A used-machine file for a Vietnamese factory can fail at the port even when the machine itself is sound. It fails when the nameplate year is misread, when the arrival slips into the next calendar year, or when the file relies on a maker’s certificate that nobody can produce. All three can be checked in Japan before any money moves.
💬 Looking at a specific used machine in Japan? Send us the listing and nameplate photos before you pay a deposit — Sunsho Trade sources equipment from Japan and reads the seller’s papers in Japanese. Tell us about the machine.
Four checks before you pay a Japanese dealer a deposit
Do not pay until you can answer four questions on paper: the manufacture year in Western calendar terms, the machine’s age in the year it will actually arrive, the age limit for its HS heading, and whether it was made in a country whose maker’s certificate the Circular accepts — and the maker will issue one — or it must go to inspection.
| # | Check | Where the answer comes from | If you cannot answer it |
|---|---|---|---|
| 1 | Manufacture year, converted from the Japanese era if needed | Nameplate photo, confirmed in writing by the seller | You cannot calculate the age. Stop |
| 2 | Age in the year the machine reaches the Vietnamese border gate | Your realistic shipping date, not today’s date | Assume the later year |
| 3 | Age limit for the machine’s HS heading: 10, 15 or 20 years | Article 6(1) and Appendix I of Circular 56/2026 | Classify the machine first |
| 4 | Country of manufacture on the nameplate is Japan (or another G7 country or Korea), and the maker will certify it | Nameplate, then the manufacturer — not the dealer | Plan for the inspection route |
Reading the year. Japanese nameplates often give the year of manufacture (製造年) in the Japanese era rather than the Western calendar. Heisei began on 8 January 1989 and Reiwa on 1 May 2019, so Heisei N is 1988 + N, and Reiwa N is 2018 + N; 2019 appears as both Heisei 31 and Reiwa 1 (令和元年). Have the seller confirm the Western year in writing and check the serial number against the documents.
Counting the age. Article 3(4) of Circular 56/2026 defines age as the time in years from the year of manufacture to the year of import, and the year of import is the year the goods reach a Vietnamese border gate. The note under Appendix I counts whole years, not months, and gives its own example: made in January 2008, arrived in December 2018, age 10.
A worked example from the Japan end: a machine whose HS heading is not in Appendix I, so the default 10-year limit applies, with a nameplate reading Heisei 29. Heisei 29 is 2017. Arriving in 2027 it is 10 and inside the limit. If the vessel slips and it reaches Vietnam in January 2028, it is 11 and outside it — the same machine, the same paperwork, a different outcome. Plan against the later year.
Maker’s certificate or inspection: which route your machine takes
If the machine was manufactured in Japan (a G7 country), Article 9(1)(b) lets you prove year and standard with the original manufacturer’s certificate, legalised and translated into Vietnamese; if it was made elsewhere, or the maker will not issue one, the file needs an inspection certificate from a designated inspection body instead.
The Circular names a certificate of the manufacturer (giấy xác nhận của nhà sản xuất) on year and manufacturing standard. The condition is where the machine was made, not where it is bought: the route is open only to machines manufactured in a G7 country or Korea. A machine sold in Japan but built in a plant outside those countries — including a Japanese-brand model built abroad — goes to inspection, so read the country of manufacture on the nameplate. A dealer’s statement or an auction lot sheet is not a maker’s certificate. Whether a maker will certify a machine that has passed through other hands is the maker’s decision, so get its answer in writing early.
The Circular still says “consular legalisation”, but since 11 September 2026 Decree 293/2026/ND-CP, Article 25(2) and (3), exempts an apostilled public document from a Convention state from consular legalisation, and a Vietnamese body may not ask for more. Japan has lodged no objection to Vietnam’s accession on the HCCH notifications page. Our note on apostille or legalisation explains why a maker’s certificate is notarised first. In Japan the chain is a notary, then the Legal Affairs Bureau certifying the notary’s seal, then the apostille from the Ministry of Foreign Affairs; in some prefectures, including Tokyo, the notary office can arrange all three in one visit — confirm with the notary office. Decree 293, Article 27(1), also requires a Vietnamese translation, certified or notarised unless a specialised law says otherwise — ask the customs office how it wants it certified.
