Vietnam Customs Tightens Rules for EPE: What It Means for Russian Sellers

WHAT HAPPENED

Vietnam's Regional Customs Branch IV published clarifications on customs procedures for export processing enterprises (EPEs) on October 24, 2026. This is not a separate regulatory act but a summary of enforcement practice under existing documents: Official Dispatch No. 20010/CHQ-GSQL, Official Letter No. 17769/CHQ-NVTHQ dated June 22, 2026, and Official Letter No. 15225/CHQ-GSQL dated April 14, 2026. All three documents rely on Decree No. 134/2016/NĐ-CP and amendments under Decree No. 18/2021/NĐ-CP.

The essence of the clarifications is that an enterprise that "no longer meets" customs control requirements for non-tariff zones loses its right to the EPE preferential regime. According to PwC Vietnam (review dated August 20, 2026), customs directly links EPE status to compliance with the inspection and control regime, not merely formal registration. Branch IV separately reported 14 risk groups for EPEs and provided regional statistics: out of 3,040 enterprises, only 149 hold EPE status (4.89%). Typical violations include undeclared expansion of production space and changes in warehouse functions.

Additionally, effective September 9, 2026, automation of transaction confirmation through the "customs supervision area" came into force under Official Document No. 20991/CHQ-GSQL dated August 26, 2026. EPEs are required to update their "Enterprise's Internal Management Number"; otherwise, declarations will not pass automated processing.

WHAT IT MEANS

For Russian e-commerce, this is primarily about cost and lead times, not legal exotica. An EPE is a factory that purchases raw materials and components free of import duties and VAT, provided all output is exported. A significant portion of contract manufacturing in Vietnam—footwear, textiles, small electronics, accessories, home goods—is built on this scheme. If a supplier loses EPE status, it suddenly becomes an ordinary importer of raw materials, subject to duties and VAT on incoming materials. These costs are almost always passed on to the shipment price.

The second risk is lead times. When customs reclassifies an enterprise or requires additional documents on raw material balances (and Letter No. 17769/CHQ-NVTHQ specifically addresses handling of surplus materials, equipment, and property), a shipment can sit in the warehouse for weeks. For a seller planning a delivery for a seasonal peak on a marketplace, this means either a missed schedule or emergency air freight that erodes margin.

The third layer is documentation. Branch IV's clarifications reinforce the emphasis on confirming EPE status and ensuring the actual production site matches the declared one. If your Vietnamese partner has one line "on paper" but has actually expanded the workshop without notifying customs, that is their violation—but the supply chain risks are yours. According to EY Vietnam (review dated March 2026), enforcement practice remains transitional: different interpretations persist regarding when exactly an EPE loses its preferential regime, and factual grounds rather than formal criteria are required.

And the fourth point is automation from September 9, 2026. This is a technical requirement, but it hits operations: if a supplier has not updated its internal identifier, the declaration is not automatically confirmed, and the shipment waits for manual processing. According to THT Cargo Logistics, this also applies to EPE transactions with domestic Vietnamese enterprises.

VIETSMART EXPERT COMMENTARY

I see this constantly in operations in Ho Chi Minh City: Russian brands come asking to "find a cheaper factory," and two months later it turns out the factory's EPE status is registered for one site while production has been partially moved to an adjacent site not covered by that status. Formally, this is not your responsibility, but your shipment will be the first to be held for inspection. The most common mistake is asking the supplier only for a price list and samples without requesting confirmation of EPE status and documents for the production premises.

If I were a Russian entrepreneur, I would not try to decipher customs letters in Vietnamese myself. Instead, I would build status verification into the supplier onboarding checklist—before signing the contract, not after the first problematic shipment. And I would build a time buffer into the procurement plan in case of manual declaration processing.

Expert Commentary

"EPE status is not a line in a registry but an operational obligation of the factory. If a supplier cannot show that its premises, warehouses, and inventory records comply with the declared regime, you are buying not a benefit but potential customs delays."

Dmitrii Vasenin Founder, VietSmart

CONCLUSIONS AND WHAT TO DO

• Request confirmation of EPE status before contracting. You need: the EPE registration certificate, documents for the production site and warehouse, and confirmation that actual areas match declared ones. Check not only the head office but every production location.
• Verify the internal identifier update. As of September 9, 2026, EPEs must update their "Enterprise's Internal Management Number" under Official Document No. 20991/CHQ-GSQL. Ask the supplier for a screenshot or system confirmation—a cheap check that saves weeks.
• Clarify the procedure for handling raw material surplus. Letter No. 17769/CHQ-NVTHQ dated June 22, 2026 regulates the processing of excess materials and equipment. If the factory accumulates leftovers for your orders, clarify how it declares them—otherwise the shipment may get stuck at inspection.
• Build a time buffer into your supply plan. For seasonal purchases for marketplaces, add 2–3 weeks to standard transit time in case of manual declaration processing. For short-lifecycle goods (electronics, trend-driven accessories), this is critical.
• Diversify suppliers within Vietnam. Keep at least two manufacturers for each key category: if one loses EPE status or undergoes re-registration, the other covers the volume without schedule disruption.

Source: Vietnam.vn dated October 24, 2026