Vietnam Removes Mandatory Energy Labeling for Commercial Kitchen Appliances

Vietnam’s Ministry of Industry and Trade (MOIT) issued Decision No. 38/QĐ-BCT on May 10, 2026, removing mandatory energy labeling and third-party energy efficiency testing requirements for imported commercial kitchen appliances (HS code 8516.60). The change affects exporters, importers, and compliance service providers in the commercial kitchen equipment sector — particularly those sourcing from China — and is notable for its immediate operational impact on customs clearance and compliance cost structure.

Event Overview

On May 10, 2026, Vietnam’s Ministry of Industry and Trade (MOIT) published Decision No. 38/QĐ-BCT, officially取消 (removing) the mandatory energy label requirement and associated third-party energy efficiency testing for commercial kitchen appliances classified under HS code 8516.60. The decision retains only the basic safety certification requirement under National Technical Regulation QCVN 4:2020/BKHCN. The measure entered into force immediately upon publication.

Industries Affected

Direct Trading Enterprises (Importers/Exporters)

These entities are directly impacted because the removal eliminates two compliance steps previously required before customs release: affixing the official energy label and submitting test reports from accredited laboratories. As a result, documentation preparation time and customs coordination effort are reduced.

Manufacturing Enterprises (OEM/ODM Producers)

Manufacturers supplying commercial kitchen appliances to the Vietnamese market no longer need to allocate resources for energy efficiency testing or label design and printing aligned with MOIT specifications. However, they remain responsible for meeting QCVN 4:2020/BKHCN safety standards — including factory audits, technical file submission, and certified product marking.

Supply Chain & Compliance Service Providers

Third-party testing labs and local representative offices that previously supported energy label applications face reduced demand for those specific services. Their service portfolios may need adjustment toward safety certification support, document verification, or post-clearance surveillance — all still required under current rules.

Key Considerations and Recommended Actions

Monitor Official Implementation Guidance

While Decision No. 38/QĐ-BCT is effective immediately, MOIT or Vietnam Customs may issue supplementary notices clarifying label removal scope (e.g., whether existing stock with labels must be relabeled or exempted). Importers should track updates via MOIT’s official portal and licensed customs brokers.

Verify Applicability Against HS Code 8516.60

The exemption applies strictly to products under HS 8516.60 (‘other electro-thermic appliances for cooking or heating food’ used commercially). Products falling outside this code — such as refrigerated prep tables (HS 8418), dishwashers (HS 8422), or ventilation hoods (HS 8414) — remain subject to their respective regulatory requirements. Classification accuracy remains critical.

Distinguish Between Policy Change and Operational Readiness

Although the regulation changed on May 10, 2026, customs officers at ports may require time to update internal checklists or digital systems. Traders should confirm label-related fields are no longer flagged in VNACCS/VCIS declarations and retain written confirmation from their customs broker for audit traceability.

Adjust Cost and Timeline Assumptions for Future Shipments

Based on MOIT’s announcement, the removal is expected to shorten average customs clearance by 3–5 working days and reduce per-container compliance costs by approximately USD 180. Exporters and logistics planners should revise lead-time forecasts and budget templates accordingly — but only for shipments cleared after May 10, 2026, and confirmed as HS 8516.60.

Editorial Observation / Industry Perspective

Observably, this decision reflects Vietnam’s broader trend of streamlining non-tariff barriers for priority import categories — especially where overlapping regulatory requirements create redundant verification layers. Analysis shows the move does not relax safety oversight; rather, it removes an energy efficiency layer that had limited enforcement history and low correlation with actual usage patterns in commercial kitchens. From an industry perspective, it is best understood not as a broad deregulatory shift, but as a targeted administrative simplification — one that signals MOIT’s willingness to revise technical regulations based on implementation feedback. Continued attention is warranted, as similar reviews may follow for other appliance categories under MOIT’s 2025–2027 regulatory review agenda.

This update marks a concrete reduction in procedural friction for commercial kitchen appliance trade with Vietnam — not a relaxation of core safety obligations. For affected stakeholders, the most pragmatic interpretation is that compliance focus should now shift more decisively toward QCVN 4:2020/BKHCN readiness, while treating energy labeling as a discontinued requirement — unless explicitly reinstated in future MOIT guidance.

Source: Vietnam Ministry of Industry and Trade (MOIT), Decision No. 38/QĐ-BCT, issued May 10, 2026.
Note: Ongoing observation is recommended for any subsequent circulars or customs directives clarifying transitional treatment of shipments declared before May 10, 2026.