Guidance on the procedure for declaration of conformity
Declaration of conformity is a mandatory legal procedure that all organizations and individuals manufacturing or importing Group 2 goods (goods that may pose safety risks) must complete before placing their products on the Vietnamese market. This is more than an administrative formality: it is a legal commitment that the products fully comply with the relevant national technical regulations (QCVN), are subject to supervision by competent state authorities, and carry full accountability to consumers.
Many importers overlook or incorrectly carry out the declaration of conformity procedure, resulting in goods being held at ports, administrative fines, or even the destruction of shipments – losses that can amount to hundreds of millions of Vietnamese dong per container. Under Decree 128/2020/NĐ-CP, violations of state quality inspection requirements for imported goods may incur fines ranging from VND 10,000,000 to VND 30,000,000 and compulsory re-export or destruction of the goods.
In this article, 3W Logistics provides a comprehensive overview and detailed guidance on the declaration of conformity process applicable from 2025 onward – including the latest legal framework (Circular 14/2026/TT-BKHCN and Decree 22/2026/NĐ-CP), the list of products subject to mandatory requirements, required documentation, step-by-step procedures, and actual costs – from the perspective of a freight forwarder with over 10 years of experience supporting importers.
1. What Is a Declaration of Conformity?
Declaration of conformity is a mandatory activity for organizations and individuals manufacturing or importing Group 2 products and goods. Through this activity, they declare and accept responsibility for their products’ compliance with the relevant national technical regulations (QCVN), then register this commitment with the sector-specific regulatory authority.
According to Clause 1, Article 3 of Circular 14/2026/TT-BKHCN (dated April 9, 2026, effective May 25, 2026) and Decree 22/2026/NĐ-CP detailing the implementation of certain provisions of the Law on Standards and Technical Regulations:
Declaration of conformity is mandatory; the result of a declaration of conformity is the organization’s or individual’s commitment that its products and goods comply with the corresponding technical regulations. The organization or individual bears full responsibility for the declaration.
Distinguishing Between Declaration of Conformity, Declaration of Compliance with Standards, and Conformity Certification
| Criterion | Declaration of conformity | Declaration of compliance with standards | Conformity certification |
|---|---|---|---|
| Nature | Self-declaration + registration with a state authority | Self-declaration of compliance with standards (TCVN/TCCS) | Certificate issued by a designated third-party body |
| Mandatory status | Mandatory (Group 2Guidance on the procedure for declaration of conformity goods) | Voluntary | Mandatory (required by certain QCVNs) |
| Legal basis | QCVN (National Technical Regulations) | TCVN / in-house standards | QCVN (National Technical Regulations) |
| Outcome | Notice of receipt from the sector-specific authority | Declaration issued by the enterprise | Certificate of conformity + CR mark |
| Mark | Conformity mark (CR mark) | Standards compliance mark (CS mark) | Conformity mark (CR mark) |
Important note: The notice of receipt of a declaration of conformity issued by the sector-specific authority only acknowledges the enterprise’s commitment and does not certify product quality. Full legal responsibility rests with the declaring organization or individual.
2. Why Must Products Have a Declaration of Conformity?
In international and domestic trade, a declaration of conformity serves as a “legal passport” allowing products to circulate on the Vietnamese market. This requirement arises from both legal obligations and practical business considerations:
Mandatory legal basis
- Law on Standards and Technical Regulations (Law No. 68/2006/QH11, as amended and supplemented by Law No. 35/2018/QH14 and Law No. 70/2025/QH15) – makes declaration of conformity mandatory for Group 2 goods.
- Law on Product and Goods Quality (Law No. 05/2007/QH12, as amended by Law No. 78/2025/QH15) – requires Group 2 goods to undergo quality control before being placed on the market.
- Decree 22/2026/NĐ-CP – provides detailed guidance on implementing requirements for declarations of compliance with standards and declarations of conformity.
- Circular 14/2026/TT-BKHCN (effective May 25, 2026) – sets out the latest procedures, conformity assessment methods, and declaration of conformity application forms.
