Vietnam's Ministry of Industry and Trade (MoIT) has issued Consolidated Document No. 43/VBHN-BCT (2026), folding two earlier circulars — No. 38/2025/TT-BCT and No. 26/2026/TT-BCT — into a single, tightened rulebook governing how Chinese goods may transit Vietnamese territory. The ministry frames the move as a housekeeping exercise: merging overlapping regulations into one transparent legal text so logistics and trading companies have a single reference point for customs procedures. In practice, the consolidated text does something more consequential — it narrows the physical and temporal space in which transit cargo can move, at a moment when Vietnam is under intense pressure to prove it isn't a backdoor for Chinese goods dodging tariffs in the US and EU.
Four border gates, and nowhere else
The headline change is a “whitelist” for transit corridors. Under the new document, Chinese goods may only cross into and out of Vietnam through four designated pairs of international border gates:
- Lào Cai (Vietnam) – Hekou (China)
- Hữu Nghị (Vietnam) – Youyiguan (China)
- Móng Cái (Vietnam) – Dongxing (China)
- Đồng Đăng (Vietnam) – Pingxiang (China)
Any additional crossing can only be opened if the Vietnamese and Chinese governments jointly agree to it through a bilateral arrangement — meaning logistics firms can't simply route transit cargo through whichever gate is most convenient or least congested. Routes via third countries are likewise not part of the current framework. The intent, according to Vietnamese officials cited in domestic coverage of the rule, is to concentrate enforcement resources on a small number of corridors rather than spread customs oversight thin across the dozens of border crossings Vietnam shares with China.
A hard 30-day clock
Transit goods now face an explicit dwell-time cap: cargo may remain inside Vietnamese territory for a maximum of 30 days from the date customs procedures are completed at the entry border gate. Businesses needing more time must apply for an extension through the competent authority before the clock runs out; the consolidated text does not spell out a fixed cycle of how many extensions are available, so companies should treat any extension as case-by-case rather than assume an automatic renewal.
What can transit, and what definitely can't
Not everything qualifies for transit in the first place. Goods that are prohibited from export, temporarily suspended from export, prohibited from import, or temporarily suspended from import under Vietnamese law are barred from transiting the country outright — no permit can override that. Everything else needs a transit permit issued by the competent authority before it moves; the document also lays out the required documentation, procedures, and processing timeframes for that permit, along with rules on how the goods may be transported once approved.
Cargo is tracked from the moment it enters
Perhaps the most operationally significant section concerns in-transit supervision. Once goods cross into Vietnam, customs authorities maintain continuous oversight until they exit. Several requirements run through the whole journey:
- Cargo must enter and exit only via the registered gates and route, with the volume leaving the country matching the volume that entered.
- Goods must remain in their original packaging and seals — no repackaging, reprocessing, swapping, or consolidating shipments into different containers while in Vietnam.
- If damage, breakage, or any other incident occurs during transport or warehousing, the cargo owner or carrier must immediately notify customs at the location where the incident happened, so an official record can be made before further handling.
- As a matter of principle, transit goods may not be sold or consumed inside Vietnam.
Worth noting: the consolidation isn't purely about tightening. Some domestic reporting on the document highlights that it also trims certain paperwork requirements and shortens processing times elsewhere, while pushing more approval authority down to local customs offices — a nod to logistics companies that have complained about congestion and inconsistent enforcement at individual crossings.
Why this, and why now
The ministry's own language sticks to procedural housekeeping, but the timing speaks for itself. Vietnam has spent the past two years under growing scrutiny from Washington and Brussels over whether Chinese-made goods are being routed through Vietnamese territory, lightly processed or simply relabeled, and then exported as “Made in Vietnam” to skirt tariffs aimed at China. US officials, including statements made before Congress in 2025, have explicitly accused Vietnam of serving as a pass-through for Chinese goods, and Vietnamese officials have responded over the past year with a string of directives aimed at cracking down on transshipment fraud and tightening origin-of-goods enforcement. The EU has voiced similar concerns about anti-dumping circumvention through Southeast Asian “gateway” routes.
Seen against that backdrop, the four-gate whitelist and the 30-day cap function as much as a credibility move as a customs reform. By shrinking the number of entry points it must police and putting a hard ceiling on how long cargo can sit in the country, Vietnam narrows the practical window in which goods could be diverted, relabeled, or otherwise manipulated to obscure their Chinese origin — and gives itself a cleaner answer the next time a trading partner asks how it controls transit flows.
What it means for businesses moving goods through Vietnam
For Chinese exporters, freight forwarders, and Vietnamese logistics companies handling transit cargo, a few practical takeaways follow directly from the new text:
- Re-check your routing. If a shipment plan relies on a border crossing outside the four named pairs, it no longer qualifies for transit and needs to be rerouted or reclassified.
- Build in permit lead time. Anything beyond the prohibited/suspended list needs a transit permit before it moves — leave time in the schedule for approval rather than assuming transit is automatic.
- Watch the 30-day window closely. Cargo sitting in bonded warehouses or awaiting onward transport needs active tracking against the entry date; an extension request filed too late won't help.
- Keep packaging and seals intact. Any plan that involves consolidating shipments, repackaging, or reprocessing goods while they're in Vietnam is now explicitly off-limits for transit cargo.
- Report incidents immediately, not after the fact. Damage or loss discovered during transit needs to go to customs at the time it's found, with documentation, rather than being resolved quietly downstream.
Companies with shipments currently in transit, or transit plans built around the older circulars, should review them against the consolidated document promptly — the merger took effect as the operative rulebook, and confusion between the old and new requirements is exactly the kind of gap customs enforcement is now positioned to catch.