Starting January 1, 2027, the Vietnamese Ministry of Science and Technology will enforce Circular 63/2026/TT-BKHCN, a regulation banning the import of used digital technology products. The mandate prohibits the entry of secondhand mobile phones, computers, cameras, and their associated electronic components.
Strategic Implications for Repair Operations
- Repair shops may continue to service domestic devices but must source replacement parts legally within Vietnam.
- Importing used units or components from abroad for the specific purpose of cannibalizing them for parts is strictly prohibited.
- Inventory stockpiling before the 2027 deadline provides no legal safe harbor, as existing regulations already restrict the import of obsolete technology.
Attorney Nguyen Van Duy, director of Hoang Duy & Associates, emphasizes that the circular distinguishes between legal domestic circularity and illegal cross-border importation. Shops that harvest screens, motherboards, or sensors from locally sourced used devices remain compliant, provided the origin of those components is documented. In an interview with journalist Doan Thuy of the newspaper Dan Tri, Duy clarified that while the circular directly updates the list of prohibited imports, it does not impede the fundamental ability of repair shops to service devices already circulating within the country.
Legal Risks of Illicit Supply Chains
The prohibition extends beyond finished goods to include the components themselves. Under point d, clause 2, article 2 of Circular 63, the ban explicitly covers used parts, accessories, sub-assemblies, and electronic components associated with the listed digital products. Attorney Duy warned that shops utilizing components sourced from smuggled goods risk legal repercussions, regardless of whether the parts remain functional. He emphasized that importing used devices from abroad specifically to dismantle them for spare parts remains a violation of the law.
The legal framework relies on the enforcement of existing standards, including Circular 11/2018/TT-BTTTT, which already governs the import of obsolete technology.
Tightening Import Controls Will Increase Repair Service Costs
The tightening of import controls is expected to exert upward pressure on the cost of repair services. As the supply of cheap, non-certified, or imported used components dries up, repair facilities will likely see an increase in procurement costs for verified, legal alternatives.
| Regulatory Category | Import Status | Compliance Requirement |
|---|---|---|
| Locally Sourced Used Parts | Permitted | Proof of domestic purchase |
| Imported Refurbished Units | Prohibited | N/A |
| New Certified Components | Permitted | Standard import documentation |
| Used Components (Foreign) | Prohibited | N/A |
Operational Compliance Requirements
Repair businesses must maintain strict documentation regarding the origin of their inventory. Moving forward, the legality of a repair operation will be determined by its ability to prove that all harvested parts were acquired through domestic channels rather than international shipments that circumvent the new import schedule.
Disclaimer: The information provided in this article is for educational and informational purposes only and does not constitute financial advice.
