A new heat-treatment line or boiler from Japan passes three separate checks in Vietnam, at three different moments, under two different lists. Most delays come from treating them as one step — and from asking the Japanese maker for its technical file only once the crates are already in the port. The file the inspector will want is easy to get while the order is still being negotiated, and hard to get afterwards.
💬 Buying heat-treatment or washing equipment from Japan? Sunsho Trade supplies Japanese industrial equipment and collects the maker’s documents in Japanese before anything ships. Send us the specification.
Three checks, three moments: do not merge them
The three checks are the quality route (a conformity declaration or a pre-clearance inspection, depending on the risk tier), the safety inspection (before first use, then periodically) and the declaration of use; they come from two different laws and two different lists, so one piece of equipment can fall under both, one, or neither.
The quality side runs on the Law on Product and Goods Quality as amended by Law No. 78/2025/QH15, detailed by Decree 37/2026/ND-CP (Nghị định 37/2026/NĐ-CP). The safety side runs on the Law on Occupational Safety and Health, No. 84/2015/QH13 (Luật An toàn, vệ sinh lao động).
| Check | When it falls due | What the text says | Instrument |
|---|---|---|---|
| 1. Quality route: declaration of conformity (medium-risk goods) | Before the goods are placed on the market | No quality inspection on import, but the importer must declare conformity with the national technical regulation | Decree 37/2026, Article 82(1) |
| 1. Quality route: state quality inspection on import (high-risk goods) | Before customs clearance | Register for inspection; clearance follows the notice that the goods meet the requirements | Decree 37/2026, Articles 82(2) and 83(4)–(5) |
| 2. Safety inspection: first | After installation, before first use | Equipment with strict safety requirements is inspected before use and periodically during use | Law 84/2015, Article 31(1) |
| 2. Safety inspection: periodic | Throughout its working life | Same inspection duty, repeated | Law 84/2015, Article 31(1) |
| 3. Declaration of use | When the equipment is put into use | The user declares it to the provincial authority where it is used | Law 84/2015, Article 30(2) |
Checked against the published texts on 18 September 2026.
Three things changed recently. Occupational safety now sits with the Ministry of Home Affairs, not the former Ministry of Labour, Invalids and Social Affairs. Its Circular 16/2026/TT-BNV, in force from 28 July 2026, sets the medium- and high-risk product list for equipment under that ministry, and Article 7(2) repeals Circular 01/2021/TT-BLDTBXH — still quoted by service pages as the list for imported safety equipment. And Decree 37/2026 replaced the old “group 2” regime from 1 July 2026 (Article 97(2)–(3)).
Find your equipment on the lists by its nameplate, not its name
Both lists describe equipment by function and by thresholds such as working pressure, medium temperature and lifting load, so the test is the numbers on the nameplate and in the specification, never the product name.
The general safety list is the one attached to Circular 36/2019/TT-BLDTBXH, in force since 1 March 2020; when we checked, we found no circular that replaces it, but confirm this against the current text before you rely on it. It is not the only list. Law 84/2015, Article 33(1), gives sector ministries their own lists; for example, Article 33(1)(d) gives the Ministry of Industry and Trade pressure and special lifting equipment specific to industry, chemicals, industrial explosives, mining and oil and gas. The use declaration goes to the authority those provisions point to (Article 30(2)), so check which list covers your site. Section I of the Circular 36/2019 list has 45 numbered items. The ones that matter for heat and pressure equipment are:
- Boilers with a rated steam working pressure above 0.7 bar, and hot-water boilers with a medium temperature above 115 °C (item 1).
- Thermal-oil heaters (item 2).
- Steam and hot-water piping above the pipe classes and diameters the item sets (item 3).
- Pressure vessels with a rated working pressure above 0.7 bar, not counting hydrostatic pressure, classified under TCVN 8366:2010 (item 4), and gas cylinders (item 6).
- Gas supply, generation and filling systems, and fixed fuel-gas and compressed-gas piping (items 7 and 8).
- Lifting equipment such as overhead cranes and electric hoists (items 11 and 14).
