Tiếng Việt
中文 (中国)
TOUCH PANEL EXPORT PROCEDURE FROM VIETNAM
“Touch panel” is not a sufficient customs description. Depending on the actual construction, the goods may be a flat-panel display module of heading 85.24, a touch-sensitive input screen, or a dedicated part/assembly for a phone, HMI or other equipment.
This guide follows product scope → market scan → HS → FTA/origin → market compliance → Cargo Ready/cut-offs → post-shipment. As no destination was specified, it uses a multi-market overview supported by shipment signals for the HS 8524 variant.
1. QUICK FACTS
Commercial shipment data for Vietnam-origin touch screen panels under HS 8524 shows South Korea 23% (21 shipments), Slovakia 19% (18), China 14% (13) for May 2024–Apr 2025. It is shipment-level commercial data, not official aggregate customs statistics.
On 28 Aug 2026, review the current framework under Decree 69/2018. Decree 292/2026 takes effect on 5 Sep 2026 and replaces Decree 69/2018, so shipments crossing that date need a new scope check.
Key routes to review are heading 85.24 for flat-panel display modules with/without touch and 8471.60.40 for touch-sensitive X-Y input screens. Export duty and VAT depend on the final HS and evidence.
Korea: AKFTA/RCEP (and compare VKFTA where relevant); Slovakia: EVFTA; China: ACFTA/RCEP. PSR must be checked against the final HS.
EU: RoHS/REACH and exact Ecodesign/CE scope; Korea: RRA/KC if the configuration becomes active ICT equipment; China: CCC Catalogue and China RoHS by product scope.
Freeze P/N, HS, compliance, origin evidence and packing before Cargo Ready; customs/gate-in before CY/CFS; SI/VGM and draft B/L/AWB before cut-off.
High-value fragile panels may move by Air or Sea depending volume. Packing should combine ESD + shock + moisture + stack control; screen battery/DG only where integrated.
2. PRODUCT SCOPE & TECHNICAL CLASSIFICATION
The commercial name cannot determine HS. Review the catalogue/drawing/BOM for display function, LCD/OLED technology, driver/control circuits, touch controller, interfaces, power, wireless features, completion level and end-use.
| Variant | Technical indicators | HS route to review | Evidence | Application note |
|---|---|---|---|---|
| LCD flat-panel display module without drivers/control circuits | LCD display + touch layer; no driver/control board | 8524.11 | Drawing, BOM, block diagram, interface spec | WCO HS 2022 created heading 85.24 for flat-panel display modules, whether or not incorporating touch. |
| OLED module without drivers/control circuits | OLED + touch; no driver/control circuits | 8524.12 | Panel spec, BOM | Separate from LCD. |
| LCD/OLED with driver/control circuits | Driver IC/board, control circuits or more complete interface | 8524.91 / 8524.92 or 8524.99 | Architecture, PCB/BOM, power/interface | Do not use the “without drivers” branch. |
| Touch-sensitive X-Y input screen for ADP | Main function is coordinate/touch input rather than a flat display module | 8471.60.40 | Functional spec, host connection, controller | Vietnam Trade Portal explicitly includes touch-sensitive screens. |
| Phone/wearable touch display part | Designed solely/principally for a specific device | Dedicated parts heading or 85.24 depending construction | P/N mapping, end-use statement | Do not apply the industrial/monitor conclusion automatically. |
| HMI/control assembly or complete touch monitor | CPU/PLC/control function or complete monitor | May fall outside 85.24/8471.60.40 | System architecture, OS/CPU, I/O | Separate conclusion/article recommended. |
3. EXPORT MARKETS & MARKET ACCESS
The brief did not specify a destination. A market scan of Vietnam exports of Touch Screen Panel under HSN 8524 for May 2024–Apr 2025 shows meaningful shipment signals to Korea, Slovakia and China; no single market dominates enough to force a one-market title.
