You agreed a price “FOB Ho Chi Minh”. Then an origin invoice arrives with lines you never discussed — THC, CIC, LSS, seal fee, bill fee, telex release, VGM submission — and the supplier says none of them were in the price. Usually nobody is cheating. The argument is about which of those lines the three letters were supposed to swallow — and they were never written to answer that at a Vietnamese port.
💬 An origin invoice in front of you with lines you never agreed to? Sunsho Trade coordinates sourcing and shipment handling from Vietnam and can go through the charge list with you, line by line. Ask us to read the origin invoice.
Which origin charges land on you, by term
Under EXW you carry every line from the supplier’s gate onward; under FCA and FOB the seller carries the origin block and the export declaration; under CFR and CIF the seller also carries the ocean freight — but the carrier’s surcharges follow whoever contracts the carriage, which is why they are the lines that get argued about.
The reference edition here is Incoterms 2020, published by the International Chamber of Commerce; name the edition in the contract rather than writing “FOB” alone. The rules split by mode. FOB and CIF, like CFR, are sea and inland waterway rules and deliver on board a vessel; FCA and CIP are the any-mode equivalents, and they are what fits a container handed to the carrier at a depot or terminal. Under the 2020 edition CIF requires the seller to insure only at the minimum level, Institute Cargo Clauses (C), unless the parties agree more; CIP requires the higher level. Match the rule to the way the goods actually move, and name the place in the term itself.
A Vietnamese origin invoice itemises. The depot move and the terminal move are billed apart, the seal, the bill and the telex release each carry their own line, and in our experience local charges are invoiced in dong while the freight is quoted in dollars, so the conversion rate is a term worth naming. A supplier who says “FOB includes everything” is describing a bundle the invoice will not be laid out in.
| Charge line on a Vietnamese origin invoice | What it is, and how it behaves here | EXW | FCA | FOB | CFR / CIF |
|---|---|---|---|---|---|
| Loading at the supplier’s premises | Stuffing at the plant, in Binh Duong, Dong Nai, Long An or wherever it sits | Buyer | Seller, if the named place is the seller’s premises | Seller | Seller |
| Inland trucking to the port | To Cat Lai, Hai Phong or the port named; a southern factory quoted from a northern port is a different shipment | Buyer | Depends on the named place | Seller | Seller |
| Empty pick-up, lift-on / lift-off, gate moves | The empty is released at a depot, not the terminal, so the two moves arrive as separate lines | Buyer | Confirm with your forwarder | Seller, in normal practice | Seller |
| Export declaration and clearance | Lodging the electronic declaration through VNACCS/VCIS, plus licences and any export permit | Buyer | Seller | Seller | Seller |
| VGM submission | Verified gross mass, declared before the terminal’s cut-off; a late VGM costs the vessel, not just the fee | Buyer | Seller | Seller | Seller |
| Seal fee | The numbered seal goes onto the declaration, so a seal cut for inspection means a second one | Buyer | Seller | Seller | Seller |
| Terminal handling at origin (THC) | Terminal-to-vessel handling, priced inside a state bracket, so the least movable line here | Buyer | Market practice — confirm | Seller, in normal practice | Seller |
| Bill of lading / documentation fee | House bills and carrier bills behave differently on release and on claims | Buyer | Buyer | Usually the named shipper — confirm | Seller |
| Telex release fee | Release without original bills; a carrier procedure, instructed by the named shipper | Buyer | Buyer | Usually the named shipper — confirm | Seller, where offered |
| CIC (Container Imbalance Charge) | Carrier surcharge for repositioning empties out of a net-export region; outside the bracket, so it varies on one lane | Buyer | Buyer | Buyer in principle, often collected at origin — confirm | Seller |
| LSS (Low Sulphur Surcharge) | Carrier surcharge for compliant low-sulphur fuel; also outside the bracket | Buyer | Buyer | Buyer in principle, often collected at origin — confirm | Seller |
| Ocean freight | The sea leg itself | Buyer | Buyer | Buyer | Seller |
| Marine cargo insurance | Cover in transit | Buyer, if wanted | Buyer, if wanted | Buyer, if wanted | CFR none required; CIF seller buys the minimum, Institute Cargo Clauses (C), unless more is agreed |
Destination lines — terminal handling, the delivery order, the import declaration, duty and import VAT, demurrage and storage — stay with the buyer on all five terms. That is where a cheap-looking CIF offer reappears, collected by the supplier’s nominated forwarder once the goods have arrived and the leverage is gone.