Without a maker’s certificate, the file moves to inspection. Article 11(1) requires the certificate to state the machine’s identity, year and maker; when and where it was inspected; whether it was running; the method and standard applied; and a conclusion against Article 6. Under Article 11(2)(b) it is valid for no more than six months from issue to the machine’s arrival at the Vietnamese border gate — so a certificate issued too early in Japan can expire on the water.
Only a designated body can issue it. Article 12(1) makes the Ministry of Science and Technology publish the list of designated bodies on its portal, and Article 12(2)(b) allows a foreign body to be designated if it is accredited under a recognised mutual-recognition arrangement. Bodies designated under Decision 18 keep working until their designation expires (Article 17(1)). Check the current list, and check that the body’s scope covers your machine, before you book.
💬 Not sure whether your seller can get a maker’s certificate? We can put the question to the Japanese side in Japanese and tell you which route the file is on. Ask about a machine.
Every document, who produces it and when
The file splits cleanly by author, and every Japan-side row has to be settled before the machine leaves Japan.
| Document | Produced by | Certified or legalised | When in the sequence |
|---|---|---|---|
| Nameplate photos, serial number, written Western-calendar year | Japanese seller | None | Before the deposit |
| Catalogue, technical data, design capacity and consumption figures | Seller or maker | None | Before the deposit |
| Maintenance and repair history | Seller or previous owner | None | Before the deposit |
| Manufacturer’s certificate of year and standard (maker’s route; machine made in Japan, another G7 country or Korea) | The manufacturer | For a Japanese maker: notary, Legal Affairs Bureau, then apostille in Japan; Vietnamese translation | Before shipment |
| Inspection certificate (inspection route) | Designated inspection body | Issued under Article 11; valid six months to arrival | Before arrival, or within 30 days after the machine goes into storage |
| Inspection service registration confirmed by the body | Vietnamese importer, confirmed by the body | None | At customs declaration, if no certificate yet |
| Customs declaration and commercial documents | Vietnamese importer or its broker | None | On arrival |
| Enterprise registration certificate copy | Vietnamese importer | Only if customs cannot pull it from the database (Article 9(1)(a)) | On arrival, if asked |
| Import entrustment document | Importer and the factory | None | Only if a third party imports on the factory’s behalf |
| Ministry approval letter (over-age route) | Ministry of Science and Technology | None | Before shipment (recommended); filed at customs (Article 10(4)) |
One set of documents is filed with the customs office where the declaration is registered (Article 9(2)).
The file in order, Japan side then Vietnam side
The Japan-side steps are the ones nobody in Vietnam can do for you, and they are the ones that cannot be repeated once the machine has shipped.
- Settle the four checks with the seller.
- Choose the route. Maker’s certificate with apostille and translation, or inspection. If inspecting in Japan, time the certificate so it is still valid on arrival.
- Ship and declare with the Article 9 documents.
- Storage pending inspection, if needed. Under Article 9(3)(a), an importer holding neither certificate may take the goods into storage under customs law after lodging an inspection-service registration confirmed by a designated body.
- Lodge the certificate within 30 days of the machine going into storage (Article 9(3)(b)).
- Clearance. Customs clears only a complete file with, where inspection applies, a certificate concluding the machine meets Article 6. If it does not, the enterprise faces an administrative penalty.
The electrical data on the nameplate, and any boiler, pressure vessel or furnace duties after arrival, are a separate branch — see importing Japanese furnaces and boilers into Vietnam.
Over the age limit: the Article 10 route
An enterprise already producing in Vietnam can ask the Ministry of Science and Technology to allow an over-age machine that keeps at least 85% of its design capacity or efficiency and uses no more than 15% more materials or energy than designed — but it is an application, not an entitlement.
Article 10 allows the application only to maintain existing production. It goes to the Ministry in person, by post or online, with the Form 05 request explaining the need and intended use, and an inspection certificate. For this route Article 11(1)(g) asks the inspector for more: operating and maintenance condition, remaining capacity, consumption against design, remaining service life, and colour photographs including the nameplates. At customs the importer then files the Ministry’s approval letter (Article 10(4)).
In our reading, remaining capacity is hard to evidence on a machine that cannot be powered up where it stands, so ask the seller whether it can be run for the inspector — and get the Ministry’s answer before you pay.
