In import operations, ensuring that goods comply with regulations regarding original labels and storage locations under customs supervision is a key factor in helping businesses avoid customs clearance delays or administrative penalties. Based on the guidance in Official Letter No. 105/CHQ-GSQL dated January 6, 2026, from the Customs Department, this article summarizes and analyzes the points that businesses need to pay special attention to when carrying out import labeling procedures and registering warehouses for goods storage.
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Legal requirements for labeling imported goods.
Product labels are not merely a formality; they also serve as a basis for regulatory authorities to determine the origin, legal responsibility, and conformity of a product. According to current regulations, importing businesses must ensure that the original labels of goods contain complete information upon arrival at the port.
The information that must be displayed on the original label.
Based on Decree 43/2017/ND-CP and Decree 111/2021/ND-CP, the original label of imported goods must display at least the following information (in a foreign language or Vietnamese):
- Product name: Accurately reflects the nature and use of the product and is consistent with the commercial documentation (Invoice, Packing List, Contract).
Origin of goods: Clearly state the country or territory of manufacture in accordance with regulations on the origin of goods. - Information on the responsible party: The name or abbreviation of the manufacturer, exporter, or organization responsible for the goods in the foreign country.
Businesses need to physically inspect product labels before proceeding with import procedures. If the information on the label is inaccurate or incomplete, the shipment may be subject to penalties or face difficulties in undergoing specialized inspections and conformity declarations. For products with specific characteristics, businesses should proactively consult the Ministry of Science and Technology for specific guidance on labeling.
Conditions for the location where goods are brought in for storage.
While awaiting the completion of tax obligations or the results of specialized inspections, businesses may request to move goods to their own warehouses for storage. However, not all warehouses are approved; they must meet all the conditions stipulated by customs law.
Technical and legal requirements for storage facilities.
According to the guidelines in Official Letter 105/CHQ-GSQL, referencing Circular 39/2018/TT-BTC (amending Circular 38/2015/TT-BTC), the location for storing goods must meet the following conditions:
- Clearly defined location: The warehouse has a specific address, clearly shown on legal documents and management maps.
- Independence and isolation: The goods storage area must be separated by fences, partitions, or equivalent technical measures to ensure that goods are not illegally accessed while under customs supervision.
- Ensuring the integrity of goods: Warehouse conditions must be suitable for the characteristics of the goods (temperature, humidity, etc.) and ensure that the quantity, quality, and customs seals remain intact.
- Valid legal documentation: Businesses must prove their legal right to use the warehouse through a warehouse lease agreement, land use right certificate, or valid building ownership certificate.
Several risks often arise.
In practice, many applications to bring goods into storage are rejected due to common reasons such as:
- The warehouse does not meet the requirements for separation and does not ensure isolation.
- The warehouse lease agreement has expired or is not in the name of the importing legal entity.
- The warehouse information is inconsistent with the customs registration documents.
To minimize risks, before submitting documents, businesses should directly consult with the Customs Sub-department where the procedures are being carried out to receive guidance or conduct an on-site inspection of the warehouse if necessary. This helps avoid situations where goods have arrived at the port but are not allowed to be moved to the warehouse, leading to additional container and storage fees.
Recommendations aimed at improving compliance levels for businesses.
Strict adherence to the guidelines in Official Letter 105/CHQ-GSQL not only facilitates customs clearance but also contributes to building a strong long-term compliance record.
Control from the contract signing stage
Businesses should clearly specify the requirement for original labels in the sales contract or order form, and also require foreign partners to provide images of the actual labels before shipment to allow for timely corrections if any errors occur.
Monitoring and updating legal policies
Business documents that need to be regularly updated include:
- Decree 111/2021/ND-CP: Detailed regulations on product labeling and cases where labeling is exempted.
- Circular 39/2018/TT-BTC: Guidance on customs procedures and conditions for bringing goods into storage.
Proactive coordination with Customs authorities and specialized management agencies will help businesses operate their import chains safely, legally, and cost-effectively in 2026 and subsequent years.
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Content production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Source: Official document No. 105/CHQ-GSQL Circular dated January 6, 2026, from the Customs Department on guidelines for affixing import stamps and storing goods in warehouses.
MAN Editorial Board – Master Accountant Network