No amounts appear here, deliberately: every line moves by carrier, lane, container type, port and season, so take each from a written quotation with a validity date. Rebuilding two offers quoted on different terms into one comparable sheet is a separate job — the worksheet is in how to compare two Vietnamese supplier quotations.
The order the lines land, and where an argument gets expensive
Origin charges arrive in sequence, and the two points where they turn into real money — the customs channel and the bill of lading — are both decided after the price is agreed and long after anyone is willing to reopen it.
The normal sequence runs: booking; the empty released at a depot and trucked to the plant; stuffing and sealing on site; VGM declared; the declaration lodged and routed into a channel; the truck gated in before the cut-off; the box loaded; the bill of lading issued; and only then telex release or original bills.
The channel is the first trap. A Vietnamese export declaration is routed into one of three: green, where the goods clear on the declaration itself; yellow, where the documents are examined; red, where the container is physically inspected. Green costs nothing beyond the fees already quoted; yellow costs time, and time in front of a cut-off is what makes a box miss its vessel. Red costs money — the container is moved, opened, in practice unstuffed and restuffed, the seal cut and replaced, with storage running meanwhile — and almost no quotation says whose account that is. Allocate it in writing, and by cause.
The bill of lading is the second. Whoever is named shipper controls the release, so a seller who has not been paid can decline to instruct the telex release, whatever the Incoterm says about delivery having happened. On an FOB purchase where your own forwarder issues the house bill, that leverage sits differently than on a CIF purchase routed through the supplier’s nominated forwarder. Decide which you are buying before you agree the term, not when the box is on the water.
💬 If you are not certain which term fits the way your goods move, ask before the contract is signed rather than after the container is gated in. Talk to Sunsho Trade.
What to ask before you accept an “FOB Ho Chi Minh” price
Six questions turn a three-letter price into a checkable one, and all six can be asked by email before you commit.
| Ask this | What a usable answer looks like |
|---|---|
| Which origin charge lines are inside your price? List them by name. | A named list — trucking, depot and terminal moves, declaration, VGM, seal, origin handling, documentation — and an explicit “everything else to your account” |
| Which port are you quoting from? | The port named, and the province the goods leave from |
| Who issues the bill of lading, the carrier or a forwarder? | A clear statement of which, and whose forwarder is nominated |
| Is telex release included, and who instructs it? | A named party, a named fee treatment, and the trigger for instructing it |
| Who pays if the container is routed for inspection? | A written allocation, split by cause — documentation error versus random selection |
| Is each line at 8% VAT, at 10%, or zero-rated, and what happens after 31 December 2026? | A line-level answer from the supplier’s accountant, not a verbal “no tax” |
One line is missing from that table because it is not always there. If your buyer claims a tariff preference, somebody has to apply for the certificate of origin before the vessel sails, and whoever applies will bill for it. Which form your goods need and which body issues it is set out in proof of origin from Vietnam by destination market — settle it while the price is still open.
Checking who you are dealing with before any of this is covered in how to verify a Vietnamese supplier remotely.
The rules behind these lines, checked on 15 September 2026
Two of these lines sit inside Vietnamese law, two are carrier surcharges with no Vietnamese basis at all, and one is a tax question whose answer changes on 1 January 2027 — which tells you where there is room to argue and where there is none.
Container handling at a Vietnamese seaport is not a free price. Circular 12/2024/TT-BGTVT, issued by the Ministry of Transport on 15 May 2024 and in force since 1 July 2024, sets the mechanism for managing seaport service prices, including a maximum price for pilotage and brackets for berth and buoy use, container handling and towage. It replaced Circular 39/2023/TT-BGTVT, which had replaced Circular 54/2018/TT-BGTVT, so a forwarder still quoting you 54/2018 is two instruments out of date. Pushing THC down means arguing against a bracket, which is why the surcharges beside it are where a quotation actually varies.
