Vietnam’s New Risk-Based Management Framework for Imported ICT Goods from July 2026

1. Introduction: the context of the transformation

Prior to 2026, the state management system for the quality of imported information technology and telecommunications goods will operate on a pre-inspection model based on the 2007 Law on Product and Goods Quality. All products capable of broadcasting or network connectivity must undergo physical testing and conformity certification before customs clearance, carried out by the Telecommunications Department.

Pressure from international integration and the need for institutional reform have led to the promulgation of new legal documents. These documents shift the management model from “pre-approval” to “risk management” combined with the digitalization of administrative procedures.

2. Current management status before July 1, 2026

2.1. General import inspection under Group 2

• Legal basis : Law on Product and Goods Quality 2007; Decree No. 132/2008/ND-CP, Decree No. 74/2018/ND-CP, Decree No. 154/2018/ND-CP.
• Principle : Goods that may pose a safety risk (Group 2) are required to undergo state quality inspection at the border before customs clearance.

2.2. Quality management during import of goods in Group 2 in the ICT sector according to Circular No. 30/2011/TT-BTTTT and Circular No. 29/2025/TT-BKHCN

• Test results : Must be issued by a designated testing laboratory or in accordance with a Mutual Recognition Agreement (MRA) and comply with national technical regulations (QCVN). Results according to international standards (FCC, CE) are not accepted directly.
• Appendix I – Mandatory Conformity Certification and Declaration (for devices with radio wave radiation and high-frequency interference risks):
• Radio transmitting and receiving equipment for fixed or mobile terrestrial services.
• Base station equipment for mobile networks (GSM, W-CDMA, E-UTRA, 5G).
• Digital microwave equipment.
• Short-range radio equipment (WLAN – Wi- ‑Fi, Access Point).
• Radar equipment is used in transportation applications.
• DECT cordless telephone.
• Flycams (unmanned aerial vehicles) are equipped with cameras and transmit signals.

Appendix II – Mandatory conformity declaration only (consumer information technology equipment): Desktop personal computers, industrial computers (HS code 84714090), laptops, tablets…

3. New legal framework from July 1, 2026

Law No. 78/2025/QH15 (amending Law No. 05/2007/QH12 on Product and Goods Quality) – effective from January 1, 2026.

Decree No. 37/2026/ND-CP, effective from January 23, 2026 , provides detailed regulations for Law No. 78/2025/QH15 .

Circular No. 14/2026/TT-BKHCN, effective from May 25, 2026 , regulates the declaration of conformity to standards, declaration of compliance with regulations, and methods for assessing conformity.

3.1. Classification of products according to risk level (Article 4 of Decree No. 37/2026/ND-CP)

Decree No. 37/2026/ND-CP replaces the classification of goods into Group 1 ( unlikely to cause safety hazards ) and Group 2 ( likely to cause safety hazards ) with a three-level risk scale:

3.2. Restructuring the conformity assessment methodology (Circular No. 14/2026/TT-BKHCN)

Circular No. 14/2026/TT-BKHCN stipulates 8 conformity assessment methods (from Method 1 to Method 8). A noteworthy point is the regulation that Method 1 (as in the current Circular 30/2011/TT-BTTTT) and Method 6 cannot be used to assess conformity for high-risk products and goods.

Explain the methods:

• Method 1 – Typical sample testing: Submit one sample. If it passes, certification applies to all products of that type. Low cost, fast. Not allowed for high‑risk goods.
• Method 2 – Sample + process assessment (monitoring via process): Test a sample and assess the factory’s quality management system. Monitoring is done through periodic production process checks (not sample retesting).
• Method 3 – Sample + periodic sample monitoring: Test a sample, then monitor by periodically retesting samples taken from production or the market. No production process assessment.
• Method 4 – Sample + process + periodic sample monitoring: Combines Method 2 and Method 3 – both production process assessment and periodic sample retesting.
• Method 5 – Sample + process + comprehensive periodic monitoring: Assess the quality management system and also periodically retest samples from production or the market. Requires stable production.
• Method 6 – Management system only: Assess and monitor the factory’s quality management system without product sample testing. Not allowed for high‑risk goods.
• Method 7 – Batch testing: Test each batch separately. The certificate is valid only for that specific batch. Suitable for intermittent production or high batch‑to‑batch variation.
• Method 8 – Combined methods: Allows the certification body to create a flexible method by combining any of the above or adding other technical measures, as long as reliability is equivalent.

Applicable subjects:

• High-risk goods: methods 2, 3, 4, 5, 7, or 8 must be applied (methods 1 and 6 are not permitted).
• Medium-risk goods: Method 1 is permitted.

3.3. State inspection upon import (Article 7 of Decree No. 37/2026/ND-CP) Imported products and goods with a high level of risk must undergo state quality inspection before customs clearance.

Goods with medium and low risk are not subject to state inspection upon import; businesses carry out the procedure of self-declaring conformity.

3.4. Traceability and electronic labeling (Article 32 of Decree No. 37/2026/ND-CP)

Product traceability: For high-risk goods, establishing a traceability system and connecting to the National Traceability Portal (managed by the Ministry of Science and Technology) is mandatory.

Electronic labels: Businesses are allowed to use electronic labels to display part or all of the mandatory labeling information, replacing physical labels, in accordance with Decree No. 43/2017/ND-CP and Decree No. 111/2021/ND-CP.

4. Impact on the product list (Circular 29/2025/TT-BKHCN)

The entire list of goods in Circular No. 29/2025/TT-BKHCN will be replaced by the List of High-Risk Goods and the List of Medium-Risk Goods issued by the Ministry of Science and Technology (as required by the Government , this list must be issued and take effect from July 1, 2026). Currently, two units under the Ministry of Science and Technology (MST), namely the National Standards, Metrology and Quality Committee ( STAMEQ) and VNTA, are negotiating to finalize this list . According to the new assessment method for classifying goods, it is possible that: Items listed in Appendix II (only requiring conformity declaration) of Circular 29 (laptops, tablets, STBs, televisions) may be moved to the medium or low risk group, and even many items listed in Appendix 1 (mandatory conformity certification and declaration) may not be classified as high-risk goods.

5. Recommendations

5.1. Point c, Clause 2, Article 97 of Decree No. 37/2026/ND-CP stipulates the transitional period as follows:

“From January 23, 2026 to June 30, 2026, the classification of products and goods into Group 1 and Group 2, and the application of management measures for products and goods in Group 1 and Group 2, will continue to be implemented according to the old regulations.”

Therefore, during the period from January 23, 2026 to June 30, 2026, businesses must still comply with Circular No. 30/2011/TT-BTTTT and Circular No. 29/2025/TT-BKHCN. From July 1, 2026, the three-tiered risk management mechanism will officially come into effect.

As of April 2026, the Ministry of Science and Technology has not yet issued a list of high-risk and medium-risk products and goods to replace Circular 29. Businesses need to closely monitor the issuance of this document.

5.2. Closely monitor the issuance of high/medium risk lists: 

Note that current Vietnamese legal documents are issued very quickly, take effect immediately after signing (or after a very short time), and amendments also occur more rapidly than before. Businesses must regularly update their tax identification numbers (MST) and VNTA.

Note: This report is compiled based on legal regulations in effect as of April 2026. Detailed guidance documents may be issued or amended after this date; businesses should update regularly