Choosing a Testing Laboratory for Vietnam Compliance 2026

Quick summary

• Three tiers of paperwork determine whether a testing laboratory is “usable”: the activity registration certificate (Decree 22/2026/NĐ-CP — conditions for practice), the ISO/IEC 17025 accreditation certificate (issued by VILAS, BoA or another accreditation body registered to operate in Vietnam — independently verified technical competence) and the designation decision (Decree 37/2026/NĐ-CP — valid for state management purposes).
• Test results may support a declaration of conformity only when the issuing body is recognised, designated or acknowledged and its testing scope covers the corresponding national technical regulation (Article 3.3, Circular 36/2026/TT-BKHCN).
• The conditions for designating a testing organisation (Article 72, Decree 37/2026/NĐ-CP) are four: a certificate of activity registration for the field of designation; accreditation by a registered accreditation body; satisfactory proficiency testing or interlaboratory comparison results; and at least 06 official test technicians, each with at least 02 years of experience.
• The list of designated organisations is published and updated before the 25th of every month; a designation decision is valid for a maximum of 05 years and re-designation must be requested 60 days before expiry.
• The choice of laboratory follows the conformity assessment method: Methods 1–2 need testing only; Methods 3–6 also assess the production process or management system; Method 7 works batch by batch; Method 8 assesses every single unit. High-risk goods may use only Method 5 or Method 7.
• Also in this article: a 12-question checklist and the eight common mistakes that get a declaration of conformity rejected — ready to use when you start working with a testing laboratory or a certification body.

Drawing on practical experience at ticforall.com, this article synthesises Decree 22/2026/NĐ-CP, Decree 37/2026/NĐ-CP, Circular 14/2026/TT-BKHCN, Circular 16/2026/TT-BKHCN and Circular 36/2026/TT-BKHCN.

1. Why the wrong testing laboratory can sink your whole declaration of conformity

Working with manufacturers and importers, I have seen conformity dossiers rejected not because the products were poor, but because the test results had no legal value for the declaration. The cause usually lies in three small words in the paperwork: scope, validity and recognition.

Four practical consequences of choosing the wrong laboratory:

• Your dossier is rejected and the shipment is held. The inspection authority will not accept the results because the laboratory is not on the list designated for that regulation, or because the designated scope does not cover the test method used.
• You have to start the testing over. Retesting, storage and delay usually cost many times more than you saved by picking a cheaper laboratory in the first place.
• Results can lose their validity retroactively. If the issuing body later has its designation decision withdrawn for false results or falsified documents, the standing of results already issued becomes a legal problem for everyone who relied on them.
• You can still be inspected after customs clearance. Goods already in circulation may be re-tested; at that point the partner’s competence file kept in your quality records is the only thing that justifies your choice.

Choosing a laboratory is therefore not a matter of picking a supplier by price but a step in compliance governance. Rule of thumb: settle the laboratory when you design the conformity assessment plan, not after sampling.

2. The three layers of legal standing of a “usable” testing laboratory

Under Vietnamese law, a laboratory that is legally “usable” is more than one sheet of paper. There are three independent statuses, answering three different questions, and a laboratory is usable only when every layer is still valid within the scope you actually need.

2.1. Layer 1 — Activity registration: the licence to practise (Decree 22/2026/NĐ-CP)

Decree 22/2026/NĐ-CP of 16 January 2026 details activities in standards and technical regulations, under which conformity assessment bodies must register their activities (Chapter V). In effect this is a practising licence: a testing, inspection, certification, verification/validation or accreditation body may operate lawfully only with an activity registration certificate whose registered field matches its professional competence.

For businesses, this layer answers one question: “May my partner test in Vietnam?” Our article on the two lawful routes under Decree 22 and Decree 37 goes deeper into this layer.

