EXPORTING METAL SAWING MACHINES FROM VIETNAM
A machine may clear Vietnam export customs and still be delayed or rejected at destination if the exporter classifies by trade name, promises preferential origin before checking the PSR, or waits until production is finished to review CE/TISI/PSE and buyer specifications. For industrial machinery, a change in model, voltage, controller or packing can affect customs, origin, certification and booking at the same time.
This guide covers new industrial metal sawing/cutting-off machines from product identification → market access → Vietnam export policy → HS/duty/VAT → origin → compliance → Cargo Ready/cut-offs → post-shipment. Hand-held saws, laser/plasma cutters, woodworking machines, standalone blades and used equipment are separated where the legal logic changes.
1. QUICK OVERVIEW
HS6 846150 data supports reviewing Czech Republic/EU, Cambodia, Japan and Thailand. Trade data is a market signal, not the final classification of a specific model.
Do not invent a licence from the product name. Review Decree 292/2026/ND-CP and perform strategic-trade/dual-use screening where technical characteristics or end-use trigger it.
Reference HS 8461.50.00 where the goods are qualifying machine tools for sawing/cutting off metal by material removal. Export duty is separate from MFN import duty; 0% VAT is conditional.
EU: EVFTA; Japan: AJCEP/VJEPA/CPTPP/RCEP; Cambodia & Thailand: ATIGA/RCEP. Select the route based on PSR + destination tariff + evidence.
EU requires careful 2026–2027 machinery-law transition planning. Japan PSE and Thailand TISI are scope-based and should not be applied as blanket requirements.
Lock packed dimensions, GW/NW, center of gravity, lifting points, crating/lashing, fluids/batteries, SI/VGM/CY-CFS cut-offs and final documents before the shipment starts moving.
QUICK GLOSSARY
Market Access = destination entry/placing-on-market conditions; PSR = Product Specific Rule; Cargo Ready Date = cargo-ready date; SI Cut-off = Shipping Instruction deadline; CY/CFS Cut-off = terminal/CFS delivery deadline; VGM = Verified Gross Mass; OOG = out-of-gauge cargo; DG = dangerous goods.
2. PRODUCT SCOPE & DETAILED CLASSIFICATION
Do not classify by the generic term “metal saw.” Identify at least the machine type, cutting technology, work material, automation level, power supply, CNC/PLC, accessories, battery/liquid content, new/used status and intended use.
| Variant | What to check | Evidence | Possible policy/compliance | Application note |
|---|---|---|---|---|
| Industrial band/circular saw | Fixed machine; metal working; cutting with saw blade | Catalogue, datasheet, photos, model, power, dimensions | Reference HS 8461.50.00; destination safety; origin | Core scope of this article. |
| Hand-held powered saw | Designed to be held during operation | Catalogue, construction, power source | Hand-held tool HS; separate electrical/safety rules | Do not use the fixed-machine conclusion. |
| Laser/plasma/water-jet cutter | Cutting by laser, plasma or water jet | Technology spec, CNC data | Different HS and compliance | Separate conclusion required. |
| Wood/plastic saw | Primary material is not metal | Catalogue, work material | Woodworking/other hard-material machine heading | Do not group with metal saws. |
| Saw blade/part | Blade, tool or part only | Part number, material, function | Tool/part HS; separate origin | Not a complete machine. |
| Used/refurbished | Used or reconditioned | Year, serial, condition records | Separate market access and buyer requirements | Split analysis where triggers change. |
3. EXPORT MARKETS & MARKET ACCESS
Trade statistics should be used as a market-selection signal, not as a substitute for legal research. Under HS6 846150, Czech Republic reported 2023 imports from Vietnam of about USD 1.013 million; Cambodia reported about USD 2.098 million. Reporter/mirror statistics may differ because of timing, valuation, re-exports or reporting methods, so the figures should not be added to infer market share.
