Energy labeling is one of the mandatory procedures that businesses manufacturing and importing electrical equipment must complete before bringing products to the Vietnamese market. What makes this procedure complicated is not the labeling itself, but the fact that the document system governing it has just undergone a major change: The law was amended in 2025, the guiding decree was completely replaced in early 2026, and the list of equipment that must be labeled was transferred from the Prime Minister’s level to the Ministry of Industry and Trade level.
Reference translation by ticforall.com. The Vietnamese version published on this site is the authoritative text; in case of any discrepancy, the Vietnamese original prevails.
In this article, we systematize the entire string of documents currently in effect, clearly indicate which documents have been replaced, list the full list of equipment groups that must be labeled with a roadmap according to each timeline, and the TCVN stipulating the corresponding minimum energy performance levels. All document numbers, issuance dates and effective dates are quoted from the original source, with links at the end of the article.
1. Three document layers that are easily confused
The most common mistake we observe is that businesses consider “categories subject to energy labeling” and “categories subject to minimum energy performance levels” as one. In fact, these are two different obligations, governed by two different documents, with different legal consequences. Distinguishing the three layers below is a condition for reading the rest of the article correctly.
First layer: minimum energy performance levels (MEPS)
This is a required technical threshold. Equipment does not meet the minimum performance level specified in the corresponding TCVN are not allowed to be imported, produced or traded domestically. The amending document is Decision No. 14/2023/QD-TTg dated May 24, 2023 of the Prime Minister. For imported goods, this is a condition related to customs clearance.
Second layer: declaration and energy labeling obligations
This is an administrative obligation implemented after the product has reached the technical threshold, before being released to the market. The list and roadmap are currently prescribed by Circular No. 52/2025/TT-BCT dated November 14, 2025 of the Ministry of Industry and Trade, effective from January 1, 2026.
Third layer: the list of items with HS codes
Decision No. 1725/QD-BCT dated July 1, 2024 of the Minister of Industry and Trade promulgating a list of items for energy efficiency testing and energy labeling under the management responsibility of the Ministry of Industry and Trade, with HS codes and notes on the scope of application according to capacity and capacity. This is a special decision-making document serving management work, useful for looking up whether a specific product is subject to management or not, but is not a source of determining mandatory obligations for businesses.
2. Current laws and decrees
2.1. Law on Economical and Efficient Use of Energy and the 2025 amending law
The original document is the Law on Economical and Efficient Use of Energy No. 50/2010/QH12. This Law has been amended and supplemented by Law No. 77/2025/QH15 dated June 18, 2025, effective from date January 1, 2026.
According to Article 38 of the Law on Economical and Efficient Use of Energy 2010 (amended in 2025), the core contents of energy labeling include:
- Vehicles, equipment and construction materials are on the list of required energy labeling must be labeled before being placed on the market.
- Manufacturing facilities, importers, distributors, and traders — including on e-commerce platforms — energy declaration and labeling must be made after the product is tested and assessed for conformity with national standards on energy performance.
- The Minister of Industry and Trade and the Minister of Construction, within the scope of their duties, are responsible for developing and promulgating a list of energy labels and a roadmap for implementation; regulate label content and specifications; regulations on qualified testing laboratories; instructions and announcement of labeling; regulates the recognition of energy labels of imported vehicles and equipment.
- Provincial People’s Committees develop annual plans, organize inspections, and check compliance with regulations on energy labeling in the area.
The addition of e-commerce to the scope of regulation and the assignment of authority to promulgate the list to the ministerial level are the two changes that have the most direct impact on businesses. The second change is the legal basis for Circular 52/2025/TT-BCT to be born.
2.2. Decree 30/2026/ND-CP replacing Decree 21/2011/ND-CP
On January 21, 2026, the Government issued Decree No. 30/2026/ND-CP detailing a number of articles and measures to organize and guide the implementation of the Law on Economical and Effective Use of Energy. Decree takes effect from the date of signing and replace Decree No. 21/2011/ND-CP dated March 29, 2011.
