Guidelines For Identifying Specialized Electronic Equipment

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Guidelines-For-Identifying-Specialized-Electronic-Equipment.

On June 17, 2025, the Ministry of Science and Technology – Department of Information Technology Industry issued a guidance document on distinguishing between specialized electronic and household electronic devices. 

1. Legal basis:  

  • Article 4.11 of the Law on Information Technology: Electronic equipment is refers to digital devices used to produce, transmit, collect, process, store and exchange digital information. 
  • Article 3.15 of Decree No. 71/2007/ND-CP: Special-use electronic equipment means electronic equipment serving specialized fields such as medical equipment, transportation, construction, automation, biology, geology, environment, etc. 
  • Article 3.14 of Decree 71/2007/ND-CP: Household electronic devices are electronic devices refers to devices used in domestic settings. For example, air conditioners, refrigerators, washing machines, microwave ovens, vacuum cleaners, etc. 

2. Criteria for identification of specialized electronic equipment: 

Criteria  Description 
Structure  Must consist of fundamental electronic components such as diodes, transistors, integrated circuits, microprocessors, etc. 
Functionality  Must perform one or more of the following as defined by the IT Law: production, transmission, collection, processing, storage, or exchange of digital information. 
Purpose of Use 
  • Designed and manufactured to perform a specific, specialized function, which is not a universal appliance;  
  • Serving a specific profession, field or professional job;  
  • Have specialized operating processes such as medical, transportation and construction, automation, biology   
  • Distinguishes it from household electronics: designed and manufactured to perform common or multifunctional functions; serving the needs of households and individuals  

3. CNC Machines and Industrial Equipment Not Classified as Specialized Electronic Equipment: 

In this regard, the Department of Information Technology Industry believes that machine tools are usually composed of two main parts:  

  • A main functional component (e.g., processing, lifting, injection molding, separation systems), and 
  • A control component (hardware/software). 

Therefore, in terms of structure and function, specific machine tools in industries are not considered electronic devices. 

Some types of industrial machinery that are not considered electronic devices in question include: 

  • CNC Machine,  
  • Elevator  
  • Plastic injection molding machine,  
  • Gas Chromatography Equipment,  
  • Liquid chromatography equipment,  
  • Spectral mass equipment…  
  • Other specific types of machinery in other industries. 

However, enterprises are advised to self-assess their products based on the actual structure and function, using the criteria above  

(According to Official Letter No. 520/CNITTT-CL  dated June 17, 2025) 

Related services: 

Legal Analysis and verification, Compliance Check, Tax refund consulting. 

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