A Bare PCB is a printed circuit board without mounted active or passive components. The main control point is not the word “PCB”, but the distinction between bare board and PCBA, the layer count used for HS classification, and origin evidence required by the destination market.

This guide uses actual HS 8534 trade flows and compares China, Korea, Hong Kong, Japan and Thailand, then follows classification, origin, buyer compliance, packing and shipping controls through post-shipment.

1. QUICK OVERVIEW

MARKETS

2024 mirror-import data show China, Korea, Hong Kong, Japan and Thailand as the five largest destinations for HS 853400 from Vietnam.

EXPORT POLICY

New unpopulated bare boards generally follow the normal export route, subject to separate screening for scrap/waste, dual-use or special triggers.

Heading 85.34; indicative 8-digit codes: 8534.00.10 / .20 / .30 / .90 for single-sided, double-sided, multilayer and other.

C/O / FTA

RCEP can be reviewed for China/Korea/Japan; ATIGA/RCEP for Thailand; AHKFTA for Hong Kong. RCEP PSR for 8534.00: CTH or RVC40.

SPECIAL CONTROLS

Do not automatically impose CE/KC/PSE on a bare component. Focus on material declarations, restricted substances, buyer specs and end-use.

ETD / CUT-OFF

Freeze lot, quantity, package, GW/NW, origin evidence, SI and VGM before cut-off.

TRANSPORT

Air for urgent/high-value boards; Sea for stable volume. Protect against moisture, oxidation, warpage and surface damage.

Glossary: Bare PCB = unpopulated printed circuit board; PCBA = assembled PCB; CTH = change in tariff heading; RVC40 = at least 40% regional value content; Cargo Ready = date cargo is ready; SI/VGM Cut-off = carrier deadlines for shipping instructions/container mass data.

2. PRODUCT SCOPE & CLASSIFICATION

This guide covers new, unpopulated printed circuit boards. It does not cover assembled PCBA, complete mainboards, functional modules, PCB scrap/waste or used boards.

Variant	What to verify	Technical evidence	HS / trigger	Application note
Single-sided rigid PCB	One conductive side; substrate type	Drawing, stack-up, material spec, finish	8534.00.10 if facts match	Never classify only by trade name.
Double-sided PCB	Two conductive sides; plated through-holes where relevant	Layer map, drill file, finish	8534.00.20	Vias, plated through-holes or edge-finger/contact pads do not by themselves turn the board into PCBA; a mounted connector/component requires the product scope to be re-checked.
Multilayer / HDI PCB	Three or more conductive layers; blind/buried/microvia where relevant	Stack-up, copper thickness, impedance/via data	8534.00.30	Customs advance rulings on similar bare multilayer boards support this logic but are not universal precedents.
Flex / rigid-flex / metal-core	PI flex, rigid-flex, aluminium/copper core	Construction/BOM/material spec	Do not default to .90; review .10/.20/.30/.90 by sidedness/layer count and actual construction	Flex, rigid-flex and metal-core boards may still be single-sided, double-sided or multilayer; use .90 only when the facts do not fit those branches.
PCBA / assembled board	Mounted functional components	Component BOM, schematic, function	May fall outside 85.34	Separate classification is required.

Primary gate: once components are mounted so that the board performs a function, do not retain heading 85.34 merely because the commercial name still contains “PCB”.

3. EXPORT MARKETS & MARKET ACCESS

WITS/UN Comtrade mirror-import data for HS 853400 – Printed circuits in 2024 show imports from Vietnam of approximately USD 555.12m into China, 398.85m into Korea, 353.21m into Hong Kong, 169.34m into Japan and 165.13m into Thailand. As demand is distributed across several Asian electronics hubs, this article remains a multi-market guide.