The Decree details Article 44, Clause 1, Article 45, Article 48 of Law No. 50/2010/QH12 and Clauses 11, 18, 19, 20, Article 1 of Law No. 77/2025/QH15. Scope of coverage: management and monitoring of energy use; key energy use facilities; organize energy audits; energy use in agencies using state budget; energy labeling for vehicles, equipment and construction materials; Fund to promote economical and efficient use of energy; energy service organizations; check, inspect.
This is the most important document to read today, because Articles 11, 12 and 13 lay out the entire basis for label classification, publication records and suspension sanctions — covered in sections 5, 6 and 7 below. A notable transition point: energy management certificates issued before the Decree’s effective date are valid until December 31, 2030.
3. List of vehicles and equipment subject to energy labeling
According to Article 2 of Circular 52/2025/TT-BCT, the list under the management of the Ministry of Industry and Trade is divided into three groups:
- Household appliance group: Straight tube fluorescent lamps, compact fluorescent lamps, electromagnetic and electronic ballasts for fluorescent lamps, air conditioners, refrigerators, household washing machines, rice cookers, electric fans, televisions, LED lights, storage water heaters, induction cookers, infrared cookers, microwave ovens.
- Office and commercial equipment group: copiers, printers, computer monitors, laptops, desktops, commercial refrigerators, commercial air conditioners.
- Industrial equipment group: distribution transformers, electric motors, LED street and street lighting.
Circular not applicable For: vehicles and equipment manufactured, assembled, imported and used directly for defense and security purposes, imported according to separate regulations of the Prime Minister; Means and equipment temporarily imported for re-export, transit, border-gate transfer, diplomatic and consular goods; Means and equipment for repair and replacement, checking energy performance levels.
List table and implementation roadmap
The table below summarizes the list according to Article 2, the roadmap according to Article 3 of Circular 52/2025/TT-BCT, and TCVN on minimum energy performance levels according to Appendix I of Decision 14/2023/QD-TTg. Note that the TCVN column reflects the required technical threshold for import, production, and business – the first layer stated in section 1, not the content of Circular 52/2025/TT-BCT.
| Device group | Device name | TCVN on minimum energy performance levels | Energy labeling roadmap |
|---|---|---|---|
| Household appliances | Straight tube fluorescent lamp | TCVN 8249:2013 | Required |
| Compact fluorescent lamps | TCVN 7896:2015 | Required | |
| Electronic ballasts for fluorescent lamps | TCVN 7897:2013 | Required | |
| Electromagnetic ballasts for fluorescent lamps | TCVN 8248:2013 | Required | |
| Air conditioner (no duct) | TCVN 7830:2021 (from April 1, 2025) | Required | |
| Refrigerator | TCVN 7828:2016 (from April 1, 2025) | Required | |
| Household washing machine | TCVN 8526:2013 | Required | |
| Rice cooker | TCVN 8252:2015 | Required | |
| Electric fan | TCVN 7826:2015 | Required | |
| Video recorder | TCVN 9536:2021 (from April 1, 2025) | Required | |
| The water heater has storage | TCVN 7898:2018 (from April 1, 2025) | Required | |
| Household appliances | LED lights | TCVN 11844:2017 (from April 1, 2025) | Required |
| Household appliances | Induction cooker | TCVN 13372:2021 (from April 1, 2025) | Voluntary until December 31, 2026; Mandatory from January 1, 2027 |
| Infrared stove | TCVN 13373:2021 (from April 1, 2025) | Voluntary until December 31, 2026; Mandatory from January 1, 2027 | |
| Microwave | TCVN has not been verified in Appendix I of Decision 14/2023/QD-TTg | Voluntary until December 31, 2026; Mandatory from January 1, 2027 | |
| Office and commercial | Laptop | TCVN 11848:2021 (from April 1, 2025) | Required |
| Commercial refrigerators | TCVN 10289:2014 | Required | |
| Office and commercial | Desktop | TCVN 13371:2021 (from April 1, 2025) | Voluntary until December 31, 2026; Mandatory from January 1, 2027 |
| Office and commercial | Photocopier | TCVN 9510:2012 | Voluntarily |
| Printer | TCVN 9509:2012 | Voluntarily | |
| Computer screen | TCVN 9508:2012 | Voluntarily | |
| Commercial air conditioners | Not included in the list of mandatory MEPS applications in Decision 14/2023/QD-TTg | Voluntarily | |
| Industry | Distribution transformer | TCVN 8525:2015 | Required |
| Electric motor (squirrel-cage rotor three-phase asynchronous motor) | TCVN 7540-1:2013 | Required | |
| Industry | LED electric lights illuminate roads and streets | TCVN 12666:2019 (from April 1, 2025) | Voluntary until December 31, 2026; Mandatory from January 1, 2027 |
In addition to the above list, Clause 3, Article 3 of Circular 52/2025/TT-BCT encourages voluntary energy labeling for vehicles and equipment that are not on the list in Article 2 but have national standards regulating energy performance levels and are also capable of domestic testing.
