Quick answer: Yes — for imported goods, international freight (F) and international insurance (I) up to the first import gateway are mandatory additions to the customs value. But “how to add, up to where, and which exceptions apply” is where companies most often go wrong.
1. Legal basis: points g and h, Clause 2, Article 13, Circular 39/2015
International freight and insurance costs are mandatory additions to the customs value of imported goods (points g and h, Clause 2, Article 13 of Circular 39/2015/TT-BTC, as amended by Circular 60/2019/TT-BTC, effective 15 October 2019; consolidated document 21/VBHN-BTC). The general principle (Clause 1, Article 5): the customs value of imports is the price actually paid calculated up to the first import gateway.
This was restated by the Customs Department in Official Letter 15317/CHQ-NVTHQ (15 April 2026): “international freight, international cargo insurance and costs related to transporting the goods to the first import gateway are additions… when fully satisfying the conditions in Clause 1, Article 13”.
2. Three conditions for additions (Clause 1, Article 13)
Additions are made only when all three conditions are met:
- Paid by the buyer and not yet included in the price actually paid or payable;
- Related to the imported goods;
- Based on objective, quantifiable data consistent with the relevant documents.
Practical consequence: if the purchase price (invoice) already includes F/I (CIF/CIP terms, etc.), nothing is added — to avoid double counting. Estimates and verbal agreements are not accepted.
3. Scope of addition: freight (point g)
Added: freight and related transport costs for the imported goods up to the first import gateway; excluding loading/unloading costs from the means of transport at the first import gateway (post-gateway costs are not added).
If loading/unloading costs are embedded in the international freight or in the price actually paid, they may be deducted where the conditions of Clause 1, Article 15 (deductions) are met. Freight and insurance costs exclude VAT payable in Vietnam; where VAT is embedded in the freight/insurance or in the actual price, it may be deducted (subject to Article 15).
A special case companies often hit: the purchase price excludes freight but the buyer has no transport contract/documents, or the documents are not lawful → the transaction value method may not be used (move to the next method). This is a common trap for EXW/FCA purchases where the forwarder does not issue complete invoices/documents.
4. What is the “first import gateway”?
The “first import gateway” is the valuation cut-off point — not the company’s warehouse, not the final gateway. Consequences:
- Domestic transport costs from the gateway to the company’s warehouse are not added to the customs value;
- CIF does not mean “never add anything” — that holds only where the (I)+(F) in the CIF price covers the entire leg to the first import gateway; if the CIF contract ends at a transshipment port with onward carriage, the onward leg’s costs to the first import gateway must still be added.
5. FOB vs CIF: when to add
- FOB (and similar terms like EXW/FCA without F/I): the invoice price excludes international freight and insurance → (I)+(F) paid by the buyer must be added. This is the most common error: declaring the value as the FOB invoice price while “forgetting” to add (I)+(F).
- CIF/CIP: the invoice price already includes (I)+(F) to the destination port → nothing added, provided that (I)+(F) covers the entire leg to the first import gateway (see the transshipment note above).
The Incoterms delivery term determines whether F/I is already in the invoice price — companies must read the contract carefully before declaring.
6. What if no insurance was purchased?
Key exception: where the importer did not purchase insurance, no insurance cost is added (point h.1, Clause 2, Article 13 — as numbered in consolidated document 21/VBHN-BTC; Official Letter 15317/CHQ-NVTHQ). No insurance ≠ a deduction; there is simply no corresponding addition. Nor may an estimated insurance amount be “assigned”. However, if insurance was purchased (domestically or internationally) for the leg to the first import gateway, it must be added.
7. Allocating costs across multiple items
Where freight/insurance documents do not break down costs per item, allocate by one of: the carrier’s tariff schedule; weight/volume; the ratio of each item’s purchase value to the consignment’s total value (for freight); or by each item’s value (for insurance). The declarant self-declares and self-allocates. (Point numbering follows consolidated document 21/VBHN-BTC; the QA panel will re-check before publishing.)
8. For exports: (I) and (F) excluded
The reverse of the import rule: the customs value of exports is the selling price up to the export gateway, excluding international insurance (I) and international freight (F) (point a, Clause 1, Article 4). Specifically: for delivery outside Vietnam’s territory, take the contract/invoice price minus (I), (F) from the export gateway to the delivery point; for domestic delivery, add domestic transport/insurance costs from the delivery point to the export gateway. Note the asymmetry: post-first-gateway domestic costs are not added to import value, but pre-export-gateway domestic costs are added to export value.
9. Penalties for omission
Failing to add international freight/insurance when required is misdeclaration of customs value causing tax shortfall → penalties under Article 10 of Decree 169/2026/ND-CP (10%/20% of the under-declared tax; effective 1 July 2026). Failing to make supplementary declarations on customs value that are discovered during inspection/audit falls under point c, Clause 3, Article 10 (20% penalty).
Note: This article provides general information for reference only and does not constitute legal advice. Companies should check the legal instruments in force at the time of application or consult a lawyer before acting.
Need help reviewing dutiable value and customs declaration dossiers? Contact FLAT Law Firm for advice.
For reference only, not legal advice. Content quality-checked by the AI Legal Council; not yet reviewed by a human lawyer.