Which rules apply from 5 September 2026
Circular 56/2026/TT-BKHCN of the Ministry of Science and Technology now sets the criteria, the file and the inspection rules for used machinery in HS Chapters 84 and 85 imported for production in Vietnam, and a transition clause keeps the older Decision 18 rules for files already under way.
| Instrument | Date | What it does for your machine |
|---|---|---|
| Circular 56/2026/TT-BKHCN | Issued and in force 5 September 2026 | Scope (Article 1), age and standards criteria (Article 6), import file (Article 9), over-age route (Article 10), inspection certificate (Article 11), inspection bodies (Article 12) |
| Circular 56, Appendix I | Same | Headings allowed 20 years (for example 84.20, 84.54, 84.55, 84.56–84.63, 84.65, 84.79, 84.39–84.41) and 15 years (84.19.35) |
| Decision 18/2019/QD-TTg, as amended by Decision 28/2022/QD-TTg | Earlier regime | Still governs declarations registered before 5 September 2026 that were waiting for an inspection result, and over-age applications already received (Circular 56, Article 17) |
| Decree 293/2026/ND-CP | In force 11 September 2026 | Apostilled public documents from Convention states are exempt from consular legalisation in Vietnam (Article 25) |
Checked against the published texts on 18 September 2026.
Three rules sit underneath. Article 4(3) allows used machinery only for the importing enterprise’s own production in Vietnam, so a machine bought to resell does not qualify. Article 6(2) requires it to meet Vietnam’s national technical regulation on safety, energy saving and environmental protection or, where none exists, the Vietnamese standard or a G7 or Korean national standard. And Article 1(2) takes some cases outside the Circular — among them the business of temporary import for re-export (but not temporary imports for processing contracts or for investment projects), machinery on a ministry’s high-risk product list, and machinery a line ministry regulates by its own instrument. Outside this Circular means another rulebook, not no rulebook. Read Appendix I line by line against your HS code; the 20-year lines are specific headings, not whole sectors.
What Sunsho Trade does here, and what it does not
We look for the machine in Japan or check one you have found, read the seller’s papers in Japanese and coordinate with the Vietnam-side filing; the inspection itself is carried out by a designated inspection body.
Sunsho Trade is a Japanese-managed trading company in Ho Chi Minh City. We source any equipment you need from Japan — heat-treatment equipment and industrial washing and cleaning machines are lines we supply regularly — with installation support, maintenance and spare parts. Because Article 4(3) ties a used machine to the factory’s own production, the factory stays the importer, or the principal behind an entrusted import.
💬 Want a second pair of eyes on a used-machine file before you sign? Send the nameplate photos and the seller’s documents and we will tell you plainly what is missing. Contact us about sourcing from Japan.
Frequently asked questions
1. How is the age of a used machine calculated?
Year of import minus year of manufacture, in whole years. The year of import is the year the machine reaches a Vietnamese border gate (Circular 56/2026, Article 3(4)), so a delayed arrival can push a machine over its limit.
2. Which machines are allowed more than 10 years?
Those listed in Appendix I of Circular 56/2026: certain metalworking, casting, rolling (including 84.20 and 84.55) and machine-tool headings, pulp and paper machinery, and the whole of heading 84.79 at 20 years, and heading 84.19.35 at 15 years. Check your exact HS code, not the sector name.
3. Can a Japanese used-machine dealer issue the manufacturer’s certificate?
No. Article 9(1)(b) names a certificate of the manufacturer, and only for machines made in a G7 country or Korea. If the maker will not issue one, the file needs an inspection certificate from a designated inspection body.
4. Does the manufacturer’s certificate still need the Vietnamese embassy in Japan?
Since 11 September 2026 an apostille replaces consular legalisation for public documents from Japan (Decree 293/2026, Article 25). For a maker’s certificate, the apostille goes on the Japanese notarial certificate.
5. Can we import a used machine and resell it to another factory?
No. Article 4(3) of Circular 56/2026 allows used machinery only to serve the importing enterprise’s own production in Vietnam.
Checked on 18 September 2026 against the signed text of Circular 56/2026/TT-BKHCN on the Ministry of Science and Technology portal, Decree 293/2026/ND-CP on the Government portal and the HCCH notifications page. Confirm anything load-bearing with your customs office before you rely on it.