- Circular 86/2026 and Decree 252/2026 Effective from July 1, 2026: Five Key Changes Directly Impacting FDI Manufacturers Engaged in Import and Export – What You Need to Do Now
- Change 1: New Customs Office Codes – Mandatory from July 1 with No Transition Period
- Change 2: Transaction-Based Tax Declarations Become More Comprehensive, Covering Additional Tax Categories
- Change 3: Tax Exemption, Reduction and Refund Procedures Fully Shift to Digital Processing
- Change 4: Decree 252/2026 – New Tax Enforcement Measures and Clearer Enforcement Thresholds
- Change 5: Circular 86 Introduces Re-inspection Procedures When Signs of Violations Are Identified
- Additional Update: From 01/09/2026 – Four Categories of Taxpayers Will Be Subject to Enhanced Monitoring
- Customs Compliance Checklist Under the New Regulations – July 2026
- Conclusion
- Need Support Updating Your Customs Compliance Process?
Circular 86/2026 and Decree 252/2026 Effective from July 1, 2026: Five Key Changes Directly Impacting FDI Manufacturers Engaged in Import and Export – What You Need to Do Now
Import & Export Regulatory Update – Effective from July 1, 2026
July 1, 2026 is not just another ordinary day in the operational calendar of FDI manufacturers. It marks the date on which more than 200 legal documents simultaneously take effect. Among them, the three regulations with the most direct impact on daily import-export operations are Circular 86/2026/TT-BTC on tax administration for imported and exported goods, Decree 252/2026/NĐ-CP on tax enforcement measures and tax debt management, and Circular 84/2026/TT-BTC on VAT refunds.
The Customs Department has confirmed that these new regulations are designed with taxpayers at the center, promoting digital transformation, strengthening data connectivity and information sharing between tax and customs authorities, while reducing documentation requirements and simplifying procedures related to tax declaration, tax payment, tax refunds, tax exemptions, and tax reductions.
From a long-term perspective, these reforms are positive—fewer administrative procedures, greater digitalization, and better data integration. However, in the short term, every regulatory change requires businesses to update their internal processes before they can benefit from these improvements. For FDI manufacturers processing dozens or even hundreds of customs declarations each month, continuing to operate under outdated procedures after the regulations have changed creates measurable risks—administrative penalties, rejected customs declarations, and extended customs clearance times.
Below is a detailed analysis of the five most significant changes and the practical actions businesses should take.
Change 1: New Customs Office Codes – Mandatory from July 1 with No Transition Period
This is a technical change but one with immediate operational impact and no exceptions. From July 1, 2026, all new customs declarations must use the new customs office codes. Previous codes will no longer be accepted. Businesses must immediately update their customs declaration software, customs branch and checkpoint codes, tax payment accounts, tax refund accounts, and guarantee information.
There is no transition period and no mechanism allowing the old and new codes to be used simultaneously. Any declaration submitted using the previous customs office codes after July 1 will be rejected by the system and must be re-submitted from the beginning.
Why Are FDI Manufacturers More Vulnerable Than Domestic Enterprises?
Many FDI manufacturers operate internal ERP systems (SAP, Oracle, or group-developed platforms) in which customs office codes are hardcoded and cannot automatically synchronize with updates issued by the General Department of Vietnam Customs. Updating these systems requires coordination with the IT department or software vendors and may take anywhere from several days to several weeks, depending on the system architecture. If this has not yet been completed, it should be treated as an urgent priority this week.
What You Should Do
Immediately verify whether your customs declaration system (whether an internal platform or one managed by your freight forwarder) has already been updated with the new customs office codes. If customs declarations are handled by a freight forwarder, obtain written confirmation that their system has been updated and that all declarations submitted from July 1 onward use the new customs office codes.
Change 2: Transaction-Based Tax Declarations Become More Comprehensive, Covering Additional Tax Categories
Under Circular 86/2026/TT-BTC, tax declarations for imported and exported goods submitted on a transaction-by-transaction basis now include export duty, import duty, safeguard duty, anti-dumping duty, countervailing duty, special consumption tax, environmental protection tax, and value-added tax (VAT).
The key implication for FDI manufacturers is that the list of taxes required for each transaction has been expanded and more clearly regulated than before. This is particularly significant for manufacturers importing goods subject to multiple taxes simultaneously—for example, consumer electronics that are subject to both import duty and special consumption tax, or products imported from countries currently subject to anti-dumping duties in Vietnam.