2.2. Layer 2 — ISO/IEC 17025 accreditation: independently verified technical competence

The accreditation certificate (issued by VILAS, BoA or another accreditation body registered to operate in Vietnam) confirms that the laboratory meets TCVN ISO/IEC 17025 — management system, personnel competence, equipment, calibration and assurance of measurement results. This is proof of technical competence. Several accreditation bodies are registered to operate in Vietnam — BoA is only one of them — so do not equate “ISO/IEC 17025 accreditation” with any single acronym.

But the accreditation certificate only means something when read together with its “scope of accreditation” — the section listing the exact tests, test methods and objects covered. A laboratory may hold a very impressive ISO/IEC 17025 accreditation while its scope contains only a few tests unrelated to the standard you need.

2.3. Layer 3 — Designation under Decree 37/2026/NĐ-CP: validity for state management

This is the layer that decides whether test results can be used for a declaration of conformity. Decree 37/2026/NĐ-CP of 23 January 2026 governs the designation of conformity assessment bodies and the recognition of conformity assessment results (Section 2, Chapter VII). Article 72 sets out four conditions for testing organisations, and this is where businesses must check most carefully:

1. Already hold a certificate of activity registration for testing under the law on standards and technical regulations, covering the field of the requested designation.
2. Be accredited by a registered accreditation body for the correct scope of the requested designation.
3. Have satisfactory proficiency testing or interlaboratory comparison results for the test methods of the products and goods registered for designation.
4. Have at least 06 official test technicians, each with at least 02 years of experience in the registered field of designation.

The easiest point to get wrong is the word “official”: the Decree counts only public employees and staff on fixed-term contracts of 12 months or more or on indefinite-term contracts. Short-term contracts, ad hoc collaborators and seconded staff do not count towards the minimum of 06.

For businesses — the side that uses the results — there are four implications to keep in mind:

• Results serve state management purposes only when the issuing body is on the designated list, correct in scope and still valid on the date the results are issued.
• The list is published and updated before the 25th of every month — check it when you sign the contract and again before shipping, especially for consignments that have been delayed.
• A designation decision is valid for a maximum of 05 years; re-designation must be requested 60 days before expiry. A partner going through re-designation may suffer interruptions in service capacity.
• Mutual recognition of competence assessment results between ministries (12-month validity) can shorten the time needed where the body is already designated by another ministry — handy when several ministries manage the regulations you need.

Layer	Underpinning document	Question it answers	Where to check
Activity registration	Decree 22/2026/NĐ-CP (Chapter V)	May the body test in Vietnam?	Activity registration certificate; public registers of the competent authority
ISO/IEC 17025 accreditation	TCVN ISO/IEC 17025; accreditation activities under Decree 22/2026/NĐ-CP	Is technical competence verified, and to what extent?	Accreditation certificate and scope of accreditation
Designation	Decree 37/2026/NĐ-CP (Articles 71–78)	Do the results count for state management?	Designation decision and published list, updated before the 25th of each month

Bottom line: a laboratory may hold all three layers and still be unusable if the scope at layers 2 and 3 does not cover the standard and test method you need. The question is not “what paperwork does this laboratory have?” but “does this laboratory have what I need, valid on my dates?”

3. How to read the “scope” correctly

Rarely taught, yet it accounts for 90% of the risk in a dossier. When you receive the scope of accreditation and the designation decision, check that five things match:

1. The right regulation: the exact designation of the national technical regulation, including amendments (for example QCVN 4:2009/BKHCN and Amendment 1:2016). An amendment is part of the requirement, not an option.
2. The right test method: if the scope names the test method (TCVN, IEC or ISO), the report must use that method and that version.
3. The right object and parameter range: two scopes may both say “electric fan”, yet one is limited by power, voltage, volume or IP rating; wires and cables also depend on construction, cross-section and insulation.
4. The right product group/HS code: for imports, the HS code on the customs declaration must fall within the goods group covered by the designated scope.
5. The right timing: the paperwork must be valid both on the contract date and on the date the results are issued — not merely on the date of filing.

