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Customs Department: Quality Inspection Registration Certificate Is Not an Import License
The Customs Department maintains that a certificate of registration for quality inspection and an import license constitute two legally distinct documents within a customs dossier. Consequently, there is no legal basis to enforce the statutory timing requirements of import licenses upon quality inspection registration certificates prior to customs declaration registration. The agency has also requested formal guidance to clear pending shipments affected by recent policy transitions.
Specialized Inspection Documents Distinct from Import Licenses
The Customs Department has recently issued an official dispatch to the Department of Quality, Processing, and Market Development (under the Ministry of Agriculture and Environment) to clarify the regulatory application of quality inspection documents during customs clearance.
Previously, in Official Dispatch No. 1948/CCPT-CL, the Department of Quality, Processing, and Market Development cited Clause 3, Article 25 of Decree No. 08/2015/ND-CP (as amended and supplemented by Decree No. 167/2025/ND-CP), asserting that prior to July 1, 2026, customs declaration registrations for imported animal feed shipments could only proceed once certified registration for state quality inspection had been endorsed by the competent specialized authority.
In response, the Customs Department detailed the relevant statutory grounds:
Nature of Licensing Control: Pursuant to Clause 1, Article 29 of the Law on Foreign Trade Management, licensing administration refers to the issuance of import/export licenses or equivalent legal authorizations permitting traders to execute foreign trade transactions. In contrast, a quality inspection registration certificate is an administrative record issued during the state quality inspection process for imported goods; it is neither an import license nor a formal import permit.
Classification within Customs Dossiers: Clause 1, Article 24 of the 2014 Customs Law explicitly distinguishes between “import-export licenses” and “notices of specialized inspection results or exemptions” as two separate document categories in customs filings.
According to the Customs Department, the receipt and verification of a submission by a specialized authority does not equate to deeming that document an “import license” under Clause 3, Article 25 of Decree No. 08/2015/ND-CP. Therefore, the agency determined that no legal grounds exist to mandate that traders possess certified quality inspection registrations prior to lodging their customs declarations based on licensing-timeline regulations.
Request for Guidance on Transitional Shipments
In addition to clarifying the nature of these documents, the Customs Department requested the Department of Quality, Processing, and Market Development to coordinate with the Department of Animal Health and Husbandry to issue specific operational guidelines for shipments declared and registered for inspection before July 1, 2026, but whose inspection procedures remain unfinalized.
A practical bottleneck has emerged due to the regulatory shift:
At declaration time (prior to July 1, 2026): Shipments were subject to mandatory state quality inspection pursuant to Decree No. 132/2008/ND-CP and its implementing amendments.
Post-July 1, 2026: Under Circular No. 27/2026/TT-BNNMT, certain categories (such as animal feed raw materials reclassified as medium-risk) were removed from mandatory import quality inspection requirements.
Under Clause 3, Article 29 of the Customs Law, regulatory policies are determined at the date of customs declaration registration. However, because the specialized inspection body ceased conducting certifications for these designated goods on July 1, 2026, importers lack the required legacy inspection certificates to finalize clearance.
To ensure uninterrupted trade flows, the Customs Department has petitioned the Ministry of Agriculture and Environment for prompt guidance on clearance protocols for these transitional consignments, along with a comprehensive review of similar goods under the Ministry’s oversight.
Key Takeaways for Importers and Exporters
Ascertain Applicable Policies at Declaration Time: Under Vietnamese customs legislation, regulatory and clearance regimes apply based on the official declaration registration date. Traders must account for this timeline during regulatory phase-outs to identify the correct compliance requirements.
Carefully Verify Product Scopes and Risk Tiers: Cross-check HS codes, trade names, and specific risk classifications against newly enacted circulars (such as Circular 27/2026/TT-BNNMT) to confirm whether an item qualifies for inspection exemption, avoiding broad assumptions across entire commodity groups.
Monitor Inter-Agency Transitional Directives: Enterprises with consignments registered prior to July 1, 2026 that remain uncleared should closely monitor forthcoming joint guidance between the Ministry of Agriculture and Environment and customs authorities to resolve lingering documentation bottlenecks
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