1. Introduction: What Is the Purpose of Circular 36/2026/TT-BKHCN?

In the manufacturing, importing, and trading of electrical and electronic equipment in Vietnam, controlling product quality and safety levels is of paramount importance. Substandard electrical devices pose severe risks, including electric shock, short circuits, fire hazards, overheating, and operational interference with other equipment.

To enhance the management of product and goods quality based on risk classification, the Ministry of Science and Technology (MOST) issued Circular 36/2026/TT-BKHCN on June 30, 2026, taking effect on July 1, 2026. This Circular stipulates the list of medium-risk and high-risk products and goods under the management responsibility of MOST.

A crucial point for enterprises to note is that this updated list is not merely a product inventory. The Circular explicitly links each product category to its applicable technical regulations (QCVN), conformity assessment schemes, and quality management mandates.

Electrical and Electronic Equipment Categories Requiring Attention

According to the list promulgated with Circular 36/2026/TT-BKHCN, electrical and electronic devices are classified under distinct regulatory groups.

Regarding electrical safety, the list covers single-phase electrical equipment operating at nominal voltages up to 250V, while excluding certain devices powered exclusively by storage batteries, rechargeable batteries, or direct current (DC) sources.

Key products falling within this scope include:

• Instantaneous water heaters;

• Storage water heaters;

• Hair dryers;

• Electric rice cookers;

• Electric kettles;

• Hair care and styling appliances;

• Electric fans;

• Immersion liquid heaters;

• Specified low-voltage electric wires and cables.

Notably, the list also encompasses electrical and electronic equipment regulated for Electromagnetic Compatibility (EMC). Featured products include immersion water heaters, hand-held electric drills, vacuum cleaners, and other appliances governed by corresponding technical standards.

Therefore, enterprises should not rely solely on a product’s commercial trade name to determine whether conformity certification is required. A thorough cross-check must be performed considering product classification, intended use, rated voltage, power supply type, HS code, regulatory scope, and specific exemption criteria.

2. How Should Enterprises Prepare to Comply with Circular 36/2026/TT-BKHCN?

With Circular 36/2026/TT-BKHCN coming into force on July 1, 2026, manufacturers, importers, and distributors of electrical and electronic goods must proactively audit all product lines currently circulating in the market.

Rather than waiting for market surveillance inspections or customs queries, enterprises should establish a structured management workflow covering product identification, testing, certification, and declaration of conformity.

Step 1: Review the Complete Product Portfolio

This is the vital first step. Enterprises should compile a master list of all electrical and electronic items currently or planned for:

• Local manufacturing;

• Importation;

• Wholesale/Retail distribution;

• Commercial trading;

• Market release.

Cross-reference each item against the product catalog in Circular 36/2026/TT-BKHCN. Beyond the commercial product name, evaluate:

Product Name -> Function -> Intended Use -> Voltage -> Power Source -> Wattage -> HS Code -> Applicable QCVN Standard.

For example, two versions of the same appliance—one AC-mains powered and the other battery-only—may fall under entirely different regulatory scopes. This renders preliminary product classification indispensable prior to filing for certification.

Step 2: Identify Applicable National Technical Regulations (QCVN)

Once a product is confirmed within the regulatory scope, identify its corresponding technical standard:

• For electrical safety, QCVN 4:2009/BKHCN and its amendment Amendment 1:2016 QCVN 4:2009/BKHCN remain the core standards cited in the list.

• For Electromagnetic Compatibility (EMC), products may be subject to QCVN 9:2012/BKHCN and Amendment 1:2018 QCVN 9:2012/BKHCN.

Crucially, a single product may simultaneously trigger multiple compliance mandates (e.g., both Electrical Safety and EMC). Businesses must assess products holistically rather than searching for a single standard based on appliance names alone.

Step 3: Determine the Required Conformity Assessment Scheme

Enterprises must pay close attention to the designated conformity assessment schemes (schemes 1, 5, or 7 under Circular 14/2026/TT-BKHCN, depending on the product type and regulatory requirements).

This means compliance procedures are not one-size-fits-all. Enterprises must clarify:

• Which risk group does the product belong to?

• Which QCVN technical regulations apply?

• Which assessment scheme (Scheme 1, 5, or 7) is mandated?

• Is third-party certification by an accredited body required?

• Is State Quality Inspection required for imported consignments?

• Must a Declaration of Conformity be completed prior to market distribution?

Determining these specifics upfront prevents testing against incorrect standards, selecting improper assessment schemes, or re-submitting dossier files.

