Imported electronics do not stop at a correct customs declaration. Before the goods may be placed on the market, the consignment must also pass a quality inspection step under Decree 37/2026/ND-CP, and that step depends on the risk level assigned to each product type. This article follows the real sequence of a consignment: which regulatory track applies, the dossier to prepare, the processing deadlines, the conditions for reduced or exempted inspection, how to handle a discrepancy, and what to do before the goods reach the port.
1. Three regulatory tracks when electronics arrive at the border
Article 82 of Decree 37/2026/ND-CP divides imports into three tracks, and the enterprise must work out which track its consignment falls into before starting procedures.
| Track | What the enterprise must do | When |
|---|---|---|
| Medium-risk goods | No quality inspection at import, but a declaration of conformity is required under the corresponding national technical regulation | Before the goods are placed on the market |
| High-risk goods | Quality inspection must be registered with the inspection body of the line ministry | Before customs clearance |
| Goods that already hold a circulation licence, or are already subject to an equivalent quality regime under specialised law | No re-inspection under Decree 37/2026/ND-CP; the specialised law applies | As provided by the specialised law |
For electrical and electronic equipment, most products sit in the medium-risk group: they are not held at the border, but a declaration of conformity is still required before sale. The high-risk group is usually made up of devices with a strong potential to cause unsafe conditions, or devices already subject to a quality warning; those must register for inspection before clearance. The lists are issued by each line ministry, so the same device can fall under two different lists where it has both electronic and telecommunications functions.
2. Article 68: mandatory conditions before the goods reach the market
Article 68 sets the underlying duty: importing organisations and individuals must meet the quality management requirements of Article 34 of the Law on Product and Goods Quality, as amended by paragraph 19 of Article 1 of Law No. 78/2025/QH15, before the goods are placed on the market.
Paragraph 2 of Article 68 deals with the hardest group in practice: medium-risk or high-risk goods with a new characteristic that may create an unsafe condition in normal transport, storage, preservation or use, where that characteristic is not yet covered by the corresponding national technical regulation; or goods imported for the first time that may create an unsafe condition. For this group the enterprise must prove that the product is safe for people, animals, plants, property and the environment, as required by the line ministry. The goods may only be placed on the market once that ministry gives permission.
This is the point distributors of new equipment most often miss. A product with no corresponding national technical regulation is not thereby free to sell. Without a regulation there is no basis for a declaration of conformity, and the only route left is to prove safety as the line ministry requires.
3. The inspection registration dossier: two situations, two sets of documents
Article 83 splits according to whether the consignment already has a certificate of conformity, because the handling and the timing differ.
| Document | Certificate of conformity held | No certificate of conformity |
|---|---|---|
| Registration of state quality inspection of imports, Form No. 1, Annex VII | Required | Required |
| Certificate of conformity issued by a designated conformity assessment body | Required | Filed later, once the assessment result is available |
| Photograph or description of the goods together with the content of the main label | Required for goods that must carry a label | Required for goods that must carry a label |
| Draft supplementary label where the main label is incomplete | Required if the main label is insufficient | Required if the main label is insufficient |
Where the certificate of conformity is issued for a specific consignment, it must carry the full consignment data: product name, brand, model, technical characteristics, origin, manufacturer, weight or quantity, import declaration number and invoice. If one of those is missing, the inspection body treats the certificate as not matching the consignment file and issues a notice that the goods do not meet quality requirements.
An electronic label is accepted where it meets the law on goods labelling. Responsibility for the validity of the import dossier rests with the enterprise, not with the foreign supplier.
4. Sequence, deadlines and the milestones that matter
Where the dossier is complete and compliant: within 01 working day of the dossier becoming complete and valid, the inspection body issues the notice of state quality inspection of imports confirming that quality requirements are met, and sends it to the importer so that customs clearance can proceed.
