On-spot export and import is a form of trade in which the buyer and seller sign a foreign trade contract, but the goods are actually delivered within Vietnam as designated by the buyer, instead of physically crossing the national border. This form is commonly applied to processed goods, goods traded with export processing enterprises, and goods that a foreign trader designates for delivery inside Vietnam.
Many businesses confuse on-spot export and import with regular export and import, and are unclear about which goods qualify, what documentation is required, and the applicable deadlines. The article below sets out the full definition, purpose, documentation, procedure, and current legal basis for on-spot export and import in Vietnam.
1. What Is On-Spot Export and Import?
On-spot export and import is a transaction in which goods are traded under a foreign trade contract between a Vietnamese business and a foreign trader or an export processing enterprise, but the actual delivery of the goods takes place within Vietnamese territory as designated by the buyer, without the goods physically crossing the national border. The goods must still go through full export and on-spot import customs procedures, just as in a regular export-import transaction.
Vietnamese law does not currently provide a standalone definition of “on-spot export and import”; instead, the customs procedure for this form is regulated directly under Article 86 of Circular 38/2015/TT-BTC (as amended by Circular 39/2018/TT-BTC and Circular 121/2025/TT-BTC).
Real-world example: Company A in Vietnam signs a contract to sell electronic components to Company B in Japan. However, Company B designates Company A to deliver the goods directly to Company C — an export processing enterprise located in Vietnam. This transaction is carried out as on-spot export (for Company A) and on-spot import (for Company C), even though the goods never leave Vietnamese territory.
2. What Is the Purpose of On-Spot Export and Import?
On-spot export and import helps businesses save significantly on international shipping costs, delivery time, and logistics procedures, while still recording the transaction correctly as a foreign trade activity so it can benefit from related tax policies.
The specific role of this form includes:
- Cost and time savings: no round-trip international shipping cost is incurred, and delivery time between the parties is shortened.
- Supporting processing and manufacturing supply chains: well suited to processing transactions and trade in raw materials or work-in-progress goods between domestic businesses and export processing enterprises.
- Preserving tax benefits: qualifying on-spot export goods can still enjoy the 0% VAT rate applicable to regular exports.
- Fitting global supply chains: meets the needs of foreign traders who want to receive goods directly in Vietnam for further processing, assembly, or distribution without actually importing them back to their home country.
3. Characteristics of On-Spot Export and Import
The defining characteristic of on-spot export and import is that the goods do not cross the national border, yet both an export declaration and an import declaration must still be filed simultaneously, under customs supervision.
- No cross-border transport: goods are delivered directly between two businesses both located within Vietnamese territory.
- Parallel customs declarations required: the seller files an on-spot export declaration, while the buyer in Vietnam files the corresponding on-spot import declaration.
- Carried out at a convenient Customs Sub-Department: under Clause 2, Article 86 of Circular 38/2015/TT-BTC, the declarant may choose any convenient Customs Sub-Department to complete the procedure.
- Tax policy applied at the declaration date: tax policy and import-export management policy apply as of the date the customs declaration is registered.
4. What Goods Qualify for On-Spot Export and Import?
Under Clause 1, Article 86 of Circular 38/2015/TT-BTC, goods eligible for on-spot export and import fall into 3 main groups: processed goods, goods traded with non-tariff zones, and goods designated for delivery in Vietnam by a foreign trader.
- Processed products; leased or borrowed machinery and equipment; surplus raw materials and supplies; scrap and defective products under a processing contract, as regulated under the law on commercial processing activities.
- Goods traded between a domestic enterprise and an export processing enterprise or an enterprise in a non-tariff zone.
- Goods traded between a Vietnamese enterprise and a foreign organization or individual without a presence in Vietnam, where the foreign trader designates delivery to or receipt from another enterprise in Vietnam.
Note: Aside from the three groups above, ordinary domestic sales transactions between two Vietnamese businesses do not qualify for the on-spot export-import procedure.
