Are Roasted and Seasoned Pine Nuts and Cashews Considered Minimally Processed for VAT Exemption Purposes?
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The Ministry of Finance clarifies the VAT classification of roasted and seasoned pine nuts and cashews under the revised VAT regime effective 1 January 2026. Under Decree No. 181/2025/ND-CP, 'minimal processing' is narrowly defined to include only: cleaning, drying, husking, milling, polishing, salting, vacuum sealing, cold storage, and similar standard preservation methods. Roasting and seasoning are not included in this list. Where classification is unclear, businesses should consult the Ministry of Agriculture and Environment. Products that exceed minimal processing are subject to 10% VAT rather than the 0% exemption or 5% rate applicable to minimally processed agricultural goods.
VAT Treatment of Roasted and Seasoned Nuts
Responding authority: Ministry of Finance Date of inquiry: 6 April 2026
Issue
A trading company purchases roasted and seasoned pine nuts and cashews for resale. The question is whether these products qualify as 'minimally processed' agricultural goods under the VAT Law and Decree 181/2025/ND-CP.
Applicable Rules
Article 5(1) of VAT Law No. 48/2024/QH15 (as amended by Law No. 149/2025/QH15): Agricultural, forestry, and aquaculture products that are unprocessed or only minimally processed by the producer and sold, or at the import stage: VAT exempt.
Enterprises and cooperatives purchasing minimally processed agricultural goods and reselling to other enterprises/cooperatives: not required to declare or pay VAT but may deduct input VAT.
Article 9(2)(d) of VAT Law No. 48/2024/QH15: Minimally processed agricultural products sold through commercial channels (other than Article 5(1) cases): 5% VAT rate.
Article 9(3): All other goods and services: 10% VAT rate.
Article 4(1) of Decree No. 181/2025/ND-CP - Definition of 'minimal processing': Minimal processing includes only: cleaning, drying, husking, milling, grinding, de-hulling, separating, cutting, polishing, salting, vacuum sealing, refrigeration/freezing, sulfur dioxide preservation, soaking in preservation solutions, and other standard preservation methods.
Conclusion
The definition of 'minimal processing' is clearly set out in Decree 181/2025. Roasting and seasoning are not listed among acceptable minimal processing methods. When classification is uncertain, businesses should consult the Ministry of Agriculture and Environment.