On April 25, 2025, the General Department of Customs issued Official Letter No. 3366/CHQ-GSQL providing guidance on customs procedures for goods containing industrial precursors that are not exempt from export–import licensing.
Accordingly, the General Department of Customs provides the following opinion:
The term goods as prescribed in Decree No. 113/2017/NĐ-CP has been replaced by the term mixtures in Article 2.1 of Decree No. 82/2022/NĐ-CP. Therefore, export–import conditions shall only apply to mixtures containing industrial precursors, and not to goods containing industrial precursors.
Legal documents such as the Law on Chemicals, Decree No. 113/2017/NĐ-CP, and Decree No. 82/2022/NĐ-CP only provide regulations on the management of industrial precursors and mixtures containing industrial precursors, and do not contain specific provisions for goods containing industrial precursors.
In this Official Letter, the General Department of Customs also refers back to the guidance in Official Letter No. 7678/TCHQ-GSQL dated November 22, 2017 on a similar matter: ” Types of goods which are consumer products containing chemicals such as: sulfuric acid in lead–acid batteries; phenylacetic acid as an auxin (a type of plant hormone) in fruits; phenylacetic acid used in certain perfumes; acetic acid (used in food) applied as an organic solvent, pharmaceutical, rubber, paint, dye, food, fabric bleaching agent, etc.; acetone found in detergents, cleaning agents, epoxy resin solvents, paints, and varnishes; tartaric acid found in plants; printing inks, paints containing precursors… (as stated in Official Letter No. 7678/TCHQ-GSQL) are not subject to the provisions of Decree No. 113/2017/NĐ-CP.”
(According to Official Letter No. 3366/CHQ-GSQL dated April 25, 2025)
Customs Strengthens Verification Of Goods Origin In 2025
On May 14, 2025, the General Department of Customs issued Official Letter No. 4976/CHQ-GSQL to local customs departments regarding the strengthening of origin verification of goods.
Key verification measures include:
1. Verification of Goods Origin According to Circular 33/2023/TT-BTC
- The Customs Department requires strict compliance with Circular 33/2023/TT-BTC regarding the determination of origin for exported and imported goods. Most notably, there is an emphasis on strengthening the verification of origin criteria to ensure goods meet origin requirements.
- Example provided by the Customs Department:
- Product A needs to meet the origin criterion of RVC40% or CTH
- However, on the C/O, the goods only satisfy the origin criterion of SP (Specific Process)
- Therefore, according to regulations, Product A does not qualify for preferential treatment based on goods origin criteria.
2. Rejection of Certificates of Origin (C/O) When Customs Has Sufficient Grounds
- Customs authorities will reject C/Os if there are sufficient grounds to determine that goods do not meet origin criteria.
- The rejection process must ensure:
- Implementation within the stipulated timeframe and proper sequence
- Notification through the Customs electronic data processing system or by written document sent directly to the business
- Direct notification on the document, stating the reason for rejection on the document and returning it to the business
3. Review of Import Declarations from the Philippines
Customs Sub-Departments of Regions I and II are required to review all import declarations from the Philippines with HS codes 851629 and 853710 that have been entitled to special preferential tariffs under the ATIGA Agreement The inspection results must be reported to the Customs Department before July 1, 2025.
Customs Sub-Departments of Regions I and II include the following localities:
- Region I: Hanoi, Vinh Phuc, Phu Tho, Hoa Binh, Yen Bai, headquartered in Hanoi.
- Region II: Ho Chi Minh City.
(According to Official Letter No. 4976/CHQ-GSQL dated May 14, 2025)
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