Practical tip: ask your partner for scanned copies of the scope of accreditation, the designation decision and the activity registration certificate already at quotation stage, and file them with the shipment’s quality records. That trio of evidence answers every question an inspector may ask about the legal standing of the results.

4. Choosing a laboratory by conformity assessment method (Circular 14/2026/TT-BKHCN)

The question “which testing laboratory to choose” comes after an earlier question: “which conformity assessment method applies?” Circular 14/2026/TT-BKHCN (in force from 25 May 2026) keeps the 8 assessment methods (Article 5) and adds Article 6 and Appendix II detailing how to apply them — mandatory rules, not guidance.

Each method calls for different capabilities, and therefore a different partner:

Method	Main elements	Partner you need	Validity
1	Testing a representative sample of the model	Testing laboratory	Per model tested; no monitoring
2	Sample testing + market sampling and monitoring	Testing laboratory + certification body	Valid up to 05 years
3 – 4	Sample testing + production process assessment	Certification body (able to assess the production process)	Valid up to 05 years
5	Sample testing + assessment of the production process or management system	Designated certification body	Valid up to 05 years; for high-risk goods
6	Assessing and monitoring the management system	Management-system certification body	Valid up to 05 years
7	Testing and assessment by batch	Certification body (per batch)	Valid for that batch only; for high-risk goods
8	Testing or inspection of every unit	Inspection body	Per individual unit

Three points deserve emphasis:

• Method 1 and Method 6 do not apply to high-risk goods. If your product is in Appendix I of Circular 36/2026/TT-BKHCN, only Method 5 and Method 7 are open to you.
• Methods 2–6 share the same maximum validity of 05 years and require monitoring; Method 7 is valid for one batch only; Method 8 applies to each individual unit.
• The certificate must state the assessment method used to demonstrate conformity with the technical regulation.

In practice: if you simply have a laboratory “test” the sample and then declare conformity yourself, you are implicitly using Method 1 — and that is not allowed for high-risk goods. Our article on the 8 assessment methods under Circular 14/2026/TT-BKHCN explains the choice in detail.

5. A 12-question checklist before you sign the contract

Print this checklist and use it with every testing partner. If an answer is “no” or “unclear”, do not sign.

#	Question	Why it matters	Evidence to keep
1	Does the body hold a valid activity registration certificate for testing?	Activity registration conditions under Decree 22/2026/NĐ-CP	Scan of the certificate
2	Is the designation decision issued for the technical regulation you need?	Results count for state management only within the designated scope	Scan of the designation decision
3	Is the designation still valid on the date the results are issued?	Valid up to 05 years; re-designation can cause a gap	Expiry date; written confirmation
4	Does the scope of ISO/IEC 17025 accreditation cover the test method to be used?	Methods outside the scope are not accepted	Scope of accreditation (check the relevant lines)
5	Does the scope cover the correct parameter range, objects and HS codes?	The “nearly right” risk	Scope + product/consignment description
6	Does the body have satisfactory proficiency testing or interlaboratory comparison results for that method?	Condition 3 of Article 72, Decree 37/2026/NĐ-CP	Proficiency testing report/certificate
7	Does the body have at least 06 official test technicians in that field?	Condition 4 of Article 72	Staff list (if needed)
8	Does the assessment method match the product’s risk level?	High-risk goods use only Method 5 or Method 7	Certificate stating the method explicitly
9	If the product falls under several regulations, have you identified which requirements must be assessed?	Avoid omissions and duplicate assessment	Table of regulations × requirements
10	Does the partner undertake to notify you if the designation is withdrawn or suspended?	Protects the value of results already issued	Clauses in the contract
11	Does the turnaround match the customs clearance or release schedule?	Waiting usually costs more than testing	Written timeline commitment
12	Does the quote include the follow-on steps (monitoring, production process assessment, certification fees)?	Avoid hidden costs while the dossier is live	Full quotation per method