Step 4: Prepare Technical Product Documentation

Enterprises should assemble a comprehensive Technical File for each model or product family. The dossier should include:

• Product name and SKU/Code;

• Specific Model designation;

• Product catalog/brochure;

• Technical specifications;

• User manual / Operating instructions;

• High-resolution product photos;

• Product rating label design;

• Manufacturer details;

• Importer/Distributor details;

• Voltage and power ratings;

• Circuit schematics (where required);

• Critical component list (CCL);

• Original manufacturer technical documents;

• Test reports;

• Certificates of origin and shipment documents.

For imported goods, commercial documents and shipment dossiers matching quality control criteria must also be prepared. The more complete the file from the outset, the smoother the evaluation process.

Step 5: Perform Product Testing

Product testing is a critical phase in the conformity certification journey. Enterprises must engage testing laboratories accredited for the specific test methods and QCVN standards required.

Depending on the product, test parameters may evaluate:

• Electrical safety;

• Dielectric strength / Voltage withstand;

• Leakage current;

• Insulation resistance;

• Heat and fire resistance;

• Mechanical structural integrity;

• Grounding/Earthing continuity;

• EMC disturbance emissions;

• Electromagnetic immunity.

Enterprises should review test parameters and product configurations before submitting samples to avoid sending non-commercial prototypes or missing technical data.

Step 6: Select an Accredited Certification Body

Where the Circular requires a Declaration of Conformity based on third-party certification, enterprises must select a certification body accredited or officially designated by MOST for the relevant scope.

ISSQ Institute of Quality is fully accredited to conduct product certification and testing for electrical and electronic products in accordance with QCVN 4:2009/BKHCN.

When choosing a certification body, verify:

• Scope of accreditation/designation;

• Technical expertise and lab capabilities;

• Experience with similar appliance categories;

• Turnaround timeframes;

• Sample requirements;

• Fee structures;

• Audit and assessment procedures;

• Post-certification support.

Selecting the right partner directly impacts product time-to-market.

Step 7: Complete the Declaration of Conformity 

Upon obtaining the Certificate of Conformity and finalizing the technical file, enterprises must submit the Declaration of Conformity to local authorities as required.

For specified imported goods, regulations mandate completing State Quality Inspection or filing conformity declarations prior to customs clearance and market distribution. Importers must manage these milestones carefully to prevent logistics bottlenecks or customs holds.

To expedite processing, ISSQ Institute of Quality offers end-to-end Declaration of Conformity services for electrical and electronic devices complying with QCVN 4:2009/BKHCN.

3. Common Compliance Pitfalls to Avoid

In practice, many businesses face delays not because their products fail safety standards, but due to procedural errors or incomplete documentation:

1. Relying Solely on Trade Names: Commercial names do not always reflect technical classifications or regulatory scopes.

2. Ignoring Exemption Clauses: Overlooking specific exclusions related to power source, operating voltage, or specialized commercial applications.

3. Confusing "Certification" with "Declaration": Conformity Certification (issued by a certification body) and Declaration of Conformity (administrative registration) are distinct legal steps.

4. Using Inapplicable Test Reports: Test reports must match the exact model, component structure, and applicable QCVN standards.

5. Failing to Re-evaluate Product Modifications: Changing key components, suppliers, enclosure designs, or power ratings requires reviewing the validity of existing certificates.

4. Building a Proactive Compliance Roadmap

To adapt smoothly to the new requirements, enterprises should implement a 5-step operational model:

Product Portfolio Audit -> Risk & Scope Classification -> Determine Applicable QCVN Standards -> Engage Accredited Certification Body (ISSQ)  -> Complete Declaration of Conformity  -> Post-Market Surveillance & Maintenance.

Establishing an internal management tracking matrix is highly recommended:

This standardized tracking matrix aligns technical, import/export, legal, quality assurance, and sales departments around a single source of truth.

Circular 36/2026/TT-BKHCN (effective July 1, 2026) establishes a updated regulatory environment for electrical and electronic products in Vietnam.

For businesses operating in categories covered by QCVN 4:2009/BKHCN, QCVN 9:2012/BKHCN, and related standards, early action is essential. Companies must audit their product lines, confirm regulatory scope, select proper evaluation schemes, and secure necessary certifications ahead of enforcement deadlines.

Need QCVN 4 Compliance and Certification Support?

For expert guidance, product testing, and accredited QCVN 4 certification services, contact ISSQ Institute of Quality:

• Hotline: +84 981851111

• Email: vienchatluong@issq.org.vn | tcvn@issq.org.vn