| Market | Fit | Shipment signal | Market Access review | Data/evidence |
|---|---|---|---|---|
| South Korea | High for HS 8524 module route | 23% / 21 shipments | RRA conformity assessment where the actual goods are broadcasting/communications/ICT equipment; do not automatically apply a complete-monitor route to a passive component. Review KC/safety if a powered finished product is in scope. | P/N, circuit/driver status, EMC/RF evidence if active, importer role, AKFTA/RCEP origin file. |
| Slovakia / EU | High for display-module supply chain | 19% / 18 shipments | RoHS/REACH substance data; assess whether the item is a testable electronic display or a component/sub-assembly. CE/Ecodesign are not blanket requirements for every passive panel. | Material declarations, RoHS/SVHC evidence, technical drawing/BOM, importer data, EVFTA origin file. |
| China | Medium–high | 14% / 13 shipments | CCC only if the exact product is in the Catalogue; China RoHS 2026 by product definition. OEM buyers may impose additional material/quality requirements. | P/N, materials declaration, China RoHS evidence if in-scope, CCC scope check, ACFTA/RCEP origin file. |
4. VIETNAM EXPORT POLICY
For standard new touch panels used in normal electronics/industrial applications, the key issue is the exact product scope and any special triggers. Do not state “no export licence” based on name alone.
| Situation | Policy review | Legal timing | Trigger |
|---|---|---|---|
| New passive/standard module | Ordinary export framework, HS, duty, origin and destination compliance | Decree 69/2018 framework on 28 Aug 2026 | Final HS, end-use, condition |
| Shipments on/after 5 Sep 2026 | Re-check under the new foreign-trade-management framework | Decree 292/2026 effective 5 Sep 2026 | Effective date and any new lists/permits |
| Wireless/encryption/special function | Review relevant export-control/dual-use rules if triggered | Sectoral rules effective on the application date | RF, encryption, end-user/end-use |
| Used/refurbished/warranty/temporary export | Review customs procedure and used-goods rules separately | Foreign trade + customs rules | Condition, RMA/warranty, ownership |
5. HS CODE – EXPORT DUTY – EXPORT VAT
| Variant | Reference HS | Classification basis | Export duty | Export VAT | Evidence |
|---|---|---|---|---|---|
| LCD without driver/control | 8524.11 → final Vietnam 8-digit code | LCD, no driver/control | Check Decree 26/2023 Appendix I and current amendments | 0% only if statutory conditions are met | Drawing, BOM, driver status |
| OLED without driver/control | 8524.12 | OLED, no driver/control | As above | As above | Panel spec/BOM |
| LCD/OLED with driver/control | 8524.91 / 8524.92 or 8524.99 | Driver/control present | As above | As above | PCB/BOM/interface |
| X-Y touch input screen | 8471.60.40 | Vietnam Trade Portal description | Check final HS | Check 0% conditions | Functional spec/controller |
| Dedicated phone/HMI part | Not finalized in this overview | End-use/parts rules may apply | Final HS only | Actual export file | P/N mapping/end-use |
EXPORT DUTY
Conclusion: do not write “0% export duty” mechanically. Finalize the Vietnam 8-digit HS and check Decree 26/2023 plus amendments in force, including Decree 201/2026 effective 23 Jul 2026. If the HS is not named in the Export Tariff Schedule, apply the Decree 26 rule for unlisted goods and retain evidence of the tariff lookup.
EXPORT VAT
Conclusion: the 0% VAT rate is conditional, not automatic. Review Articles 17–18 of Decree 181/2025 and current amendments. Decree 144/2026 took effect on 20 Jun 2026; Finance/Tax should verify the contract, invoice, customs declaration and payment evidence for the actual transaction.
