EXTENDMAX - 25/11/2025 - On 14 November 2025, the Ministry of Industry and Trade issued Circular No. 52/2025/TT-BCT, stipulating the list of vehicles and equipment subject to mandatory energy labeling and the implementation roadmap. This Circular fully updates the groups of household, office–commercial, and industrial equipment that are required to carry energy labels, together with a detailed application schedule. The Circular takes effect from 1 January 2026.
At present, the Ministry of Industry and Trade and the Government have three documents simultaneously in force concerning minimum energy performance and energy labeling. However, each document has a different purpose and scope of application. To help you better understand the meaning and applicability of Circular No. 52/2025/TT-BCT, we will systemize and analyze the current legal instruments on minimum energy performance and energy labeling, including:
Decision No. 14/2023/QD-TTg of the Prime Minister:
This Prime Ministerial Decision promulgates the list and roadmap of energy-using vehicles and equipment that must be phased out, and low-efficiency power-generation units that are not permitted to be newly constructed. In substance, it sets out Vietnamese Standards (TCVN) on minimum energy performance levels that products must meet to be eligible for importation, and the efficiency thresholds that newly built power-generation units must satisfy. For imported products, enterprises must obtain test results proving compliance with the relevant TCVN standards specified in Decision No. 14/2023/QD-TTg in order to complete customs clearance.
However, this Decision does not regulate the roadmap or the list of products required to bear energy labels. Energy labeling is a step that businesses may carry out after customs clearance but before products are placed on the market, and it is governed by a separate instrument.
Decision No. 1725/QD-BCT dated 1 July 2024 of the MOIT:
This Ministerial Decision issues the “List of goods (with corresponding HS codes) subject to energy performance inspection and energy labeling under the management responsibility of the Ministry of Industry and Trade.” From a legal-meaning perspective, it provides detailed product descriptions, corresponding HS codes, and scope notes limited by power rating, capacity, and product type (excluding high-capacity or large-volume products that are not commonly used in household applications).
Under Article 4 of the Law on Promulgation of Legal Documents, a Ministerial Decision has not reached the level of a normative legal document, and therefore does not impose mandatory obligations on enterprises. Moreover, Decision No. 1725/QD-BCT contains no wording such as “must” or “mandatory”; it merely sets out a “List of goods (with corresponding HS codes) subject to energy performance inspection and energy labeling under the management responsibility of the Ministry of Industry and Trade.”
Circular No. 52/2025/TT-BCT of the Ministry of Industry and Trade:
This Circular stipulates the list of vehicles and equipment subject to energy labeling within the Ministry’s management scope, together with the implementation roadmap. Its scope covers only matters relating to “energy labeling,” and it does not regulate the list of vehicles and equipment required to meet minimum energy performance levels (which are already prescribed in Decision No. 14/2023/QD-TTg).
In terms of hierarchy, Circular No. 52/2025/TT-BCT is a lower-level instrument and does not replace or amend the Prime Minister’s Decision No. 04/2017/QD-TTg. However, in practice, it can be understood as a supplementary list introducing additional products compared with Decision No. 04/2017/QD-TTg regarding the energy-labeling product list and the corresponding application roadmap.
>>> Download link for Circular No. 52/2025/TT-BCT from the Government’s Portal: https://chinhphu.vn/?pageid=27160&docid=215951&classid=1&orggroupid=4
Guidance on implementing Circular No. 52/2025/TT-BCT
(issued by the Ministry of Industry and Trade)
Full contents of the Circular No. 52/2025/TT-BCT
| Ministry of Industry and Trade | Socialist Republic of Viet Nam |
| No.: 52/2025/TT-BCT | Hanoi, 14 November 2025 |
CIRCULAR
PROVIDING THE LIST OF VEHICLES AND EQUIPMENT SUBJECT TO MANDATORY ENERGY LABELING UNDER THE MANAGEMENT SCOPE AND IMPLEMENTATION ROADMAP OF THE MINISTRY OF INDUSTRY AND TRADE
Pursuant to the Law on Economical and Efficient Use of Energy dated 17 June 2010; and the Law No. 77/2025/QH15 amending and supplementing a number of articles of the Law on Economical and Efficient Use of Energy dated 18 June 2025;
Pursuant to Decree No. 40/2025/ND-CP dated 26 February 2025 of the Government defining the functions, duties, powers, and organizational structure of the Ministry of Industry and Trade;
At the proposal of the Director General of the Department of Innovation, Green Transformation and Industrial Promotion;
The Minister of Industry and Trade hereby issues this Circular providing the list of vehicles and equipment subject to mandatory energy labeling under the management scope and implementation roadmap of the Ministry of Industry and Trade.
