Decree 372/2026/NĐ-CP: What Should Manufacturing, Exporting and Processing Businesses Note?
Decree 372/2026/NĐ-CP takes effect from 1 January 2027. The Decree moves the identification, authentication and traceability of products and goods onto a shared national platform running on blockchain technology. For manufacturing, exporting and processing businesses, UID codes, master data and digital certificates may become part of their compliance records.
1. Mandatory Scope Depends on the Risk Level of the Goods
For high-risk goods, identification, authentication and traceability are mandatory, according to the list and roadmap. Medium- and low-risk goods are encouraged to apply them voluntarily (Article 1). The list of high-risk goods and the roadmap are issued by each line ministry (Point a, Clause 2, Article 1; Clause 3, Article 11); traceability is carried out under Decree 37/2026/NĐ-CP (Clause 6, Article 1).
| Goods group | Level of application |
| High-risk goods | Mandatory identification, authentication and traceability according to the list and roadmap |
| Medium- and low-risk goods | Voluntary application encouraged (Article 1) |
| Exported goods | Voluntary application, unless specialized laws provide otherwise |
| Goods temporarily imported for re-export, in transit, under entrepôt trade, transshipped, and goods deposited in bonded warehouses for export to a third country | Outside the scope |
Regarding processed goods, the Decree lists processing organizations and individuals among the subjects of application (Article
2). However, this does not mean that all processed goods are subject to mandatory requirements.
In UNI’s assessment, for processed products or export-manufactured products converted to domestic consumption, businesses need to check the list of high-risk goods and specialized requirements to determine their obligations.
2. Products Must Have a GTIN Before a UID Is Created
A UID is a link following the GS1 Digital Link standard, generated automatically and free of charge by the platform (Articles 5 and 9 and the Appendix). Under the structure in the Appendix, element “01” (GTIN) is mandatory. Therefore, products without a GTIN need to register a number and barcode before creating a UID.
High-risk goods that must be identified down to each unit also need a batch number (element “10”) or serial number (element “21”). The UID does not replace legally issued GTIN, GLN or tracking codes.
3. Master Data Should Be Consistent with Invoices, Declarations and Labels
Manufacturers and importers are responsible for creating master data for products and goods (Point a, Clause 3, Article 21). Under Clause 8, Article 3, master data includes:
- Name of the product or goods
- Name, address and tax code (or identification number) of the manufacturing or trading organization or individual
- Code and name of the product group/sector under the Vietnam Product Classification System
- HS code (for exported and imported goods)
- Origin
- Brand, trademark, lot/batch number or serial number (if any)
- Expiry date (if any)
- Applicable standards and technical regulations
The UID will be used to match the goods name on the invoice with the master data. The Ministry of Finance will provide guidance on how to show the UID on e-invoices (Clause 4, Article 5). The platform automatically alerts the regulatory authorities to conflicting or abnormal data (Point c, Clause 6, Article 21). Therefore, goods names and information on invoices need to be consistent with the registered master data.
4. Businesses Digitally Sign Their Own Data and Are Responsible for It
Businesses create and digitally sign data at key events, including when the invoice is issued and when customs decides on clearance (Articles 8 and 11).
- Private key: kept by the business itself and must not be disclosed to anyone, including the National Data Center (Article 7).
- If a digital certificate creation service provider is engaged: an agreement is mandatory, clearly stating who does what, the scope of work and the legal responsibility of each party.
- Incorrectly declared data before the product is put into circulation: may only have its status updated and must not be deleted (Clause 2, Article 24). Businesses are exempt from liability if they can prove force majeure, an objective technical incident, or a third-party data error that they could not have known about (Article 25).
- Violations: the Ministry of Public Security will publicly name violating organizations on the platform (Article 31).
- Customs Looks Up UIDs, C/Os Digitized According to a Roadmap, 6-Month Connection Deadline
Customs authorities and competent forces at border gates may look up and authenticate UIDs to inspect exported and imported goods (Clause 6, Article 14).
For goods within the scope of application, data from quality certificates, C/Os, and certificates of conformity with technical regulations and standards are created as digital certificates. Digital certificates created on the National Platform have the same validity as originals in accordance with regulations (Clause 6, Article 11).
Businesses operating traceability systems must connect to the platform no later than 6 months after the National Data Center announces that the platform is ready. Validly issued data and barcodes remain unchanged (Article 37).
Need Support with Decree 372/2026/NĐ-CP?
UNI is ready to help businesses review the scope of application and standardize master data, HS codes and origin. UNI also supports the review of processing contracts and supply contracts under Decree 372/2026/NĐ-CP. Contact UNI for an assessment by product group and specific business model. Learn more about UNI’s customs consulting services.
Source: Based on Decree 372/2026/NĐ-CP dated 29 September 2026
Related UNI services:
- Full-Package Customs Declaration Service – UNI Customs Consulting
- C/O Application & FTA Consulting Services
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