Export customs documents and procedures

Export customs procedures and the C/O application are two different procedures, handled by two different authorities, but they are linked by one document: the cleared export declaration forms part of the C/O application under Point c, Clause 1, Article 15 of Decree 31/2018/ND-CP. The customs documentation for exported goods is set out in Clause 1, Article 16 of Circular 38/2015/TT-BTC. That article has been amended twice, most recently by Clause 4, Article 1 of Circular 121/2025/TT-BTC, applicable from 1 February 2026. The time limit for lodging the declaration is set out in Article 25 of the Law on Customs No. 54/2014/QH13. How origin is entered on the declaration is set out in Circular 33/2023/TT-BTC.

An incorrect entry on the export declaration carries over into the C/O application, and the discrepancy usually comes to light at post-clearance inspection, not at clearance. After reading this page, you will know what the customs documentation for exported goods comprises under the current version, when it is lodged, how the origin field is completed, and which particulars on the declaration must match the C/O.

• The customs documentation for exported goods is set out in eight points, a to h, of Clause 1, Article 16 of Circular 38/2015/TT-BTC, as amended by Clause 4, Article 1 of Circular 121/2025/TT-BTC, applicable from 1 February 2026. Only the customs declaration is always required; the other seven documents are submitted only where the relevant condition is met.
• The current version of Article 16 no longer specifies, for exported goods, whether an original or a copy is required or how many copies. The rules on the method of submitting documents are now in Article 3 of Circular 38/2015/TT-BTC, as amended by Clause 1, Article 1 of Circular 121/2025/TT-BTC.
• Proof of origin does not form part of the customs documentation for exported goods; the customs authority is entitled to require that it be produced where there are grounds to doubt the origin and the authority needs the exporter to prove the origin of the goods.
• The export declaration is lodged after the goods have been brought together at the notified location and no later than 4 hours before the means of transport departs; for express consignments, no later than 2 hours. The declaration is valid for 15 days from the date of registration (Article 25 of the Law on Customs No. 54/2014/QH13).
• Origin is declared in the goods-description field of the electronic declaration using the format "goods description#&VN" for goods of Vietnamese origin, "#&(country code)" for goods originating in another country, and "#&KXĐ" where the origin has not yet been determined (Circular 33/2023/TT-BTC).
• The exporter's name, the importer's name, the description of the goods, the HS code, the unit of measurement and the quantity on the export declaration must match the C/O; the HS code on the declaration is the code used to find the origin criterion (Clause 1, Article 16 of Decree 31/2018/ND-CP).
• The customs declarant keeps the customs documentation for 5 years from the date of registration of the declaration under the Law on Customs No. 54/2014/QH13; this period coincides with the time limit for post-clearance inspection.

Clause 1, Article 16 of Circular 38/2015/TT-BTC sets out the documents that form part of the customs documentation for exported goods. This article has been amended twice: first by Clause 5, Article 1 of Circular 39/2018/TT-BTC, then by Clause 4, Article 1 of Circular 121/2025/TT-BTC, applicable from 1 February 2026. Since the latest amendment the article has been titled "Customs documentation when carrying out customs procedures"; Clause 1, which has eight points, covers the documentation for exported goods.

What this means for the documentation: Point e is often read more broadly than it is written. The entrustment contract does not have to be submitted for every entrusted export consignment, but only where that consignment requires an export licence, a specialised inspection certificate, or supporting evidence of eligibility to export.

Proof of origin is not among the eight points above. The customs declarant may submit it voluntarily, and the customs authority is entitled to require that it be produced where there are grounds to doubt the origin of the exported goods, under Circular 33/2023/TT-BTC.

The version of Article 16 before 1 February 2026 stated for each document whether an original or a copy was to be submitted and how many copies. The current version no longer contains those requirements in the part on the documentation for exported goods. The provisions on the method of submission have moved to Article 3 of Circular 38/2015/TT-BTC, as amended by Clause 1, Article 1 of Circular 121/2025/TT-BTC; the article is titled "Provisions on the submission, certification and use of documents forming part of the customs documentation and the tax documentation".

What this means for the documentation: guidance written before 2026 still states "01 copy" or "01 original" for each document for exported goods, following the old version. If you cannot find those requirements in the current version of Article 16, that is correct; nothing is missing.

What this means for the documentation: companies exporting raw timber must still comply with forestry legislation on forest product documentation, but the forest product packing list no longer forms part of the customs documentation that the customs authority can require when the declaration is registered.

Article 25 of the Law on Customs No. 54/2014/QH13 sets the time limit for lodging the customs documentation and the validity of the declaration.

