Effective from July 1, 2026, Circular No. 36/2026/TT-BKHCN issued by the Ministry of Science and Technology introduces a list of medium-risk and high-risk products and goods under the Ministry’s management responsibility. This is an important matter for businesses involved in the manufacturing, importation and trading of electrical and electronic equipment to consider when complying with product quality requirements, conformity certification and declaration of conformity.

1. A One-Size-Fits-All Approach Should Not Be Applied to All Electrical and Electronic Equipment

QCVN 4:2009/BKHCN specifies safety requirements for electrical and electronic equipment included in the list prescribed by the technical regulation. This regulation is currently still recorded as being in force in the national standards database.

However, when determining their product quality management obligations, businesses should not rely solely on the commercial names of products. They need to accurately cross-check the product category, intended use, technical specifications, HS code and the product list issued together with relevant legal documents.

Circular No. 36/2026/TT-BKHCN classifies goods according to their risk levels. Therefore, even within the same category of electrical and electronic equipment, individual products may be subject to different management requirements and compliance procedures.

2. What Should Businesses Pay Attention To?

First, businesses need to determine whether their products fall within the scope of the management list under QCVN 4:2009/BKHCN and its relevant amendments.

Next, they should consult the list under Circular No. 36/2026/TT-BKHCN to identify the applicable risk level, HS code and corresponding conformity assessment requirements. Certain specified products may be subject to conformity assessment methods under Circular No. 14/2026/TT-BKHCN. Businesses should check the exact product entry in the relevant appendix rather than applying a single assessment method to the entire list.

For imported goods classified as high-risk products, importing organizations and individuals are required to register for quality inspection in accordance with regulations through the National Single Window Portal or the National Public Service Portal.

For imported goods classified as medium-risk products, according to the implementation guidance for Circular No. 36/2026/TT-BKHCN, businesses are not required to undergo quality inspection at the import stage. However, they must still complete the declaration of conformity with the relevant technical regulation before placing the goods on the market.

Four Steps Businesses Should Take

Step 1: Accurately identify the product. Review the product name, intended use, structure, technical specifications and HS code. Do not rely solely on the commercial name stated in contracts or catalogues.

Step 2: Cross-check the applicable technical regulations and management lists. Review QCVN 4:2009/BKHCN, its relevant amendments and the appendices to Circular No. 36/2026/TT-BKHCN.

Step 3: Determine the applicable conformity assessment method. Based on the product's risk category and specific requirements, determine whether testing, certification, self-assessment or declaration of conformity is required under the applicable regulations.

Step 4: Complete the documentation before placing products on the market. Prepare technical documentation, conformity assessment results, quality documents and declaration of conformity dossiers in accordance with the relevant requirements.

3. Choosing a Conformity Assessment Body: Verify Its Scope of Authorization

When selecting a conformity assessment body, businesses should verify its accredited or designated scope, product categories, applicable technical regulations and the validity of relevant designation decisions. They should not rely solely on promotional information or service names displayed on a website.

Keeping up to date with regulatory changes will help businesses minimize risks relating to documentation, import schedules and the circulation of goods, while enabling them to take a more proactive approach to product quality management.

If your company requires conformity assessment and certification under QCVN 4:2009/BKHCN, please contact ISSQ Quality Institute via hotline: +84 981851111 or email: vienchatluong@issq.org.vn | tcvn@issq.org.vn for assistance with the relevant procedures.