Importing into Vietnam

A manufacturer in Vietnam that imports materials from China uses its import document set twice: first to complete import customs procedures, and again to prove the origin of the finished product when applying for a C/O. This page answers three questions: which groups of work an import consignment gives rise to, which figures on the import customs declaration are reused when applying for a C/O, and which article on this website to read first. Export customs procedures, the sequence of applying for a C/O and transport through border gates are outside the scope of this page.

Summary

• The customs dossier for imported goods comprises 12 groups of documents, from Point a to Point m, Clause 2, Article 16 of Circular No. 38/2015/TT-BTC dated 25 March 2015 of the Ministry of Finance, as amended and supplemented by Circular No. 39/2018/TT-BTC and Circular No. 121/2025/TT-BTC (hereinafter referred to as Circular No. 38/2015/TT-BTC); the customs declaration is the only document present in every consignment.
• An import consignment has four time limits to track: 60 days for a supplementary declaration, 30 days for consultation on the customs value, 01 year to submit the proof of origin later, and 05 years to keep the customs dossier. The four time limits do not run from the same date.
• The import customs declaration for materials is an input document of the C/O application file for the finished product; the HS code, value and quantity on the declaration are reused in that file.
• The HS code and the description of each material should be fixed when the purchase contract is signed, before the time of import.

Four groups of work for an import consignment and the article to read for each

An import consignment gives rise to four groups of work in chronological order, from preparing the documents to the end of the period for keeping the customs dossier.

The four time limits above do not run from the same date: the 60-day limit runs from the date of customs clearance, the 30-day limit from the date of release of goods or the date of taking the goods into the declarant's storage, and the 01-year and 05-year limits from the date of registration of the customs declaration. An enterprise needs to record all of these dates in the tracking log of each consignment.

Figures on the import customs declaration are reused in the C/O application file

Of the four groups of work for a consignment, the one with the longest effect is the figures on the import customs declaration. The declaration for a consignment of materials does not cease to matter once the goods are cleared. When the enterprise applies for a C/O for the finished product, that declaration is the document proving the source and the value of the non-originating materials.

Three figures on the declaration are reused:

• The HS code of the material is the code compared with the HS code of the finished product when the change in tariff classification criterion is assessed.
• The value of the material is the basis for proving the value of non-originating materials when the value percentage is calculated.
• The quantity of the material is the quantity deducted step by step with each C/O application. The record of the quantity already deducted is what people who prepare these files call the deduction ledger.

The consequence is that errors in the import customs declaration are discovered late. An HS code for a material declared by following the previous consignment without rechecking, an abbreviated description of goods, or a value redetermined after consultation all throw off the statement demonstrating compliance with the origin criterion, which is prepared many months later. By then the 60-day time limit for a supplementary declaration from the date of customs clearance has passed, and a supplementary declaration is a case subject to handling under the regulations (Point b.2, Clause 1, Article 20 of Circular No. 38/2015/TT-BTC).

When I review a factory's statement, I place the detailed report of imported goods for the import customs declarations of the materials next to the statement and compare the three figures above before looking at any other document. The full comparison is the four-way cross-check: the statement must reconcile at the same time with the quantity of materials imported, the quantity of finished goods exported, the production process and the origin criterion of the product.

I recommend that an enterprise fix the HS code and the description of each material when the purchase contract is signed, or at the latest before the time of import. On import, the enterprise uses exactly that code and that description on the commercial invoice and the import customs declaration, and later on the statement when applying for a C/O. These three documents are prepared at different times, usually by different departments. They are placed side by side only when the C/O application file is examined. An error at import is hard to correct at export.

If you are preparing to import the first consignment of materials for a product for which a C/O will be applied for, you may send me the intended HS code of the material, the HS code of the finished product and the export market. I will reply with the origin criterion that applies to the finished product and the figures on the import customs declaration that need to match the C/O application file.

Are you preparing an origin-criterion statement and unsure whether the numbers reconcile? Send me the material import declarations, input invoices, exported output quantity and finished-product HS code. I will run the four-way reconciliation and identify which direction does not match.

Contact form

Article to read first

The article Customs value and value consultation in Vietnam is the most complete article in this section as at 6 October 2026. It sets out the six methods for determining the customs value of imported goods, four cases of rejection, five cases of doubt and the consultation sequence.

Legal basis

The Articles of Circular No. 38/2015/TT-BTC are cited as amended by Circular No. 121/2025/TT-BTC, effective from 1 February 2026. The status of validity in the table was checked on 3 October 2026. The provisions cited on this page have been checked against the full text of the documents; the Law on Customs No. 54/2014/QH13 was checked against the original 2014 text.

Read next

• Origin of goods and export C/O. Conditions, documents and where to file a C/O application for goods produced in Vietnam.
• C/O application file. Where the import customs declaration for materials sits in the file for each consignment.
• Transport and border gates. Road transport on the China, Vietnam, Cambodia route.