Lubricant Oil Import Procedures into Vietnam is a process that requires businesses to understand quality inspection regulations, conformity certification, and three specific types of tax simultaneously – including environmental protection tax, which is a major difference compared to many other consumer goods categories.
Lubricant oil (engine oil) is an essential product for industry, automobiles, and motorcycles, with stable import demand from major markets such as South Korea, Japan, Singapore, and Thailand.
This article by 3W Logistics presents the complete lubricant oil import procedure according to current regulations – from legal conditions, 8-digit HS codes, how to calculate the three types of tax, documentation, step-by-step process, to real-world risks from the perspective of a forwarder experienced in handling lubricant and lubricating oil imports.
1. Legal Conditions for Importing Lubricant Oil into Vietnam
Lubricant oil is not on the list of prohibited import goods under Decree 187/2013/ND-CP; however, for lubricating oil used in internal combustion engines (2-stroke and 4-stroke), businesses are required to obtain conformity certification before bringing the product to market.
| Condition | Detailed Content |
|---|---|
| State quality inspection | Mandatory for lubricating oil used in internal combustion engines (mineral, synthetic, semi-synthetic base oil) under Circular 10/2018/TT-BKHCN, registered at the regional Sub-Department of Standards, Metrology and Quality |
| Conformity certification | Under QCVN 14:2018/BKHCN (and its 2018 amendment), samples are taken at the goods storage location and tested at a designated inspection center before the product can be circulated on the market |
| Post-clearance inspection mechanism | Businesses may bring goods to their warehouse for storage while awaiting quality inspection results, processed through the National Single Window Portal, which helps shorten the time goods spend at the port |
| Environmental protection tax | Lubricating oil is subject to environmental protection tax under Resolution 42/2023/UBTVQH15 (amending Resolution 579/2018/UBTVQH14), with the tax rate set per unit of goods (VND/liter) |
| Product labeling | Vietnamese supplementary labels required under Decree 43/2017/ND-CP and 111/2021/ND-CP; petroleum-based products additionally require warnings/handling instructions specific to their mineral oil properties |
Practical note: The most important point in lubricant oil import procedures is the “customs clearance first, quality inspection later” mechanism – businesses are allowed to bring goods to their warehouse for storage while awaiting test results, rather than having to wait at the port as required for some other goods categories. However, if the inspection result does not meet QCVN 14:2018/BKHCN, the business is required to re-export or destroy the entire shipment already brought to the warehouse, incurring very large costs. This is a risk that businesses new to the market should pay particular attention to.
2. 8-Digit HS Codes and Import Tax on Lubricant Oil
Lubricant oil is divided into 2 main HS code groups depending on the mineral base oil content: group 2710 (oil derived from petroleum, content ≥70%) and group 3403 (lubricating preparations containing <70% mineral oil).
| Product Type | 8-Digit HS Code | Detailed Description | Import Tax (MFN) |
|---|---|---|---|
| Mineral base oil, content ≥70% | 2710.19.43 | Lubricating oil derived from petroleum or bituminous minerals, with mineral oil content ≥70% by weight | 5–20% |
| Waste oil (used petroleum oil) | 2710.19.44 | Waste oil derived from petroleum, usually not imported for direct reuse | 5–20% |
| Synthetic/semi-synthetic lubricating preparations | 3403.19.90 | Lubricating preparations containing <70% mineral oil by weight, including synthetic and semi-synthetic oils for engines | 10% |
| Lubricating grease | 3403.19.10 | Solid lubricating grease used for industrial machinery and equipment | 10% |
Important note on HS codes: Correctly determining the HS code in lubricant oil import procedures depends on the percentage of mineral base oil in the product, information that must be confirmed through a Certificate of Analysis (COA) provided by the manufacturer. Misclassifying the HS code between group 2710 and group 3403 can result in penalties under Decree 128/2020/ND-CP, with fines ranging from a minimum of 2,000,000 VND up to 3 times the resulting tax amount. For goods imported from FTA-partner countries (South Korea under VKFTA, Japan under VJEPA/CPTPP, ASEAN under ATIGA, etc.), a valid C/O that meets the agreement’s conditions can result in a significantly lower special preferential import tax rate compared to the standard MFN rate.