| Market | Trade signal | Market Access to lock | FTA/origin | Operational point |
|---|---|---|---|---|
| Czech Republic / EU | 2023 imports from Vietnam about USD 1.013m. | Machinery safety, CE, technical file, risk assessment, declaration and instructions; plan for 20 Jan 2027 transition. | EVFTA; current origin rules under Circular 14/2026. | Packing must withstand sea + EU inland legs; technical documents should be ready before placing on market. |
| Cambodia | 2023 imports from Vietnam about USD 2.098m. | Do not invent one universal machine certificate; importer should confirm exact technical/electrical/import requirements. | ATIGA e-Form D or RCEP. | Road can be practical; lock border, axle/weight/dimensions and any OOG/transloading need. |
| Japan | Relevant actual trade and a documentation-intensive machinery market. | PSE only if the exact product/component is in designated Electrical Appliances and Materials; workplace machinery safety is a separate layer. | AJCEP / VJEPA / CPTPP / RCEP. | Standardize manual, wiring diagram, rating plate, serial, test/spec and packing records before production freeze. |
| Thailand | Significant HS846150 import market and actual Vietnam trade. | Check exact model against the current compulsory TISI list; a general TIS standard does not make every saw compulsory. | ATIGA e-Form D or RCEP. | Confirm fixed/transportable status, voltage and importer requirements before concluding compliance. |
4. VIETNAM EXPORT POLICY
For a new ordinary industrial metal sawing machine, do not create an export-licence requirement merely from the trade name. Screen the actual goods against current prohibited/restricted/licensed mechanisms and technical/end-use controls. Decree 292/2026/ND-CP, effective 5 Sep 2026, replaced Decree 69/2018 as the general foreign-trade framework.
Circular 48/2026/TT-BCT sits within the new framework but its detailed scope is limited to the matters it actually regulates; it should not be cited as creating a machine-specific export licence where the product is outside that scope.
Where technical characteristics or end-use trigger strategic-trade controls, screen under the applicable framework and Circular 42/2026/TT-BCT, effective 12 Sep 2026, on MOIT-controlled dual-use goods. The conclusion must come from technical specifications/end-use, not the words “metal saw”.
Prepare a Policy Screening Sheet showing working HS, model, cutting technology, CNC/controller, accuracy, power, end-use/end-user, destination, condition and included fluids/batteries. Then screen in sequence: prohibited/restricted → licence/condition → dual-use → DG → destination requirements.
5. HS CODE – EXPORT DUTY – EXPORT VAT
5.1 HS CODE: CLASSIFY BY FUNCTION AND CUTTING TECHNOLOGY
For qualifying industrial band/circular/cold saw machine tools that remove metal/cermets by sawing or cutting off, the reference code is 8461.50.00. Do not apply it to hand-held tools, laser/plasma equipment, woodworking machines, standalone blades or separately exported parts without a separate classification analysis.
| Variant | HS route | Key distinction | Evidence |
|---|---|---|---|
| Industrial band/circular/cold saw | 8461.50.00 reference | Machine tool; metal/cermet; material removal | Catalogue, blade spec, cutting capacity, photos/model |
| Hand-held powered saw | 8467… | Held during operation | Manual, weight, power source |
| Laser/plasma/water-jet | 8456… | Different cutting process | Technology/source/CNC spec |
| Woodworking saw | 8465… | Different work material | Application/catalogue |
| Standalone saw blade | 8202… | Tool, not machine | Material/dimensions/part number |
| Parts/accessories | 8466… or other | Part/fixture, not complete machine | Drawing/function/compatibility |
5.2 EXPORT DUTY: DO NOT COPY THE MFN IMPORT RATE
The 5% figure often shown under 8461.50.00 is an import MFN rate, not export duty. Export duty must be checked against the Export Tariff under Decree 26/2023 and current amendments, including Decree 201/2026 effective 23 Jul 2026. A specific rate should only be stated after the final HS is verified against the applicable Appendix I on the declaration date.
5.3 EXPORT VAT: 0% IS CONDITIONAL
Qualifying exports may apply 0% VAT when the current statutory conditions are met. The implementing framework has been amended through 2025–2026, including Decree 181/2025 and amendments such as Decree 144/2026, effective 20 Jun 2026. Review the actual contract, payment evidence, customs declaration and commercial file under the current rules.
