Guidance on Determining the Origin of Semi-Finished Products Self-Manufactured by Enterprises

On 01 September 2026, the Import-Export Department issued Official Letter No. 1163/XNK-XXHH to provide detailed guidance on the determination of origin, supporting documents and the origin cumulation rule for semi-finished products in the export production chain.

The details are as follows:

1. Determination of origin for lead plates (HS code 8507.90.19)

  • Non-preferential rules: Apply the “LVC 30% or CTH” criterion prescribed in Appendix I of Circular 44/2023/TT-BCT. The production process must go beyond the “simple processing operations” under Article 9 of Decree 31/2018/ND-CP.
  • Preferential rules (EVFTA): Pursuant to Appendix II of Circular 14/2026/TT-BCT, the specific rule for code ex Chapter 85 is “Manufacture from materials of any Heading, except that of the product; or Manufacture in which the value of all the materials used does not exceed 70% of the ex-works price of the product”. The processing must also satisfy the requirement of going beyond simple processing under Article 10 of Circular 14/2026/TT-BCT.

2. Documents proving the origin of self-manufactured materials

For lead plates manufactured domestically and used in the subsequent stage to make storage batteries, an enterprise applying for a C/O must provide the Declaration and Undertaking of Origin of Goods using the form in Appendix X attached to Circular 05/2018/TT-BCT in order to complete the C/O application dossier as prescribed.

3. Cumulation of originating materials

The cumulation of originating materials for non-preferential C/O (Form B) is carried out in accordance with Decree 31/2018/ND-CP, Circular 05/2018/TT-BCT and Circular 44/2023/TT-BCT.

For preferential C/O, it is carried out in accordance with the corresponding FTAs to which Vietnam is a party.

(Pursuant to Official Letter No. 1163/XNK-XXHH dated 01 September 2026)

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