4. Minimum energy performance levels and related TCVN standards
Decision No. 14/2023/QD-TTg dated May 24, 2023 of the Prime Minister, effective from July 15, 2023, promulgate a list and roadmap of energy-using vehicles and equipment that must be eliminated and low-performance generating sets must not be newly built. This decision does Decision No. 24/2018/QD-TTg dated May 18, 2018 expires. from the date it takes effect. Core content: does not allow importing, manufacturing and trading of equipment with energy efficiency that does not meet the minimum level specified in TCVN listed in Appendix I.
In addition to the Vietnamese standards listed in the table in section 3, Appendix I of Decision 14/2023/QD-TTg also stipulates two groups of products outside the labeling list of Circular 52/2025/TT-BCT:
- Cooler — TCVN 7828:2016
- Boilers in industrial enterprises — TCVN 8630:2019, applicable from April 1, 2025 (previously TCVN 8630:2010)
Mold April 1, 2025 appearing many times in Appendix I is the time to switch to applying the newer, more stringent version of TCVN, for refrigerators and freezers, storage water heaters, ductless air conditioners, television sets, and industrial boilers; At the same time, it is the time to start applying MEPS with LED lights, induction cookers, infrared cookers, laptops, desktop computers and LED street lighting. For businesses that are circulating old products, this is a milestone that needs to be compared to test results.
Decision 14/2023/QD-TTg also stipulates performance thresholds for coal and gas generating sets in Appendix II, but this content is beyond the scope of the article. We only state the model number and standard name; Detailed technical content of each TCVN needs to be looked up in the official standard.
5. The two types of energy label
Article 11 of Decree 30/2026/ND-CP classifies energy labels into three types:
- Compare labels: Labels provide information about energy consumption, type of energy used, energy efficiency and other information, helping consumers compare with products, construction materials, vehicles and equipment of the same type on the market to identify and choose energy-saving products. In fact, this is the type of label that shows the performance level on a star scale that consumers are used to seeing on refrigerators and air conditioners.
- Confirmation label: stickers on products, vehicles, equipment, construction materials with thermal characteristics, energy consumption or energy performance index achieved or higher according to prescribed standards. This type of label corresponds to the logo commonly known as “Vietnamese Energy Star”.
- Vehicle energy label: The label provides information about the type of energy used, energy consumption and vehicle type.
The essential difference between the first two types: comparison labels position products on a scale for consumers to compare; Verification labels only confirm that a product has passed a certain threshold, not a rating. Energy performance index, energy consumption and thermal characteristics are all specified in national standards; The Ministry of Industry and Trade and the Ministry of Construction, within the scope of their assigned functions, regulate these levels shown in the corresponding comparison labels and confirmation labels.
Regarding label specifications — size, color, layout, presentation of parameters — the Law assigns the Minister of Industry and Trade to regulate. We have not verified the current document number specifying label specifications after Decree 30/2026/ND-CP takes effect; This content needs to be checked again at the official source of the Ministry of Industry and Trade.