Consequences of Failing to Declare Product Conformity
| Violation | Legal consequences | Indicative penalties |
|---|---|---|
| Failure to declare conformity before importation | Goods held at the port and denied customs clearance | Fine of VND 10–30 million + compulsory re-export/destruction (Decree 128/2020) |
| Improper use of the CR mark | Product recall and suspension of circulation | Fine of up to VND 40 million (Decree 119/2017) |
| Inaccurate declaration documentation | Revocation of the notice of receipt and legal accountability | Administrative sanctions + compensation for damages |
| Products failing to meet QCVN requirements after declaration | Full recall, substantial fines, and public notification | Fine of up to VND 100 million (depending on the sector) |
Practical insight from 3W Logistics: Many imported shipments of food, electronics, and construction materials are held at Cat Lai Port and Hai Phong Port because declaration of conformity documentation is missing or incomplete. Daily storage costs can reach VND 1–5 million per container, excluding the risk of spoilage (food and refrigerated goods) or contractual penalties for late delivery. — Ms. Apple, CCO, 3W Logistics
3. Products Subject to Mandatory Declaration of Conformity
Under the Law on Product and Goods Quality (Law No. 78/2025/QH15), goods are classified into two groups. Only Group 2 goods – goods that may pose safety risks – are subject to mandatory declaration of conformity under QCVNs issued by the relevant line ministries. The main product groups are listed below:
| Product group | Typical products | Technical regulations | Responsible ministry | Submission authority |
|---|---|---|---|---|
| Food & Food Additives | Nutritional products, energy drinks, food additives, functional foods, and micronutrient-fortified foods | QCVN 6-1, 6-2, 6-3, 11:2012/BYT and product-specific QCVNs; Decree 46/2026/NĐ-CP | Ministry of Health | Vietnam Food Administration (VFA) |
| Electrical, Electronic, and Telecommunications Equipment | Phones, Wi-Fi devices, routers, televisions, computers, IoT devices, chargers, electrical cables, and telecommunications equipment | QCVN 9:2016/BTTTT; QCVN 18:2014/BTTTT; QCVN 102:2016/BTTTT; Circular 15/2023/TT-BTTTT | Ministry of Information and Communications | Vietnam Telecommunications Authority |
| Construction Materials | Cement, construction glass, ceramic/porcelain tiles, PVC pipes, construction steel, insulation materials, and concrete admixtures | QCVN 16:2023/BXD; Circular 41/2026/TT-BXD (effective July 1, 2026) | Ministry of Construction | Provincial/municipal Department of Construction |
| Vehicles & Parts | Cars, motorcycles, helmets, tires, seat belts, vehicle lights, rear-view mirrors, and ABS brakes | QCVN 41:2019/BGTVT; QCVN 78:2014/BGTVT; and vehicle-specific QCVNs | Ministry of Transport | Vietnam Register / Department of Transport |
| Chemicals, Detergents & Fertilizers | Household detergents, inorganic fertilizers, organic fertilizers, and plant protection products (pesticides) | QCVN 01-195:2022/BNNPTNT (fertilizers); Law on Chemicals 69/2025/QH15; Decrees 24, 25, 26/2026/NĐ-CP | Ministry of Agriculture and Rural Development / Ministry of Industry and Trade | Department of Industry and Trade / Plant Protection Department |
| Medical Devices & Healthcare Products | Medical masks, blood pressure monitors, blood glucose meters, diagnostic imaging equipment, and medical instruments | QCVN 10:2011/BYT; QCVN 12:2011/BYT and medical device-specific QCVNs; Circular 23/2024/TT-BYT | Ministry of Health | Drug Administration of Vietnam / Department of Health |
| Animal Feed & Veterinary Products | Complete compound feed, supplementary feed, mineral–vitamin premixes, and veterinary preparations | QCVN 01-183:2016/BNNPTNT; QCVN 01-190:2020/BNNPTNT; Decree 13/2020/NĐ-CP | Ministry of Agriculture and Rural Development | Department of Livestock Production / Department of Agriculture and Rural Development |
| Children’s Toys & Textile Products | Toys for children under 14, helmets, flame-resistant clothing, and occupational protective clothing | QCVN 3:2019/BKHCN (toys); QCVN 22:2012/BKHCN (helmets); Circular 06/2016/TT-BKHCN | Ministry of Science and Technology / Ministry of Industry and Trade | Provincial Sub-department of Standards, Metrology and Quality |
| Petroleum Products & Gas | Gasoline, diesel, lubricating oil, LPG, compressed natural gas (CNG), and biogas | QCVN 1:2015/BKHCN; QCVN 2:2015/BKHCN; QCVN 8:2018/BCT | Ministry of Science and Technology / Ministry of Industry and Trade | Sub-department of Standards, Metrology and Quality / Department of Industry and Trade |
Note: The above list is representative. Enterprises should check the precise QCVN applicable to each specific product on the relevant ministry’s portal or contact the sector-specific authority. Certain products are exempt from declaration of conformity under Clause 2, Article 48 of the Law on Standards and Technical Regulations (amended in 2025) if they have fully met quality management requirements under sector-specific legislation.
