Circular 24/2026/TT-BCT: Rules of Origin for Goods under the Vietnam-UAE Comprehensive Economic Partnership Agreement
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Based on:24/2026/TT-BCT - Government Official Gazette
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On May 5, 2026, Vietnam's Ministry of Industry and Trade issued Circular 24/2026/TT-BCT, setting out the Rules of Origin that implement the Vietnam-United Arab Emirates Comprehensive Economic Partnership Agreement (CEPA), signed October 28, 2024. Goods qualify as originating either by being wholly obtained in a member country (grown, raised, mined, etc. entirely within Vietnam or the UAE) or by undergoing sufficient working or processing, meaning a change in tariff classification at the 4-digit heading level (CTH) or a regional value content (QVC) of at least 35% of the ex-factory price. A 20% de minimis tolerance applies to non-originating materials that fail the tariff-shift test. Businesses trading between Vietnam and the UAE can prove origin to claim preferential tariffs through three channels: a UAE-VN Certificate of Origin (C/O) issued by the Import-Export Department or provincial People's Committees, a self-issued certification by an approved exporter, or a self-declaration for shipments valued at 500 USD or less. Certificates are valid for one year and must be submitted to customs within that period. The Circular also covers retroactive (back-dated) C/O issuance, replacement of lost or damaged certificates, tolerance for minor discrepancies, and an origin-verification process that gives the exporting country's authority up to six months to respond to a customs inquiry from the importing country. The Circular takes effect May 5, 2026, but applies retroactively: authorities may issue back-dated C/O for Vietnamese exports shipped from February 3, 2026, and customs will accept origin certificates for import declarations registered from that same date. This means businesses that already traded with the UAE in this window can still claim preferential tariff treatment. Exporters and importers dealing with the UAE, particularly SMEs and foreign-invested businesses building Middle East supply chains, should review their origin documentation now to take advantage of CEPA preferences.
Overview
Circular 24/2026/TT-BCT, issued by the Ministry of Industry and Trade on May 5, 2026, sets out the Rules of Origin applicable under the Vietnam-United Arab Emirates (UAE) Comprehensive Economic Partnership Agreement (CEPA), signed on October 28, 2024. It applies to bodies issuing Certificates of Origin (C/O), traders, and any organization or individual involved in the origin of exported or imported goods.
Origin criteria
Goods qualify as originating in a member country (Vietnam or the UAE) under one of three routes:
- Wholly obtained goods: produced entirely within a member country's territory - for example plants, live animals, minerals, fish caught by vessels flying a member country's flag, or waste generated locally.
- Sufficient working or processing, meeting either: a Change in Tariff Heading at the 4-digit level (CTH) for all non-originating materials used; or a Regional Value Content (QVC) of at least 35% of the ex-factory price, calculated as QVC = (Ex-factory price - V.N.M) / Ex-factory price x 100, where V.N.M is the customs value of non-originating materials used.
- Produced solely from originating materials within the member country's territory.
Certain products listed in Appendix I are subject to Product Specific Rules instead of the general criteria above.
De minimis tolerance: goods that fail the tariff-shift test still qualify as originating if the value of non-shifting non-originating materials does not exceed 20% of the ex-factory price.
Cumulation: materials originating in Vietnam used to manufacture goods in the UAE (and vice versa) are treated as originating in the country where the final product is made.
Insufficient working or processing
The Circular lists simple operations that do not confer origin even if they change the tariff classification, including: slaughtering animals; preservation operations (drying, freezing, chilling); simple washing, cutting, or sharpening; cleaning; simple painting or polishing; bottling, packing, or labelling; simple mixing; simple assembly or disassembly; milling or polishing rice; and dilution with water.
Territoriality, transit, and free trade zones
Production must occur wholly and without interruption within a member country's territory, including free trade zones and export processing zones. Goods exported and later re-imported lose their originating status unless proven to be the identical goods, having undergone no more than the operations necessary to preserve them. Goods transiting through a non-member country retain their origin if they remain under customs supervision and undergo nothing beyond unloading, reloading, labelling, or splitting of shipments.
Certification of origin
Three types of documents can support a preferential tariff claim:
- UAE-VN Certificate of Origin (C/O) - issued in Vietnam by the Import-Export Department (Ministry of Industry and Trade) or provincial People's Committees; issued in English, valid for one year; available in paper or electronic form via the eCoSys system (www.ecosys.gov.vn).
- Self-issued certification of origin by an approved exporter recognized by the competent authority of Vietnam or the UAE.
- Self-declaration of origin by the exporter for shipments valued at 500 USD or less, provided the shipment is not part of a series suspected of being structured to evade compliance.
Vietnamese exporters using self-certification must declare and upload the certification on the eCoSys system within three working days of issuance.
The Circular also covers back-dated (retrospective) C/O issuance within one year of the shipment date, replacement C/O in case of errors, certified true copies for lost or damaged originals, and tolerance for minor discrepancies or typographical errors that do not otherwise raise doubts about authenticity.
Verification and denial of preferential treatment
Importing-country customs may verify origin on a random basis or when there is reasonable doubt, sending a request to the exporting country's competent authority, which has up to six months to respond. A late or missing response, insufficient information, or a finding that the goods do not meet the origin criteria are grounds for denying preferential tariff treatment; the importer is entitled to a written explanation on request and may appeal the decision.
Recordkeeping
Producers, exporters, and importers must retain supporting origin documentation for at least five years from the date of issuance or importation.
Effective date
The Circular takes effect May 5, 2026. However, issuing authorities may grant back-dated UAE-VN C/O for Vietnamese exports shipped from February 3, 2026, and customs authorities will accept origin certificates for preferential tariff consideration on import declarations registered from February 3, 2026 onward.