Domestic VAT-reduction measures and the 0% export regime are different mechanisms and should not be mixed.
6. C/O – FTA – RULES OF ORIGIN
For industrial machinery, origin management starts with the BOM, not the C/O application. Imported motors, PLC/controllers, bearings, hydraulic components and steel structures can materially affect the PSR. Review final-product HS, input HS/origin, values and Vietnam processing before promising preferential treatment.
| Market | FTA routes | Proof of origin | What to review | Origin evidence |
|---|---|---|---|---|
| Czech/EU | EVFTA | EUR.1 or proof under the applicable EVFTA mechanism | PSR in Appendix II to Circular 14/2026; certification mechanism; invoice/transport conditions | BOM, norms, supplier declarations, input origin, production/inventory records |
| Japan | AJCEP / VJEPA / CPTPP / RCEP | Route-specific; e.g. Form AJ under AJCEP | Destination tariff + PSR + ability to evidence origin | BOM by HS, component origin, RVC/value file if required, production records |
| Thailand | ATIGA / RCEP | ATIGA e-Form D or RCEP proof | Final-HS PSR, exporter/producer data, transport/invoice | BOM, RVC/CTC worksheet where applicable, supplier/stock records |
| Cambodia | ATIGA / RCEP | ATIGA e-Form D or RCEP proof | Preferential tariff, PSR and importer claim route | BOM, supplier/production/invoice/shipment evidence |
EVFTA update: Circular 14/2026/TT-BCT applies from 10 May 2026 and repealed Circulars 11/2020 and 41/2022. Existing checklists should be refreshed against the current PSR annex and evidence requirements.
7. PRODUCT-SPECIFIC & DESTINATION COMPLIANCE
For metal sawing machinery, compliance is rarely one single “export permit.” The real control points are machinery safety, electrical configuration, technical documentation, certificate scope and manufacturer/importer obligations in the destination market. Each market must therefore be reviewed against the exact model and configuration.
CZECH REPUBLIC / EU — 2026 → 2027 TRANSITION
As of 5 Oct 2026, Machinery Directive 2006/42/EC remains the core framework. Shipments close to 20 Jan 2027 should be managed by the expected placing-on-market date, not ETD alone.
- Essential health & safety requirements.
- Technical file and risk assessment.
- Instructions/manual.
- Conformity assessment.
- Declaration of Conformity and CE marking.
- Exact model/version/voltage and certificate scope.
- Expected placing-on-market date.
- Correct technical-documentation framework.
- Importer/distributor transition confirmation.
- Document-retention plan.
JAPAN — PSE IS NOT A UNIVERSAL MARK FOR EVERY ELECTRIC MACHINE
An electrically powered saw does not automatically mean the whole industrial machine requires PSE. Exact product/component scope must be checked.
- Rated voltage/frequency and components.
- Identify any item/component in PSE scope.
- Separate PSE from workplace machinery safety.
- Review manual, wiring, rating plate and safety devices.
- Importer confirmation on PSE applicability.
- Electrical BOM/component evidence if relevant.
- Buyer-required manual/warnings/nameplate.
- Do not label workplace safety as a customs permit.
THAILAND — GENERAL STANDARD VS COMPULSORY STANDARD
TISI lists TIS 62841 Part 3(5)-2567 for transportable band saws as a general standard. That alone does not prove every metal saw requires mandatory TISI certification.
- Identify fixed vs transportable.
- Check exact model against compulsory list.
- Review voltage/frequency and scope.
- Confirm with importer before testing.
- Model, machine type and technical specification.
- Importer confirmation of compulsory scope.
- Standard/version stated in PO/Contract.
- Do not incur certification cost before confirming the trigger.