4. Approaches to Declaration of Conformity
Under Circular 14/2026/TT-BKHCN and current regulations, a declaration of conformity may be based on one of the following approaches (conformity assessment methods). Each approach is suited to different product types and risk levels:
| Approach | Description | Commonly applied to |
|---|---|---|
| Approach 1: Self-assessment (Methods 1, 5, 6) | The organization/individual conducts its own testing or engages an accredited laboratory, prepares an assessment report, and submits the declaration registration dossier. A third-party certification body is not required. | Medium-/low-risk products; domestically manufactured goods with stable production; low-/medium-risk construction materials |
| Approach 2: Third-party conformity certification (Methods 3, 4, 7) | A conformity certification body designated by the relevant ministry (OCB) conducts assessments, testing, and production process verification, then issues a certificate of conformity. The enterprise uses these results to register its declaration. | Electrical/electronic/telecommunications equipment; medical devices; vehicles; high-risk products; imported goods without existing assessment results |
| Approach 3: Based on inspection results (Method 8) | Based on inspection results from an accredited/designated inspection body (applied on a shipment-by-shipment basis). Suitable when representative sampling cannot be carried out using standard procedures. | Individual imported shipments; raw materials and semi-finished products; high-value individual goods (industrial equipment) |
| Approach 4: Based on recognized certification/assessment results | Based on international certification results recognized by Vietnam under bilateral/multilateral mutual recognition agreements (MRAs), or assessment results from foreign organizations accepted under applicable law. | Products with CE (EU), UL (US), CCC (China), or JIS (Japan) certification recognized under Vietnamese regulations |
Key practical consideration: The specific assessment method must follow the requirements of the QCVN applicable to the product. Enterprises cannot freely choose a method—the QCVN specifies which methods are permitted. For example, QCVN 16:2023/BXD requires Method 5 (product certification) for high-risk construction materials but allows Method 1 (self-assessment) for medium-risk products.
5. Documents Required for the Declaration of Conformity Procedure
The dossier for the declaration of conformity procedure consists of two main groups of documents: corporate legal documents and product technical documents. The specific requirements under Circular 14/2026/TT-BKHCN are as follows:
| Document | Important notes | Applicable to |
|---|---|---|
| Declaration of conformity registration form (Form in Appendix IV of Circular 14/2026) | Complete all required information: product name, technical characteristics, applicable QCVN, assessment method, signature, and company seal | All cases |
| Enterprise Registration Certificate / Business License | Notarized copy or certified true copy; must remain valid | All cases |
| Test results / Conformity self-assessment report (Form in Appendix V of Circular 14/2026) | The laboratory must be accredited to ISO/IEC 17025; results must be no more than 3 years old (depending on the QCVN); all parameters required by the QCVN must be tested | Self-assessment approach |
| Certificate of conformity issued by a designated certification body | Must remain valid; the issuing body must appear on the relevant ministry’s list of designated bodies; the certificate must clearly state the QCVN and scope of certification | Third-party certification approach |
| Product technical documentation (Technical File / Datasheet) | Description of technical characteristics, specifications, and intended use; foreign-language documents must be accompanied by a notarized Vietnamese translation | Imported goods; technical equipment |
| Sales Contract / Commercial Invoice / Packing List | Clearly identify the product name, model, quantity, manufacturer, and country of origin | Imported goods |
| Sample product label (with a supplementary Vietnamese label attached) | Under Decree 37/2026/NĐ-CP (goods labeling, effective January 23, 2026, replacing Decrees 43/2017 and 111/2021); must include all mandatory information in Vietnamese | All cases (depending on QCVN requirements) |
| Product sample photographs (for certain sectors) | Clear photographs showing the product, label, and identifying features; subject to each authority’s requirements | Toys, construction materials, and electrical equipment |