5. Customs Dossier for On-Spot Export and Import
Under Clause 3, Article 86 of Circular 38/2015/TT-BTC (as amended by Clause 53, Article 1 of Circular 121/2025/TT-BTC), the customs dossier for on-spot export-import goods follows Article 16 of Circular 38/2015/TT-BTC, and basically includes:
- Electronic customs declaration (both the corresponding export and on-spot import declaration must be filed)
- Commercial invoice or an equivalent document, where the buyer must make payment to the seller
- Sales contract, or a processing/lease contract (depending on the type of transaction)
- Specialized inspection license or certificate (if the goods fall under specialized management)
Note: For transactions under points a and c of Clause 1, Article 86, businesses use a commercial invoice; for transactions under point b (trade with an export processing enterprise or non-tariff zone), businesses use a VAT invoice or sales invoice, per the customs authority’s practical guidance.
6. Deadline for Completing Customs Procedures
Under Clause 4, Article 86 of Circular 38/2015/TT-BTC (as amended by Clause 58, Article 1 of Circular 39/2018/TT-BTC), the on-spot importer must complete the corresponding import customs procedure within 15 working days from the date the export goods are cleared.
For priority businesses, or businesses in compliance with customs law trading with a partner that is also in compliance with customs law, under Clause 6, Article 86, where goods are delivered in multiple batches within a set period under the same contract, the parties may deliver the goods first and declare customs later, with a maximum declaration deadline of 30 days from the date of delivery.
7. Customs Procedure for On-Spot Export and Import
The on-spot export-import procedure under Clause 5, Article 86 of Circular 38/2015/TT-BTC consists of filing the export declaration together with a combined bonded-transport declaration, after which the on-spot importer receives and completes the corresponding import procedure.
Step 1: The on-spot exporter files the export declaration
The declarant enters information on the export customs declaration and files a combined transport declaration, in which the “Destination point for bonded transport” field records the location code of the Customs Sub-Department handling the import procedure, and the “Enterprise’s internal management number” field records the code #&XKTC.
Step 2: The customs authority processes the export declaration
The Customs Sub-Department where the on-spot export declaration is registered receives and inspects the dossier according to the system’s channel-classification result, and processes clearance as with a regular export procedure.
Step 3: The on-spot importer completes the import procedure
The Customs Sub-Department handling the import procedure monitors on-spot export declarations that have completed customs procedures, then receives and inspects them according to the channel-classification result. If the goods have already undergone physical inspection at the export Customs Sub-Department, the import Customs Sub-Department does not need to repeat the physical inspection.
Step 4: Monthly reporting (for goods designated by a foreign trader)
For on-spot export-import goods designated by a foreign trader, the Customs Sub-Department handling the import procedure compiles a monthly list of cleared declarations and sends it to the tax authority directly managing the on-spot importing organization or individual.
8. Responsibilities of Each Party in On-Spot Export and Import
Under Clause 5, Article 86 of Circular 38/2015/TT-BTC (as amended by Clause 58, Article 1 of Circular 39/2018/TT-BTC), responsibility for completing the on-spot export-import procedure is clearly divided among 4 parties: the exporter, the importer, the Customs Sub-Department handling the export procedure, and the Customs Sub-Department handling the import procedure.
Responsibilities of the on-spot exporter:
- Declare information on the export customs declaration and file the combined transport declaration.
- Complete the export procedure as required.
- Notify the importer as soon as the export customs procedure is complete, so the importer can carry out the import procedure and receive delivery.
- Receive confirmation from the importer once the on-spot import declaration has completed customs procedures, in order to proceed with the next steps.
Responsibilities of the on-spot importer:
- Declare information on the import customs declaration within the required deadline (15 working days).
- Complete the import procedure as required.
- Notify the exporter immediately after completing the on-spot import procedure.
- Only release the goods into production or consumption after the import goods have been cleared.
Responsibilities of the Customs Sub-Department handling the export procedure:
- Carry out the customs procedure for the export goods as required.
- Monitor on-spot export declarations that have completed customs procedures where the importer has not yet completed the corresponding import procedure.
- Notify the Customs Sub-Department expected to handle the import procedure, to coordinate management, monitoring, and follow-up with the on-spot importer to complete the procedure on time.
Responsibilities of the Customs Sub-Department handling the import procedure:
- Receive and inspect the dossier according to the system’s channel-classification result. If the goods have already undergone physical inspection at the export Customs Sub-Department, no repeat physical inspection is required.