3. Documentation for Lubricant Oil Import Procedures
The documentation set for lubricant oil import procedures includes an additional layer of quality inspection registration and conformity certification documents compared to ordinary goods, requiring coordination with the standards, metrology and quality authority.
| Document | When to Prepare | Important Notes |
|---|---|---|
| Sales Contract | Before placing deposit | Clearly state oil type, composition, origin, and terms for providing C/O and COA |
| Commercial Invoice & Packing List | Before goods are shipped | State fully the product name, number of drums/cans, and volume by product type |
| Bill of Lading | After goods are loaded onto the vessel | Lubricant oil is usually shipped in 20’/40′ dry containers packed in drums or in ISO tanks for large quantities |
| COA (Certificate of Analysis) | Before goods are shipped | Provided by the manufacturer, serves as the basis for determining the mineral base oil ratio to apply the correct HS code group (2710 or 3403) |
| Quality Inspection Registration Application | When goods arrive at the port | Submitted at the Sub-Department of Standards, Metrology and Quality, together with the contract, invoice, packing list, and technical documents |
| C/O (Certificate of Origin) | Before goods are shipped | Needed to obtain the special preferential import tax rate under the applicable FTA, if conditions of the agreement are met |
| Quality inspection/conformity certificate | After receiving the test results | Submitted to the Sub-Department of Standards, Metrology and Quality to complete the conformity declaration, allowing the product to be circulated |
| Electronic customs declaration (VNACCS/VCIS) | When documentation is complete | Declare the correct HS code under group 2710/3403, and record the C/O number and quality inspection registration number on the declaration |
4. Step-by-Step Lubricant Oil Import Procedure
Step 1: Negotiate the contract and determine the HS code
Sign the lubricant oil purchase contract, request the supplier to provide the COA to determine the mineral base oil ratio, thereby identifying the correct HS code group (2710 or 3403) and requesting the C/O as a contract term.
Step 2: Register for quality inspection
Submit the quality inspection registration application at the regional Sub-Department of Standards, Metrology and Quality before or as soon as the goods arrive at the port, processed through the National Single Window Portal.
Step 3: Transport goods to a Vietnamese port
Lubricant oil is usually transported in dry containers packed in drums or ISO tanks for large shipments; sealing and storage conditions must meet proper standards to prevent leakage or degradation during transit.
Step 4: Customs declaration and clearance
Open the VNACCS/VCIS declaration with the complete HS code, C/O number, and quality inspection registration number. Thanks to the post-clearance inspection mechanism, businesses may obtain customs clearance and bring the goods to their warehouse for storage while awaiting the test results.
Step 5: Sampling, testing, and conformity certification
The inspection authority takes samples at the goods storage location (warehouse) and sends them for testing under QCVN 14:2018/BKHCN. If the results are satisfactory, the business submits the additional results to the Sub-Department of Standards, Metrology and Quality to complete the conformity declaration.
Step 6: Pay taxes and release goods into circulation
Pay the import tax, environmental protection tax, and VAT in full according to the cleared declaration. Once the conformity certificate is obtained, the product may officially be sold on the market.
5. How to Calculate Import Tax on Lubricant Oil
Unlike other consumer goods categories, lubricant oil is subject to three specific types of tax – import tax, environmental protection tax, and VAT. For example, for a shipment of engine oil under HS code 2710.19.43 imported from South Korea, with a CIF value of 600 million VND and a volume of 20,000 liters, compare the case with and without a Form VK C/O:
| Tax / Cost Item | Without C/O (MFN 20%) | With Form VK C/O (10%) |
|---|---|---|
| CIF value | 600,000,000 VND | 600,000,000 VND |
| Import tax | 20% × 600M = 120,000,000 VND | 10% × 600M = 60,000,000 VND |
| Environmental protection tax (2,000 VND/liter) | 2,000 × 20,000 liters = 40,000,000 VND | 2,000 × 20,000 liters = 40,000,000 VND |
| VAT (10%) | 10% × (600+120+40)M = 76,000,000 VND | 10% × (600+60+40)M = 70,000,000 VND |
| Total tax payable | 236,000,000 VND (~236 million) | 170,000,000 VND (~170 million) |
| Savings with C/O | ~66,000,000 VND – a significant difference from a single valid C/O; note that the environmental protection tax remains unchanged with or without a C/O since it is calculated based on volume, not value. | |
From 3W Logistics’ practical experience: With lubricant oil, many businesses overlook the environmental protection tax when planning import costs, because this tax is calculated based on volume (liters) rather than as a percentage of the CIF value like import tax or VAT, which can easily cause confusion when comparing with other goods categories. In addition, while the post-clearance inspection mechanism helps shorten the time at the port, businesses need to anticipate the risk of re-export or destruction if the test results fail to meet QCVN 14:2018/BKHCN after the goods have already been brought to the warehouse. – Ms. Apple, CCO, 3W Logistics
6. Common Risks in Lubricant Oil Import Procedures
| Risk | Symptom | Prevention |
|---|---|---|
| Misclassifying the HS code between group 2710 and 3403 | Incorrect mineral base oil ratio leads to a wrong HS code declaration – customs reclassifies the goods, collects the tax shortfall, and imposes penalties under Decree 128/2020/ND-CP | Request an accurate COA from the manufacturer before declaring; consult a forwarder experienced with lubricant oil shipments |
| Failed quality inspection result | Product does not meet QCVN 14:2018/BKHCN after already being brought to the warehouse under the post-clearance mechanism – forcing re-export or destruction, causing large losses | Request test samples from the supplier before placing a large order to ensure compliance with Vietnamese standards |
| Overlooking the environmental protection tax | Underestimating the environmental protection tax when budgeting import costs due to confusion with special consumption tax or VAT – affecting the selling price plan | Calculate all three types of tax fully from the start, and cross-check the current environmental protection tax rate under the Standing Committee of the National Assembly’s resolution |
| Leakage or damage during transport | Drums/tanks that do not meet sealing standards lead to leakage and loss of goods during long-distance transport | Require the supplier to use packaging that meets international shipping standards, and purchase full cargo insurance before shipment |
| Labels missing required information | Missing specific warnings for petroleum-based products on the Vietnamese supplementary label – customs holds the goods and requests the label be supplemented at the port | Prepare a complete supplementary label sample under Decree 43/2017/ND-CP and 111/2021/ND-CP before the goods arrive at the port |
FAQ – Frequently Asked Questions about Lubricant Oil Import Procedures
Question 1: What documents are needed for lubricant oil import procedures?
