Vietnam Requires Bilingual RoHS/REACH for PCB Imports

Image placement plan: no images are required for this article. On June 3, 2026, Vietnam’s Ministry of Industry and Trade (MOIT) issued Circular No. 38/2026/TT-BCT, introducing a new compliance requirement for imported printed circuit boards. Starting September 1, 2026, imported PCB products will need to be accompanied by a manufacturer-signed bilingual Chinese-English RoHS and REACH declaration bearing an official seal, a change that directly affects PCB trade, manufacturing coordination, customs preparation, and shipment risk control.

Confirmed Regulatory Requirements

According to the provided event information, MOIT released Circular No. 38/2026/TT-BCT on June 3, 2026. The rule will take effect on September 1, 2026.

The requirement applies to all imported printed circuit boards, including HDI boards, flexible boards, and metal-core boards. For these goods, a bilingual Chinese-English declaration of conformity for RoHS and REACH must accompany the shipment. The declaration must be signed by the manufacturer and stamped with an official seal.

The provided information also states that non-compliant goods will be detained at Ho Chi Minh City Port and fined at 15% of cargo value.

How the Change May Affect Market Participants

Importers and trading companies

These companies are directly affected because the new rule is tied to import clearance and shipment documentation. The impact is likely to appear first in order confirmation, export document collection, pre-shipment review, and customs submission. What deserves closer attention is whether every shipment file includes a compliant bilingual declaration signed by the manufacturer and sealed before dispatch.

Raw material and component sourcing teams

Companies responsible for upstream sourcing may be affected because procurement decisions for PCB categories now connect more closely with documentary compliance. The effect may be seen in supplier selection, purchasing terms, and supply continuity planning. From an industry perspective, buyers may need to pay closer attention to whether suppliers can provide the required RoHS and REACH conformity statements in the exact bilingual format required for shipment support.

Processing and manufacturing businesses

Manufacturing businesses that rely on imported PCB inputs may face operational pressure if shipments are delayed or detained. The impact could extend to production scheduling, material readiness, engineering coordination, and delivery commitments. Analysis shows that the new requirement is not only a trade document issue, but also a production planning issue for manufacturers dependent on timely PCB arrivals.

Supply chain and logistics service providers

Logistics firms, customs support providers, and related supply chain service companies may also be affected because document completeness now becomes a more visible control point. The operational impact may emerge in booking preparation, document checking, customs coordination, and port-side exception handling. Observably, service providers may need stronger pre-alert review processes to reduce detention risk and avoid cost escalation linked to non-compliant paperwork.

What Companies Should Prioritize Now

Check declaration format before shipment

Businesses should focus on whether the RoHS and REACH declaration is bilingual in Chinese and English, whether it is signed by the manufacturer, and whether it bears the required official seal. This is a shipment-level compliance checkpoint directly connected to the stated detention and penalty risk.

Align supplier documentation responsibilities

Procurement and trade teams should clarify which party is responsible for preparing, signing, sealing, and delivering the conformity declaration with the goods. In practical terms, this may require updating purchase conditions, document checklists, and supplier communication procedures so that compliance paperwork is ready before dispatch.

Review lead time and delivery planning

Because the requirement takes effect on September 1, 2026, companies shipping affected PCB products should pay attention to timing around production release, export packing, and customs documentation. It is more appropriate to understand this as a delivery planning issue as well as a compliance issue, especially where material arrival dates are tightly linked to downstream production schedules.

Strengthen traceability and file retention

Companies may also need to improve retention of declarations, technical records, and shipment-linked compliance files for affected PCB categories. This is closely related to quality traceability, customs response readiness, and internal review efficiency if questions arise during import handling.

Industry Observation and Editorial View

Analysis shows that this measure may raise the practical compliance threshold for PCB imports into Vietnam, not because new technical substances or limits were described in the provided information, but because documentary form, language format, signature authority, and sealing requirements are now explicitly linked to import enforcement.

From an industry perspective, the rule may push manufacturers and exporters to treat compliance declarations as an operational deliverable rather than a secondary paperwork item. What deserves closer attention is the transition period before September 1, 2026, when suppliers, traders, and logistics teams may need to synchronize document templates and approval paths.

Observably, the rule may also increase the importance of document discipline across the PCB supply chain. Even where product compliance may already be managed internally, the import process could still face disruption if the required bilingual declaration is incomplete, unsigned, or unstamped. This suggests that execution quality, not only technical compliance, may become a key differentiator.

Closing Takeaway

The newly announced Vietnamese requirement places clear emphasis on shipment-accompanying RoHS and REACH conformity documentation for imported PCB products. Based on the provided information, the significance of this change lies in its direct connection to port detention and a 15% cargo-value fine for non-compliant goods. A measured conclusion is that affected businesses should treat the new rule as a concrete trade compliance requirement and prepare document workflows accordingly, while continuing to watch for further implementation details.

Source Note and Follow-up Points

This article was generated based on the user-provided news title, event date, and event summary. Relevant source types for developments of this kind usually include ministry circulars, customs notices, trade compliance updates, certification guidance, and import control documents. Specific official source links were not provided in the input and should be verified continuously.

Items that still merit ongoing observation include possible implementation details, interpretation standards for the declaration format, practical enforcement scope at import checkpoints, changes in procurement or tender documentation, and industry feedback after the rule takes effect.