6. FTA / C/O / RULES OF ORIGIN
FTA selection comes after the final HS, destination and production structure are known. Touch panels can contain glass, polarizer, sensor layers, FPC, driver/controller ICs, adhesives, PCB and display cells, so the Origin Audit Trail must start at factory/procurement level.
| Market | FTA options | Origin document | PSR approach | Evidence |
|---|---|---|---|---|
| Korea | AKFTA / RCEP; compare VKFTA if relevant | Form AK / RCEP C/O or applicable mechanism | Check HS 2022 PSR; Circular 49/2025 applies new AKFTA PSR from 1 May 2026 | BOM, supplier origin, invoices, production records |
| Slovakia / EU | EVFTA | EUR.1 or eligible origin statement mechanism | Check Annex II to Circular 14/2026/TT-BCT | BOM, non-originating materials, production process |
| China | ACFTA / RCEP | Form E / RCEP C/O or applicable mechanism | Compare PSR and tariff benefit under the final HS | BOM, supplier declarations, inventory/batch records |
7. PRODUCT-SPECIFIC MARKET COMPLIANCE
| Trigger | EU / Slovakia | Korea | China | Pre-Cargo Ready action |
|---|---|---|---|---|
| Passive touch/display component | RoHS/REACH materials data; EC guidance says display components such as an LCD panel are outside the electronic-display Ecodesign regulation and some sub-assemblies are excluded when not independently assessable. | Do not assume standalone RRA; verify exact equipment status and attached tables. | Do not assume CCC; check Catalogue and China RoHS scope. | Materials declaration, BOM, drawing, intended-use evidence. |
| Active module with driver/control and data/power | Potential deeper Ecodesign scope if independently testable; CE directives only where the item meets their scope. | RRA may apply if it becomes ICT/broadcasting communications equipment. | Check CCC product category and China RoHS definition. | Test plan, circuitry, interface, importer confirmation. |
| Wireless / RF | RED/EMC/radio route if RF is integrated | RRA wireless conformity | Check applicable radio/CCC rules | RF bands/power/antenna/module ID. |
| SVHC / restricted substances | EU article suppliers face REACH information/notification duties where Candidate List SVHC >0.1% w/w; supply-chain role determines SCIP obligations. | Buyer environmental requirements vary. | China RoHS 2026 where exact product is in scope. | Supplier declarations/lab evidence. |
8. EXPORT DOCUMENT SET
| Group | Documents | Used for | Typical owner | Core matching data | Common error |
|---|---|---|---|---|---|
| Commercial | Contract/PO, Commercial Invoice, Packing List | Customs, booking, buyer docs | Sales/Docs | P/N, description, qty, value, Incoterm | Generic “touch panel” description. |
| Technical | Catalogue, drawing, BOM, block diagram, driver status, interface spec | HS/policy/compliance | Engineering/QA | Exact P/N/version | Using a nearby model datasheet. |
| Customs | Declaration and documents by customs type | Export clearance | Customs/Docs | HS, qty, value, origin | HS mismatch across documents. |
| Market compliance | RoHS/REACH/RRA/KC/CCC/China RoHS evidence where applicable | Market access | QA/Compliance/Importer | P/N/scope/manufacturer | Certificate does not cover exact variant. |
| Origin | C/O, BOM, supplier origin, production/inventory records | FTA | Factory/Procurement/Docs | HS, criterion, invoice, lot | Missing audit trail. |
| Transport/buyer | Booking, SI, VGM, B/L/AWB, insurance, L/C docs | Shipping/post-shipment | Forwarder/Docs/Finance | Packages, weight, marks, parties | Cut-off/B/L/L/C discrepancies. |
9. LEGAL BASIS – OLD → NEW MATRIX
