacement confirmation, old-to-new model/serial mapping and declare the facts accurately.
What if repair takes longer than the registered period?
Before expiry, submit a supplementary declaration and a copy of the extension agreement with the overseas party to the Customs office handling the temporary export.
What if the machine is unrepairable and remains abroad?
Do not leave the declaration to expire silently. Retain confirmation and destruction/transfer records, complete the appropriate change-of-purpose or closing procedure and determine tax consequences.
Is sectoral inspection required again on re-import?
It depends on the product, post-repair model/configuration, purpose and sectoral law. Do not assume exemption merely because the item was previously imported; also check any express exemption or simplified mechanism.
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