Customs Department Issues New Procedure for Inspection and Verification of Goods Origin

Table of Contents

On April 29, 2025, the Customs Department issued Decision No. 467/QD-CHQ regarding the procedure for the inspection and verification of the origin of exported and imported goods. This new procedure replaces the former processes stipulated in Decision No. 4286/QD-TCHQ (2015) and Decision No. 136/QD-TCHQ (2016). This move aims to strengthen the management of goods origin in alignment with directives from the Government and the Ministry of Industry and Trade.

Key Points of the New Procedure:

1. General Structure of the Decision

The procedure attached to Decision No. 467/QD-CHQ consists of 14 Articles, structured into 5 main Chapters:

Chapter I: General Provisions

Chapter II: Advanced Rulings on the Origin of Exported and Imported Goods

Chapter III: Inspection and Verification of the Origin of Exported Goods

Chapter IV: Inspection and Verification of the Origin of Imported Goods

Chapter V: Implementation Provisions.

2. Effective Date and Scope of Application

Effective from April 29, 2025, concurrent with Decision No. 467/QD-CHQ.

During the period this Decision is effective, any amendments, supplements, or replacements of the referenced documents shall follow the latest regulations.
This procedure supersedes the previous procedures stated in Decision No. 4286/QD-TCHQ (2015) and Decision No. 136/QD-TCHQ (2016).

3. Procedure for Inspection and Verification of the Origin of Imported Goods

3.1. Verification of Declared Origin Information and C/O Deduction Monitoring

a. At the time of customs clearance:

Enterprises submit the Certificate of Origin (C/O) electronically or in paper form.

Customs authorities verify the country of origin, tariff schedules, reference numbers, and other declared information.

b. In the case of supplementary C/O submission after customs clearance or goods release:

Customs authorities validate the C/O’s effectiveness on the AMA declaration and cross-check with related documents to determine the origin.

c. When enterprises change the purpose of use:

Customs authorities inspect the C/O information (reference number, date of issuance, etc.) on the original or amended declaration form.

d. Monitoring and deducting C/O:

Before clearing the first consignment from the bonded warehouse or multiple consignments under the same contract, Customs guides enterprises to register for C/O deduction monitoring.

Customs issues a Monitoring Slip, guides enterprises to fill out information, and inspects the actual quantity to confirm the deduction until the entire amount is used up.

3.2. Inspection of the Certificate of Origin (C/O) Documentation

a. Content Inspection of C/O

Inspection Content

Criteria

Reference Number and Issue Date

Must match the information declared on the customs declaration;

If the C/O issuing authority has provided notification regarding reference number format, verification must follow that notification;

Each C/O must be unique – if duplicate reference numbers and issuance dates are detected on different import declarations, the C/O must be rejected;;

Signature and seal on C/O

For C/Os without electronic data for verification: check signature, seal specimen of the C/O issuer;

Ensure these elements are valid, effective, and comply with published notifications;

If the FTA does not require signature verification: only check the validity of the seal on the C/O

C/O Issuance Date

C/O is only valid for 12 months from the date of issuance;

Ensure the C/O is submitted within its validity period, except in cases where supplementary submission is permitted under Article 13 of Circular 33/2023/TT-BTC.

Exporter’s Name

Must be consistent with information on the customs declaration and documents in the file;

For third-party transactions: carefully examine third-party information according to regulations

Importer’s Name

Must match the importer’s name on the customs declaration;

In case of differences between the importer’s name on the C/O and on the declaration, approval is only granted for back-to-back C/O cases.

Loading Port, Transport Vessel Name

Ensure goods comply with the direct transport rule according to the FTA

For transit through a third country: require submission of supporting documents as per Article 18 of Circular 33/2023/TT-BTC.

