Certificate of Origin (C/O) in Vietnam: Forms, Rules of Origin and Filing

A certificate of origin (C/O) proves where goods were made. For Vietnamese exporters, a valid preferential C/O is often worth more than any freight saving, because it lets the buyer import at a reduced or zero duty rate under a free trade agreement (FTA). For importers into Vietnam, the right C/O can cut landed cost substantially. This guide explains the forms Vietnam uses, the basics of rules of origin, how C/Os are issued through eCoSys and the most common reasons customs reject them.

Preferential and non-preferential C/O

A preferential C/O is issued under an FTA and allows the importing country to apply the agreement’s preferential tariff, provided the goods meet that agreement’s rules of origin and the formal requirements. A non-preferential C/O, issued in Vietnam as Form B, simply certifies origin for purposes such as buyer requirements, quotas, labelling or trade remedy measures; it does not reduce duty. In Vietnam, origin rules are set out mainly in Decree 31/2018/ND-CP and the circulars of the Ministry of Industry and Trade (MoIT) implementing each FTA.

C/O forms used by Vietnam

When goods qualify under more than one agreement, for example Form E and Form RCEP for China, or Form AK and Form VK for Korea, the exporter and buyer should compare the preferential tariff for the specific HS code under each agreement and the ease of meeting each rule of origin. The lower duty is not always under the newest agreement.

Self-certification under CPTPP and EVFTA

CPTPP allows origin to be certified by the exporter or producer, and by the importer where a party has implemented that option, in a document that need not follow a fixed format but must contain the minimum data elements set out in the agreement. Vietnam issues Form CPTPP through the MoIT and also applies self-certification under MoIT rules. Under EVFTA, Vietnamese exports to the EU are mainly covered by an EUR.1 issued by the MoIT, while consignments with a total value not exceeding EUR 6,000 can be covered by an origin declaration made by any exporter; the agreement provides for Vietnam to move to self-certification through the EU’s REX system once it notifies application. EU exporters shipping to Vietnam make an origin declaration on the invoice or another commercial document, and must be registered in REX when the consignment exceeds EUR 6,000. UKVFTA mirrors these arrangements for the United Kingdom.

Rules of origin basics

Each FTA defines when goods are originating. The main criteria are:

• WO (wholly obtained): goods entirely grown, harvested, mined, caught or born and raised in the exporting country, such as fresh fruit or fish caught by a national vessel.
• RVC (regional value content): the value added in the FTA region must reach a threshold, commonly 40 percent of the FOB value under ATIGA, ACFTA, AKFTA and AANZFTA. AIFTA uses 35 percent combined with a change of subheading.
• CTC (change in tariff classification): non-originating materials must change classification during production, at chapter level (CC), heading level (CTH, four digits) or subheading level (CTSH, six digits).
• SP (specific process): certain products, especially textiles and chemicals, must undergo a defined process, such as fabric-forward rules for garments under EVFTA and CPTPP.
• PE (produced entirely): goods made in the territory exclusively from originating materials.

Under the build-down method used in ASEAN agreements, RVC = (FOB value − value of non-originating materials) ÷ FOB value × 100 percent. The build-up method adds up originating materials, labour, overheads and profit instead. Product-specific rules (PSR) in each agreement decide which criterion applies to which HS code, and for many products the exporter can choose between RVC and CTH.

Three further concepts matter. De minimis allows a small share of non-originating materials that do not meet the CTC rule, typically 10 percent of FOB value under ATIGA or of ex-works price under EVFTA, with specific rules for textiles. Cumulation allows materials originating in other FTA parties to count as local. Minimal operations, such as simple packing, labelling, mixing or cutting, never confer origin on their own. Most agreements also require direct consignment, or proof that goods passing through a third country stayed under customs control.

Origin is determined by HS code. A wrong classification can lead to the wrong product-specific rule, and therefore a C/O that is invalid even if the production really took place in Vietnam.

Applying for a C/O on eCoSys

1. Register a trader profile with the MoIT the first time, including business registration, authorised signatories and seal specimens.
2. Prepare the origin file: commercial invoice, export customs declaration, bill of lading or other transport document, bill of materials and origin calculation, and evidence of origin for inputs such as supplier declarations or purchase invoices.
3. Submit the application and draft C/O on eCoSys, the MoIT’s electronic origin system, and choose the issuing office.
4. Respond to any queries or requests for factory inspection; the issuing office may verify production capacity for new products.
5. Receive the signed C/O, or an electronic C/O for partners that exchange data electronically, such as ASEAN through the ASEAN Single Window, and send it to the buyer.

Before submitting, check that the HS code on the draft C/O matches the export declaration at the level required by the agreement, that the origin criterion box uses the agreement’s exact code (for example WO, RVC 40%, CTH or PE), and that the consignee and port of discharge match the bill of lading. Agree with the buyer in advance whether a paper original, an electronic C/O or a self-certified declaration will be accepted by their customs.

Back-to-back C/O and third-country invoicing

A back-to-back C/O, also called a movement certificate, is issued by an intermediate FTA party based on the original C/O when goods are re-exported to another party without further processing, for example goods from Thailand stored in a Vietnamese bonded warehouse and then shipped to the Philippines. Third-country invoicing applies when the invoice is issued by a company in a non-party, such as a Singapore or Hong Kong trading company for some agreements; the relevant box must be ticked and the invoice details shown as the agreement requires.

Common reasons for rejection

• Description, HS code, quantity or invoice number on the C/O does not match the invoice or customs declaration.
• Wrong origin criterion or HS code classified differently by the importing customs.
• Missing or unrecognised signature or seal, or an unauthorised amendment.
• C/O presented after its validity period, or issued after shipment without the retroactive box marked where the agreement requires it.
• No proof of direct consignment when goods transited a third country.
• FOB value missing when the RVC criterion is used, where the form requires it.
• Inconsistent consignor, consignee or third-party invoicing information.

If the importing customs doubts a C/O, it may request verification from the issuing authority, which can take months and may lead to preferential duty being refused. Keeping a complete origin file for each shipment, for the period required by the agreement and Vietnamese law, is the best defence. GLG’s customs team can review origin files and draft C/O applications before submission.

Frequently asked questions

Which C/O should I use for exports to Korea?

Usually Form AK or Form VK, and in some cases RCEP. Compare the preferential tariff for your HS code and the rule of origin under each agreement before choosing.

Does a Form B reduce import duty?

No. Form B is a non-preferential certificate that only confirms origin; preferential duty requires a C/O or origin declaration under an FTA.

What does RVC 40% mean?

At least 40 percent of the product’s FOB value must come from originating materials and processing in the FTA region, calculated by the method set out in the agreement.

Can a C/O be issued after the goods have shipped?

Yes under most agreements, but it may need to be marked as issued retroactively and must still be presented within the validity period.

This content is for general guidance and does not replace legal or banking advice for a specific transaction.