| Letter of authorization (if the person submitting the dossier is not the legal representative) | Signed by the legal representative and bearing the company seal; clearly state the scope and duration of authorization | When authorizing another party to submit the dossier |
Practical experience from 3W Logistics: For imported goods, sample testing typically accounts for 60–70% of the total time required to prepare a declaration of conformity dossier. Enterprises should submit samples for testing before the goods depart from the port in the exporting country (approximately 30–45 days before the expected ETD), especially for product groups such as electronic equipment, functional foods, and construction materials. This ensures the dossier is ready for submission when the goods arrive at a Vietnamese port, preventing interruptions to customs clearance. — Ms. Apple, CCO, 3W Logistics
6. Declaration of Conformity Process for Domestic and Imported Goods
Based on Circular 14/2026/TT-BKHCN and sector-specific regulations, the declaration of conformity process is carried out under the following two scenarios:
6.1. Declaration of Conformity Process for Domestically Manufactured Goods
Step 1: Identify the applicable QCVN and assessment method
Look up the national technical regulation (QCVN) corresponding to the product on the relevant ministry’s portal. Identify the mandatory conformity assessment method under each QCVN (for example, Method 1 – self-assessment, or Method 5 – certification with surveillance). This is the most important step, as it determines the entire implementation process.
Step 2: Conduct conformity assessment
– For self-assessment (Approach 1): Take representative product samples and send them for testing to a VILAS-accredited or designated laboratory. Prepare a conformity self-assessment report using the form in Appendix V of Circular 14/2026.
– For third-party certification (Approach 2): Contact a certification body designated by the ministry (for example, QUATEST 1/2/3, QUACERT, TÜV Rheinland, Bureau Veritas, SGS, etc.). The certification body conducts the assessment and issues a certificate of conformity.
Step 3: Prepare and submit the declaration of conformity registration dossier
Compile all documents listed in Section 5. Submit the dossier in person, by post, or through the online Public Service Portal to the designated sector-specific authority (depending on the sector: Department of Industry and Trade, provincial Sub-department of Standards, Metrology and Quality, Department of Construction, Department of Health, etc.). Pay the filing fee in accordance with the relevant ministry’s regulations.
Step 4: The sector-specific authority reviews and acknowledges the dossier
– Within 03 working days of receiving the dossier: if documents are missing, the authority issues a written request for additional information.
– Within 05 working days for a complete dossier: the authority checks its validity and issues a Notice of Receipt of the Declaration of Conformity.
– If the dossier is invalid: the authority issues a written notice explaining the reasons for rejection.
Step 5: Affix the CR conformity mark and place the product on the market
After receiving the notice of receipt, the enterprise may affix the CR conformity mark to the product/packaging in accordance with the dimensions, proportions, and placement specified in Appendix I of Circular 14/2026. The product is then officially permitted to circulate on the market. The enterprise must maintain conformity throughout the product’s circulation and remains subject to inspection and supervision by state authorities.
6.2. Declaration of Conformity Process for Imported Goods
For imported goods, the declaration of conformity procedure is linked to the state quality inspection process at the border checkpoint. The procedure applies as follows, depending on the circumstances:
Step 1: Identify Group 2 goods and the applicable QCVN
Check whether the imported product falls within the list of Group 2 goods subject to mandatory declaration of conformity. Look up the HS code and cross-check it against the relevant ministry’s list. Identify the competent inspection authority (depending on the product category).
Step 2: Conduct conformity assessment before importation (recommended)
– If a certificate of conformity is already available (from a previous assessment or issued by a recognized international organization): Prepare the import documentation and register for inspection through the Vietnam National Single Window (VNSW).
