Importing Used Machinery and Moulds under Circular 56/2026

Legal update — 24 September 2026: from 5 September 2026, imports of used machinery, equipment and technology lines within the regulated scope are governed by Circular 56/2026/TT-BKHCN. Decision 18/2019/QD-TTg is no longer the main basis for new declarations; it remains relevant only to the transitional cases listed in Article 17.

Importing used machinery and moulds: the key conclusion

It is no longer safe to state that every used mould is automatically exempt from inspection. The correct treatment depends on the HS code, actual construction, operating principle and import purpose. Circular 56 applies to used machinery, equipment and technology lines classified in Chapters 84 or 85 and imported for direct use in manufacturing in Vietnam.

For used machinery within that scope, the importer must verify the equipment age, manufacturing standards and the supporting manufacturer confirmation or inspection certificate. For a mould, the importer must first determine whether it is merely a passive tool or a complete assembly capable of operating or moving for its designed purpose under Article 3.1.

1. Scope of Circular 56/2026/TT-BKHCN

Under Article 1.1, the Circular applies where the goods are used machinery, equipment or a technology line; fall in HS Chapter 84 or 85; are imported for direct manufacturing use in Vietnam; and are not prohibited or excluded under Article 1.2.

Article 3.1 defines machinery and equipment as a complete structure made of connected parts, assemblies and components that operates or moves for its designed purpose. Classification in Chapter 84 alone does not automatically make an item “machinery or equipment” for this Circular.

2. Does a used casting mould require inspection?

1. Identify the HS code: many moulds for metals, rubber or plastics may fall under heading 84.80, subject to the goods' construction and use.
2. Test the legal definition: a passive mould or tool with no independent operating or moving mechanism may be supported as outside the definition in Article 3.1. A complete equipment module with its own operating mechanism may be within scope.
3. Check other import rules: goods outside Circular 56 must still comply with HS classification, customs valuation, labelling and any applicable sector-specific regulation.

The practical approach is not to use a blanket “no inspection required” statement. Prepare catalogues, drawings, nameplate photographs, an operating-principle description and videos before signing the purchase contract.

Reference value of Official Letters 2126/BKHCN-DTG and 1441/BKHCN-DTG

Official Letter 2126/BKHCN-DTG dated 17 July 2019 previously treated a fixed used casting mould, unable to operate or move independently like machinery, as outside Decision 18/2019/QD-TTg. Official Letter 1441/BKHCN-DTG dated 20 May 2020 provided similar guidance for a fixed shoe-sole mould under HS 8480.71.10.

Those letters remain useful references on the technical nature of a passive mould. However, they are administrative guidance issued under the former Decision 18 framework, not legislative instruments and not a general inspection exemption for every mould. Pending new guidance under Circular 56, an importer should submit them only as supporting references together with the technical dossier and should seek written clarification for a shipment whose construction or function is uncertain.

3. Criteria for importing used machinery

Article 6 sets two principal requirements:

• Age: normally no more than 10 years, calculated from the year of manufacture to the year the goods arrive at a Vietnamese border gate. Appendix I sets different limits for specified sectors.
• Manufacturing standards: compliance with applicable Vietnamese technical regulations on safety, energy efficiency and environmental protection; where no relevant QCVN exists, the equipment must meet the technical indicators of a Vietnamese standard or a national standard of a G7 country or Korea.

4. Documents for used machinery

In addition to the ordinary customs dossier, Article 9 requires corporate information and, where applicable, import-entrustment documents. Machinery manufactured in a G7 country or Korea may be supported by an original manufacturer confirmation, consularly legalised and translated into Vietnamese, showing the manufacturing year and applicable standard. If that confirmation is unavailable, or the machinery was made outside the G7 or Korea, an inspection certificate issued by a designated inspection body is required.

If neither the manufacturer confirmation nor the inspection certificate is available when the declaration is lodged, the goods may be brought to a preservation location after the importer submits a confirmed inspection-service registration. The inspection certificate must be submitted within 30 days from the date the goods are brought to preservation.

5. Machinery older than 10 years

Article 10 provides a separate approval route for a business already manufacturing in Vietnam where older machinery is necessary to maintain production, retains at least 85% of its designed capacity or efficiency, and consumes no more than 15% above the designed level of materials and energy. Approval from the Ministry of Science and Technology and a compliant inspection certificate are required.

6. Transitional treatment of Decision 18/2019/QD-TTg

New imports from 5 September 2026 should be assessed under Circular 56. Article 17 preserves specified pre-existing inspection-body appointments, inspection certificates issued before the effective date, applications already received and declarations registered before 5 September 2026 while awaiting inspection. Decision 18 should therefore not be used as the principal legal basis for a new shipment outside those transitional situations.

7. Pre-import checklist

1. Collect the model, serial number, year and country of manufacture, standards, catalogue and nameplate photographs.
2. Determine the goods' actual nature and proposed HS code.
3. Check Articles 1 and 3 to confirm whether Circular 56 applies.
4. For a passive mould, include Official Letters 2126 and 1441 as supporting references and monitor new competent-authority guidance.
5. Verify the age limit under Article 6 and Appendix I.
6. Select the manufacturer-confirmation or designated-inspection route under Article 9.
7. Include document, rejection and refund protections in the purchase contract.
8. Ship only after the import-policy and customs-clearance plan has been reviewed.

Official sources

• Circular 56/2026/TT-BKHCN — Official Gazette;
• Circular 56/2026/TT-BKHCN — Government Portal;
• Decree 292/2026/ND-CP — Government Portal.

Note: This is general guidance as of the update date. A shipment-specific conclusion requires the catalogue, construction, HS code, intended use, country and year of manufacture, and the actual documents.