LOGISTICS TRIGGERS THAT MUST NOT BE MISSED
Product compliance and transport compliance are different layers. A machine may be exportable but still be rejected by a carrier if fluids, batteries, wood packaging or heavy/OOG data are not declared correctly.
| TRIGGER | DATA REQUIRED | OPERATIONAL IMPACT |
|---|---|---|
| Hydraulic oil / coolant / chemicals | SDS, composition, flash point, quantity, UN status | DG/non-DG, carrier acceptance, packing/marking |
| Battery | Type, Wh, UN38.3/test summary where applicable | DG screening and carrier documents |
| Wood packaging | Solid vs processed wood, treatment/mark | ISPM 15 where applicable |
| Heavy/off-center machine | GW, footprint, CoG, lifting points, forklift pockets | Floor load, crane/forklift and lashing plan |
| OOG | Packed dimensions and over-width/height/length | FR/OT, carrier/port/trucking approval |
8. EXPORT DOCUMENT SET & SUBMISSION
| File group | Documents | Used for | Typical owner | Core data match | Common error |
|---|---|---|---|---|---|
| Commercial | Contract/PO, Commercial Invoice, Packing List | Customs, booking, buyer docs | Sales/Docs/Exporter | Description, model, quantity, value, Incoterm | Invoice description too generic or model mismatch. |
| Customs | Declaration, type-specific file, catalogue/classification memo where needed | Export clearance | Customs/Docs | HS, description, value, origin | Wrong type/HS/description. |
| Compliance / market | Dual-use screening; safety/test/cert/manual where applicable | Pre-shipment / Market Access | Compliance/Engineering/QA | Exact model, serial, certificate scope | Certificate does not cover shipped model. |
| Origin | C/O, BOM, norms, supplier docs, PSR worksheet where applicable | Origin claim | Docs/Factory/Procurement | HS, criterion, invoice, shipment | Weak audit trail or wrong FTA PSR. |
| Transport & buyer | Booking, SI, VGM, B/L/AWB, insurance, L/C docs | Shipping/post-shipment | Forwarder/Docs/Finance | Shipper/consignee, package, GW/NW, marks | B/L error; late SI/VGM; discrepancy. |
Submission channels: customs declaration through the electronic customs system; C/O through the relevant issuing system/authority; destination compliance files according to the destination authority/importer. Do not describe a technical file as a Vietnam customs permit unless the law requires it.
9. LEGAL MATRIX & DESTINATION REQUIREMENTS
| Layer | Instrument/source | Authority | Effective / transition | Reference to check | Application | Old → new / note |
|---|---|---|---|---|---|---|
| Vietnam foreign trade | Decree 292/2026/ND-CP | Government | 05 Sep 2026 | Relevant articles/appendices for actual goods | General export-policy screen | Replaced Decree 69/2018 |
| MOIT detail | Circular 48/2026/TT-BCT | MOIT | 05 Sep 2026 | Only the scope actually covered | Use only where applicable | Do not use as blanket machine-licence basis |
| Strategic trade | Decree 259/2025 + Circular 42/2026 | Government / MOIT | Circular: 12 Sep 2026 | Dual-use list | Specification/end-use screening | New technical-goods control layer |
| Export tariff | Decree 26/2023 + Decree 201/2026 | Government | 201: 23 Jul 2026 | Appendix I/current amendments | Export-duty check | Import MFN ≠ export duty |
| Export VAT | VAT Law current version; Decree 181/2025 as amended incl. 144/2026 | NA / Government | 144: 20 Jun 2026 | Current 0% conditions/evidence | 0% VAT | Use amended framework |
| Customs | Customs Law 54/2014; Decree 08/2015 as amended | NA / Government | Current 2026 framework | Type-specific rules | Export customs | Law 11/2026 applies 01 Mar 2027 |
| EVFTA origin | Circular 14/2026/TT-BCT | MOIT | 10 May 2026 | Appendix II PSR | EU origin | Repealed 11/2020 and 41/2022 |
| EU machinery | Directive 2006/42/EC | EU | Current pre-20 Jan 2027 period | Article 5/technical annexes | CE/technical file/declaration | Transition to Regulation 2023/1230 |
| EU machinery new | Regulation 2023/1230 | EU | 20 Jan 2027 | Article 54/transitional rules | 2027 placing-on-market | Replaces Directive on schedule |
| Japan | PSE Act / workplace safety framework | METI / MHLW | Current scope | Designated items / machine safety | PSE if in scope; workplace safety | No blanket PSE |
| Thailand | TISI standards/compulsory list | TISI | Exact model/standard | TIS scope | Exact-model check | General ≠ compulsory |
10. PRACTICAL E2E EXPORT PROCESS
PRODUCT + MARKET SCAN
Define the product scope, model/variant, buyer requirement, market access and compliance triggers.