– If no certificate of conformity is available: Submit samples for testing to an accredited laboratory or engage a designated certification body to conduct an assessment. It is recommended to complete this in the exporting country before the vessel departs.
Step 3: Submit the declaration of conformity registration dossier
The importing organization or individual submits the declaration of conformity registration dossier through the Vietnam National Single Window (VNSW) or directly to the specialized inspection authority at the port/border checkpoint of entry. For goods with an already registered declaration of conformity, subsequent imports may use the registration number for inspection procedures without restarting the process (under the latest draft decree).
Step 4: The inspection authority reviews the dossier and the goods undergo customs clearance
– Goods with a certificate of conformity: The inspection authority reviews the dossier within 01 working day. If valid, it issues a clearance notification.
– Goods without a certificate of conformity: The enterprise selects a designated conformity assessment body. Samples are taken at the port and sent for testing. Storage time while awaiting test results typically ranges from 7–30 days (depending on the product type). Once results are available, the inspection authority issues a notification and the goods are cleared through customs.
Step 5: Complete the documentation, affix the CR mark, and distribute the goods
After customs clearance and receipt of the declaration of conformity, the enterprise affixes the CR mark and a supplementary Vietnamese label (if required) before distributing the goods. Retain all documentation for at least 05 years for inspection and supervision purposes.
7. Costs and Processing Times for the Declaration of Conformity Procedure
The cost and time required for the declaration of conformity procedure depend on the product type, assessment method, and service provider. The table below summarizes common reference figures:
| Item | Indicative cost | Time required | Notes |
|---|---|---|---|
| Sample testing at a laboratory | VND 1,000,000–15,000,000 per testing round (depending on the product type and number of parameters) | 5–20 working days | Depends on the laboratory; complex equipment may take 30 days |
| Third-party conformity certification services | VND 5,000,000–30,000,000 per certification (including testing + certification) | 15–45 days | QUATEST 1/2/3, SGS, Bureau Veritas, TÜV Rheinland, etc. |
| Dossier submission fee at the sector-specific authority | In most cases: VND 0 (free under Circular 232/2016/TT-BTC and newer fee circulars); certain sectors: VND 50,000–500,000 | – | Refer to the relevant ministry’s circular on fees and charges |
| Dossier processing time at the authority | – | 05 working days (for a complete dossier) | Under Circular 14/2026/TT-BKHCN; may vary between ministries |
| Translation + notarization of foreign-language documents | VND 500,000–3,000,000 per document set | 3–7 days | Applicable when technical documents are in a foreign language |
| Total actual turnaround time (end-to-end) | Total cost: VND 3–50 million (depending on complexity) | 15–60 working days (from sample submission to receipt of the notice of receipt) | Estimated; actual figures depend on the product type and responsible ministry |
Time-saving tip: The validity of the notice of receipt of a declaration of conformity is generally linked to the certificate of conformity’s validity period (usually 03 years for third-party certification) or the period specified in the applicable QCVN. Upon expiry, the enterprise must undergo reassessment and register a new declaration. Early preparation and coordination of conformity assessment with the overseas manufacturer can significantly shorten the overall timeline.
FAQ – Frequently Asked Questions About Product Declaration of Conformity
Question 1: What is the difference between declaration of conformity and conformity certification? Are both required?
Declaration of conformity is a mandatory legal obligation under which an organization/individual makes a commitment and registers it with a state authority. Conformity certification is performed by a third party (a designated certification body), which issues a certificate of conformity. In many cases, these two activities are closely linked: the QCVN requires the enterprise to obtain a certificate of conformity from a third party as the basis for registering its declaration.
However, certain QCVNs permit self-assessment without third-party certification – in these cases, the enterprise only needs test results from an accredited laboratory.
Question 2: Do imported goods with CE (Europe) or UL (US) certification still require a declaration of conformity in Vietnam?
Yes. Although international certifications such as CE, UL, and CCC are partially recognized, imported Group 2 products must still undergo declaration of conformity in Vietnam under the relevant QCVN, because Vietnamese QCVNs contain specific technical requirements that do not fully align with CE or UL standards.