- For on-spot export-import goods designated by a foreign trader, compile a monthly list of cleared on-spot import declarations and send it to the tax authority directly managing the on-spot importing organization or individual.
- Coordinate with the Customs Sub-Department handling the export procedure to follow up with the on-spot importer on completing the customs procedure.
Note: Clearly dividing responsibility among the four parties helps businesses proactively coordinate information between buyer and seller and between the two Customs Sub-Departments, avoiding delays caused by a missed notification that the export or import procedure has been completed.
9. VAT on On-Spot Export Goods
On-spot export goods that meet the required conditions are still eligible for the 0% VAT rate, the same as regular export goods, under Clause 1, Article 9 of Circular 219/2013/TT-BTC.
The conditions for applying the 0% rate, under Clause 3, Article 53 of Circular 38/2015/TT-BTC (as amended by Clause 33, Article 1 of Circular 39/2018/TT-BTC): the business must hold both the export customs declaration and the corresponding on-spot import customs declaration, each confirmed as cleared, and use a commercial invoice (for transactions under points a and c of Clause 1, Article 86) as the basis for tax declaration.
10. Real-World Example of On-Spot Export and Import
A component manufacturer in Vietnam signs a processing contract with a South Korean group. After completing the processed product, instead of exporting the surplus raw materials abroad, the Korean group designates that the surplus be delivered to another export processing enterprise located in Vietnam. The transaction is carried out under the on-spot export-import procedure, helping both businesses save on international shipping costs and shorten delivery time.
11. Advantages and Disadvantages of On-Spot Export and Import
On-spot export and import helps businesses save on cost and time, but requires close coordination between Customs Sub-Departments and strict compliance with the declaration deadline.
Advantages:
- Saves on round-trip international shipping costs and shortens delivery time.
- Still eligible for the 0% VAT rate applicable to regular exports, if all conditions are met.
- Well suited to processing and manufacturing supply chains involving multiple parties within Vietnam.
- Priority businesses can receive delivery first and declare customs later, reducing procedural wait time.
Disadvantages:
- The declaration process is more complex than an ordinary domestic transaction, since both an export and an import declaration must be filed simultaneously.
- Requires accurate coordination of information between the two Customs Sub-Departments managing the exporter and the importer.
- Businesses unfamiliar with the 15-working-day deadline risk penalties for late completion of the on-spot import procedure.
12. How Does On-Spot Export and Import Differ from Regular Export and Import?
On-spot export and import does not involve goods crossing the national border, while regular export and import requires goods to physically move from Vietnam abroad, or vice versa, through a checkpoint.
| Criteria | On-Spot Export and Import | Regular Export and Import |
|---|---|---|
| Movement of goods | No cross-border movement; delivered directly within Vietnam | Physically transported through a checkpoint or border |
| Applicable to | Processed goods, trade with export processing enterprises, goods designated by a foreign trader | All types of goods crossing the border |
| Number of declarations | Export and on-spot import declarations filed simultaneously | A single export or import declaration filed separately |
| Deadline | 15 working days from export clearance | As required for regular declaration registration (before/upon arrival of goods) |
| Legal basis | Article 86, Circular 38/2015/TT-BTC | Article 25, Customs Law 2014, and general customs procedure provisions |
13. Common Mistakes Businesses Make with On-Spot Export and Import
The most common mistakes when carrying out on-spot export and import are completing the import procedure after the 15-day deadline, declaring the wrong transaction type, or confusing eligible and ineligible goods.
| Common Mistake | Consequence | How to Fix It |
|---|---|---|
| Completing the import procedure after 15 days | Administrative penalty under customs regulations | Track the export clearance date closely to complete the import procedure on time |
| Entering the wrong “Destination point for bonded transport” | The system cannot link the export and import declarations, and the declaration gets held up | Enter the correct code for the import Customs Sub-Department and the #&XKTC marker as instructed |
| Mistaking an ineligible transaction as qualifying | The on-spot procedure is rejected, and the transaction must be redeclared under a different type | Cross-check the transaction against the three goods groups under Clause 1, Article 86 before declaring |
| Using the wrong type of invoice | The VAT declaration dossier becomes invalid, affecting the 0% tax rate | Use the correct commercial invoice or VAT/sales invoice for each specific case |
Real-world example: A business completed an on-spot export to an export processing partner but forgot to complete the on-spot import procedure within 15 working days of clearance, resulting in an administrative penalty from the managing Customs Sub-Department for missing the declaration deadline.