| Layer | Instrument/source | Authority | Effective timing | Article/Annex | Application | Old → new |
|---|---|---|---|---|---|---|
| Vietnam foreign trade | Decree 69/2018 | Government | Current baseline on 28 Aug 2026 | Product-specific lists/measures | Export prohibitions/conditions/licensing | Replaced from 5 Sep 2026 by Decree 292/2026 |
| Vietnam foreign trade | Decree 292/2026 | Government | 5 Sep 2026 | Relevant annex/list | New implementing framework | Replaces Decree 69/2018 |
| Export duty | Decree 26/2023 + amendments incl. Decree 201/2026 | Government | Decree 201 effective 23 Jul 2026 | Export Tariff Schedule | Duty by final HS | Use current version on declaration date |
| VAT | Decree 181/2025 + Decree 144/2026 | Government | Decree 144 effective 20 Jun 2026 | Articles 17–18 | 0% export VAT scope/conditions | Use amended version |
| EVFTA origin | Circular 14/2026/TT-BCT | MOIT | 10 May 2026 | Annex II PSR | EVFTA origin | Repeals 11/2020 and 41/2022 |
| AKFTA origin | Circular 49/2025/TT-BCT | MOIT | 1 May 2026 | HS2022 PSR / Form AK | Korea origin | Replaces prior AKFTA circular set named in the instrument |
| EU | Regulation (EU) 2019/2021 + RoHS/REACH guidance | EU | By applicable regulation | Scope/exclusions; article obligations | Display/component and substances | Do not apply complete-display scope to excluded components |
| Korea | Radio Waves Act Art. 58-2 / RRA system | RRA | Current | Attached Tables 1–3 | Broadcasting/communications equipment conformity | Exact product assessment |
| China | CCC rules + China RoHS Catalogue 2026 | SAMR / MIIT | China RoHS 2026 catalogue published 28 May 2026 | Catalogue/product definitions | CCC and restricted substances when in scope | 2026 RoHS catalogue replaces first catalogue |
10. E2E EXPORT PROCESS
The process uses the new vertical 8-step timeline required by export-procedure v1.4: phase → action → items to freeze → gate risk.
Product scope + market scan
Freeze whether the item is a flat-panel display module or a touch-input device; LCD/OLED; with/without drivers or control circuits; interface, controller IC, wireless/power, condition and end-use. Scan markets by the exact HS rather than the commercial name.
HS – policy – FTA/C/O
Build a classification file distinguishing heading 85.24, code 8471.60.40 and any heading for a dedicated part/assembly; only then choose the FTA and PSR evidence.
Contract + buyer requirements
Freeze Incoterm, payment, P/N, dimensions, LCD/OLED/capacitive/resistive technology, resolution where relevant, controller, interface, labels, packing spec and compliance deliverables.
Complete market compliance
EU: review RoHS/REACH and Ecodesign/CE scope; Korea: assess RRA/KC where the item is active ICT equipment; China: assess CCC Catalogue and China RoHS by exact product. Lock origin evidence in parallel.
Booking – packing – trucking
Choose Air/Sea according to value and sensitivity; use ESD bags, protective films, foam/trays, shock and moisture protection; check ISPM 15 wood packaging and battery/DG if any.
Export customs declaration
Declare under the final HS/type and cross-check Invoice, PL, catalogue, drawing, BOM and origin; describe display technology, driver/control circuits and intended function where relevant.
SI – VGM – cut-offs – loading
Freeze shipper/consignee, packages, GW/NW, marks and VGM where applicable; meet gate-in/CFS; check draft B/L/AWB and destination data before release.
Complete post-shipment file
Finalize B/L/AWB, C/O, certificates/material declarations, buyer/bank set, payment follow-up, claims/surveys if any, and archive the Origin Audit Trail and compliance file.