6. Eight common mistakes that get a conformity dossier rejected

1. Trusting the words “ISO/IEC 17025” without reading the scope. An accreditation certificate says nothing about whether your specific test is covered; only the scope does.
2. Choosing a laboratory that is not on the list designated for that regulation. The results may be technically correct yet unusable for a declaration of conformity.
3. Signing the contract as the designation decision is about to expire. Re-designation must be requested 60 days in advance; if the gap is missed, results issued in that window may be unusable.
4. Mismatching the method with the risk level. Using Method 1 for high-risk goods is the commonest error; Methods 1 and 6 must not be used for this group.
5. Testing one sample and extrapolating to the whole batch. The sample must represent the registered model or type; Method 7 assesses batch by batch.
6. Using results outside the accredited or designated scope, or from a body that is not recognised, and attaching them to the dossier anyway.
7. Skipping state inspection on import or declaring conformity only after the goods are in circulation; and failing to check whether the product falls under more than one regulation.
8. Keeping no record of the partner’s competence. When a post-clearance inspection comes, or the partner’s designation is withdrawn, the business has nothing to justify its choice.

7. State quality inspection on import: the step most businesses skip

For imports subject to quality inspection, the conformity assessment results are only half the story; the other half is state inspection at the border gate. Decree 37/2026/NĐ-CP devotes a separate section to state quality inspection of imported goods, including rules for high-risk goods and mechanisms to waive or reduce inspection based on compliance history and recognised conformity assessment results.

What this means for your choice: ask the partner whether their results are accepted directly by the inspection authority for customs clearance, and whether their turnaround fits your shipping schedule. Our analysis of high-risk goods that must be tested to QCVN 4 under Circular 36/2026/TT-BKHCN describes a typical group in this category.

Do not forget the reverse risk: goods already in circulation remain subject to inspection. If the authority samples them and finds deviations from the declared results, the partner’s competence file you kept becomes the basis for allocating responsibility.

8. Overseas testing laboratories: when their results are accepted

Many businesses hold test results issued by factories or laboratories abroad and want to use them straight away. The principle: foreign test results are usable only when recognised under Vietnamese law. Circular 16/2026/TT-BKHCN (9 April 2026) details the conclusion and implementation of agreements on recognition of conformity assessment results and distinguishes two channels:

• Mutual recognition agreements (MRA) between Vietnam and one or more countries or territories — a state-to-state channel governed by the law on international treaties.
• Mutual recognition or unilateral recognition arrangements between Vietnamese and foreign conformity assessment bodies — an organisation-to-organisation channel governed by domestic law.

The definition of “unilateral recognition” is an agency or organisation in Vietnam recognising and accepting the results of a foreign body without relying on a treaty or mutual recognition agreement. In addition, each technical regulation or specialist document may set its own rules on accepting foreign test results.

Professional warning: results from a foreign laboratory that is not located in any recognition channel (and is not allowed by the relevant regulation) carry internal reference value only — they cannot support a declaration of conformity. Ask for concrete evidence of the recognition channel; do not accept “our laboratory is ISO 17025 accredited internationally” as an answer. Our analysis of Circular 16/2026/TT-BKHCN on recognition of conformity assessment results goes deeper into this mechanism.

9. Cost and time: what to look at so nothing is left out

When comparing quotes, do not compare the price of one sample. Compare the total cost of compliance under the chosen method:

• Testing fees per group of tests — they rise with the number of samples, the number of models and the complexity of the method.
• Cost of assessing the production process or management system under Methods 3–6 (factory audit, travel costs where applicable).
• Periodic monitoring fees — Methods 2–6 require monitoring and are valid for a maximum of 5 years; the most commonly forgotten line when budgeting.
• Certification and maintenance fees charged by the certification body.
• State inspection fees and related costs at the border gate (where inspection applies).
• The biggest hidden cost: a rejected dossier. Retesting, restocking and slow sales normally dwarf the difference between a cheap laboratory and a sound one.

On timing, plan backwards from the end point: customs clearance or expected sale date → less state inspection time → less certification or assessment of the production process → less testing time → less time for sampling, shipping samples and sample preparation. Delays usually hide in sampling and in waiting for monitoring results.