Product Description

Must match the product name on the declaration and other documents;

If a C/O includes multiple items, only problematic items will be excluded from preferential treatment, while the remaining items will still be considered;

Goods with the same name, HS code, origin criteria but different models, capacity, size, etc., and grouped in box 7 are still accepted if physical inspection or documentation confirms their validity;

If goods have different origin criteria: mandatory to declare each item separately.

HS Code: in case of differences in HS codes between exporting and importing countries

If the product name on the C/O does not match the name declared on the customs declaration or does not match the classification analysis results or does not match the actual goods: the C/O may be rejected;

If there is insufficient basis for determination: process according to Article 16 of Circular 33/2023/TT-BTC regarding “Handling differences in HS codes on certificates of origin of imported goods and HS codes on customs declarations in special cases”

Quantity/Weight of Goods:

If the actual imported quantity differs from the quantity on the C/O: handle according to Clauses 5 and 6, Article 15 of Circular 33/2023/TT-BTC.

Commercial Invoice:

If the invoice is issued by a third party: verify third-party information according to the applicable FTA and related legal documents..

Origin Criteria:

Check how origin criteria are recorded: regional value content, HS code change, processing operation criteria, wholly obtained criteria, etc…;

Cross-reference origin rules according to the FTA, Ministry of Industry and Trade Circulars, or Decree 31/2018/ND-CP.

Retroactive C/O:

Check for the text “ISSUED RETROACTIVELY/ISSUED RETROSPECTIVELY” or appropriate marking;

Compare the export date on the bill of lading with the C/O issuance date to ensure validity;;

For goods transported by land/river from China, Laos, Cambodia: the export date is the delivery date at the export border gate.

b. Checking the C/O Format

For electronic C/Os or those issued through electronic portals::

Check all information fields according to the C/O template specified in the corresponding Free Trade Agreements (FTAs);

Verify the C/O form name: FORM D, FORM E, FORM AK, FORM AJ… to ensure the correct FTA application.

For paper C/Os, scanned copies with digital signature verification, or submitted as electronic data:

Check if the format conforms to the correct template: FORM D, FORM E, FORM AK, FORM AJ…;

Ensure all mandatory information is included;

For paper C/Os: check language and the reverse side of the C/O according to regulations in the relevant FTA and current legal documents.

c. List of Reasons for C/O Rejection

No.	Rejection Reason (Vietnamese)	Rejection Reason (English)
1	C/O cấp thay thế nhưng không đáp ứng quy định về cấp thay thế (thiếu dẫn chiếu số C/O ban đầu)	– No replaced reference C/O number – Not show the replaced reference C/O number – The new C/O did not reflect the Ref No and date of the previous one
2	Tiêu chí xuất xứ không phù hợp (ví dụ: RVC, WO, CTSH, CTH…)	Inappropriate/Wrong/Incorrect origin criteria (for example: RVC, WO, CTSH, CTH…)
3	Dấu, Chữ ký trên C/O không có trong bộ dấu, chữ ký mẫu	– Unrecognised/Illegible signature and stamp – Incorrect specimen signature and stamp
4	Khai báo trên C/O sai khác với khai báo trên tờ khai và thực tế hàng nhập khẩu (ví dụ: tên hàng, mã số HS, số lượng, trọng lượng ….)	Information discrepancies between C/O with Customs Declaration and imported goods (example: Name of  goods/description/quantity/weight…)
5	Mã số HS trên C/O không đúng với thực tế hàng hóa NK khai trên tờ khai hải quan	HS codes are different between C/O and imported goods
6	C/O được cấp sau nhưng không đánh dấu vào ô “Issued Retroactively”	No tick on box “Issued Retroactively”
7	C/O được cấp sau nhưng đánh dấu vào ô “Issued Retroactively” không đúng quy định	Wrong mark on box “Issued Retroactively”
8	Quá thời hạn xác minh mà cơ quan hải quan không nhận được kết quả	No verification result within retroactive check time
9	Hàng hóa trên C/O được cấp sai tiêu chí (ví dụ: RVC, WO, CTSH, CTH…)	– Origin criteria(s) is/are not correct – Goods are not subject to origin criterion in the C/O (example: RVC, WO, CTSH, CTH…)
10	Phụ lục đính kèm C/O không được cấp theo quy định	Illegal annex to C/O
11	C/O cấp trong trường hợp có hóa đơn bên thứ 3 nhưng tại ô số 7 không thể hiện tên nước phát hành hóa đơn	– Country of invoicing not shown in box 7 while third party invoicing. – C/O was not issued correctly according to rule of third country invoicing
12	C/O mẫu E cấp thay thế (Hiệp định không quy định)	Replaced C/O form E is not allowed
13	Tại ô số 1 C/O mẫu E đứng tên người thừa ủy quyền	Entrusted company in the box 1
14	Ô số 11 không có chữ ký của người XK (Mẫu E, D)	No exporter’s signature in the box 11 (C/O form E, D)
15	Trường hợp lô hàng nhập khẩu quá cảnh qua một nước thành viên/không thành viên nhưng hồ sơ hải quan không có vận tải đơn chở suốt, chứng từ vận tải được cấp tại nước xuất khẩu	– Direct consignment without through B/L issuing in the exporting country – Goods not qualified according to rule of direct transportation
16	Trường hợp hóa đơn bên thứ 3 nhưng C/O không cấp đúng quy định	– Illegal third party invoicing C/O – Third country invoicing is not issued in accordance with the provision of Agreement
17	C/O không đúng thể thức quy định	Incorrect C/O form