An industrial furnace or a washing machine is not listed by name; its components can be. Ask the maker for the rated pressure, volume and medium temperature of each, and check them separately. For a gas-atmosphere heat-treatment line:
| Component of the line | Circular 36/2019 item to check | What decides it |
|---|---|---|
| Furnace body and quench tank | None by name | Your own acceptance test |
| Atmosphere gas generator | Item 7 | Whether it generates or supplies gas |
| Fuel-gas and process-gas piping | Items 7 and 8 | Fixed gas piping is listed |
| Compressed-air receiver | Item 4 | Rated working pressure above 0.7 bar |
| Steam or hot-water supply to a washer | Items 1 and 3 | Boiler pressure or temperature; pipe class and size |
| Basket hoist or overhead crane | Items 11 and 14 | Lifting equipment of that type |
The quality list works in tiers. Under Circular 16/2026, the high-risk items are personal protective equipment, lifts and lift safety parts, and escalators and passenger conveyors. Boilers above 0.7 bar, pressure vessels above 0.7 bar (the entry excludes single-use gas cylinders and rotating gas containers imported temporarily for re-export), certain refrigeration systems, cranes and several kinds of lifting equipment are medium risk.
| If the component is… | Before customs clearance | Before it is sold or used | After installation |
|---|---|---|---|
| A boiler or pressure vessel above 0.7 bar | No quality inspection on import | Declaration of conformity with QCVN 01-2008/BLDTBXH | First safety inspection, then declaration and periodic inspection |
| A high-risk item, such as a lift | Registered quality inspection; clearance after a passing notice | Covered by the inspection | Safety inspection where Circular 36/2019 lists it |
| On neither list | Ordinary customs declaration | Nothing specific to these lists | Your own acceptance test and maintenance |
For the medium tier, Circular 16/2026 bases the declaration either on a certificate from an accredited certification body or on the importer’s own assessment backed by test results from an accredited or designated laboratory. Decree 37/2026, Article 86(5), says a later shipment does not need a new declaration if it has the same name, use, brand, type, technical characteristics, producer and origin — useful when a second identical unit follows.
For high-risk goods, Article 83(4) puts the registration on the National Single Window or the National Public Service Portal, and Circular 16/2026, Article 5(1), names the ministry’s Department of Employment as the central inspection authority. You do not register with that department, though: Article 5(2) sends importers to the provincial People’s Committee or its specialised agency.
What to get from the Japanese maker before it ships
The boiler inspection procedure lists the documents an inspector reviews at the first inspection, so write those documents into the purchase order and collect them in Japan — they are made at the factory and nobody in Vietnam can produce them later.
The procedure for boilers and hot-water boilers is QTKĐ 01-2016/BLĐTBXH, issued with Circular 54/2016/TT-BLDTBXH; thermal-oil heaters have their own procedure, QTKĐ 02-2016/BLĐTBXH, with a near-identical list. We quote them as issued under Circular 54/2016; check for a newer procedure before you rely on them. For a first inspection, section 7.2.1 of the boiler procedure has the inspector review:
| What the inspector reviews | What to ask the Japanese maker for |
|---|---|
| Material specifications for the base metal and weld metal | Material certificates (材料証明書 / ミルシート) for pressure parts |
| Strength calculations for pressure parts | Strength calculation sheet (強度計算書) |
| Manufacturing drawings | Fabrication drawings (製作図面) for the unit being shipped |
| Operation, maintenance and repair instructions | Instruction manual (取扱説明書), with the language agreed |
| Weld quality inspection results | Weld inspection records (溶接検査記録) |
| Factory acceptance test record | Factory test report (出荷検査成績書) |
| Conformity certificate, where a national technical regulation exists | Test data needed for the Vietnamese conformity declaration |
| Calibration reports for measuring instruments; earthing, lightning-protection and protective-device checks | Calibration certificates for the gauges and safety devices supplied |
Installation records on the same list are made in Vietnam, so name who prepares them in the installation contract. The thermal-oil procedure adds a system schematic and the physical and chemical property sheet of the thermal oil.
Two contract clauses save most arguments later. First, the serial number and year on every document must match the unit delivered, not a catalogue model. Second, agree who translates the file into Vietnamese and who pays for it; a Japanese maker’s file is normally in Japanese. The trade term matters too, because it decides who pays each charge when the crates reach the Vietnamese port; destination lines such as terminal handling, the import declaration, duty and import VAT stay with the buyer on the common terms, as set out in local charges by Incoterm.
A used boiler or furnace takes on these duties as well as its own import criteria. Age limits and the maker’s certificate are covered in importing used Japanese machinery into Vietnam; the safety inspection still applies after installation.
💬 Want the document list sent to the maker in Japanese, with the serial number tied to every item? Sunsho Trade handles that when we source equipment from Japan. Ask us about your order.
The 200 V and 60 Hz question: read four nameplate lines first
Vietnam’s low-voltage distribution is 0.38 kV (3-phase) at 50 Hz, while Japanese industrial equipment is often rated for 200 V and, in western Japan, for 60 Hz, so the nameplate decides between a transformer, a transformer plus a frequency converter, or a 50 Hz build specified in the order.