6. Dossier for the energy labeling declaration
According to Article 12 of Decree 30/2026/ND-CP, dossiers announcing energy labeling for vehicles, equipment and construction materials include:
- Technical specifications of vehicles, equipment and construction materials;
- Test results for energy efficiency (for equipment), energy consumption (for vehicles) or thermal properties (for building materials), because the testing laboratories have been announced by the Ministry of Industry and Trade and the Ministry of Construction on the ministry’s electronic information portal carry out;
- Energy labeling announcement paper;
- Proposed energy label sample.
Regarding receiving agencies, the Decree clearly defines: Ministry of Industry and Trade Guide and organize the reception of energy labeling announcement dossiers for vehicles and equipment; Ministry of Construction Guide and organize the reception of documents for vehicles and construction materials.
This delimitation explains why Circular 52/2025/TT-BCT no longer has the group of vehicles, while Decision 04/2017/QD-TTg previously had this group (cars, motorbikes, mopeds).
Requirements for testing laboratories
The Law on Economical and Efficient Use of Energy (amended in 2025) assigns the Minister of Industry and Trade and the Minister of Construction the responsibility of “regulating testing laboratories that are eligible to be granted testing certificates in accordance with energy performance standards”. Decree 30/2026/ND-CP further requires that the test results in the records must be from the testing laboratory. has been announced by the ministry on its electronic information portal perform. Enterprises therefore need to compare the testing laboratory they plan to use with the list being announced at the time of implementation, and not rely on a previously saved list.
We have not yet verified a stable link to the officially published list of testing laboratories, so no names are listed. The Decree also stipulates that the Ministry of Industry and Trade and the Ministry of Construction preside over and organize inspection of testing implementation at testing laboratories.
7. Suspension, withdrawal and periodic reporting obligations
Article 13 of Decree 30/2026/ND-CP regulates cases suspended Energy labeling:
- Fake energy labeling;
- Labeling energy without declaring energy labeling according to regulations;
- Energy labels do not have the correct content or specifications, or incorrectly state energy performance parameters (for equipment), energy consumption (for vehicles) or thermal characteristics (for construction materials).
Cases suffered suspension and revocation Energy labeling:
- There is fraud in the energy labeling declaration documents;
- Test results on energy efficiency, energy consumption or thermal characteristics do not match published information;
- Penalized 02 times for violations in the group of suspension cases mentioned above.
Regarding reporting obligations, Decree 30/2026/ND-CP sets out two reporting lines that businesses need to know:
- Establishments that produce or import vehicles, equipment and construction materials on the list requiring energy labeling are responsible for submitting annual reports to Provincial People’s Committee where the production facility is located and the business is registered. The Provincial People’s Committee summarizes and sends it to the Ministry of Industry and Trade and the Ministry of Construction before March 31 of the following year.
- Every year, production facilities and importers that have announced energy labeling are responsible for calculating the number and types of energy-labeled vehicles, equipment and materials put on the market during the year, and sending reports to specialized management ministries. before March 1 of the following year.
The Provincial People’s Committee presides over and coordinates with relevant agencies to periodically or unexpectedly inspect energy labeling activities for products circulating on the market, including trading on e-commerce platforms.
8. Legal status of the document system
The table below summarizes the validity status up to the time of our search. This is the area businesses should check first before relying on any guidance found on the internet, as much of the content in circulation was written before the 2025–2026 change.
