On February 02, 2026, the General Department of Customs issued Official Dispatch No. 8444/CHQ-GSQL to provide guidance on the implementation of Circular No. 121/2025/TT-BTC. The document focuses on clarifying and guiding the resolution of difficulties in implementing customs procedures, management of raw materials – products, consumption norms, final accounts reports, and activities of processing enterprises, export manufacturing enterprises, and export processing enterprises.
To support the business community in complying with regulations and minimizing compliance risks, the General Department of Customs has compiled and provided detailed answers to practical questions and difficulties in the Appendix attached to Official Dispatch 8444/CHQ-GSQL. For details, see here.
Here are some notable instructions:
1. Regulations on Cancellation of Declarations and Actual Norms (Article 55)
Cancellation of on-spot import-export declarations exceeding 15 days: For on-spot or non-tariff export declarations that have exceeded 15 days without a corresponding reciprocal import declaration, the Customs system will automatically send a notification 5 days in advance and proceed with the cancellation upon expiration.
Establishment of norms for re-imported products: It is necessary to establish actual norms for re-imported products from the time they arise until the end of the fiscal year and submit them along with the Final Accounts Report. If repair activities extend into the following year, the norms will continue to be calculated from the beginning of the next fiscal year until the end of the activity.
2. Notification of Production Facilities & Sub-contracting (Article 56)
Location of notification: The Customs authority managing the production facility is the Border-gate Customs Branch or the Outside Border-gate Customs Branch managing the area where the facility is located. In cases where an enterprise has multiple production facilities in different locations, it must notify the managing Customs authority in each respective area.
Changes in production scale: If changes in machinery or labor are minor and do not alter the production capacity (quantity of products per unit of time), the enterprise may notify the change no later than the 10th day of the following quarter instead of notifying immediately.
3. Implementation Validity and Final Accounts Reports (Article 60)
Time of application of Circular 121/2025/TT-BTC: This Circular takes effect from 01/02/2026
If the fiscal year ends before February 01, 2026: Final accounts reports shall be implemented in accordance with Circular No. 38/2015/TT-BTC, as amended and supplemented by Circular No. 39/2018/TT-BTC.
If the fiscal year ends after February 01, 2026: Final accounts reports shall be implemented in accordance with Circular 121/2025/TT-BTC.
Submission location for Final Accounts Reports: For the year 2025, reports are to be submitted to the Customs unit currently managing the enterprise; for subsequent years, reports will be submitted to the Regional Customs Branch as assigned
4. Activities of Export Processing Enterprises (EPEs) (Article 74, Article 80)
Option for customs procedures: EPEs and their partners have the right to choose not to perform customs procedures for goods brought in/out for repair, warranty, inspection, R&D, or internal circulation within the same tax code. However, if choosing not to perform procedures, the enterprise must notify the managing Customs authority in writing once before bringing goods into or out of the EPE.
External warehouse leasing: EPEs are permitted to lease warehouses located within industrial parks or economic zones to store goods (including machinery and equipment) and must follow the procedural regulations in Article 80 of Circular No. 38/2015/TT-BTC, as amended and supplemented by Circular No. 121/2025/TT-BTC.
5. Pre-delivery of Goods, Post-opening of Customs Declarations (Article 86)
This regulation currently applies only to priority enterprises and partners trading with priority enterprises. Customs declarants may use the goods immediately after delivery has been performed.
The above is a summary of key contents based on the response table for 40 professional difficulties arising during the implementation of Circular No. 121/2025/TT-BTC. These new regulations directly impact processing, export manufacturing, and EPE activities. Therefore, Enterprises should proactively update and apply them consistently in practice.
(According to Official Letter No. 8444/CHQ-GSQL (with appendix) dated February 02, 2026)
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