The complete documentation set for lubricant oil import procedures includes: Sales Contract; Commercial Invoice and Packing List; Bill of Lading; C/O (if seeking FTA preferential treatment); COA (Certificate of Analysis); Quality Inspection Registration Application; Quality Inspection/Conformity Certificate; Electronic Customs Declaration (VNACCS/VCIS).
Question 2: Is imported lubricant oil required to have conformity certification?
Yes. Lubricating oil used for internal combustion engines (2-stroke, 4-stroke) must obtain conformity certification under QCVN 14:2018/BKHCN before being circulated on the market. This is an indispensable step in lubricant oil import procedures, carried out through the post-clearance inspection mechanism after the goods have been brought to the warehouse for storage.
Question 3: How many types of tax must be paid when importing lubricant oil?
Lubricant oil is subject to three types of tax: (1) Import tax calculated on the CIF value, ranging from 5-20% (group 2710) or 10% (group 3403) under MFN, lower if an FTA C/O applies; (2) Environmental protection tax calculated based on volume (VND/liter), under the Standing Committee of the National Assembly’s resolution; (3) VAT of 10% calculated on the total of CIF plus import tax plus environmental protection tax. Lubricant oil is not subject to special consumption tax.
Question 4: How long do lubricant oil import procedures take?
The total time from signing the contract to the goods arriving at the warehouse is typically 25–45 days. This includes: quality inspection registration and opening the customs declaration, 3-5 days; shipping from Asia, 10-15 days, from Europe/the US, 25-35 days; testing and conformity certification, 10-15 days (which can be carried out in parallel after the goods reach the warehouse thanks to the post-clearance mechanism). Shipments with a prior history of passed test results from earlier imports will complete the procedure faster.
How Does 3W Logistics Support Lubricant Oil Import Procedures?
With experience handling a diverse range of chemical goods and imported industrial lubricating oil, and registered as an OTI-NVOCC with FMC bond (Federal Maritime Commission) in the US, 3W Logistics provides a full-service package for businesses covering lubricant oil import procedures – from HS code classification consulting through to the goods arriving at the distribution warehouse.
- Consulting on accurate HS code determination based on product composition: Correctly classifying between group 2710 and 3403 based on the COA, avoiding the risk of reclassification and tax collection.
- Calculating the three types of tax realistically before placing an order: Including import tax, environmental protection tax, and VAT for each country of origin – helping businesses get accurate cost figures before negotiating.
- Supporting quality inspection registration and conformity certification: Coordinating with the Sub-Department of Standards, Metrology and Quality, and leveraging the post-clearance mechanism to shorten time at the port.
- Assisting with obtaining the correct FTA C/O form from the supplier: Guiding South Korean suppliers to obtain Form VK, and Japanese suppliers to obtain Form JV/CPTPP, to optimize import tax costs.
- Electronic customs declaration via VNACCS/VCIS and handling issues at the border gate: Declaring the correct HS code, and coordinating to submit the quality inspection certificate on time.
Why choose 3W Logistics for your imported lubricant oil shipment? Lubricant oil import procedures require handling multiple layers of regulation simultaneously – quality inspection and conformity certification under QCVN 14:2018/BKHCN, accurate HS code classification between group 2710/3403, and correctly calculating three types of tax including the environmental protection tax. We accompany you from the HS code determination step through to the goods arriving at your warehouse – helping your business shorten customs clearance time and avoid unnecessary costs. Contact 3W for specific advice before signing your import contract.
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Hotline: +84 28 3535 0087
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Ms. Apple is the CCO (Chief Commercial Officer) at 3W Logistics, with over 10 years of experience in sales and business operations management.
At 3W Logistics, Ms. Apple is responsible for commercial strategy, corporate customer development, managing a team of more than 50 sales professionals, and improving business performance in the logistics sector.
With practical experience in sales management and market development, Ms. Apple shares professional insights on business logistics solutions, international transportation, freight forwarding, customer management, trade lane development, and growth strategies in the logistics industry.