4. Procedures for Verification and Determination of Origin for Export Goods

4.1. Verification Procedure

In cases of suspected origin fraud or illegal transshipment, the company is required to provide explanations and additional documents for Customs Authority verification:

If verification results are satisfactory, clearance is permitted.

If there is insufficient basis for conclusion, the shipment is directed to physical inspection.

During physical inspection of goods, Customs Authorities examine origin information on the goods, packaging, labels, and cross-check with declarations and documents.

If origin information is consistent with the declaration, clearance is permitted.

If origin information is inconsistent but there is sufficient basis to determine the origin of goods, the company is required to submit supplementary declarations and is processed according to Article 20 of Circular 38/2015/TT-BTC.

If there is insufficient basis to determine the origin of goods, the case is reported to superiors, and files are transferred for verification at the C/O issuing organization or manufacturing facility.

4.2. Origin Verification for Preferential Tariff Application under CPTPP, EVFTA, UKVFTA Agreements

a. Verification of Conditions for Applying Special Preferential Tariffs

Regarding submission deadline: verify that documents proving preferential conditions must be submitted within 1 year from the date of export declaration registration.

Regarding conditions for applying preferential tariffs under Agreements (CPTPP, EVFTA, UKVFTA):

Goods must be imported into the territory of a member country.

Transport documents must indicate a member country territory as the destination.

Import customs declaration or alternative document for the export shipment from Vietnam imported into member countries must be provided.

If documents are not in Vietnamese/English, they must be translated, and the declarant is responsible for the accuracy of the translation.

Regarding consistency between declared information and related documents:

Verify consistency of loading/unloading locations.

Names and addresses of exporters, importers, and consignees.

Product names, types, HS codes, quantities, weights, origins.

Name of transport vehicle, loading date, arrival date at the importing country’s border gate.

b. Processing Verification Results:

If documentation is appropriate and goods meet the conditions for preferential tariff rates, apply the tariff rate according to the corresponding Decree.

If documentation is inappropriate or goods do not meet the conditions, reject the application and notify the customs declarant in writing.

If there are doubts about the authenticity of information or insufficient basis to determine eligibility for preferential tariffs:

The Local Customs Sub-department reports to the Customs Department for verification with authorities in the importing country;

Specifically for transport documents, direct verification with shipping lines or their agents in Vietnam.

