Vietnam Used Digital Products Import Ban: Draft 2026 List
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Vietnam: MST Consults on Draft Circular Updating the Used Digital Products Import Ban
Vietnam's Ministry of Science and Technology (MST) opened a public consultation on a draft Circular announcing the list of used digital technology products prohibited from import, together with their HS codes. The draft is published on the MST legal-documents portal and would update the long standing prohibition on importing used information and communications technology products. Importantly, this is a draft under review, not enacted law the comment window ran from 21 May 2026 to 31 May 2026 and is now closed.
What MST published
The consultation dossier consists of a draft Circular (version 1.7) plus a supporting comparison and explanatory note. Key administrative details from the portal:
Field | Detail |
Issuing authority | Ministry of Science and Technology (MST), Vietnam |
Instrument | Draft Circular — list of used digital technology products prohibited from import, with HS codes |
Document title (VN) | Dự thảo Thông tư công bố danh mục sản phẩm công nghệ số đã qua sử dụng cấm nhập khẩu kèm theo mã số HS |
Consultation start | 21 May 2026 |
Consultation deadline | 31 May 2026 (closed) |
Current status | Post-consultation; not yet adopted; proposed effective date not stated on the portal |
Dossier files | Draft Circular (v1.7) + comparison/explanatory note |
A notable change in language: the draft frames the scope as "digital technology products" (sản phẩm công nghệ số), whereas the regime it would replace refers to "information technology products" (sản phẩm công nghệ thông tin). The substantive mechanism a prohibited list keyed to HS codes is retained.
How this fits Vietnam's existing import-ban regime
This draft does not create a new prohibition from scratch. Vietnam has prohibited the import of used IT products for years. The current framework is Circular 11/2018/TT-BTTTT (issued 15 October 2018, effective 30 November 2018), originally administered by the former Ministry of Information and Communications.
Following Vietnam's 2025 government restructuring, the relevant functions sit with MST, which is why the refreshed draft is issued under the new ministry.
The draft is best understood as a scheduled refresh of the prohibited list and HS-code mapping under updated tariff nomenclature and updated product terminology not a reversal or relaxation of the underlying ban.
Scope of the Vietnam used digital products import ban
Under the current framework (which the draft is expected to carry forward in structure, pending confirmation against the draft text), the prohibited list operates on the following classification logic:
4-digit HS heading listed → all 8 digit codes within that heading are prohibited.
6-digit HS subheading listed → all 8 digit codes within that subheading are prohibited.
8-digit codes detailed → only those specific 8 digit codes are prohibited.
Used components, spare parts, sub-assemblies and accessories of products on the list are also prohibited.
Refurbished products carrying an HS code on the list are prohibited (a refurbished product being a used product repaired or rebuilt to a like new function/appearance, labelled as refurbished, with a manufacturer equivalent warranty).
Multi-colour digital printers and photocopiers are handled under printing sector legislation on import.
Exception: monochrome (black and white) digital printers/photocopiers with A0 capability or a speed of 35 pages/minute (A4) or above, and used laser toner cartridges (HS 8443.99.20), are not prohibited.
Separately, used mobile phones remain prohibited from import under Decree 69/2018/NĐ-CP, independent of this circular.
The specific product categories and HS codes added, removed, or amended in the draft versus Circular 11/2018 are set out in the dossier's comparison note and the v1.7 draft text. These line-item changes should be read directly from the draft documents before any commercial decision.
What this means for manufacturers
For manufacturers, importers, and refurbishers placing digital technology products on the Vietnamese market, the practical implications are:
A prohibited-list entry overrides certification. If a used or refurbished item's HS code falls on the list, no type approval or conformity route legalizes its import the item simply cannot be brought in. Compliance effort on used lines is therefore an import-eligibility question first, and a certification question only for eligible (typically new) goods.
New (unused) products are not the target of this list. Conformity and type-approval obligations for new ICT/digital products continue to apply as normal; this draft does not change those pathways.
Refurbished-goods business models carry concentrated risk. Refurbished units bearing listed HS codes are caught, even with manufacturer warranties — relevant for trade-in, remanufacturing, and circular-economy programmes.
Spare parts and sub-assemblies need separate screening. Used components of listed products are independently prohibited, so service-and-repair supply chains relying on used parts require review.
Reclassification work is coming. If adopted, the updated HS-code mapping may move specific products in or out of scope; portfolios classified against the 2018 list should be re-screened against the new list once finalised.
Certification impact summary
Product situation | Effect under the draft framework | Action driver |
Used / refurbished item with HS code on the list | Import prohibited; no certification route available | Re-source as new, or exit the line |
New (unused) digital/ICT product | Not affected by this list; standard conformity/type approval applies | Maintain existing certification pathway |
Refurbished product with listed HS code | Prohibited despite warranty/refurbished labelling | Review refurbished import model |
Used components/parts of listed products | Independently prohibited | Audit used-parts supply chain |
Items not on the list (e.g. certain monochrome printers/copiers, toner cartridges) | Importable, subject to other applicable rules | Confirm HS code against final list |
Timeline and required actions
Date | Event | Required action |
15 Oct 2018 | Circular 11/2018/TT-BTTTT issued (current framework, effective 30 Nov 2018) | Treat as the rule in force until the new circular is adopted |
21 May 2026 | MST opened consultation on the draft circular | — |
31 May 2026 | Consultation deadline (now closed) | Comment window has passed; do not rely on it being open |
Now (post-consultation) | MST reviewing input; draft not yet adopted; effective date TBD | Obtain the v1.7 draft + comparison note; map your used/refurbished SKUs and HS codes against both the 2018 list and the draft |
On adoption (future) | New circular expected to supersede Circular 11/2018 | Re-screen portfolio against the final list; update import-eligibility and HS-classification records; brief logistics/customs partners |
Pre-import (each shipment) | Customs classification at clearance | Verify each HS code against the list in force at time of import; pre-classify high-risk or borderline items |