HS – POLICY – FTA/C/O
Classify by function/technology; review Decree 292, dual-use triggers and FTA/PSR.
CONTRACT + BUYER REQUIREMENTS
Lock Incoterm, payment, importer, model/spec, serial logic, warranty and compliance deliverables.
COMPLIANCE / ORIGIN
Complete manuals, label/nameplate, safety files, importer confirmation and origin evidence.
BOOKING – PACKING – TRUCKING
Fix mode, booking, package dimensions, GW/NW, center of gravity, lifting, crating/lashing, DG/OOG screening and trucking.
EXPORT DECLARATION
Declare by HS/type; cross-check Invoice/PL/catalogue/origin and handle customs channel/inspection.
SI – VGM – CY/CFS CUT-OFF – LOADING
Lock shipper/consignee, marks, packages, GW/NW, VGM, gate-in/CFS/loading and draft B/L/AWB.
FINAL DOCS – BUYER/BANK – ARCHIVE
Complete final transport docs, C/O/certificates, buyer/bank set, payment follow-up, claim/survey and origin/compliance archive.
11. PRE-ETD / CARGO READY / CUT-OFF TIMELINE
| Milestone | What must be locked | Documents/data | Typical owner | Delay risk |
|---|---|---|---|---|
| Before Contract | Market access, preliminary HS, FTA, Incoterm, payment | Spec, buyer requirement, end-use, origin input | Sales/Compliance/Procurement | Order accepted before market requirements are understood. |
| Before Cargo Ready | Compliance, nameplate/label, origin evidence, packing, booking | Manual/test/cert if any, BOM, packing data | Factory/QA/Docs/Forwarder | Machine ready but documentation/origin evidence incomplete. |
| Before CY/CFS Cut-off | Customs, trucking, stuffing/gate-in | Declaration, booking, verified dimensions/GW/NW | Ops/Customs/Forwarder | Miss cut-off/roll/rebooking/storage. |
| Before SI/VGM Cut-off | B/L and weight data | SI, VGM, shipper/consignee/marks | Docs/Forwarder | B/L amendment/discrepancy. |
| After On-board | C/O, final B/L/AWB, buyer/bank set | On-board data, Invoice/PL, C/O/certs | Docs/Finance | Late documents/payment; weak origin-verification response. |
12. INCOTERMS – TRANSPORT – PACKING – COST
Incoterms: EXW/FCA where buyer controls main carriage; FOB/CFR/CIF for suitable sea shipments; CPT/CIP for container/air; DAP/DPU/DDP only after importer-of-record, destination customs/tax and local compliance responsibilities are understood. Do not confuse risk transfer with cost allocation.
| Area | Machine-specific control |
|---|---|
| Sea FCL/LCL | FCL is often safer for large/heavy machinery; LCL requires a crate designed for repeated handling. Check floor loading and lifting/forklift requirements. |
| Air | Suitable for small/urgent machines or parts; screen battery/fluid/DG and airline size/weight limits. |
| Road / regional | Potentially relevant for ASEAN routes depending on delivery point, border, axle load and line; no fixed lead-time promise without a confirmed route. |
| OOG / Flat Rack | For dimensions/weight beyond standard container; needs lifting plan, center of gravity, lashing and port handling approval. |
| Packing | Engineered wooden case/crate or steel frame; secure moving parts; anti-rust/moisture; lifting points; ISPM 15 where applicable. |
| Cost | Compliance/test/cert, C/O, crating, trucking, lifting, local charges, freight, insurance, amendment/rebooking/storage. |
13. RISKS & CONTROL POINTS
| Risk | Root cause | Impact | Control | When |
|---|---|---|---|---|
| Market access failure | Vietnam procedure checked but buyer/importer requirements ignored | Buyer hold/rejection or inability to import | Pre-contract market review | Before order |
| Wrong HS/policy | Trade-name classification | Declaration/C/O/policy correction | Technical classification file | Before declaration |
| Late dual-use screening | HS checked without spec/end-use review | Shipment interruption for assessment | Strategic-trade screening | Pre-contract |
| C/O fails PSR | Weak BOM/audit trail or wrong FTA | Loss of preference/verification | Origin review | Before C/O |
| Wrong market standard | Blanket PSE/TISI/KCs assumption | Unnecessary certification or missing required evidence | Exact-model compliance matrix | Before production/Cargo Ready |
| Miss cut-off/roll | Late packing/customs/trucking/SI-VGM | Rebooking/storage/delay | Milestone control | Before CY/CFS/SI/VGM |
| Transit damage | Weak crate/lashing/moisture protection | Claim/commissioning delay | Packing engineering + photo record | Before pickup/stuffing |
| B/L/L/C discrepancy | Master data inconsistent | Amendment/discrepancy/payment delay | Document cross-check | Before release/presentation |
14. FAQ
Is HS 8461.50.00 automatic for every metal saw?
