Many traders still handle temporary import–re-export (TNTX) business out of habit: applying for a TNTX business code, depositing a security bond, and checking the three conditional product groups under Decree 69/2018/ND-CP. Since 05/9/2026, this legal framework has fundamentally changed: the business-code and security-deposit regime has been fully abolished, and Decree 69/2018 has been replaced by Decree 292/2026/ND-CP. This article updates the new legal milestones so businesses do not apply expired rules by mistake.
New legal milestones: before and after 05/9/2026
- 01/7/2026: all previously issued TNTX business codes expired; traders may withdraw the full security deposit from the credit institution (Article 64 of Decree 292/2026/ND-CP).
- 05/9/2026: Decree 292/2026/ND-CP (dated 22/7/2026) entirely replaces Decree 69/2018/ND-CP on foreign trade management (Article 65). All current TNTX business lists and conditions are found in Decree 292/2026, no longer in Decree 69/2018.
- 31/12/2026: guiding documents of Decree 69/2018 remain applicable until this date (unless otherwise provided) — Clause 4, Article 64 of Decree 292/2026/ND-CP.
Abolition of TNTX business codes and deposits
The regime of TNTX business codes and security deposits — previously applied to frozen foodstuffs, used goods and goods subject to special consumption tax under Article 15 of Decree 69/2018/ND-CP and Circular 12/2018/TT-BCT — has been fully abolished. Circular 12/2018/TT-BCT no longer has a legal basis after the code regime was abolished.
For historical reference only: the old regime set three conditional TNTX groups — (i) frozen foodstuffs (code + VND 10 billion deposit + warehouse conditions), (ii) goods subject to special consumption tax (code + VND 7 billion deposit), (iii) used goods (code + VND 7 billion deposit). These figures are now of historical value only and do not apply to current procedures.
The new framework: prohibited / suspended / ordinary goods
Instead of the old “conditional” framework, businesses should now work with three groups:
- Prohibited list: TNTX business and transit are prohibited for goods posing environmental pollution or disease-spread risks, or listed in Appendix V of Decree 292/2026/ND-CP.
- Suspended list: the Ministry of Industry and Trade may publish lists of goods temporarily suspended from TNTX business and transit (Clause 3, Article 13 of Decree 292/2026/ND-CP); it has issued Circular 41/2026/TT-BCT dated 22/7/2026 on the list of scraps and the list of used goods temporarily suspended from TNTX business and transit.
- Ordinary goods and sector-licensed goods: where sectoral law already requires a license for TNTX of certain goods, traders follow that regime and need not obtain an additional TNTX license under Decree 292/2026.
Caution: Decree 292/2026/ND-CP provides a “TNTX business license” mechanism, but its exact scope of application must be checked against the full text of the Decree. Businesses should not speculate and should consult the original text or professionals before proceeding.
Time limit for keeping goods in Vietnam
TNTX business goods may remain in Vietnam for no more than 60 days from the date temporary-import customs procedures are completed, with up to 02 extensions of no more than 30 days each. After the deadline, goods must be re-exported from Vietnam or destroyed in accordance with environmental protection and customs laws (Decree 292/2026/ND-CP, effective 05/9/2026).
FAQs
1. What about businesses holding an old TNTX code?
The codes expired on 01/7/2026. Traders may withdraw the full security deposit from the credit institution under Article 64 of Decree 292/2026/ND-CP.
2. Is a security deposit still required for TNTX business?
No. The TNTX security-deposit regime has been fully abolished since Decree 292/2026/ND-CP took effect.
3. How do I know if my product is prohibited or suspended from TNTX?
Check Appendix V of Decree 292/2026/ND-CP (prohibited list), Circular 41/2026/TT-BCT (suspended list), and the latest announcements of the Ministry of Industry and Trade. Do not rely on unverified product lists.
4. Are online articles citing Decree 69/2018 still usable?
No. Decree 69/2018/ND-CP expired on 05/9/2026. Articles written before that date cite the old regulation and are a source of confusion — use only the current regulation as the standard.
The information in this article is for reference only and does not constitute legal advice. Customs and foreign trade regulations change frequently; businesses should check current legal documents or consult a lawyer before applying.
Need to review TNTX conditions for your products? Contact FLAT Law Firm.
For reference only, not legal advice. Content quality-checked by the AI Legal Council; not yet reviewed by a human lawyer.
