Requirements for Claiming "Made in Viet Nam" When Using Imported Raw Materials

The Government of Viet Nam has issued Decree No. 384/2026/ND-CP governing the determination of Vietnamese origin for goods produced and circulated domestically, effective from January 1, 2027.

Using imported raw materials to manufacture goods in Viet Nam is a standard practice for many businesses. However, to legally label or claim finished products as “Made in Viet Nam”, companies must comply with specific statutory criteria.

Note: This Decree applies exclusively to goods circulated within the domestic market of Viet Nam. It does not regulate the issuance of C/O for import/export goods, nor does it lay down general goods labeling rules.

1. Two Criteria to Determine Vietnamese Origin for Imported Materials

Under Decree 384/2026/ND-CP, goods manufactured in Viet Nam using imported materials (non-originating materials) are recognized as having Vietnamese origin if they satisfy one of the following two criteria:

Change in Tariff Classification (CTC): The finished product manufactured in Vietnam must undergo a change in HS code at the 4-digit level (Heading) compared to the non-originating materials used in production
Viet Nam Value Content (VVC): At least 30% of the product’s value must be generated within Vietnam. Businesses may choose either the direct calculation method or the indirect calculation method, applying it consistently throughout the fiscal year

Packing materials, containers, and qualifying domestic R&D, design, software programming, and testing expenses incurred in Viet Nam can be included in the VVC calculation under specific terms outlined in the Decree.

Important: Meeting the CTC or VVC criteria alone is not sufficient to confirm origin. Businesses must also review related constraints, particularly regulations on minimal/simple processing operations.

2. Minimal Operations That Do Not Confer Origin

To prevent trade fraud and origin spoofing, the following simple processing operations do not qualify a product for Vietnamese origin, regardless of other criteria met:

Preservation and Preliminary Processing: Storage, preservation during transport, washing, sifting, selecting, and sorting
Packaging and Labeling: Packing, repacking, changing packaging, affixing or printing logos, labels, or similar distinguishing marks
Simple Treatments: Sharpening, simple grinding, basic cutting, and basic grain or rice processing
Assembly and Testing: Simple assembly of parts, as well as basic inspection or testing operations
Animal Slaughtering: Slaughter of animals

If imported products undergo only one or a combination of the above operations in Viet Nam, they will not be granted Vietnamese origin.

3. Neutral Elements (Indirect Materials Excluded from Origin Determination)

Materials or elements used in the manufacturing process that do not physically enter the final composition of the product are excluded when assessing origin. These include:

Fuel, energy, lubricants, and power sources
Tools, dies, and molds
Spare parts and maintenance materials used for equipment and factory premises
Work safety equipment, including gloves, footwear, and protective clothing
Machines, devices, and testing equipment used to inspect goods
Catalysts and solvents used during processing

4. Compliance and Documentation Obligations

Enterprises that self-declare Vietnamese origin are fully responsible for the accuracy and truthfulness of their declarations. When requested by competent authorities, businesses must present supporting documentation, which typically includes:

Invoices and purchasing receipts for raw materials
Detailed Bill of Materials (BOM)
Manufacturing process flowcharts and technical records
VVC calculation worksheets and accounting records (if applicable)
Other relevant technical and commercial documents depending on the product category and chosen origin determination method

5. Effective Date and Transition Period

Effective Date: January 1, 2027
Transitional Provision: Goods labeled with Vietnamese origin legally prior to January 1, 2027, may continue to circulate under their existing labels until their expiration date

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