No. It is only a reference for qualifying machine tools that saw/cut off metal/cermets by material removal. Hand-held, laser/plasma, woodworking machines, blades and parts require separate classification.
Does a new metal sawing machine always require a Vietnam export licence?
No blanket answer. Ordinary industrial machinery should be screened under Decree 292/2026 and any applicable technical/end-use controls; a licence should not be invented from the trade name.
Is export duty 5% because the MFN import rate is 5%?
No. The 5% figure is an import MFN rate. Export duty must be checked separately against the current Export Tariff and final HS.
Is export VAT automatically 0%?
No. 0% is conditional and requires the current export transaction and supporting evidence conditions to be met.
For Czech/EU shipments in late 2026, Directive or Regulation?
As of 5 Oct 2026, Directive 2006/42/EC remains the current core framework; Regulation 2023/1230 applies from 20 Jan 2027. Shipments around the transition need a placing-on-market plan.
Does every electric saw exported to Japan require PSE?
No. PSE applies only to designated products/components within the Act’s scope. Check exact configuration and separate workplace safety from customs requirements.
Does every saw exported to Thailand require compulsory TISI?
No. A general TIS standard is not automatically a compulsory-market requirement. Check the current compulsory list for the exact model.
Form D or RCEP for Cambodia?
Either route may be relevant. Select based on destination tariff, PSR, available origin evidence and how the importer will claim preference.
Does oil/coolant/battery make the machine DG?
Not automatically. Use SDS, flash point, UN classification, battery type/quantity, packing configuration and carrier rules.
What booking data matters beyond CBM?
Packed dimensions, GW/NW, package count, center of gravity, lifting points, forklift pockets, stackability, OOG status, fluids/batteries and stuffing requirements.
When should origin/C/O work start?
Origin review should start before production/booking. A non-compliant BOM cannot be cured by paperwork at the last minute.
What should be archived after on-board?
Final customs/transport docs, origin proof and audit trail, compliance file, buyer/bank set, payment records, packing/nameplate/serial photos and DG/claim records where applicable.
15. POST-SHIPMENT OUTPUT & RECORDS
- Completed export customs declaration and supporting customs records.
- Final B/L/AWB/Sea Waybill, booking, SI/VGM and final transport documents.
- C/O/proof of origin and Origin Audit Trail where preference is claimed.
- Manual, test/cert/safety file, importer confirmation and exact-model market-compliance records.
- Buyer/bank document set under Contract/L/C/payment term.
- Payment, insurance, debit/credit note and claim/survey records where applicable.
- Packing, lashing, serial/nameplate photos and handover records for audit/claims.
OPERATING SOLUTION
Control risk before Cargo Ready through one consistent data chain: model/spec → HS/policy → market access → origin → packing → booking/cut-off → final docs.
Product scope, HS, policy, dual-use trigger, market requirement and origin/PSR.
Invoice – Packing List – declaration – SI/VGM – B/L/AWB – C/O – buyer/bank docs.
Packing/crating, trucking, lifting, OOG/DG screening, cut-offs and post-shipment archive.
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