Those surcharges have no Vietnamese basis at all. CIC recovers the cost of repositioning empty boxes out of a net-export region; LSS traces to the global 0.50% m/m sulphur limit under MARPOL Annex VI, Regulation 14, in force since 1 January 2020. Both are set by the carrier, outside the state bracket, which is why two quotations for the same lane in the same week can differ on them without either being wrong.
The export declaration is lodged electronically through VNACCS/VCIS under the Customs Law, No. 54/2014/QH13, and Circular 38/2015/TT-BTC as amended by Circular 39/2018/TT-BTC. That text changed this year: Circular 121/2025/TT-BTC, issued on 18 December 2025, amends both and took effect on 1 February 2026, so a checklist written before that date is the previous version.
Tax is the line most often wrong in a quotation handed to you today. Vietnam’s VAT regime was rewritten in 2025: the Law on Value Added Tax No. 48/2024/QH15 took effect on 1 July 2025, guided by Decree 181/2025/ND-CP and Circular 69/2025/TT-BTC, which replaced the long-quoted Circular 219/2013/TT-BTC. The same Law zero-rates a properly documented export sale, on the conditions its Article 14 sets — a contract with the foreign buyer, a sale invoice, a cashless payment document and a customs declaration. Separately, Resolution No. 204/2025/QH15 of 17 June 2025 cuts the 10% rate by two points, to 8%, for the goods and services in Article 9(3) of that Law, from 1 July 2025 to the end of 31 December 2026. Its excluded sectors include telecommunications, financial services, real estate and excisable goods other than petrol; transport and logistics are not among them. So a quotation citing 219/2013 is citing superseded guidance. And unless the reduction is extended again, the same invoice may not carry the same rate either side of the new year, so a quotation valid across that boundary should say which rate it assumes. Checked against the published texts on 15 September 2026.
💬 Sunsho Trade is a Japanese-managed trading company based in Ho Chi Minh City and settles these charges on its own shipments. If you want an offer read line by line before you commit, send it to us.
One last origin cost: if your own country requires the commercial documents to be legalised or apostilled, that work happens in Vietnam — see apostille or legalisation for a Vietnamese dossier.
Frequently asked questions
1. Is terminal handling at a Vietnamese port a negotiable charge?
Barely. Container handling at Vietnamese seaports sits inside the price bracket set by Circular 12/2024/TT-BGTVT, in force since 1 July 2024 and checked as current on 15 September 2026. CIC and LSS sit outside it, so that is where two quotations on one lane genuinely differ.
2. Will the local charges on a Vietnamese origin invoice carry 8% or 10% VAT?
It depends on the line and on the date. Resolution No. 204/2025/QH15 cuts the standard rate by two points, to 8%, for eligible goods and services until the end of 31 December 2026, and transport and logistics are not among the excluded sectors. Ask for the treatment line by line, in writing, and what the quotation assumes after that date.
3. Who pays when a Vietnamese export declaration is routed for physical inspection?
Whoever the contract says — and most contracts say nothing, so the cost lands on whichever party the forwarder can invoice. A red-channel container is moved, opened, restuffed and resealed, storage running meanwhile. Allocate it before shipment, and by cause.
4. Can I buy FOB from a Vietnamese supplier and use my own forwarder?
Yes. Under FOB the buyer contracts the carriage, so nominating your own forwarder is consistent with the term and the origin block stays with the seller. Expect the carrier surcharges to reach you rather than the supplier, and ask for the goods priced on both FOB and CIF to see what the freight was carrying.
5. Is a telex release required by Vietnamese law?
No. It is a commercial practice of the carrier under the contract of carriage, not a Vietnamese requirement, and the named shipper instructs it. Agree the fee, and who is entitled to instruct it, in the sale contract rather than after the vessel has sailed.
Incoterms decide risk and obligation. Invoices decide cash. Naming the charge lines in the contract is what makes the two agree.