Market	Fit	Market-access review	Product/company expectations	Data to prepare
China	High	Check importer/end-use and material/EEE rules if the board itself is placed on the market; do not assume a standalone certification requirement.	Restricted-substance data, lot traceability, stack-up/finish/impedance per buyer.	Invoice/PL, drawing, COC, material declaration, origin file.
Korea	High	Distinguish component from complete equipment; do not assume KC/RRA for a passive bare board.	IPC/quality controls, material data, supplier/lot traceability.	Drawing, inspection report, chosen origin route.
Hong Kong	High	Often part of electronics/re-export supply chains; freeze buyer/importer and origin representations.	Quality, lot, packing and origin evidence.	Invoice/PL, COC, origin file, marks.
Japan	High	Do not assume PSE applies to an unpowered bare PCB; screen the end-use and buyer requirements.	Tight copper/finish/warpage/impedance control; buyer may specify JPCA/IPC.	Inspection data, drawing revision, origin route.
Thailand	High	Check if the finished product or board scope falls under a compulsory standard; do not assume TISI applies to every bare component.	Buyer quality data, lot traceability, humidity/oxidation protection.	Invoice/PL, COC, ATIGA/RCEP origin file if used.

Separate deep-dive opportunities: the US and EU also show meaningful 2024 flows. EU shipments merit a dedicated REACH/SVHC/SCIP and RoHS analysis rather than mixing those duties into the Asian-market conclusion.

4. VIETNAM EXPORT CONDITIONS / POLICY

New commercial Bare PCB

Conclusion

New unpopulated Bare PCB normally follows the ordinary export route once HS, description and source documentation are locked, provided no special end-use/product trigger applies.

Legal basis

As of 28 Aug 2026, Decree 69/2018/ND-CP remains the baseline. Decree 292/2026/ND-CP becomes effective on 5 Sep 2026 and replaces Decree 69.

Implementation

Screen model, new/used condition, end-use, buyer/destination and applicable control lists before booking.

PCB scrap/waste, used boards, PCBA, military/dual-use end-use or special hazardous material cases must be separated from this guide.

5. HS CODE – EXPORT DUTY – EXPORT VAT

Variant	Indicative HS	Classification basis	Export duty	Export VAT	Evidence
Single-sided bare PCB	8534.00.10	Printed circuit – single-sided	Check current Export Tariff Annex I after final HS	Review 0% conditions and proof	Drawing/layer count/material
Double-sided bare PCB	8534.00.20	Printed circuit – double-sided	Same approach	Same approach	Layer map/finish/drilling
Multilayer bare PCB	8534.00.30	Printed circuit – multilayer	Same approach	Same approach	Stack-up/copper/via spec
Other bare printed circuit	8534.00.90	Where the facts do not fit the three branches	Same approach	Same approach	Construction/material/end-use

Export duty

Conclusion: do not publish an export-duty rate from the trade name alone. Verify the final 8-digit code against Decree 26/2023/ND-CP and current amendments, including Decree 201/2026 effective 23 Jul 2026.

Export VAT

Conclusion: “export = 0% VAT” is not automatic. Decree 181/2025/ND-CP sets the 0% rate in Article 17 and conditions in Article 18, subject to amendments including Decree 359/2025 and Decree 144/2026 effective 20 Jun 2026. Validate contract, payment and export evidence.

6. C/O – FTA – RULES OF ORIGIN

Origin must be built from the material BOM and actual production route: laminate/prepreg, copper foil, solder mask, surface-finish chemistry, imaging/etching/plating, drilling, lamination and final inspection.

Destination	FTA options to review	Origin proof	PSR / rule	Control point
China	RCEP; compare ACFTA where relevant	Appropriate proof under selected FTA	RCEP 8534.00: CTH or RVC40	Imported semi-finished PCB under heading 85.34 may fail a CTH route.
Korea	RCEP; compare VKFTA/AKFTA	Per selected agreement	RCEP: CTH or RVC40	Choose based on tariff benefit and evidence burden.
Japan	RCEP; compare VJEPA/AJCEP	Per selected agreement	RCEP: CTH or RVC40	Freeze criterion before C/O issuance.
Thailand	ATIGA or RCEP	Appropriate proof	Check current HS 8534 rule	Compare tariff, rule and transport conditions.
Hong Kong	AHKFTA if applicable and useful	AHKFTA origin proof	Check current HS rule	Do not assume re-export via Hong Kong automatically gets preference.

Origin Audit Trail

BOM/material consumption by board revision.
Purchase invoices, import declarations and supplier declarations.
Production routing and batch records.
RVC worksheet when using the RVC route.
Input C/O where cumulation is relied on.

