Quick answer: From 6 June 2026, nuclear reactors under HS 8401.10.00 and specified reactor parts under HS 8401.40.00 appear in the dual-use list issued with Circular 30/2026/TT-BKHCN. Because these goods are nuclear equipment, however, the export-licensing route follows atomic-energy legislation rather than mechanically using the ordinary dual-use application package used for goods such as UAVs.
The exporter must answer four questions: is the shipment a complete reactor or a part; which HS code reflects its condition as exported; does a part match a listed technical type; and is the radiation-work licence dossier under Article 45 of Decree 332/2025/ND-CP complete?
This article concerns exports from Vietnam and reflects Vietnamese law checked through 27 September 2026. It is not advice under U.S., Chinese or another foreign export-control regime.
1. Legal conclusion by product type
| Actual goods | Indicative HS code | Control conclusion |
|---|---|---|
| Complete nuclear reactor | 8401.10.00 | Directly matches item 2.1.1 of the Circular 30 Appendix and is licence-controlled. |
| Nuclear-reactor part | 8401.40.00 | Falls under item 2.1.2 only when it is a reactor part and also matches a listed technical type. |
| Isotope-separation machinery | 8401.20.00 | A separate HS line requiring its own list analysis; it is not a complete reactor. |
| Unirradiated fuel element | 8401.30.00 | A separate line and regulatory subject; it should not be declared as an 8401.40.00 part. |
Core rule: Article 2 of Circular 30 and Article 7.3 of Decree 259/2025/ND-CP require a simultaneous match of HS code, goods description and technical characteristics. A complete reactor directly matches the listed description; for parts, HS 8401.40.00 alone is not enough.
2. HS classification of reactors and parts
Vietnamese heading 84.01 covers nuclear reactors; isotope-separation machinery and parts; unirradiated fuel elements; and reactor parts. Classification applies GIR 1, the relevant notes and GIR 6. A reactor shipped unassembled or disassembled must also be tested under GIR 2(a): if the shipment already has the essential character of the complete reactor, HS 8401.10.00 may apply.
- 8401.10.00: a complete nuclear reactor, including a qualifying unassembled shipment under GIR 2(a).
- 8401.40.00: a reactor part where the shipment is not itself the complete reactor and the technical record establishes its dedicated or principal reactor use.
- Do not classify by project name: a pump, pipe, valve, control system or steel structure may fall under its own heading if its objective characteristics do not satisfy the reactor-part analysis.
For a separate technical classification analysis, see nuclear-reactor HS codes 8401.10.00 and 8401.40.00 and Vietnam export policy on HS Code Checker.
3. Which 8401.40.00 parts are listed?
Item 2.1.2 does not cover every component that can be installed in a nuclear facility. Its principal technical descriptions include:
- Nuclear-reactor vessels.
- Control rods and relevant mechanisms within the listed scope.
- Fuel loading and unloading machines.
- Reactor pressure tubes.
- Zirconium tubes within the technical scope.
- Primary coolant pumps.
The control-reference column cites branches 0A001.b through 0A001.g. Those are not HS codes for the customs declaration. The exporter should build a model-by-model concordance against the Appendix rather than relying on the generic invoice phrase “reactor part”.
4. Why is the licence route different from the UAV case?
Article 3 of Circular 30 establishes licensing for dual-use goods managed by the Ministry of Science and Technology but separately provides that radioactive material and nuclear equipment are licensed under atomic-energy law and other relevant legislation.
A nuclear reactor is nuclear equipment. Articles 14 and 30 of the Law on Atomic Energy 94/2025/QH15 treat export of nuclear equipment as radiation work that may be carried out only under a competent-authority licence. Decree 332/2025/ND-CP is the applicable procedural decree from 1 January 2026.
The exporter should therefore prepare the radiation-work licence for export of nuclear equipment, not simply copy the Article 9 package under Decree 259. Strategic-trade obligations concerning the transaction, end user and end use remain relevant.
5. Nuclear-equipment export licence dossier
Article 45 of Decree 332/2025/ND-CP requires:
- An application for a radiation-work licence using Form 02 in Appendix VIII.
- The corresponding nuclear-equipment declaration form in Appendix VII.
- A copy of the document proving the equipment's origin.
- A copy of the sale contract or transfer/acceptance agreement between the Vietnamese exporter and overseas recipient.
- A copy of the import authorisation issued by the destination country's competent authority to the importer, as required for nuclear equipment.