11. CARGO READY / ETD / CUT-OFF TIMELINE
| Milestone | Items to freeze | Evidence | Owner | Late-risk |
|---|---|---|---|---|
| Before Contract | Scope, preliminary HS, market, FTA, buyer compliance, Incoterm/payment | Catalogue/drawing/BOM, buyer spec, origin inputs | Sales/Compliance/Engineering | Order accepted but P/N cannot meet market. |
| Before production / label freeze | BOM, P/N, market compliance, materials declarations | Approved BOM/test plan/artwork | Factory/QA | Retest/rework. |
| Before Cargo Ready | Origin evidence, packing, booking, certificates | Origin file, packing/booking data | Factory/Docs/Forwarder | Goods finished but file incomplete. |
| Before CY/CFS | Customs, trucking, gate-in, final weight | Declaration/booking | Ops/Customs | Roll/rebooking/storage. |
| Before SI/VGM | B/L data, weights, marks | SI/VGM/master data | Docs/Forwarder | Amendment/discrepancy. |
| Post on-board | C/O/certificates, final transport docs, buyer/bank set, payment | Origin/compliance file | Docs/Finance | Buyer hold/verification/payment delay. |
12. INCOTERMS – TRANSPORT – PACKING – COST
| Item | Operating approach | Freeze point | Possible cost |
|---|---|---|---|
| Air | Samples, replacements, urgent/high-value small lots | Chargeable weight, fragile/ESD, battery/DG | Air freight, screening, handling, DG surcharge |
| Sea LCL | Small commercial lots; stronger crate/pallet due to multiple handling | CFS cut-off, CBM, stack/moisture | LCL/CFS/local, packing, storage |
| Sea FCL | Large OEM volume; fewer direct handling events | Container plan, lashing, desiccant, VGM | Ocean freight, THC/local, trucking, dem/det if incurred |
| Packing | Protective film + ESD bag + tray/foam + carton/crate | Pressure points, glass edges, stack, ISPM 15 wood | Custom tray, ESD, crate/pallet |
| Incoterms | FCA/CPT/CIP/DAP often practical for Air/LCL; FOB/CFR/CIF where sea arrangement fits | Booking, customs, insurance, local charges, risk transfer | Freight/insurance/origin-destination charges |
13. RISKS & CONTROL POINTS
| Risk | Root cause | Impact | Control | When |
|---|---|---|---|---|
| Wrong market scan | 8524 vs 8471.60.40 not separated | Wrong market/FTA/compliance | Exact HS/end-use scan | Pre-contract |
| Wrong HS route | Commercial name only | Declaration/C/O/tariff errors | Classification file | Before quotation/customs |
| Driver status missed | No PCB/BOM review | Wrong 8524 subheading | Engineering sign-off | Before customs/C/O |
| EU complete-display rules copied to a component | No scope/exclusion review | Wrong compliance plan | Exact EU scope assessment | Before production |
| Korea RRA scope wrong | Passive vs active not separated | Importer hold or excess cost | RRA table check/importer confirmation | Pre-shipment |
| China CCC/RoHS scope wrong | Component treated as finished monitor or vice versa | Missing/wrong evidence | Catalogue/product-definition check | Pre-shipment |
| Panel damage | Poor ESD/foam/stack/moisture control | Crack/sensor damage/claim | Packing validation | Before Cargo Ready |
| Origin file incomplete | BOM/supplier origin/lot link missing | Verification/lost preference | Origin Audit Trail | Before C/O |
| Cut-off/B/L discrepancy | No master data | Roll/amendment/payment delay | Milestone owner + master dataset | Before cut-off/release |
14. FAQ
HS 8524 or 8471.60.40?
Use 85.24 for a flat-panel display module route; review 8471.60.40 where the principal function is X-Y touch input for ADP. Phone/HMI parts and complete monitors may classify elsewhere.
Can 8524.11/8524.12 be used when a driver/control circuit is fitted?
Those subheadings are the “without drivers or control circuits” branch. A module with drivers/control requires review of 8524.91/8524.92/8524.99 by technology.
Why is Korea not the only market in the title?
The dataset shows 23%, not a dominant majority, and HS 8524 data can include phone/wearable supply chains. The article therefore compares Korea, Slovakia/EU and China and requires an exact-variant re-scan.
Does every EU touch panel need CE?
No blanket conclusion is possible. A passive component/sub-assembly may not itself be apparatus subject to the same CE route as a finished monitor. Active power, control electronics or radio can change the analysis.
Is an LCD touch-panel component subject to EU Ecodesign?
European Commission guidance states display components such as the LCD panel are not covered by Regulation (EU) 2019/2021; a sub-assembly may be excluded if it cannot be independently assessed. Independently testable modules require a fresh scope check.
Does every panel entering Korea need RRA/KC?
No. RRA applies to in-scope broadcasting/communications equipment; a monitor is an ICT example. Passive panels and active/complete units must be assessed separately.
Does every panel entering China need CCC?
No. CCC is mandatory only for products in the Catalogue. Check the exact product definition and separately review China RoHS 2026 where in scope.
Can export duty be stated as 0%?
Not before the final HS and current Export Tariff Schedule are checked under Decree 26/2023 and amendments.