14. Current Legal Regulations on On-Spot Export and Import
On-spot export and import in Vietnam is currently governed directly by Article 86 of Circular 38/2015/TT-BTC, as amended by Circular 39/2018/TT-BTC and most recently updated by Circular 121/2025/TT-BTC, effective from February 1, 2026.
- Customs Law No. 54/2014/QH13 — sets the overall framework for customs procedures, inspection, and supervision.
- Circular 38/2015/TT-BTC — Article 86 regulates the customs procedure for on-spot export-import goods; Article 53 regulates the conditions for the 0% VAT rate.
- Circular 39/2018/TT-BTC — amends Clauses 4 and 5 of Article 86, and Clause 3 of Article 53 of Circular 38/2015/TT-BTC.
- Circular 219/2013/TT-BTC — Clause 1, Article 9 regulates the 0% VAT rate applicable to export goods, including on-spot exports.
- Circular 121/2025/TT-BTC (issued December 18, 2025, effective from February 1, 2026) — amends Clause 3, Article 86, updating the customs dossier requirements for on-spot export-import goods.
15. Frequently Asked Questions (FAQ)
Is on-spot export and import required to go through customs procedures?
Yes. Even though the goods do not cross the border, businesses must still file the corresponding on-spot export and on-spot import declarations under Article 86 of Circular 38/2015/TT-BTC.
Which goods qualify for on-spot export and import?
Three groups qualify: processed products, leased/borrowed machinery and equipment, and surplus materials under a processing contract; goods traded with an export processing enterprise or non-tariff zone; and goods designated for delivery by a foreign trader without a presence in Vietnam.
How long does the on-spot importer have to complete the procedure?
Within 15 working days from the date the export goods are cleared, the on-spot importer must complete the corresponding import customs procedure.
Is on-spot export goods eligible for the 0% VAT rate?
Yes, provided the conditions are met — namely, both the export and on-spot import declarations must be confirmed as cleared, together with a valid commercial invoice as required.
Can a business choose which Customs Sub-Department to use?
Yes. Under Clause 2, Article 86, the declarant may choose a convenient Customs Sub-Department to carry out the on-spot export-import procedure.
Can priority businesses deliver goods first and declare customs later?
Yes. A priority business, or one in compliance with customs law trading with a similarly compliant partner, may receive multiple deliveries first and declare customs later, within a maximum of 30 days from the date of delivery.
Does an ordinary domestic sales transaction count as on-spot export and import?
No. Only transactions falling under the three goods groups specified in Clause 1, Article 86 of Circular 38/2015/TT-BTC qualify for the on-spot export-import procedure.
What should businesses keep in mind when carrying out on-spot export and import?
Businesses should correctly identify the transaction type, accurately declare the linking information between the export and import declarations, comply with the 15-working-day deadline, and use the correct invoice type for each case.
3W Logistics – Supporting On-Spot Export and Import Procedures
Carrying out on-spot export and import requires businesses to correctly identify the applicable transaction type, coordinate accurately between Customs Sub-Departments, and strictly meet declaration deadlines. 3W Logistics works alongside businesses to handle the entire on-spot export-import procedure quickly and in full compliance.
- In-depth knowledge of on-spot export-import regulations: Well-versed in Article 86 of Circular 38/2015/TT-BTC and its amendments, handling each transaction type accurately.
- Synchronized documentation handling: Coordinates the filing of both the export and on-spot import declarations simultaneously, ensuring the 15-working-day deadline is met.
- Tax optimization consulting: Helps businesses meet the conditions for the 0% VAT rate on on-spot export goods.
Businesses that need help with on-spot export and import, please contact 3W Logistics directly for tailored consulting solutions.
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Hello, I’m Nguyen Phuong Nhan (Ms. Nina)
I currently serve as Trade Lanes Supervisor at 3W Logistics, with more than 10 years of experience in international logistics and freight forwarding.
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