Practical Risk
Existing customs declaration templates may not contain sufficient data fields for all tax categories required under the new regulations. As a result, businesses may unintentionally omit required information and subsequently need to submit supplementary declarations. Such errors may be subject to administrative penalties under Decree 169/2026 on customs administrative violations.
What You Should Do
Review your standard customs declaration templates, particularly for imported goods subject to multiple taxes. If customs declarations are outsourced to a licensed customs broker or freight forwarder, confirm that they have already updated their declaration templates in accordance with Circular 86.
Change 3: Tax Exemption, Reduction and Refund Procedures Fully Shift to Digital Processing
Under Circular 86/2026, tax dossiers are primarily processed electronically through the Customs Data Processing System. Procedures relating to tax exemption, tax reduction, tax refunds, tax payment extensions, overpaid tax settlement, post-refund inspections, and inspections on the use of duty-exempt goods have also been digitized, while many unnecessary administrative procedures have been removed.
This change brings both opportunities and challenges. On the positive side, it reduces paper-based documentation and shortens processing time. However, it also requires FDI manufacturers to establish a complete electronic document management system and be capable of submitting documents electronically through the Customs system instead of relying on hard-copy submissions.
Key Impact on FDI Manufacturers
The most significant impact applies to FDI manufacturers importing duty-exempt machinery and equipment as fixed assets under investment projects. Inspections on the use of duty-exempt goods are now conducted through digital systems, enabling Customs authorities to access and cross-check data much more efficiently. Companies without a well-organized electronic archive for duty exemption documentation or the ability to retrieve supporting records quickly may face considerable challenges during Customs inspections.
In addition, Decree 252/2026 stipulates that tax refund applications subject to pre-refund inspection must be resolved within 10 working days from the date Customs issues its inspection conclusion. While this provides businesses with a clear processing timeline, companies must ensure that complete electronic documentation is submitted from the outset in order to benefit from this commitment.
Action Required
Review your company’s internal document management system. Verify whether all customs declarations, duty exemption documents, and tax refund files are stored electronically and can be submitted through the Customs electronic system.
If your company is still relying primarily on paper-based records, now is the time to digitize all documentation and establish a standardized electronic document management process during Q3/2026.
Change 4: Decree 252/2026 – New Tax Enforcement Measures and Clearer Enforcement Thresholds
Decree 252/2026/NĐ-CP introduces several noteworthy provisions, including shorter processing times for lifting exit suspension measures for taxpayers who have fulfilled their tax obligations, as well as expanded conditions for lifting exit suspension where tax payment data has not yet been updated in the system.
One of the most significant changes for FDI manufacturers is the introduction of tax debt thresholds before enforcement measures apply. Tax authorities will not initiate enforcement procedures for organizations with tax debts below VND 3 million, or for individuals and household businesses with tax debts below VND 1 million. This helps businesses avoid enforcement actions resulting from insignificant outstanding balances caused by system errors or delayed data synchronization.
A New Enforcement Measure Introduced
More importantly, Decree 252 introduces a completely new tax enforcement mechanism for the first time. Authorities are now permitted to file a petition requesting bankruptcy proceedings against enterprises that continue to evade tax payment after other enforcement measures have failed to recover outstanding tax debts.
For FDI manufacturers, this means that prolonged customs tax liabilities—including import duty and import VAT—may no longer result only in late payment penalties. In extreme situations, they may ultimately lead to bankruptcy proceedings, creating serious legal and reputational consequences.
The Decree also clarifies the transfer of tax obligations when enterprises change their legal form and introduces mechanisms for reinstating tax liabilities that were previously cancelled but later restored pursuant to court decisions. FDI enterprises undergoing restructuring or changes to their operating model should seek legal advice before implementing such changes.
Action Required
Immediately review your company’s outstanding customs tax liabilities, including import duty, import VAT, and any applicable special taxes. Any overdue tax balances should be settled during July before the new enforcement mechanisms are fully implemented. Businesses should also verify their current tax debt status through the Vietnam Customs online information portal.
Change 5: Circular 86 Introduces Re-inspection Procedures When Signs of Violations Are Identified
Circular 86 introduces new provisions allowing Customs authorities to conduct re-inspections where indications of violations have not been fully addressed, thereby strengthening regulatory oversight and helping prevent revenue losses to the State budget.