What this means for the documentation: if more than 15 days have passed since the date of registration and the export customs procedures have not been completed, the declaration is no longer valid for customs procedures and a new declaration must be registered. For goods exported by road through the northern border crossings, this deadline must be tracked for as long as the vehicle is still queuing, the consignment has not entered the supervision area, or the export procedures remain incomplete.

Circular 33/2023/TT-BTC requires the customs declarant to declare the origin of exported goods in the goods-description field of the electronic declaration, or in the origin field of the paper declaration, using the format below.

What this means for the documentation: an export declaration that declares Vietnamese origin while the C/O application cannot show that the criterion is met gives two sets of documentation that contradict each other. This contradiction comes to light at post-clearance inspection. Goods that have undergone only the simple working or processing operations in Article 9 of Decree 31/2018/ND-CP must be declared with the code #&KXĐ, not with the origin code #&VN.

Point c, Clause 1, Article 15 of Decree 31/2018/ND-CP provides that the printout of the export declaration forms part of the C/O application, except for exported goods that do not have to be declared to customs. Clause 3, Article 15 allows this document to be submitted after the C/O has been issued, but no more than 15 working days later. If it is not submitted by that deadline, the issuing authority requires the withdrawal or cancellation of the C/O under Point c, Clause 1, Article 22.

What this means for the documentation: an incorrect HS code on the export declaration leads to the wrong criterion being found, and the whole C/O application is then built on a criterion that does not apply to the product. A discrepancy in the description of the goods or the unit of measurement between the export declaration, the invoice and the C/O is a common reason for the C/O to be rejected in the importing country, even where the issuing authority in Vietnam has issued it.

Point đ, Clause 2, Article 18 of the Law on Customs No. 54/2014/QH13 requires the customs declarant to keep the customs documentation for cleared goods for 5 years from the date of registration of the customs declaration. Books and records, accounting source documents and other related documents are kept for the period prescribed by law. The retention period for the customs documentation is the same as the period covered by post-clearance inspection and as the minimum retention period for the trader's C/O application under Clause 3, Article 30 of Decree 31/2018/ND-CP; for the C/O application, however, the period starts on the date the C/O is issued.

What this means for the documentation: the two 5-year periods do not start on the same date; one runs from the date of registration of the declaration, the other from the date of issuance of the C/O. Accounting source documents used directly for making accounting entries, such as invoices for the purchase of materials, are kept for at least 10 years under Clause 1, Article 13 of Decree 174/2016/ND-CP. The details are on the page "Substantiating origin, C/O record retention and post-issuance verification".

What this means for the documentation: guidance written before 2026 may no longer be correct in every detail. The 4-hour, 2-hour and 15-day time limits in section 4 of this page, however, still apply from 1 March 2027 under Law No. 11/2026/QH16; from that date, the basis for the 15-day time limit is Point a, Clause 1, Article 24 of the Law on Customs, instead of Clause 2, Article 25 of the law as it currently stands.

If you are not yet sure how to complete the origin field on the export declaration so that it matches the C/O application you are about to submit, you can send me the HS code of the finished product, the description of the goods and the C/O form you intend to apply for. I will tell you whether you should declare VN or KXĐ, and which items on the declaration must match the C/O.

What I do here is origin documentation and customs procedures work, within the scope of the professional certificates I hold; it is not legal advice on a specific matter.

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• C/O application for goods produced in Vietnam. The nine groups of documents in Clause 1, Article 15 and the issuing authority for each C/O form.
• Substantiating origin, C/O record retention and post-issuance verification. The documents that must be kept and how to respond when you are subject to verification.
• Common errors when applying for a C/O and how to deal with them. The errors repeated most often in real applications.
• Origin of goods and the certificate of origin (C/O) for goods produced in Vietnam. The overview page for this whole topic.

Hoàng Ngọc Quang (QuangLogi)

Registered customs-broker staff member assigned an identification number by Vietnam Customs under Official Letter No. 249/GSQL-TH dated 20 February 2025.
Customs declaration professional certificate No. 165/2018/KHQ-HN.
Vice Director of GIANG TO VIEN DUONG INTERNATIONAL TRANSPORT Co., Ltd. (Luchi Vietnam).
Member of the Vietnam Association for Logistics Manpower Development (VALOMA) under Admission Decision No. 1003/QD-BCH.
Trained as a lawyer in Course IX of the lawyer training programme for international integration at the Judicial Academy.
More than ten years handling documents and customs procedures on the China-Vietnam-Cambodia corridor, including C/O applications for goods exported from Vietnam and C/O files for goods imported from China.
About the author

I write as someone who prepares these applications myself. Any case and client details in the examples have been anonymised.