7. PRODUCT-SPECIFIC COMPLIANCE

Trigger	Potential requirement	When triggered	Control
True bare PCB	Usually no standalone technical export licence solely because it is a bare board	No active/radio/power function and no special list trigger	Keep technical evidence proving the unpopulated state.
Restricted substances	Buyer declarations/testing; downstream EU RoHS/REACH evidence	Market, end-product or buyer requires material compliance	Supplier declarations + risk-based testing.
EU article/SVHC	REACH Article 33 information plus SCIP notification data for the relevant EU duty holder where Candidate List SVHC exceeds 0.1% w/w	Board/article is placed on EU market and threshold is exceeded	Exporter supplies composition/SVHC data; the EU supplier/importer separately assesses Article 33 communication duties and SCIP notification duties under the Waste Framework Directive.
Waste/scrap/used PCB	Environmental/waste controls	Shipment is waste, scrap or used board	Separate policy workflow.
Special end-use	Export-control/dual-use screening	End-user/end-use/design falls within a controlled list	End-user screening and current-list review.

EU nuance: the European Commission describes RoHS restrictions for EEE. Under REACH Article 33, suppliers of articles above the Candidate List threshold have supply-chain communication duties; SCIP is a separate EU notification layer under the Waste Framework Directive. Do not convert any of these into a blanket “Bare PCB requires CE” statement.

8. EXPORT DOCUMENT SET & FILING

Document group	Documents	Used at	Typical owner	Core data match	Common error
Commercial	Contract/PO, Invoice, Packing List	Customs/booking/buyer	Sales/Docs	Part no., revision, qty, value, Incoterm	Description too generic; revision mismatch.
Technical/HS	Drawing, stack-up, layer count, material/finish, photos	Classification/customs	Engineering/QA	Unpopulated status, layer count, dimensions	PCBA declared as bare PCB.
Origin	C/O if used, BOM, routing, supplier files, RVC worksheet	FTA/origin	Docs/Factory/Procurement	HS, criterion, invoice, lot	Missing supplier evidence.
Quality/compliance	COC, inspection, material/restricted-substance data where required	Pre-Cargo Ready/buyer	QA/Compliance	Lot, part no., finish, revision	Report covers wrong lot/revision.
Transport	Booking, SI, weight/VGM data according to booking scope, B/L/AWB, marks	Shipping/post-shipment	Forwarder/Docs	Packages, GW/NW, parties	Weight/marks mismatch; missed cut-off.

Checklist before Cargo Ready

Part number + drawing revision.
Layer count + stack-up + copper thickness.
Surface finish: HASL/ENIG/OSP/Immersion Tin/Silver, as applicable.
Impedance/tolerance/warpage if controlled by the buyer.
Lot/date code and quantity aligned with the PO.
COC/inspection/material declaration required by market or buyer.
Origin file sufficient for the selected FTA/C/O route.

9. LEGAL / REGULATORY MATRIX

Layer	Instrument/source	Authority	Effective timing	Relevant section	Application	Old → new
Vietnam – foreign trade	Decree 69/2018/ND-CP	Government	Applicable on 28 Aug 2026	Foreign-trade scope	Export restrictions/licensing review	Replaced by Decree 292 from 5 Sep 2026
Vietnam – foreign trade	Decree 292/2026/ND-CP	Government	5 Sep 2026	Articles 64–65	New foreign-trade framework	New
Vietnam – export duty	Decree 26/2023 + amendments incl. Decree 201/2026	Government	201 effective 23 Jul 2026	Export Tariff Annex I	Rate checked only after final 8-digit HS	Current amended tariff
Vietnam – VAT	Decree 181/2025 + 359/2025 + 144/2026	Government	144 effective 20 Jun 2026	Articles 17–18 and amendments	0% only if conditions are satisfied	181 → 359 → 144
FTA – RCEP	Circular 05/2022 amended by Circular 32/2022	MOIT	HS2022 PSR from 1 Jan 2023	PSR 8534.00	CTH or RVC40	HS2022 update
FTA – EVFTA	Circular 14/2026/TT-BCT	MOIT	10 May 2026	PSR / EUR.1 annexes	EU preference if origin conditions are met	Replaces Circulars 11/2020 & 41/2022
EU – substances	RoHS / REACH-SCIP official guidance	EC / ECHA	Role/product dependent	Scope / article obligations	Restricted-substance and SVHC data	Use current Candidate List

GATE RISK

On-board does not close the job if origin/buyer/bank evidence is incomplete.