Article 83(1)(b), Decree 37/2026/ND-CP
| Situation | Processing deadline | Outcome |
|---|---|---|
| Dossier missing content | Completed within 07 working days of receipt | If the deadline is missed, a written notice must state the reason and the expected completion date |
| Dossier complete and compliant | 01 working day | Notice that quality requirements are met, Form No. 3, Annex VII |
| Dossier complete but the label fails | Corrected within 05 working days | Notice issued only once there is evidence of correction |
| Certificate of conformity does not match the regulation or the consignment file | Handled under the standard sequence | Notice that quality requirements are not met, copied to the customs office |
| Dossier not completed on time | 01 working day after the completion deadline expires | Notice recording that the consignment dossier was not completed |
For a consignment without a certificate of conformity, the sequence is one step longer: register for inspection, clear the goods to a storage location, instruct a designated certification body to carry out the conformity assessment, complete the dossier, and then return to the steps in the table. The mechanism for moving goods to a storage location applies uniformly to every case requiring quality inspection. It creates no new administrative procedure, but the storage location must meet customs supervision conditions.
Registration is made on the National Single Window portal or the National Public Service Portal. Where the system fails or there is a force majeure event, Article 17 of Decree 85/2019/ND-CP on the National Single Window and specialised inspection applies.
5. Testing: only results from a designated laboratory count
Article 83(6) provides that quality testing of high-risk imports is carried out at a testing laboratory designated under the law. The result issued by the designated laboratory is the basis for assessing conformity with the corresponding national technical regulation.
The consequence is that a result from a laboratory not designated for that field has no value as a basis, even where the laboratory has better technical competence and equipment. For electronic equipment a single model often has to be tested across several fields, such as electrical safety, electromagnetic compatibility, spectrum and SAR, and each field has its own list of designated bodies.
Where the relevant test method has not been laid down, is not consistent, or no laboratory has been designated, the minister in charge of the sector may decide a provisional test method, to apply until the national technical regulation is issued or a suitable laboratory is designated. That is the route for new products with no test guidance.
6. Reduced inspection: three consecutive passes, valid for two years
Article 86(3) creates a reduced-inspection regime based on compliance history, but the conditions are much narrower than commonly assumed.
High-risk goods qualify for reduced or exempted state quality inspection where all of the following are met and none of the cases in paragraph 2 of this Article applies: the goods share the same name, use, brand, model, technical characteristics, manufacturing facility and origin, and are imported by the same organisation or individual; and there have been 03 consecutive imports with a notice of state quality inspection confirming that quality requirements are met.
Article 86(3)(a), Decree 37/2026/ND-CP
| Condition | Content |
|---|---|
| Identity of the goods | Same name, use, brand, model, technical characteristics, manufacturing facility and origin |
| Importer | The same organisation or individual |
| Inspection history | 03 consecutive imports with a notice confirming quality requirements are met |
| Burden of proof | The enterprise determines eligibility itself and keeps the records for post-market checking |
| Period of application | 02 years from the date of the conformity assessment result on the third import |
| Ongoing duty | A report every 03 months on imports of goods under the reduced regime |
The regime is not an administrative procedure: it operates through risk management and data exchange between the inspection body and the customs office. The enterprise does not file an application, but it must declare the identifying codes accurately on the customs declaration: HS code, barcode number, serial number, model, manufacturer and country of origin. If those are wrong or missing, the system cannot identify the consignment as eligible, and the enterprise loses the benefit even after three passes.
The regime is suspended where a violation or a sign of risk arises. The inspection body publishes the list of enterprises covered, and the list of those no longer covered, on the national product and goods quality monitoring system. The customs office clears goods on the basis of that list.
7. Exemption from inspection: 21 cases and three exclusions
Article 86(1) lists 21 cases in which high-risk goods are exempt from quality inspection at import. Those most used by electronics businesses include: samples for advertising that are not sold on the market; samples for scientific research or for research serving production; trial samples; samples for testing in support of conformity assessment against a national technical regulation, or for inter-laboratory testing; goods temporarily imported for display at a trade fair and not sold off after the show; goods, materials, equipment and machinery temporarily imported for re-export and not consumed in Vietnam; and goods sent by post or express courier with a customs value below the import duty exemption threshold.
Three exclusions in paragraph 2 are where the exemption is most often lost: goods subject to a safety warning issued by a competent Vietnamese authority or a relevant international body; goods on a specific control list issued by a line ministry; and goods treated as high-risk under other specialised law that requires inspection at import.
Exemption from inspection does not mean exemption from liability. Samples used for certification testing may not be sold on the market, and if their use changes they must go through the full sequence as a commercial consignment.