5. Procedures for Advance Ruling on Origin of Export and Import Goods

5.1. Detailed File Verification

a. Verification of Origin Criteria:

For wholly obtained goods (WO) or goods produced entirely in one member country (PE): verify information on raw material producers, production processes, market information, geography, etc.

For goods of non-wholly obtained origin:

If included in the Product Specific Rules (PSR) List: apply criteria according to PSR.

If not included in the Product Specific Rules (PSR) List: apply general criteria according to relevant Circulars.

b. Verification whether the production process exceeds minimal operations:

If determined to be only minimal operations or processing, the goods do not meet the corresponding origin rules.

If the process exceeds minimal operations:

For goods with CTC criteria (CC, CTH, CTSH): verify the HS code of goods against the HS code of declared production materials to determine change in HS code.

For goods with RVC/LVC criteria: calculate percentage value from the bill of materials (product name, HS code, origin of materials constituting the product, CIF value or equivalent value of materials), material value, costs, etc.

For goods with SP criteria: check production materials, manufacturing processes, component analysis documents to compare with specific production process regulations.

c. Verification of compliance with direct transport rules:

Verify according to regulations in the relevant free trade agreement and Article 18 of Circular No. 33/2023/TT-BTC.

5.2. Information Verification and Authentication

When files show suspicious signs or risk of origin fraud, customs officers report to leadership and may implement one or more of the following measures:

Review origin information of similar goods previously declared to customs.

Collect company information from customs units: legal compliance status, import-export activities, related information.

For companies without headquarters in Vietnam: request additional information about manufacturers, production processes, product samples.

Propose coordinated verification with the Ministry of Industry and Trade, VCCI regarding production processes, origin criteria, information on C/Os previously issued to the company.

For export goods: propose inspection at the production facility if origin is suspected..

The issuance of the new Procedure in Decision 467/QD-CHQ demonstrates efforts to enhance transparency and consistency in goods origin verification. Businesses need to carefully study the regulations to ensure compliance and effectively utilize tariff preferences.

(According to Decision 467/QD-CHQ with attached Inspection Procedure dated April 29, 2025)

Full text of decision 467/QD-CHQ: view here

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Strengthening Inspection and Monitoring of Origin of Imported Goods for Export

1. Context

In the context of complex global trade fluctuations, especially with the United States strongly applying tariff measures against many economies, the Ministry of Industry and Trade of Vietnam has directed the tightening of monitoring of raw material sources and origin of goods.

In fact, trade experts warn that businesses from countries subject to tariffs may export to Vietnam, then engage in origin fraud to export to the United States or other markets, creating the risk of “collateral damage” for Vietnamese goods.

To proactively adapt to the new situation, the Ministry of Industry and Trade has just issued Official Letter 2515/BCT-XNK (dated April 10, 2025) and Directive 09/CT-BCT (dated April 15, 2025) requiring Industry Associations and export businesses to strengthen management of input materials and combat origin fraud. Along with that, on April 21, 2025, the Ministry of Industry and Trade issued Decision No. 1103/QD-BCT, revoking the authority to issue Certificates of Origin (C/O) previously granted by the Vietnam Chamber of Commerce and Industry (VCCI).

2. Main Content of the Directive and Official Letter

Official Letter 2515/BCT-XNK and Directive 09/CT-BCT emphasize the following main control measures:

a. Strict Monitoring of Input Materials:

Associations and businesses must proactively diversify material supply sources, reducing dependence on a single market.

Production materials must meet stringent requirements for quality, hygiene, and traceability as required by importing countries.

The Ministry of Industry and Trade recommends proactively selecting new partners and markets, while maintaining complete input documentation (invoices, CO/CQ of components, warehouse receipts, etc.) to be ready to provide when requested by authorities.

b. Verification of Origin of Goods:

The Import-Export Management Unit coordinates with the Customs Department to inspect the origin of imported materials.

C/O issuing agencies strengthen the review of C/O issuance, preventing illegal transshipment and origin fraud.

c. Domestic Market Inspection

The Market Management and Development Department focuses on inspecting and controlling smuggled goods and materials of unclear origin.