The file may be submitted through the National Public Service Portal or directly/by post to the Ministry of Science and Technology's receiving unit at the Vietnam Agency for Radiation and Nuclear Safety. Article 49 of Decree 332 assigns the licence to that Agency for this case. Forms, fees and the published processing period should be rechecked on the official procedure page on the filing date.
6. Technical file and end-user controls
- Equipment name, model, serial number, manufacturer/country and year of manufacture.
- Configuration diagram, module list, general arrangement and function of each part.
- Materials, dimensions, design pressure/temperature, flow and capacity where relevant.
- Reasoning for complete, unassembled or part status, including the GIR analysis.
- A concordance against Circular 30 and the relevant 0A001 control reference.
- Buyer, consignee, end user, installation site and substantiated civil purpose.
- Destination-country import authorisation and contractual diversion/retransfer restrictions.
If the contractual buyer and the receiving facility differ, identify the importer, consignee and actual end user. Article 4.3 of Decree 259/2025/ND-CP preserves controls where there is concern about weapons-of-mass-destruction use or a designated end user, even if the list classification is disputed.
7. Customs declaration and goods description
A description template, only where factually correct, is:
“Complete nuclear reactor, [assembled/disassembled], intended use ..., model ..., serial ..., manufacturer ..., country of manufacture ..., capacity ..., new 100%, exported from Vietnam, licence no. ... dated ...”
For a part, identify it precisely as a reactor vessel, control rod, fuel loading/unloading machine, pressure tube, zirconium tube or primary coolant pump; include material, specifications, model/part number and the reactor for which it is designed. Avoid generic descriptions such as “machinery spare parts”.
The Article 24 Customs Law file must remain consistent across the licence, contract, invoice, packing list, transport document, catalogue, serial/part-number list and destination import authorisation. For split shipments, maintain a configuration allocation schedule showing which items form the complete reactor.
8. Processing, export manufacturing and post-clearance records
For processing or export-manufacturing arrangements, link imported materials to the BOM, consumption norms, warehouse records, production stages, finished goods, scrap and export declarations. Differences involving zirconium, pressure-resistant alloys or pump assemblies should be reconciled by material code and part number.
Before the annual finalisation report, reconcile declaration-level receipts, issues and inventories with the ledger and actual norms. See Dương Minh Logistics' processing/export-manufacturing finalisation review and post-clearance audit preparation workflow.
9. Recommended workflow before contract signature
- Freeze the shipped configuration, serial/part numbers and shipment sequence.
- Classify the goods as a complete reactor, part or another heading 84.01 product.
- Build the HS–description–technical-characteristics matrix under Circular 30.
- Screen the importer, consignee, end user, location and end use.
- Obtain the destination-country import authorisation.
- Apply to the radiation and nuclear safety authority under Article 45 of Decree 332.
- File customs only when the licence and commercial/technical records are aligned.
- Retain the legal, technical, delivery and end-use evidence for the applicable period.
10. Dương Minh Logistics support
Dương Minh Logistics can support HS review, the HS–description–technical matrix, document checklists, consistency review before customs filing, customs procedures, BOM/norm reconciliation for processing and export manufacturing, finalisation-report review and post-clearance file preparation.
We do not replace the nuclear-safety authority's technical assessment and do not guarantee licensing outcomes. A conclusion requires the actual configuration, origin, contract, technical documents and end-user information. See also the general dual-use goods guide and the customs advisory service.
11. Frequently asked questions
Does every product declared under HS 8401.40.00 require a Circular 30 licence?
No. The HS code, goods description and technical characteristics must all match. A code alone does not prove that the part is one of the listed technical types.
Can a disassembled reactor be declared entirely as 8401.40.00 parts?
Not automatically. If the shipment has the essential character of the complete reactor, GIR 2(a) may lead to HS 8401.10.00.
Should the UAV Article 9 Decree 259 dossier be used?
Not mechanically. Circular 30 routes nuclear equipment into atomic-energy law, and Article 45 of Decree 332 directly sets the export dossier.
Is 0A001.a entered as the customs code?
No. Vietnam's HS code is declared to customs. 0A001.a and related branches are export-control references used in the technical/legal review.
Official legal sources
- Circular 30/2026/TT-BKHCN and its signed Appendix.
- Decree 259/2025/ND-CP on strategic trade controls.
- Law on Atomic Energy 94/2025/QH15.
- Decree 332/2025/ND-CP and its official signed text.
- Circular 31/2022/TT-BTC, Vietnam's export/import nomenclature.
- Customs Law 54/2014/QH13.
This material provides general legal information only. A shipment conclusion depends on the actual goods, assembly condition, technical evidence, origin, end user, end use and law in force on the transaction date.
Lawyer Dương Minh Hòa
