Vietnam: New Amendments to Customs Regulations

In brief

Law No. 11/2026/QH16 amending several articles of the current Law on Customs (“Law No. 11”) was passed by the National Assembly and will take effect on 1 March 2027. Law No. 11 marks a shift toward a more modern, connected and technology-driven customs system by streamlining procedures and improving data exchange. These changes are expected to promote seamless trade while strengthening the effectiveness and efficiency of state customs management.

Key takeaways

• Law No. 11 advances the digital transformation of customs administration by strengthening the legal framework for digital customs and enabling broader use of technology in customs procedures.
• E-commerce platform operators become customs declarants, while platform operators, carriers and other relevant parties are subject to identification, information-sharing and system-connectivity obligations.
• Goods deposited in bonded warehouses and goods sold at duty-free business locations may be stored for up to 24 months, subject to the applicable commencement date.
• Ex officio intellectual property enforcement is strengthened by authorizing customs authorities to suspend clearance where there are clear grounds to suspect that goods are counterfeit and infringe intellectual property rights (IPR).

In more detail

1. Promotion of digital customs procedures and the National Single Window mechanism

The Law permits the use of electronic documents and digital customs systems through the National Single Window. Documents issued through this mechanism need not be resubmitted or re-presented to customs authorities.

2. Customs inspection and supervision of goods traded through e-commerce platforms

Law No. 11 introduces a specific legal framework for the customs inspection and supervision of goods exported or imported through e-commerce platforms.

Specifically:

• Goods exported or imported through e-commerce platforms must undergo customs procedures and are subject to customs inspection and supervision.
• Organizations and individuals in Vietnam purchasing or selling goods from or to overseas parties through e-commerce platforms must complete electronic identification and authentication. E-commerce platform operators are responsible for connecting to the electronic customs data-processing system to enable customs authorities to conduct such electronic identification and authentication.
• E-commerce platform operators, bonded warehouse operators, goods carriers and other organizations and individuals involved in goods exported or imported through e-commerce platforms must provide the customs authorities with information relating to such goods.

3. Extended storage periods for bonded and duty-free goods

Under the new provisions, goods deposited in a bonded warehouse may be stored for up to 24 months from the date of deposit. This replaces the previous 12 month storage period and the mechanism allowing a one-time extension of up to a further 12 months upon approval by the competent customs authority.

In addition, the new provisions also require goods sold at duty-free business locations to be stored at duty-free shops or in warehouses operated by duty-free businesses that satisfy customs supervision requirements. The maximum storage period is 24 months from the date on which customs procedures are completed.

4. Strengthened customs enforcement of intellectual property rights

Law No. 11 revises the procedures for requesting customs inspection, supervision and temporary suspension of customs procedures for goods showing signs of IPR infringement. An IPR holder or its authorized person may submit a request dossier to any Regional Customs Office convenient to it. The measure applies for two years and may be extended for a further two years. The regime now expressly covers transit goods, and the customs authority may suspend customs procedures on its own initiative where it suspects counterfeit goods.

5. Key updates in the draft implementing regulations

To implement Law No. 11, the authorities have released a draft decree and a draft circular for public consultation. The draft decree would replace Decrees No. 08/2015/ND-CP and No. 167/2025/ND-CP and provide the decree-level framework for the revised customs procedures, including proposed rules on customs finalization audits and the comparison of reported consumption norms.

The draft circular would replace Circular No. 38/2015/TT-BTC, as amended, and provide more detailed procedural guidance. Among other matters, it proposes timelines for issuing post-clearance audit conclusions, enhanced surveillance-camera requirements for export processing enterprises and new procedures for movements of goods into and out of non-tariff zones within free trade zones.

As these instruments remain in draft form, their contents may change following the public consultation process.

6. What businesses should do now

• Assess digital readiness: Review customs declaration systems, electronic document management processes and capabilities for data connectivity and exchange with the customs authorities.
• Strengthen data consistency: Reconcile customs declarations with accounting, inventory, logistics and production records to identify and address discrepancies.
• Review customs procedures: Examine e-commerce, transportation, warehousing, supplementary declaration and record-retention procedures for compliance with the new requirements.
• Prepare for implementation: Closely monitor the draft decree and circular implementing Law No. 11 and promptly update internal procedures, systems and compliance controls once the final regulations are issued, before Law No. 11 takes effect on 1 March 2027.
• We will continue to monitor developments and would be pleased to discuss how they may affect your business.

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