11. PRE-ETD / CARGO READY / CUT-OFF TIMELINE

Milestone	What to freeze	Evidence/data	Owner	Delay risk
Before Contract	Scope, preliminary HS, market/FTA, buyer spec, Incoterm/payment	Drawing/sample spec/buyer list	Sales/Engineering/Compliance	PO accepted although origin/spec cannot be met.
Before production freeze	Revision, stack-up, material source, origin route	BOM/routing/supplier files	Engineering/Procurement	Material change invalidates origin/testing.
Before Cargo Ready	COC/inspection, material data, lot, packing, booking	COC/test/packing/origin file	QA/Docs/Forwarder	Cargo ready but exact-lot evidence missing.
Before CY/CFS cut-off	Customs, trucking, gate-in/CFS	Declaration/booking/package/GW	Ops/Customs	Roll/rebooking/storage.
Before SI/VGM cut-off	B/L fields and weight	SI/VGM/parties/marks	Docs/Forwarder	Amendment/discrepancy.
After on-board	Final transport docs, C/O, buyer/bank set, archive	B/L/AWB, C/O, COC, payment docs	Docs/Finance/QA	Payment delay or origin verification failure.

12. INCOTERMS – TRANSPORT – PACKING – COST

Item	Bare PCB approach	Control point
Incoterm	FCA is usually the cleaner fit for Air/road or terminal delivery; FOB is only for sea/inland-waterway shipments when delivery occurs on board. EXW/DAP/CIP depend on contract and mode.	Separate risk transfer from freight/local-charge allocation.
Air	Samples, urgent production, high-value HDI/multilayer.	Volumetric weight, carton strength, moisture protection.
Sea LCL/FCL	Large stable programs and cost-sensitive cargo.	Moisture/oxidation, consolidation damage, pallets/crates; VGM follows packed-container responsibility, while for LCL the consolidator normally finalises container VGM.
Packing	Interleaf/protective film, rigid support, moisture barrier/vacuum, desiccant; ISPM 15 for in-scope wood.	Prevent pad/finish scratches and warpage.
Cost	Testing/compliance, C/O, packing, trucking, customs, local charges, freight, insurance, amendment/rebooking.	Do not publish absolute charges without a shipment quote.

Transport-quality nuances

ENIG, OSP and other finishes have different shelf-life/storage controls under the agreed product specification.
HDI/fine-line boards require particular control of warpage, edge/corner protection and surface cleanliness.
Do not treat Bare PCB as DG by default; screen separately if the shipment includes chemicals, batteries or other dangerous materials.

13. RISKS & CONTROL POINTS

Risk	Root cause	Impact	Control	Timing
Bare PCB mistaken for PCBA	Generic description or mounted components	Wrong HS/policy/C/O	Photos + BOM + drawing + unpopulated statement	Pre-contract/classification
Wrong layer count	No stack-up/layer map	Wrong 8-digit code	Technical classification file	Before customs
Origin rule failure	Input HS/origin or RVC evidence missing	Preference lost/verification	BOM + supplier HS/origin + CTH/RVC test	Before C/O
Buyer quality rejection	Finish/impedance/warpage not tied to revision	Claim/rework/line stop	Golden spec + exact-lot inspection	Before Cargo Ready
Oxidation/moisture/scratch	Weak packing	Solderability/surface defect downstream	MBB/vacuum/desiccant/support	Packing
EU material-data gap	SVHC/restricted-substance data unmanaged	Importer/buyer compliance gap	Supplier declarations + targeted testing	Pre-contract/Cargo Ready
Missed cut-off / doc mismatch	Booking changes or SI/C/O/PL inconsistency	Roll/amendment/payment delay	Milestone + document cross-check	Before cut-off
Origin audit gap	BOM/routing/supplier records not archived	C/O cannot be substantiated later	Shipment-based audit trail	Post-shipment

14. FAQ

Can Bare PCB be exported from Vietnam?

Generally yes for new unpopulated boards under the ordinary export route, subject to product/end-use screening and the rules effective on the shipment date.

What HS code is normally reviewed?

Heading 85.34; 8534.00.10 single-sided, .20 double-sided, .30 multilayer and .90 other, subject to technical confirmation.

Is a PCB with a few mounted components still a Bare PCB?

Do not assume so. Mounted components may change the product nature and classification.

Can RCEP be used for China, Korea or Japan?