10. A five-step process for choosing a testing laboratory

1. Define the legal question first. Look up the product’s risk level and product group (Appendix I/II of Circular 36/2026/TT-BKHCN; the table of 69 goods groups in Appendix I of Decree 37/2026/NĐ-CP) to establish which regulations apply and which assessment method each requires.
2. Choose the conformity assessment method under Circular 14/2026/TT-BKHCN (remember: high-risk goods may use only Method 5 or Method 7).
3. Shortlist qualified partners: collect the three layers of paperwork — activity registration, scope of accreditation, designation decision — and check the updated designation list on the date you engage them.
4. Compare total compliance cost and lead time, using the 12-question checklist in section 5.
5. File the partner’s competence profile (scans of the three layers, the scope and notification commitment clauses) with the quality records of the products and shipments.

Useful references on this site: the conditions and procedures for designating a conformity assessment body under Decree 37/2026/NĐ-CP, the overview of Decree 37/2026/NĐ-CP and QCVN 4:2009/BKHCN with Amendment 1:2016.

Frequently asked questions

1. Is an ISO/IEC 17025 accreditation certificate enough to declare conformity?

No. ISO/IEC 17025 accreditation proves technical competence, but results support a declaration of conformity only when the issuing body is recognised, designated or acknowledged and its testing scope matches the applicable regulation. For high-risk goods the laboratory must be designated.

2. How do I know a laboratory is designated for the exact regulation I need?

Check the designation decision and the list of designated organisations — published and updated before the 25th of each month. Match the regulation, the product group and the test method, and confirm validity on the date the results are issued.

3. How long is a designation decision valid, and what should I watch?

A maximum of 05 years; re-designation must be requested 60 days before expiry. A partner mid-way through re-designation may have its delivery capacity disrupted — for long certification programmes, ask about validity in advance.

4. Are test results from an overseas laboratory accepted?

Yes, if the result falls within a recognition channel under Vietnamese law (a treaty-based mutual recognition agreement, or unilateral recognition), or is permitted by the relevant regulation. Otherwise it serves only as internal reference.

5. What if my product falls under both QCVN 4 and another technical regulation?

The product must fully meet each applicable national technical regulation, each with its own assessment method according to the risk level, but the same technical requirement is not assessed twice. Draw up a table of regulations × requirements before scheduling any test.

6. What if the laboratory’s designation is withdrawn after my results were issued?

That is a legal risk for everyone relying on the results. Keeping the partner’s competence profile as at the date of issue (designation decision, scope of accreditation, activity registration) is an essential safeguard, and the contract should include a notification commitment clause.

Related articles

• Activity registration under Decree 22/2026/NĐ-CP and designation under Decree 37/2026/NĐ-CP: two lawful routes
• Designating a conformity assessment body under Decree 37/2026/NĐ-CP: conditions, procedure, scope
• Circular 16/2026/TT-BKHCN: concluding and implementing agreements on recognition of conformity assessment results
• The 8 assessment methods under Circular 14/2026/TT-BKHCN: choosing the right one
• High-risk goods must be tested to QCVN 4 under Circular 36/2026/TT-BKHCN
• Conformity assessment procedure 2026: household electrical appliances and ICT equipment
• Decree 37/2026/NĐ-CP: overview of 8 chapters – 99 articles

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Disclaimer

This article was compiled by ticforall.com to share legal knowledge on standards, measurement and quality; the content is not legal advice. The regulations are interpreted according to Decree 22/2026/NĐ-CP, Decree 37/2026/NĐ-CP, Circular 14/2026/TT-BKHCN, Circular 16/2026/TT-BKHCN and Circular 36/2026/TT-BKHCN; referenced documents may be amended, supplemented or replaced. In case of any difference between this article and the original text, the original text prevails. Businesses should check the verbatim legal documents, technical regulations and the accreditation/designation scope of each body before applying them to any specific product or shipment.

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