The market management force coordinates between the Management Department, the Import-Export Department, and the Department of Industry and Trade to handle violations.

d. Updating the ECOSYS System:

The Ministry of Industry and Trade requires upgrading the electronic C/O issuance system, supporting businesses in easily obtaining certificates of origin.

The goal is to simplify procedures, strengthen monitoring, and process C/O documentation.

Meanwhile, the Ministry of Industry and Trade issued Decision No. 1103/QD-BCT dated April 21, 2025

Revoking the authority to issue C/O Form A, Form B, non-preferential forms, and REX registration numbers from VCCI.

The Import and Export Department will organize the issuance of these C/O forms to ensure smooth processing and avoid disruptions.

The Department of E-commerce and Digital Economy will ensure the infrastructure for electronic C/O issuance.

VCCI will cease issuing all types of C/O and REX registration numbers from the effective date of the decision, April 21, 2025.

3. Risks for Businesses

Risks of Uncontrolled Origin of Goods: Importing machinery, equipment, and mechanical components from abroad as raw materials for export production can pose significant risks if the origin is not properly controlled. The goods may be rejected by customs authorities in importing countries.

Trade Defense Measures: Goods suspected of having fraudulent origin may face anti-dumping or safeguard measures due to concerns of tax evasion.

Strict Administrative Penalties:

- Fines ranging from tens to hundreds of millions of VND, depending on the nature of the violation.

- Confiscation of violating goods.

- Mandatory correction of labeling, recovery of unlawful gains.

- Criminal liability for large-scale origin fraud.

- Strict Monitoring: The Ministry of Industry and Trade is currently analyzing data to identify key products prone to origin fraud and is prepared to strictly handle any violations.

4. Recommendations for Businesses:

To avoid losses from tightened origin policies, exporting businesses are recommended to implement the following measures:

a. Strictly Control Inputs:

- Carefully assess the composition of imported raw materials, especially machinery, mechanical equipment, and components.

- Prioritize the use of domestic materials or sources from markets that do not impose strict tax measures.

- Closely examine the added value ratio in Vietnam (localization rate) according to the origin requirements of each trade agreement.

b. Maintain complete documentation.

- Collect and store all records related to input materials (commercial invoices, packing lists, C/O, CQ of components, supplier information) to be readily available for inspection.

- Transparent records facilitate the process of proving origin when required by customs authorities.

c. Comply with Labeling Rules and C/O Issuance:

- Request Certificates of Origin (C/O) for goods that genuinely meet Vietnam’s origin criteria (sufficient localization rate, substantial processing).

- When processing C/O applications, truthfully declare the weight and value of imported materials.

- Be cautious of transit-import scenarios where goods re-enter Vietnam for origin labeling.

d. Update ECOSYS and Policy Information:

- Register to use the Electronic Certificate of Origin System (ECOSYS) as soon as required, and keep updated with relevant electronic procedures.

- Actively monitor legal documents and attend training sessions on origin rules organized by the Ministry of Industry and Trade and relevant industry associations..

The above measures help businesses comply with regulations, minimize the risk of penalties and export disruptions, while maintaining reputation and market share in the context of increasingly stringent origin monitoring.

References:

Ministry of Industry and Trade. (April 15, 2025). Directive No. 09/CT-BCT on strengthening the management of inspection and supervision of goods origin.
Ministry of Industry and Trade. (April 10, 2025). Official Dispatch No. 2515/BCT-XNK on strengthening the management of imported raw materials for export production..
National Steering Committee 389. (2025). The Standing Office of the National Steering Committee 389 requests to enhance anti-commercial fraud related to goods origin.
Vietnam Briefing (April 21, 2025). An Introduction to Rules of Origin for Vietnamese Exports.
Việt Nam News (April 19, 2025). Việt Nam takes action to prevent origin fraud in export.