Bonded warehouses are a vital link in the import-export logistics chain — but also an area under strict customs supervision. Violating bonded warehouse regulations can lead to fines of up to VND 20 million, confiscation of exhibits, and even mandatory removal of goods from Vietnamese territory. This article analyses the framework under Article 24 of Decree 169/2026/ND-CP (effective 1 July 2026).
1. What is a bonded warehouse? Which goods may be stored?
Under Article 4(10) of the Customs Law 54/2014/QH13 (still in force), a bonded warehouse is a warehouse/yard area storing goods that have completed customs procedures, kept pending export or pending import into Vietnam. The rules on bonded warehouses (establishment conditions, eligible goods, storage time limits) are set out in Article 61 of the Customs Law and detailed in Decree 08/2015/ND-CP (amended by Decree 167/2025/ND-CP, effective 15 August 2025).
A bonded warehouse differs from a tax-suspension warehouse (an enterprise’s warehouse storing imported materials for export production) and container freight stations (CFS) — these concepts should not be confused when applying the law.
2. Business conditions for bonded warehouses — note on legal validity
The conditions for recognition of bonded warehouses (minimum area, separating fences, management software connected to customs…) are set out in Decree 68/2016/ND-CP (amended by Decree 67/2020/ND-CP).
Important note: As of 14 October 2026, the validity of Decree 68/2016 on conditions for recognition of bonded warehouses is in a transitional phase — a draft replacement decree (repealing both Decrees 68/2016 and 67/2020) exists but, at the time of writing, has not been issued, with no confirmed number or effective date. Readers should check the latest text before applying. Separately, Decree 273/2026/ND-CP (effective 21 August 2026) only governs duty-free goods business (replacing Decree 100/2020) and is not the replacement for Decree 68/2016 — do not confuse the two.
3. Storage time limits and handling overdue goods
Time limits for storing goods in bonded warehouses (including maximum periods and extension conditions) are set out in Article 61 of the Customs Law and Decree 08/2015/ND-CP — businesses should consult the current text directly for the specific period applicable to their goods.
- Expiry of the storage period without removing goods from the warehouse: penalised under Article 24(1) (see section 4);
- Overdue goods without procedures: handled under the rules on backlogged goods at ports, warehouses and yards;
- Coming soon: Law 11/2026/QH16 (passed, effective 1 March 2027) contains transitional provisions on storage periods for goods already in bonded warehouses before its effective date — applicable from 1 March 2027.
4. Three groups of violations and fine frames (Article 24)
| Group | Typical conduct | Fine |
|---|---|---|
| Group 1 (Clause 1) | Bringing goods/machinery from the domestic market into the bonded warehouse for packing, sorting or maintenance without notifying customs; performing reinforcement, splitting, assembling, sorting, maintenance or sampling services without notifying customs for supervision; transferring ownership of warehoused goods without notification; failing to remove goods from the warehouse after the storage period expires | VND 1–2 million |
| Group 2 (Clause 2) | Moving goods from one bonded warehouse to another without written consent of the competent person; expanding/narrowing/relocating the warehouse site without permission; performing unauthorised services in the warehouse; failing to follow the reporting regime on time | VND 2–5 million |
| Group 3 (Clause 3) | (a) Bringing into the bonded warehouse goods ineligible for bonded warehousing; (b) dispersing goods stored in the bonded warehouse; (c) destroying goods stored in the bonded warehouse in violation of the law | VND 10–20 million |
5. Heavy sanctions: confiscation and remedial measures
- Clause 4 — supplementary penalty: (a) confiscation of administrative violation exhibits for dispersing goods in the bonded warehouse (Clause 3(b)); (b) confiscation of exhibits for bringing ineligible goods into the bonded warehouse (Clause 3(a)) where the exhibits are prohibited/suspended import-export goods;
- Clause 5 — remedial measures: (a) mandatory payment of an amount equal to the value of exhibits consumed, dispersed or destroyed in violation of regulations; (b) mandatory removal from Vietnamese territory of exhibits being ineligible goods; (c) mandatory destruction of harmful cultural products; (d) mandatory removal of violating elements on labels of goods faking Vietnamese origin before removal from the territory.
6. Bonded warehouse violations at border gates
Article 13(2)(n) of Decree 169/2026 imposes a fine of VND 10–20 million for lacking a customs notice permitting goods to be placed in a bonded warehouse at the export border gate (or returned to the original bonded warehouse) for goods exported from a bonded warehouse that exceed the storage period within the customs supervision area at the export gate without being exported.
7. Liability: warehouse operator vs goods owner
- Bonded warehouse operators (organisations operating bonded warehouses): responsible for managing and supervising stored goods, notifying customs, following the reporting regime and maintaining required management systems — violations are penalised under Article 24 as organisations;
- Goods owners: responsible for their own goods; dispersal of goods by the owner leads to confiscation and mandatory payment of an amount equal to the exhibit value;
- Liability follows the letter of Article 24 — each act is tied to its actor.
On suspension or termination of bonded warehouse operations (revocation of recognition): within customs authorities’ competence under the business-conditions regulations — businesses should check the current text (see the transitional note in section 2).
Frequently asked questions
Which goods may not be placed in bonded warehouses?
Goods subject to import/export prohibition or suspension, and other categories as prescribed, may not be warehoused — bringing them in attracts VND 10–20 million fines and possible confiscation.
What to do when the storage period expires?
Complete procedures to remove the goods (re-export, import into the domestic market, or switch to another customs regime) before expiry; failure to remove overdue goods is penalised.
Is the warehouse operator liable when the goods owner disperses goods?
Each party is liable for its own acts under Article 24; the operator has management, supervision and notification duties — lax management may expose the operator to penalties for its own violations.
This article is for general information only and does not constitute legal advice. As some regulations on bonded warehouse business conditions are in a transitional phase (as of 14 October 2026), businesses should check the latest text or consult a lawyer before applying.
Need advice on bonded warehouses, customs procedures or violation handling? Contact FLAT Law Firm: /en/contact/ — lawyers with 30+ years of experience in customs and logistics law.