This provision expands the legal basis for Customs authorities to conduct post-clearance audits or re-inspections of customs declarations that have already been cleared but subsequently show signs of violations that were not previously detected or fully handled.
Combined with Customs’ statutory authority to conduct post-clearance audits within a five-year period under the Customs Law, this means that customs declarations filed during the previous five years may all become subject to re-inspection whenever Customs has sufficient legal grounds.
Highest-Risk Areas for FDI Manufacturers
The greatest exposure typically involves declarations containing complex HS classifications, customs valuation based on related-party transactions, or preferential Certificates of Origin (C/O). As discussed in previous analyses regarding post-clearance audits, these remain the three areas most frequently targeted by Customs authorities during inspections.
Action Required
Although this is not an action that must be completed within a single week, it should be incorporated into your Q3/2026 compliance plan. Conduct an internal review of customs documentation dating back to 2023, focusing on high-value declarations, newly classified HS codes, and shipments claiming preferential Certificates of Origin. Where discrepancies are identified, businesses should proactively submit amended declarations before Customs discovers the issues through an inspection, thereby benefiting from more favorable treatment under the applicable regulations.
Additional Update: From 01/09/2026 – Four Categories of Taxpayers Will Be Subject to Enhanced Monitoring
According to the latest information released on 17/07/2026, from 01/09/2026, four additional categories of taxpayers will be placed under enhanced supervision by the tax and customs authorities.
Although detailed implementation guidance is still being updated, this is an important development that FDI manufacturers should closely monitor throughout August to determine whether their business falls within any of the monitored categories and what preparations should be completed before 01/09/2026.
Customs Compliance Checklist Under the New Regulations – July 2026
Actions to Complete This Week
- Confirm that your customs declaration system (internal software or through your freight forwarder) has been updated with the new Customs authority codes. If declarations are submitted through a third party, request written confirmation from your freight forwarder or customs broker.
- Check your current customs tax debt status through the Vietnam Customs online information portal. If any overdue tax liabilities exist, settle them immediately this week.
- Notify the Accounting and Finance Department of the complete list of taxes required to be declared under Circular 86 to ensure internal invoice templates and supporting documentation comply with the new requirements.
Actions to Complete During July
- Review your standard customs declaration templates to ensure they contain sufficient information for all tax types required under Circular 86, particularly for products subject to multiple taxes simultaneously.
- Review your internal document management system to verify that customs declarations, duty exemption documents, and tax refund files are stored electronically and are ready for submission through the Customs electronic system.
- For manufacturers importing duty-exempt machinery and equipment as fixed assets, verify the list of duty-exempt assets, their actual usage status, and all supporting documentation.
- Seek legal advice if your company is undergoing restructuring or changing its business model, as the new provisions governing the transfer of tax obligations during corporate restructuring should be clearly understood before implementation.
Actions to Include in the Q3/2026 Compliance Plan
- Conduct an internal review of customs documentation covering the period from 2023–2026, focusing on high-value customs declarations, products with HS code classification risks, and declarations using preferential Certificates of Origin (C/O).
- Establish a standardized digital customs document management process if one is not already in place, prioritizing duty exemption and tax refund documentation.
- Closely monitor further guidance regarding the four enhanced monitoring taxpayer categories effective from 01/09/2026 in order to assess potential compliance risks and prepare accordingly.
- Update internal training materials for Import & Export personnel regarding the new regulations, particularly tax declaration requirements for each occurrence and the electronic submission procedures.
Conclusion
The legal changes taking effect from 01/07/2026 represent one of the most significant regulatory updates in recent years. However, the overall direction is clear: greater digitalization, stronger data integration between government agencies, and enhanced compliance supervision.
FDI manufacturers that update their internal processes promptly and correctly will benefit from faster customs clearance procedures and fewer paper-based administrative requirements. Companies that continue operating under outdated procedures may face rejected customs declarations, declaration penalties, and customs clearance delays—precisely when they are preparing for the year-end export peak season.
Need Support Updating Your Customs Compliance Process?
THT Cargo Logistics supports FDI manufacturers in reviewing customs declaration procedures under the latest regulations, verifying that declaration systems have been updated correctly and completely, and providing practical solutions for issues arising during the transition period.
If your factory would like a compliance assessment tailored to your import and export operations, contact THT Cargo Logistics for professional support.
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