| Text | Date of issue | Content | Status |
|---|---|---|---|
| Law on Economical and Efficient Use of Energy No. 50/2010/QH12 | 2010 | Original law | Still valid, amended and supplemented |
| Law No. 77/2025/QH15 | June 18, 2025 | Amending and supplementing a number of articles of Law No. 50/2010/QH12 | Effective from January 1, 2026 |
| Decree No. 30/2026/ND-CP | January 21, 2026 | Detailed regulations and measures to implement the Law | Effective from the date of signing (January 21, 2026) |
| Decree No. 21/2011/ND-CP | March 29, 2011 | Detailed regulations and measures to implement the Law | Has been replaced by Decree No. 30/2026/ND-CP |
| Circular No. 52/2025/TT-BCT | November 14, 2025 | List of vehicles and equipment requiring energy labeling and implementation roadmap of the Ministry of Industry and Trade | Effective from January 1, 2026 |
| Decision No. 14/2023/QD-TTg | May 24, 2023 | List and roadmap of energy-using equipment that must be eliminated (minimum energy performance level); Low efficiency generating sets are not built new | Effective from July 15, 2023 |
| Decision No. 24/2018/QD-TTg | May 18, 2018 | List and schedule of equipment to be removed | Expired from the effective date of Decision No. 14/2023/QD-TTg |
| Decision No. 04/2017/QD-TTg | March 9, 2017 | List of vehicles and equipment that must have energy labels, apply minimum energy performance levels and implementation roadmap | Effective from April 25, 2017. Circular No. 52/2025/TT-BCT no is the document that replaces this Decision (different level of issuance). It is necessary to check the current validity status at the official source |
| Decision No. 51/2011/QD-TTg | 2011 | List of vehicles and equipment that must have energy labels and implementation roadmap | Has been replaced by Decision No. 04/2017/QD-TTg |
| Circular No. 36/2016/TT-BCT | December 28, 2016 | Regulations on energy labeling for energy-using vehicles and equipment under the management of the Ministry of Industry and Trade (sequence, procedures, documents) | Effective from February 10, 2017; Amended by Circular No. 42/2019/TT-BCT. It is necessary to re-check the current validity status at the official source, because Decree No. 30/2026/ND-CP has re-regulated the publication dossier. |
| Circular No. 42/2019/TT-BCT | December 18, 2019 | Amending a number of regulations on periodic reporting, including Circular No. 36/2016/TT-BCT | Effective from February 5, 2020 |
| Consolidated document No. 23/VBHN-BCT | March 24, 2020 | Consolidation of Circular No. 36/2016/TT-BCT and Circular No. 42/2019/TT-BCT | Unified document, used for lookup |
| Decision No. 1725/QD-BCT | July 1, 2024 | List of items for energy efficiency testing and energy labeling with HS codes | Decision of the Minister, used to look up HS codes and scope of application |
9. Items we have not verified
To let readers clearly know the boundaries of the article, we directly state the points that cannot be verified from the original source and are therefore not asserted above:
- Current validity status of Circular No. 36/2016/TT-BCT. We could not find any documents announcing the replacement or repeal of this entire circular. However, Decree No. 30/2026/ND-CP has re-regulated the composition of the disclosure dossier, so the provisions of the circular that are no longer compatible will have to be ceded to higher-level documents. Need to check again at official source.
- Current validity status of Decision No. 04/2017/QD-TTg. Circular No. 52/2025/TT-BCT is a ministerial-level document so it cannot replace the Prime Minister’s decision; The effective relationship between two documents needs to be looked up at official sources.
- The current document number specifies the energy label specifications after Decree No. 30/2026/ND-CP takes effect.
- List of testing laboratories being announced by the Ministry of Industry and Trade.
- TCVN on minimum energy performance levels of commercial microwave ovens and air conditioners. These two products are included in the labeling list of Circular No. 52/2025/TT-BCT but we cannot verify the corresponding TCVN in Appendix I of Decision No. 14/2023/QD-TTg.
- Promulgation date of Law No. 50/2010/QH12. The legal documents we looked up and referenced were not consistent (some dated June 17, 2010, some dated June 28, 2010), so we only listed the number and year.
- Document processing time and costs. We do not state the number of days or the fee because we cannot cite specific provisions in the currently effective document.
- Contact point for receiving documents. Circular No. 52/2025/TT-BCT assigns the Department of Innovation, Green Transformation and Industrial Promotion responsibility for guidance, inspection and supervision. Information published later on the information portal of the National Program on Economical and Effective Use of Energy showed that the state management function in this field has been transferred to the Department of Energy – Petroleum. Businesses should confirm contact at the time of submission.