In some cases, Vietnamese certification bodies accept test results from international laboratories as a basis for assessment, helping shorten processing times and reduce retesting costs.
Question 3: How long is a declaration of conformity valid? Does it need to be renewed?
The notice of receipt of a declaration of conformity does not have a single fixed validity period for all cases – its validity depends on the specific QCVN and assessment method. For third-party certification, the validity period generally matches that of the certificate of conformity (commonly 03 years).
For self-assessment, certain QCVNs require periodic reassessment (once every 01-03 years). If the product model, technical features, or manufacturer changes, the enterprise must conduct a new assessment and re-register the declaration of conformity.
Question 4: Can small or newly established enterprises prepare their own declaration of conformity dossiers?
In principle, yes. In practice, however, dossiers often require 1-3 rounds of supplementary submissions due to incorrect forms, missing technical information, or selection of the wrong QCVN. For first-time importers, 3W Logistics recommends using a professional consultancy or an experienced freight forwarder to save time and avoid the risk of goods being held at the port. Consultancy fees typically range from VND 2–10 million per dossier – a small amount compared with the losses caused by a shipment being held at the port for 30 days.
Question 5: In what cases are products exempt from declaration of conformity?
Under Clause 2, Article 48 of the Law on Standards and Technical Regulations (amended in 2025 by Law No. 70/2025/QH15), products and goods are exempt from declaration of conformity when they have fully met quality management requirements under sector-specific legislation.
Other cases, such as goods temporarily imported for re-export and not consumed in Vietnam, non-commercial samples, and goods used for scientific research, may also qualify for exemptions or special procedures. Enterprises should check the specific requirements in each QCVN and the relevant ministry’s regulations.
How Does 3W Logistics Support Enterprises with Declaration of Conformity Procedures?
As an OTI-NVOCC with an FMC Bond in the United States and over 10 years of experience in international transportation and freight forwarding, 3W Logistics understands that the declaration of conformity procedure is one of the biggest obstacles causing delays in import customs clearance. We provide comprehensive import solutions, including:
- Advice on identifying the QCVN and assessment method: Review HS codes, check the list of Group 2 goods, and accurately identify the authority responsible for receiving dossiers for each imported product type.
- Connections to laboratories and certification bodies: Connect with QUATEST 1/2/3, QUACERT, SGS, Bureau Veritas, TÜV Rheinland, and VILAS-accredited laboratories to obtain results as quickly and cost-effectively as possible.
- Preparation and completion of declaration of conformity dossiers: Prepare the complete declaration of conformity registration form, self-assessment report, technical documents, and supplementary Vietnamese labels under Decree 37/2026/NĐ-CP.
- Dossier submission and progress tracking: Submit dossiers to sector-specific authorities, monitor progress, and respond promptly to requests for additional information to minimize waiting time for acceptance.
- Electronic customs declarations: Coordinate electronic customs declarations with the declaration of conformity process to ensure goods are cleared as soon as the documentation is valid.
- Sea and air freight: Provide FCL/LCL sea freight services from the port of export to major Vietnamese ports (Cat Lai, Hai Phong, and Da Nang), with integrated quality documentation processing at the destination port.
Why Choose 3W Logistics for Imported Shipments Requiring a Declaration of Conformity?
We are more than a transportation provider – we are a logistics partner with in-depth knowledge of Vietnam’s legal procedures for goods. With experience handling hundreds of imported shipments each year across various industries, 3W Logistics helps first-time importers save time, avoid mistakes, and minimize the risk of goods being held at the port.
Address: 34 Bach Dang Street, Tan Son Hoa Ward, Ho Chi Minh City
Hotline: +84 28 3535 0087
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3W Logistics Hanoi Branch
Address: 81A Tran Quoc Toan Street, Cua Nam Ward, Hanoi
Hotline: +84 24 3202 0482
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3W Logistics Hai Phong Branch
Address: 8A, Lot 28, Le Hong Phong Street, Gia Vien Ward, Hai Phong
Hotline: +84 225 355 5939
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3W LOGISTICS CO., LTD – We here serve you there!
Email: info@3w-logistics.com
Website: www.3w-logistics.com
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.