8. Enhanced inspection and the handling of violations
Article 84 sets three cases in which enhanced inspection applies: goods that were exempted or subject to reduced inspection but failed when checked on the market; goods originating in a country or territory on the quality risk warning list; and importers with a repeated violation history as assessed by the inspection body.
The inspection body monitors, updates and publishes the list of warned countries and territories, and collects each enterprise’s compliance history to classify risk. Enhanced inspection must not create new administrative procedures and must not extend clearance time, except where a handling measure is required by law.
Article 85 deals with three groups of discrepancy. First, goods holding a valid certificate of conformity that fail on labelling or on the conformity mark: the inspection body requires correction and issues the notice that requirements are met only once the enterprise supplies sufficient evidence of correction together with the certificate of conformity for the consignment. Second, a certificate of conformity that does not match the consignment file or the corresponding technical regulation: handled under the law, in coordination with the customs office. Third, goods whose remedial measure is recycling: the conformity assessment body must reassess the consignment after recycling, issue a notice that requirements are met for clearance if it passes, or a notice that they are not met, copied to the customs office, if it fails.
A deadline comes with this: the enterprise must send evidence of the remedial measure to the inspection body within 01 working day of completing it.
9. Export goods, and goods both exported and sold domestically
Article 87 provides that goods meeting the requirements of Article 32 of the Law on Product and Goods Quality may be exported without inspection by the inspection body. Goods intended solely for export must meet the importing country’s rules in full; the rules applying to goods circulating domestically do not apply to them.
There is an important exception for manufacturers of electronic equipment: goods that are both exported and sold domestically must meet the rules of both the importing country and Vietnam. When export goods are placed on the domestic market, the enterprise must meet Articles 88, 89 and 90 of Decree 37/2026/ND-CP, which means a declaration of conformity and exposure to market quality checks. Where export goods fail to meet quality requirements in a way that affects national interests or reputation, the inspection body carries out an in-production quality check under Article 79 and handles the case under Article 81.
10. What to prepare before the goods arrive at the port
| Action | Legal basis | Risk if skipped |
|---|---|---|
| Determine the risk level of each product code against the line ministry list | Article 82 | Wrong dossier prepared, goods held at the border |
| Check whether the certificate of conformity covers the consignment or only the model | Article 83(1)(a) | Notice that quality requirements are not met |
| Complete the main label, supplementary label and conformity mark before the goods arrive | Articles 83 and 85 | A further 05 working days lost to correction |
| Choose a laboratory designated for the right field | Article 83(6) | Test result cannot be used as a basis |
| Declare the full set of identifying codes to enter the reduced regime | Article 86(3) | Loss of the reduced regime despite three passes |
| Set up the 03-month reporting schedule for goods under reduced inspection | Article 86(3)(c) | The reduced regime is suspended |
For importers of electronic equipment, the efficient order of work is to settle the risk level of the product code first, and only then deal with testing and certification. Working in the reverse order usually ends with enough test data but a dossier that does not match the consignment, or a certificate issued for a model while the consignment came from a different manufacturer.
Related reading
- Importer obligations in customs procedures under Law 11/2026/QH16
- Post-clearance audit and post-market checks for imports
- Decree 22/2026/ND-CP: structure and the two chapters on conformity assessment
- Registration under Decree 22/2026 and designation under Decree 37/2026
- Declaration of conformity and self-assessment report forms
- Law 78/2025/QH15: risk management principles and declaration of conformity
- Circular 33/2026/TT-BCT: medium-risk and high-risk goods of the Ministry of Industry and Trade
- QCVN 25:2025/BKHCN: electrical equipment installed in the home
- Choosing a testing laboratory that satisfies Vietnamese law
- Product classification and analysis for classification under Circular 85/2026/TT-BTC
Sources
- Decree No. 37/2026/ND-CP of 23 January 2026 detailing the Law on Product and Goods Quality.
- Decree No. 22/2026/ND-CP of 16 January 2026 detailing the Law on Standards and Technical Regulations.
- Law No. 11/2026/QH16 amending and supplementing a number of articles of the Law on Customs, in force from 1 March 2027.
- Law on Customs No. 54/2014/QH13.
This article is published to spread knowledge about import and export standards, regulations and procedures. It does not replace the legal documents and is not legal advice for any specific case. Enterprises should check the original texts and the instructions of the inspection body before applying.
