Vietnam Decree 292: 3 Trade Rules to Review
Vietnam’s Decree 292/2026/ND-CP took effect on September 5, 2026, replacing Decree 69/2018/ND-CP. For businesses involved in cross-border trade, temporary imports, or contract manufacturing, several provisions deserve a closer look because they can affect shipment planning, contract terms, and material reconciliation.
Rather than treating every regulatory update as a universal checklist, businesses should identify which provisions apply to their actual trading activities.
Here are three areas worth reviewing.
1. Temporary Import for Re-export: Track the 60-Day Limit
Under Article 14, goods handled under the specific temporary import for re-export business regime may generally remain in Vietnam for no more than 60 days from completion of temporary import customs procedures.
If more time is needed, the trader may request an extension from the customs office that handled the temporary import. Each extension may not exceed 30 days, and no more than two extensions may be granted for each lot of goods.
When the permitted period expires, the goods must be re-exported or destroyed. If the goods are instead imported into Vietnam, the applicable import management and tax rules must be followed.
What businesses should review
• Whether the transaction falls under the specific regime covered by Article 14.
• The date temporary import customs procedures are completed.
• Whether an extension is needed and, if so, whether the request is submitted to the appropriate customs office.
• The arrangements for re-export or other legally permitted handling before the deadline.
These time limits should not be assumed to apply to every form of temporary import. Other arrangements may be governed by different provisions.
2. Contract Manufacturing: Material Norms Need More Than Informal Agreement
For Vietnamese traders processing goods for foreign traders, Articles 31 and 32 set out important requirements for processing contracts and material-use arrangements.
A processing contract must include key terms such as the parties, processed products, price, payment arrangements, material lists and values, material-use norms, consumption norms for supplies, and permissible loss ratios. It must also address the handling of scraps, waste products, surplus materials, and leased or borrowed machinery and equipment during and after the contract.
Article 32 provides that material-use norms, consumption norms, and permissible loss ratios are to be agreed upon in the processing contract, taking into account relevant Vietnamese industry norms at the time of signing.
If these norms or ratios change during the contract, the parties must agree to the changes in a contract appendix before implementation.
What businesses should review
• Whether the contract contains the required material and production terms.
• Whether the agreed norms and permissible loss ratios reflect the relevant production process.
• Whether changes are documented in a contract appendix before being implemented.
• Whether responsibilities for surplus materials, scraps, waste, and equipment are clearly addressed.
This is particularly relevant when production specifications change or actual material consumption differs from the original plan.
3. Contract Closure: Material Reconciliation Does Not End When Production Stops
Article 37 addresses the liquidation and finalization of processing contracts.
When a processing contract is completed or expires, the parties must liquidate the contract and send periodic reports on the finalization of material use and exported products to the customs office. The Ministry of Finance is responsible for guiding the relevant finalization procedures.
The decree also addresses the treatment of surplus materials, leased or borrowed equipment, scraps, and waste. Their handling must follow the contract and applicable Vietnamese law. Destruction must comply with customs and environmental protection requirements; where environmental law does not permit destruction in Vietnam, the materials or items concerned must be re-exported as designated by the processing-ordering party.
What businesses should review
• How imported materials, actual production, and exported products will be reconciled.
• Whether the contract clearly explains the handling of surplus materials, scraps, and equipment.
• Whether the responsible teams can produce the records needed for contract liquidation and customs reporting.
• Whether the planned disposal method complies with applicable customs and environmental requirements.
The practical point is simple: production ending does not necessarily mean all related compliance and recordkeeping work is complete.
A Practical Starting Point
Not every company will be affected by all three areas. Their relevance depends on the trading model, the goods involved, and the company’s role in the transaction.
Businesses can start with three questions:
- Do we use the specific temporary import for re-export business regime covered by Article 14?
- Do our processing contracts clearly document material-use norms, permissible loss ratios, and how changes must be agreed?
- Do we have a clear process for reconciling materials and handling remaining goods when a processing contract ends?
These questions can help businesses identify which provisions deserve closer review. Where the applicable regime or required procedure is unclear, the relevant customs authority or a qualified trade and legal professional can help clarify the requirements.
Final Thoughts
Decree 292 is broader than a list of import and export restrictions. It also sets out specific requirements for particular trading and processing arrangements.
For businesses operating across borders, the most useful first step is to match the applicable provisions to the actual transaction, then review the timelines, contracts, and records that support it.
Official source
Decree No. 292/2026/ND-CP — Government of Vietnam (Vietnam Government legal database).
This article is for general informational purposes only and does not constitute legal advice. The applicable requirements depend on the specific transaction and relevant implementing rules. Businesses should verify requirements for their circumstances with qualified professionals.
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This article is provided for general informational purposes only and does not constitute legal advice.
Published: October 2026
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