On the Vietnamese side, Circular 05/2025/TT-BCT, Article 4(1), sets the nominal frequency of the national system at 50 Hz, and Article 6 lists 0.38 kV among the distribution voltages. On the Japanese side, Article 38 of the Electricity Business Act Enforcement Regulation sets the standard low voltages at 100 V and 200 V. Japan’s grid is split, with 50 Hz in the east and 60 Hz in the west. Many factories in Vietnam take medium voltage and transform it on site, so ask your electrical contractor what your panel delivers.
Ask for a clear photo of the nameplate (銘板) of every electrical unit — heaters, pumps, fans, the control panel — and read four lines: rated voltage, rated frequency (50, 60 or 50/60 Hz), whether both frequencies carry their own speed or current values, and whether the load is a motor or a resistive heater.
| What the nameplate shows | Route | Why |
|---|---|---|
| Dual 50/60 Hz, voltage within your supply | Connect after the electrical contractor reviews the wiring diagram and earthing | Rated for your frequency and voltage |
| 200 V, rated for 50 Hz or 50/60 Hz | Step-down transformer to 200 V | A transformer changes voltage only |
| 60 Hz only, with motors | Transformer and frequency converter, or ask the maker for a 50 Hz build | A transformer does not change frequency |
| New order, not yet built | State “3-phase 380 V, 50 Hz” in the purchase order | Nothing to convert on arrival |
A 60 Hz motor run at 50 Hz turns slower and runs hotter; a resistive heater cares about voltage, not frequency. How much this matters depends on the design, so write the supply into the purchase order and get the maker’s answer in writing.
After installation: inspect, then declare, then keep the records
Only an inspection organisation holding a certificate of eligibility may carry out the first inspection, it must happen before the equipment is used, and the user must then declare the equipment and keep its technical records.
Article 32 of Law 84/2015 limits an inspection organisation to the scope in its certificate, so check it covers your equipment type. Sunsho Trade does not inspect or certify equipment.
Decree 283/2026/ND-CP, in force from 10 September 2026, replaced Decree 12/2022/ND-CP as the penalty decree for labour and occupational safety. Article 35 covers the user: failing to declare the equipment to the local Department of Home Affairs within 30 days of putting it into use, not keeping full technical records, using equipment not certified as conforming to the national technical regulation, and using it without first or periodic inspection. Article 37 covers the inspection organisations themselves. We do not quote the fine amounts here; take them from the current text.
The acceptance record: write it before commissioning
An acceptance record is worth what it measures, so agree its outline with the supplier before commissioning and record measured values, not ticks.
Cover the equipment identity (model, serial number, year, contract number); pre-start checks of connections, earthing and safety devices; a no-load run and a load run on your own parts, each with measured voltage, current, pressure and temperature; open items with an owner and a deadline; documents handed over and who was trained; and the result and warranty start date, signed. Keep it with the technical safety records the user must hold under Article 30(3) of Law 84/2015.
💬 Commissioning Japanese heat-treatment or washing equipment in Vietnam? Sunsho Trade provides installation support, maintenance and spare parts here. Tell us what is arriving and when.
Frequently asked questions
1. Does a new Japanese boiler need a safety inspection if it has a factory test certificate?
Yes, if it is on the Circular 36/2019 list. Article 31(1) of Law 84/2015 requires inspection before first use, whether the equipment is new or used. The factory test report is an input to the inspection, not a substitute for it.
2. Is a heat-treatment furnace on the safety list?
Not by name. Its components can be: a gas generator, gas piping, an air receiver above 0.7 bar, a steam supply or a hoist. Check each one’s nameplate values against Section I of the Circular 36/2019 list, and whether a sector ministry’s list applies to your site.
3. Will customs hold a boiler until a quality inspection is done?
Not under the quality rules, if it is medium risk. Circular 16/2026 places boilers above 0.7 bar in the medium tier, and Decree 37/2026, Article 82(1), requires a declaration of conformity before the goods are placed on the market instead of an inspection on import. High-risk goods, such as lifts, are different.
4. Can a transformer make a 60 Hz Japanese machine run properly in Vietnam?
No. A transformer changes voltage, not frequency. A 60 Hz-only motor needs a frequency converter or the maker’s written confirmation that it can run at 50 Hz; for a new order, specify 380 V, 50 Hz in the purchase order.
5. Who carries out the safety inspection, and can Sunsho Trade do it?
An inspection organisation holding a certificate of eligibility whose scope covers your equipment type (Law 84/2015, Article 32). Inspection and certification are carried out by designated inspection bodies. We supply the equipment, collect the Japanese technical file and support installation, maintenance and spare parts.