Temporary import for re-export via a bonded warehouse lets foreign goods enter Vietnamese territory, rest in a warehouse under customs supervision, then leave again without becoming imports. The regime’s value is the suspended tax duty, and its price is deadline discipline: once the re-export deadline passes, the suspended duty turns into tax recovery, penalties and a shipment that has lost its lawful way out.
Declarations and the procedure flow through the bonded warehouse
Temporary import and re-export under Article 39 of the Law on Foreign Trade Management No. 05/2017/QH14 operates on licensing or conditions by managed goods list, and the entire process sits under customs supervision under the Customs Law 54/2014/QH13. The trader opens an electronic customs declaration for the temporary import for re-export type under Decree 08/2015/ND-CP, declaring the goods as temporarily imported for re-export; once the goods enter the bonded warehouse, they remain under customs supervision in the warehouse — the warehouse operator manages them and reports goods status to customs under Article 63 of the Customs Law — and on removal for re-export, the trader completes the export procedure matching the original temporary import declaration to close the supervision loop.
Two operating conditions decide whether a shipment completes the loop: first, goods in a bonded warehouse may undergo only preservation, sorting, repacking and permitted warehouse services — they may not enter domestic consumption before a type conversion and tax payment; second, the goods records must reconcile across the temporary import declaration, the bonded warehouse operator’s warehouse ledger, and the re-export declaration, because every discrepancy in quantity or type is handled at declaration-closure reconciliation.
The re-export deadline and tax duty at temporary import
Goods deposited in a bonded warehouse may be stored for no more than 12 months from the deposit date under Article 61 of the Customs Law 54/2014/QH13; where there is a legitimate reason, the Director of the Customs Department managing the warehouse may extend once by no more than 12 more months. A trader therefore has a maximum total window of 24 months per deposited shipment, but the window does not open fully by default: the extension must be approved before the original deadline expires, and temporary import goods must also observe the deadline of the re-export regime attaching to each shipment under foreign trade management rules — two deadline layers run in parallel and whichever expires first binds first.
On tax, temporary imports for re-export enjoy conditional import duty exemption under export and import duty law: the duty is suspended while the goods stay properly within the regime and becomes fully recoverable (import duty and import-stage VAT) if the goods are not re-exported on time or are diverted to domestic consumption. The enterprise pays no tax at temporary import, but must manage the shipment as a suspended tax liability — including where customs requires the tax duty to be secured by a guarantee or a cash deposit in particular cases as regulated.
Overstaying the deadline: handling and penalties under Decree 169/2026
Once overdue with goods not yet re-exported, the trader keeps only lawful exits: seek extension if still within the extendable frame; convert the type to bring the goods into the domestic market with full tax paid as ordinary imports; re-export urgently before customs imposes handling; or destroy the goods under customs supervision if they no longer have usable value. Leaving goods dead in the warehouse after every deadline has passed is the worst option, because overdue goods become subject to customs handling under the Customs Law while the owner still bears all tax duties and accrued storage fees.
On penalties, from 1 July 2026 the applicable frame is Decree 169/2026/ND-CP (replacing Decree 128/2020/ND-CP). The conduct must be correctly characterised: cases falling in the no-penalty tier under Clause 2, Article 7 of that Decree are not fined; false declaration causing a tax shortfall is fined at rates on the shortfall under Article 10 (10% in Clause 2, 20% in Clause 3 depending on nature), and Clause 6 of Article 10 specifically limits those fines to cases where the tax discrepancy reaches from VND 500,000 per declaration for individuals, or from VND 2,000,000 for organisations — below these reaching-from thresholds, the percentage fines of Article 10 do not apply. Deliberately failing to re-export in order to consume the goods while evading tax can be treated at the tax-evasion tier of Article 15 of the Decree and, at serious levels, under criminal law on smuggling and tax evasion.
Frequently asked questions
How must a customs declaration be filed for temporarily imported goods for re-export?
Open an electronic customs declaration for the temporary import for re-export type under Decree 08/2015/ND-CP, on the regime basis of Article 39 of the Law on Foreign Trade Management 05/2017/QH14; goods in the bonded warehouse remain under customs supervision, with the warehouse operator reporting goods status under Article 63 of the Customs Law 54/2014/QH13; on re-export, complete the matching export procedure to close the temporary import declaration. Warehouse goods may only be preserved, sorted and repacked — no domestic consumption before type conversion and tax payment.
What is the maximum re-export deadline?
Bonded warehouse storage is capped at 12 months, extendable once by up to 12 more months under Article 61 of the Customs Law 54/2014/QH13 (a maximum window of 24 months if extended before expiry), and the shipment’s own temporary import regime deadline also applies — whichever layer expires first binds first.
How is failure to re-export on time handled?
Overdue goods keep only these exits: extension if still available; type conversion into the domestic market with full tax; urgent re-export before imposed handling; or destruction under customs supervision. Penalties follow Decree 169/2026/ND-CP: cases in the no-penalty tier of Clause 2, Article 7 are not fined; false declarations causing tax shortfalls are fined 10%/20% of the shortfall under Article 10, but Clause 6 of Article 10 applies those fines only where the discrepancy reaches from VND 500,000 per declaration (individuals) or VND 2,000,000 (organisations); tax evasion is handled at Article 15.
Must tax be paid on temporary import?
No tax is payable at temporary import: the goods enjoy conditional import duty exemption, the duty is suspended, and it becomes fully recoverable (import duty plus import-stage VAT) if the goods are not re-exported on time or are diverted to domestic consumption.
This article has been quality-reviewed by the FLAW AI Legal Council