Potentially, if all conditions are met. RCEP PSR for 8534.00 is CTH or RVC40.

Which C/O is relevant for Hong Kong?

AHKFTA can be reviewed if applicable and beneficial; do not request a certificate without checking the importer tariff and origin rule.

Does Bare PCB exported to the EU automatically require CE?

No blanket conclusion should be made from the name alone. Determine whether it is a component or standalone EEE and assess the downstream product/regulation.

Is RoHS testing mandatory for every lot?

Not automatically for every Bare PCB lot. Testing frequency should follow market/buyer scope, material-change controls and risk.

Air or Sea?

Air suits urgent/high-value boards; Sea suits larger stable volumes. Compare lead time, freight and moisture/oxidation risk.

Do samples still need customs data?

Depending on value and shipping route, customs treatment varies, but the goods description/value and required compliance/origin data must remain accurate.

What should be archived after shipment?

Declaration, Invoice/PL, final B/L/AWB, C/O if used, COC/inspection/material declarations, PO/contract, payment documents and the Origin Audit Trail.

15. FINAL OUTPUT & POST-SHIPMENT ARCHIVE

Completed export declaration plus the technical classification file.
Final B/L/AWB/Sea Waybill and booking/cut-off records.
C/O/origin proof and Origin Audit Trail where a preference is used.
COC, inspection and restricted-substance/material declarations required by buyer/market.
Contract/PO, Invoice, Packing List and payment file.
Claim/survey/8D/CAPA records if issues arise.
Archive by part number + revision + lot + shipment.

FOOTNOTES / OFFICIAL SOURCES

WITS / UN Comtrade mirror-import data for 2024, HS 853400 – Printed circuits from Vietnam.
Vietnam Trade Portal – HS 85.34 nomenclature and RCEP PSR for 8534.00.
Decree 69/2018/ND-CP and Decree 292/2026/ND-CP.
Decree 26/2023/ND-CP and Decree 201/2026/ND-CP.
Decree 181/2025/ND-CP, Decree 359/2025/ND-CP and Decree 144/2026/ND-CP.
Circular 14/2026/TT-BCT – EVFTA rules of origin.
European Commission – RoHS; ECHA – Article 33/Candidate List and SCIP information requirements.

WITS 2024 market data RCEP PSR 8534.00 Decree 292/2026 EU RoHS ECHA Article 33

EXPORT OPERATING CONTROL

For Bare PCB, lock five data layers early: product scope – HS – origin – buyer quality/compliance – shipment milestones. One shipment master data sheet should keep PO, Invoice, Packing List, COC, C/O, SI and B/L/AWB aligned.

Confirm Bare PCB versus PCBA and final HS before accepting booking data.
Review market access plus FTA/PSR for the actual destination.
Check BOM, routing and supplier evidence to build the Origin Audit Trail.
Freeze packing, Cargo Ready, SI/VGM/CY-CFS cut-offs and the post-shipment file.

ELECTRICAL – ELECTRONICS – IT EQUIPMENT

F&B

MACHINERY

HOUSEHOLD GOODS

COSMETICS – PERSONAL CARE

ELECTRICAL – ELECTRONICS – IT EQUIPMENT

F&B – FOOD & BEVERAGE

MACHINERY

HOUSEHOLD GOODS

COSMETICS – PERSONAL CARE

BARE PCB EXPORT GUIDE FROM VIETNAM

1. QUICK OVERVIEW

2. PRODUCT SCOPE & CLASSIFICATION

3. EXPORT MARKETS & MARKET ACCESS

4. VIETNAM EXPORT CONDITIONS / POLICY

New commercial Bare PCB

5. HS CODE – EXPORT DUTY – EXPORT VAT

Export duty

Export VAT

6. C/O – FTA – RULES OF ORIGIN

Origin Audit Trail

7. PRODUCT-SPECIFIC COMPLIANCE

8. EXPORT DOCUMENT SET & FILING

Checklist before Cargo Ready

9. LEGAL / REGULATORY MATRIX

10. E2E EXPORT PROCESS – 8 STEPS

Product scope + market scan

HS – policy – FTA/C/O

Contract + buyer requirements

Quality / compliance completion

Booking – packing – trucking

Export customs declaration

SI – VGM – CY/CFS cut-offs – loading

Final documents + archive