On July 29, 2026, the Ministry of Industry and Trade (MOIT) issued Circular No. 42/2026/TT-BCT, promulgating the Detailed List of Dual-Use Goods under the Management Authority of the Ministry of Industry and Trade. According to the Circular, it will take effect on September 12, 2026.
The issuance of this list aims to standardize the management of goods that may be used for both civilian and special purposes. It also enables businesses to be more proactive in customs declaration, licensing procedures, and compliance with Vietnamese regulations.
For import-export enterprises, this is an important legal document that should be reviewed before the Circular takes effect in order to minimize customs clearance risks and ensure regulatory compliance.
What Are Dual-Use Goods?
Dual-use goods are products, materials, equipment, or technologies that are intended for civilian use but can also be utilized for special or strategic purposes if left uncontrolled.
For this reason, these goods are subject to stricter government control than ordinary commodities, particularly in international trade, import, and export activities.
What Does Circular 42/2026/TT-BCT Regulate?
The Circular promulgates the Detailed List of Dual-Use Goods under the management authority of the Ministry of Industry and Trade, in accordance with Decree No. 259/2025/ND-CP on strategic trade control.
In addition to listing HS codes, each controlled item includes detailed information on:
- Technical specifications
- Technological conditions
- Identification criteria
- Reference ECCN (Export Control Classification Number)
These details help businesses accurately determine whether their products fall within the scope of management.
Important HS Code Application Principles
The Circular also specifies how HS codes should be interpreted within the List:
- If only a 4-digit HS code is listed, all 8-digit HS codes under that heading are covered.
- If only a 6-digit HS code is listed, all 8-digit HS codes under that subheading are included.
- If an 8-digit HS code is specifically listed, only that exact code falls within the scope of regulation.
- ECCN codes are provided as references for export control purposes.
Businesses should pay close attention to these principles to avoid HS code misclassification during customs procedures.
Key Categories of Dual-Use Goods
According to the Appendix of the Circular, dual-use goods cover various product categories.
1. Electronic Equipment
This category includes various high-performance electrical equipment such as:
- High-capacity DC power supplies
- High-voltage power supplies
- Frequency converters
- Specialized inverters and converters
These products are only subject to control if they simultaneously satisfy the technical specifications stipulated in the Circular.
2. Chemicals and Special Materials
The List also includes:
- High explosives
- Shaped explosives
- Detonating cords
- Electric detonators
- Certain high-purity chemicals
- Organometallic compounds
- Hydrides of phosphorus, arsenic, and antimony
- Synthetic underwater foams
For each product, the Circular clearly specifies applicable technical standards, purity requirements, and control conditions.
3. Special Metals and Alloys
A significant portion of the List consists of advanced engineering materials, including:
- Magnesium alloys
- Nickel alloys
- Titanium alloys
- Aluminum alloys
- Maraging steel
- Titanium-containing duplex stainless steel
- Tungsten
- Molybdenum
- Beryllium
- Hafnium
- Rhenium
- High-purity calcium and magnesium
These materials are subject to control only when they meet specified requirements regarding composition, strength, purity, or physical form.
4. Unmanned Aerial Vehicles (UAVs)
The Circular also includes certain unmanned aerial vehicles (UAVs) if they meet criteria related to:
- Beyond visual line-of-sight (BVLOS) operation capability
- Flight endurance
- Stable flight performance under strong wind conditions
Not all drones are regulated—only those meeting the technical specifications prescribed by the Circular.
What Should Import-Export Businesses Do?
To avoid customs clearance issues after September 12, 2026, businesses are advised to:
- Review all products currently being imported or exported.
- Verify HS codes and compare them with the Dual-Use Goods List.
- Assess product technical specifications rather than relying solely on product names.
- Prepare all required documentation if the goods fall under controlled categories.
- Consult logistics providers or customs specialists whenever the legal status of a product is uncertain.
Incorrect HS classification or failure to identify controlled goods may result in requests for additional documentation, customs clearance delays, and unexpected costs.
Songwin Supports Businesses with Import and Export Procedures
Regulations governing specialized goods are becoming increasingly detailed, requiring businesses to stay updated to ensure full legal compliance.
With extensive experience in customs declaration, import-export consulting, and international logistics services, Songwin International Logistics Vietnam provides comprehensive support, including:
- HS code classification and verification
- Assessment of whether goods fall under specialized management
- Pre-import and pre-export documentation consulting
- Fast and compliant customs clearance services
- Assistance in resolving customs-related issues during clearance
If your company plans to import electronic equipment, chemicals, special materials, or other products that may fall under the Dual-Use Goods List prescribed in Circular 42/2026/TT-BCT, contact Songwin for professional guidance from the document preparation stage onward, ensuring a smooth and efficient import-export process.
Songwin is always ready to accompany your business. Contact us today for professional consultation and support!
SONGWIN INTERNATIONAL LOGISTICS VIETNAM CO., LTD.
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