Conclusion
The most important thing to keep in mind: the energy labeling text system changed platforms in the period 2025–2026, and the majority of the guidance circulating on the internet was written before that change.
The four documents that need to be grasped currently are Law No. 77/2025/QH15 (effective January 1, 2026), Decree No. 30/2026/ND-CP (effective January 21, 2026, replacing Decree No. 21/2011/ND-CP), Circular No. 52/2025/TT-BCT (effective January 1, 2026, list and labeling roadmap) and Decision No. 14/2023/QD-TTg (effective July 15, 2023, minimum energy performance level according to TCVN). Three milestones need to be included in the plan: April 1, 2025 — many products switched to the new TCVN version; December 31, 2026 — the expiration of the voluntary labeling period for induction cookers, infrared cookers, microwave ovens, desktop computers and LED street lighting; January 1, 2027 — the products mentioned above will become mandatory.
Finally, correctly identifying the three layers of documents — minimum performance thresholds, declaration and labeling obligations, HS code categories — helps avoid most common errors when preparing documents. Equipment that meets the minimum performance level but has not announced the labeling is still a violation; conversely, labeling claims are no substitute for meeting minimum performance thresholds for customs clearance.
References
The links below were accessed on October 4, 2026.
- Law No. 77/2025/QH15 of the National Assembly amending and supplementing a number of articles of the Law on Economical and Efficient Use of Energy — Government Electronic Information Portal: vanban.chinhphu.vn
- Law on Economical and Efficient Use of Energy amended 2025 (full text) — Law Library: thuvienphapluat.vn
- Decree No. 30/2026/ND-CP dated January 21, 2026 (official PDF version) — Electronic information portal of the Ministry of Industry and Trade: moit.gov.vn
- Notice of the Ministry of Industry and Trade on the Government’s issuance of the Decree guiding the implementation of the Law on Economical and Efficient Use of Energy: moit.gov.vn
- Decree No. 30/2026/ND-CP — content and provisions replacing Decree No. 21/2011/ND-CP, National Program on economical and efficient use of energy: tietkiemnangluong.com.vn
- Articles 11, 12, 13 of Decree No. 30/2026/ND-CP on label classification, declaration documents and suspension of labeling — Law Library: thuvienphapluat.vn
- Circular No. 52/2025/TT-BCT dated November 14, 2025 — original on the Government Electronic Information Portal: chinphu.vn
- Circular No. 52/2025/TT-BCT — roadmap for implementing energy labeling, Law Library: thuvienphapluat.vn
- Decision No. 14/2023/QD-TTg dated May 24, 2023 — original on the Government Electronic Information Portal: vanban.chinhphu.vn
- Decision No. 14/2023/QD-TTg — list and roadmap of energy-using equipment that must be eliminated, LuatVietnam: luatvietnam.vn
- Decision No. 04/2017/QD-TTg dated March 9, 2017 — LuatVietnam: luatvietnam.vn
- Circular No. 36/2016/TT-BCT dated December 28, 2016 — Law Library: thuvienphapluat.vn
- Consolidated document No. 23/VBHN-BCT dated March 24, 2020, consolidating regulations on energy labeling — Electronic information portal of the Ministry of Industry and Trade: moit.gov.vn
- Decision to issue a list of items for energy efficiency testing and energy labeling under the management responsibility of the Ministry of Industry and Trade — Ministry of Industry and Trade electronic information portal: moit.gov.vn
- The Department of Energy – Petroleum, Ministry of Industry and Trade performs state management functions on economical and efficient use of energy: tietkiemnangluong.com.vn
Discuss with us
This article is our interpretation to disseminate legal knowledge about energy labeling, not a legal document. Legal documents may be amended, supplemented, replaced or abolished after the time the article is published. Before applying to a specific case, readers need to look up the current document on official information portals (Government electronic information portal, Ministry of Industry and Trade electronic information portal) and consult competent authorities. The content of the article is for reference only and does not replace legal advice.