Is 0% VAT automatic for exports?
No. Articles 17–18 of Decree 181/2025 set scope and conditions; apply the amended rules including Decree 144/2026.
Which C/O route should be used?
Korea: compare AKFTA/RCEP and possibly VKFTA; Slovakia: EVFTA; China: ACFTA/RCEP. Choose after comparing tariff benefit, PSR and the ability to prove origin.
How should touch panels be packed?
Use ESD, protective film, tray/foam, moisture control, glass-edge protection and stack limits. LCL requires extra attention due to repeated handling.
What should be archived post-shipment?
Completed declaration, final transport document, C/O/origin file, compliance/material declarations, buyer/bank docs, payment evidence and the exact catalogue/BOM/test version for the P/N shipped.
15. POST-SHIPMENT OUTPUT & ARCHIVE
- Completed export customs declaration and classification file.
- Final B/L, AWB or Sea Waybill.
- C/O/origin document plus BOM, supplier evidence, production/inventory records.
- Market-compliance/material declarations and certificates where in scope.
- Contract/Invoice/PL and buyer/bank set.
- Payment evidence, debit/credit notes and claims/surveys if any.
- Exact catalogue, drawing, BOM, test report and label version for the shipped P/N.
RELATED ARTICLES
OPERATIONAL SOLUTION
For touch panels, the control chain should be P/N → technical character → HS → market requirement → origin → cut-off before Cargo Ready.
Product scope, HS, market access, FTA/origin, compliance and packing.
Invoice – PL – customs – SI – VGM – B/L/AWB – C/O against one master dataset.
Origin Audit Trail, compliance file, buyer/bank set and claim/verification records.
- Volza shipment-level market signal, HS 8524, May 2024–Apr 2025.
- WCO HS 2022 heading 85.24.
- Vietnam Trade Portal HS 84716040.
- Vietnam: Decrees 69/2018, 292/2026, 26/2023 and amendments, 181/2025 and 144/2026.
- Origin: Circular 14/2026 (EVFTA), 49/2025 (AKFTA), 05/2022 as amended by 32/2022 (RCEP).
- EU: European Commission electronic display/component guidance and ECHA.
- Korea: RRA Conformity Assessment System.
- China: SAMR CCC and MIIT China RoHS 2026.
Reconfirm HS, taxes, PSR, certificates and market compliance for the exact model/P/N and rules effective on the application date.
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.
EXPORT PROCEDURE FOR TEMPERATURE SENSORS TO SOUTH KOREA: HS, ORIGIN, DOCUMENTS AND PROCESS
RFID TAG EXPORT GUIDE FROM VIETNAM: MARKETS, HS, ORIGIN AND PROCESS
Exporting Smart Meters from Vietnam: Markets, HS, Origin, Compliance and E2E Workflow
BARE PCB EXPORT GUIDE FROM VIETNAM: MARKETS, HS, ORIGIN AND SHIPPING
EXPORTING PLC MODULES FROM VIETNAM: HS, ORIGIN, MARKET ACCESS & E2E PROCESS
HMI Panel Export Guide: Markets, HS 8537, Origin and Transport
PHOTOELECTRIC SENSOR EXPORT GUIDE FROM VIETNAM: MARKETS, HS, ORIGIN AND PROCESS
Exporting Pressure Sensors from Vietnam: US, Korea, EU, HS, Origin and E2E Workflow
EXPORTING PROXIMITY SENSORS FROM VIETNAM: MARKETS, HS, ORIGIN AND SHIPPING
OLED Monitor Export Guide: Markets, HS 8528, Origin and Transport
Projector Export Guide from Vietnam: Markets, HS, Origin and Shipping
Touch Panel Export Procedure from Vietnam: Markets, HS, Origin and E2E Process 2026
Exporting Video Wall Panels: Markets, HS, Origin, Compliance and E2E Workflow
EXPORTING ENCODERS FROM VIETNAM: MARKETS, HS, ORIGIN AND SHIPPING
Exporting Digital Signage from Vietnam: Markets, HS, Origin, Compliance and E2E Workflow