Moving machinery from a Chinese plant to Vietnam sounds simple — pack the containers, ship them, receive the goods. In reality, it is one of the most stuck links in production relocation: can used machines be imported? How much import duty? How does Customs value machines that are internal transfers between two group companies (with no real “sale price”)? This article sets out the complete tax and procedural framework for moving machinery from China to Vietnam — from used-equipment import conditions to how Customs determines dutiable value.
Import conditions: can used machines enter?
New machines: normal import, no restrictions. Used machines: under Decision 18/2019/QD-TTg, used machinery imports must meet: (1) equipment age not over 10 years (from year of manufacture); (2) manufactured to matching technical standards (certified by the manufacturer or an inspection body); (3) not on the prohibited-import list. The dossier needs an age/condition inspection by a designated inspection organisation. Common trap: Chinese production lines used for 12–15 years — ineligible for import; the options are buying new or replacing core components to “rejuvenate” (which Customs may reject if original serial numbers are too old). Tip: check the nameplate year before planning the move — many firms spend months packing before discovering the machines are over-age.
Import duty: three scenarios
Scenario 1: duty exemption (best). Under the Export/Import Duty Law 107/2016/QH13 and Decree 134/2016/ND-CP (amended by Decree 18/2021), goods imported to create fixed assets of an incentivised project are exempt from import duty. Conditions: the project holds an IRC with investment incentives (under Investment Law 143/2025), and the machines sit on the duty-free import list registered with Customs before importation. Note: exemption-list registration is a separate procedure — firms that import first and register later get no exemption for the arrived shipment.
Scenario 2: ACFTA preferential duty (C/O Form E). Without exemption, China-origin machines can enjoy special preferential rates under the ASEAN–China FTA with a valid C/O Form E. Rates vary by HS code — many industrial machines land at 0–5%. The intra-group problem: Form E needs Chinese origin proof — China-made machines qualify, but obtaining C/O for internal transfers (no sale) is trickier without standard commercial invoices. Fix: prepare proforma invoices/internal transfer agreements with stated values as the C/O and declaration basis.
Scenario 3: MFN duty (worst). No exemption, no C/O — MFN rates apply (typically 0–10% by HS code, higher for some lines). On a multi-million-dollar line, the gap between 0% and 10% is hundreds of thousands of dollars — enough to decide whether to move machines or buy new in Vietnam.
Customs valuation: the hardest problem with internal transfers
When two group companies transfer machines, there is no market sale price — but Customs must still set a dutiable value. Under the Customs Law 54/2014/QH13 and GATT/WTO valuation principles, the method hierarchy is: (1) transaction value (actual price — an internal transfer price will be considered but can be rejected if doubted); (2) transaction value of identical/similar goods; (3) deductive/computed value. For used machines, Customs typically references new-machine prices less depreciation — and Customs’ depreciation math differs from corporate accounting depreciation. Typical dispute: the firm declares book residual value (heavily depreciated, low), Customs assesses higher on market prices — the value gap drives duty gaps and fines. Prevention: (1) commission an independent valuation before import (the appraisal report anchors Customs negotiations); (2) prepare full technical dossiers (year, condition, maintenance history) evidencing real value; (3) declare honestly — under-declaration, once caught, brings back-tax plus fines and priority-inspection status for later shipments.
Import VAT and logistics: the two forgotten items
Import VAT: imported machines attract 10% VAT (with exceptions) — but it’s creditable for VAT-registered businesses on the credit method. The issue is cash flow: 10% of the shipment value paid at import, credited over time — on a USD 5 million line that’s USD 500,000 “buried” for months. Plan cash flow for this. Logistics: industrial machines are oversize/overweight — survey the route from port to plant (weak bridges, narrow roads, need for heavy-haulage), and obtain special transport permits. Many firms sort the tax then forget special-transport costs — sometimes 10–15% of machine value. Right order: survey logistics before deciding to move — some machines cannot travel Vietnamese roads (bridge limits), forcing dismantling (costly) or new purchase.
Compare: moving used machines vs buying new in Vietnam
Moving used wins when: machines are still good (under 7 years), technology isn’t obsolete, and transfer cost (duty + logistics + reinstallation) is under 50% of equivalent new-machine price. Buying new wins when: machines exceed 10 years (import-ineligible), technology is dated (new machines save power, automate more), or duty exemption applies to new machines (incentivised projects) — narrowing the cost gap. Decision formula: Total transfer cost = import duty + import VAT (cash flow) + special logistics + dismantling/reinstallation + downtime — versus new-machine price − China resale value of old machines. Compute all five components; never compare on duty alone.
Managing the move — the project playbook
Treat machinery relocation as a project, not a shipment: (1) appoint one move manager owning the timeline across the Chinese dismantling team, the freight forwarder, Customs brokers on both sides, and the Vietnamese installation team — handoffs between these parties are where months disappear; (2) photograph and catalogue everything before dismantling (each machine, each crate, serial numbers) — the photo file resolves 90% of later disputes about damage, missing parts and Customs queries; (3) sequence the move so critical-path machines travel first and arrive before the installation crew, not after; (4) keep the Chinese plant’s maintenance engineers on the reinstallation in Vietnam — nobody knows the machines’ quirks like the team that ran them, and their 2–4 weeks on site saves months of debugging; (5) run parallel production where possible (keep the Chinese line running until the Vietnamese line passes acceptance) — the cost of overlap is far less than the cost of a supply gap to customers. Firms that move machines well treat it as transplant surgery: the organ must stay alive through the journey, and the receiving body must be ready before it arrives.
Checklist: moving machinery from China to Vietnam
1. Check machine age: nameplate year — over 10 years, stop immediately. 2. Technical inspection: designated inspection body assesses age/condition. 3. Fix the duty scenario: exemption-eligible (incentivised project)? Register the exemption list before importing. 4. Prepare C/O Form E: if no exemption — internal transfer invoices/agreements for the C/O application. 5. Independent valuation: appraisal report anchoring the Customs declaration. 6. Technical dossiers: year, maintenance history, condition — evidencing declared value. 7. Cash-flow planning: 10% import VAT paid upfront, credited later. 8. Logistics survey: routes, bridges, heavy-haulage permits — before deciding to move. 9. Compare total cost of moving vs buying new (five components). 10. Work with a Customs broker experienced in industrial machinery — not a consumer-goods broker for a million-dollar line. 11. Appoint one move manager and keep the Chinese maintenance team for reinstallation.
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This article has been quality-reviewed by the FLAW AI Legal Council