E-Invoicing for Consignment Exports from 1 July 2026 under Decree 254/2026

Issue Raised

A wood chip exporter that also exports goods on consignment explained that, under its contracts, it receives payment from the foreign customer and then passes the goods value back to the consignor. Before 1 July 2026, for consigned goods, it issued VAT e-invoices to the foreign customer under Article 13.3(b) of Decree 123/2020/ND-CP.

Decree 254/2026/ND-CP applies from 1 July 2026. The company read Article 6.3(b) of the new Decree as covering only the consignee's invoice for the consignment fee, not an invoice to the foreign customer for consigned goods, and asked whether it must still invoice the foreign customer.

Provisions of Decree 254/2026/ND-CP

Decree 254/2026/ND-CP dated 30 June 2026 details certain articles of, and measures to implement, Tax Administration Law No. 108/2025/QH15 on e-invoices and e-documents, effective 1 July 2026.

Article 6.3(b) - Consignment Exports of Goods

b.1) When goods are delivered to the consignee:

• The consignor uses a warehouse release cum internal transport note (phiếu xuất kho kiêm vận chuyển nội bộ).

b.2) When the goods are actually exported:

• The consignee completes export procedures under customs law.
• Once the goods are actually exported with customs confirmation, based on documents reconciling and confirming the quantity and value of goods actually exported by the consignee:
  • The consignor issues a VAT e-invoice or sales e-invoice to the export consignee.
  • The consignee issues a VAT e-invoice or sales e-invoice to collect its consignment fee from the consignor.

Article 6.3(c) - Exported Goods and Services

Businesses exporting goods or services (including processors of export goods) use an e-invoice when exporting: an electronic commercial invoice, a VAT e-invoice or a sales e-invoice. The invoice is issued at the time set out in Article 9.1 of the Decree.

Tax Office Position

Tax Office No. 10 of Dak Lak province (Thuế cơ sở 10 tỉnh Đắk Lắk) replied on the Ministry of Finance Q&A portal:

• Article 6.3(b) of Decree 254/2026/ND-CP governs invoicing between the consignor and the export consignee, including the consignment fee invoice.
• It does not yet specifically regulate invoicing the foreign customer for the value of consigned export goods.

Implementation Guidance

For invoicing the foreign customer, the tax office asked the company to:

1. Compare the provisions:

   • Article 6.3(c) of Decree 254/2026/ND-CP.
   • Article 9.1 of Decree 254/2026/ND-CP.

2. Against its documents:

   • The export consignment contract.
   • The export contract.
   • Customs declarations.
   • Related supporting documents.

3. To determine, as required by law:

   • Which party has the obligation to issue the invoice.
   • The invoice type.
   • When the invoice must be issued.

Conclusion

From 1 July 2026, invoicing between the consignor and the export consignee is set out specifically in Article 6.3(b) of Decree 254/2026/ND-CP. For invoicing the foreign customer for the value of consigned goods, the tax office gave no direct conclusion and asked the company to apply Article 6.3(c) and Article 9.1 to its own transaction documents. Businesses should review their actual contracts and documents before issuing invoices.