Article 1. Scope and subjects of application
1. This Circular provides the list of vehicles and equipment subject to mandatory energy labeling under the management scope and the implementation roadmap of the Ministry of Industry and Trade.
2. This Circular applies to organizations and individuals engaged in the manufacture, import, distribution, and trading of products included in the list of vehicles and equipment subject to mandatory energy labeling under the management scope of the Ministry of Industry and Trade.
3. This Circular does not apply to organizations and individuals engaged in the manufacture, import, distribution, and trading of the following products:
a) Vehicles and equipment manufactured, assembled, or imported for direct use for national defense and security purposes, imported under separate regulations of the Prime Minister;
b) Vehicles and equipment for temporary import and re-export; transit, transshipment; and diplomatic or consular goods;
c) Vehicles and equipment used for repair/replacement or for inspection and testing of energy performance levels.
Article 2. List of vehicles and equipment required to carry energy labels
The list of vehicles and equipment subject to energy labeling is divided into the following groups:
1. Household equipment group, including: straight tubular fluorescent lamps; compact fluorescent lamps; electromagnetic and electronic ballasts for fluorescent lamps; air conditioners; refrigerators; household washing machines; electric rice cookers; electric fans; television sets; LED lamps; storage-type water heaters; induction cookers; infrared cookers; microwave ovens.
2. Office and commercial equipment group, including: photocopiers; printers; computer monitors; laptops; desktop computers; commercial refrigerated cabinets; commercial air conditioners.
3. Industrial equipment group, including: distribution transformers; electric motors; LED lamps for street and road lighting.
Article 3. Energy labeling implementation roadmap
1. For the household equipment group and the industrial equipment group
a) Mandatory energy labeling shall be applied to the following household and industrial equipment: straight tubular fluorescent lamps; compact fluorescent lamps; electromagnetic and electronic ballasts for fluorescent lamps; air conditioners; refrigerators; household washing machines; electric rice cookers; electric fans; television sets; LED lamps; storage-type water heaters; distribution transformers; electric motors;
b) Voluntary energy labeling shall be applied until 31 December 2026 to: induction cookers; infrared cookers; microwave ovens; LED lamps for street and road lighting;
c) Mandatory energy labeling shall be applied from 1 January 2027 to: induction cookers; infrared cookers; microwave ovens; LED lamps for street and road lighting.
2. For the office and commercial equipment group
a) Mandatory energy labeling shall be applied to laptop computers and commercial refrigerated cabinets;
b) Voluntary energy labeling shall be applied to: photocopiers; computer monitors; printers; commercial air conditioners;
c) Voluntary energy labeling shall be applied until 31 December 2026 to desktop computers;
d) Mandatory energy labeling shall be applied from 1 January 2027 to desktop computers.
3. Voluntary energy labeling is encouraged for vehicles and equipment not included in the list specified in Article 2 of this Circular, provided that national standards on energy performance levels are available and domestic testing capability exists.
Article 4. Implementation responsibilities
1. The Department of Innovation, Green Transformation and Industrial Promotion under the Ministry of Industry and Trade is responsible for providing guidance, inspecting, and supervising energy labeling for the groups of vehicles and equipment subject to energy labeling as specified in Article 3 of this Circular;
2. Provincial People’s Committees shall direct relevant specialized agencies to inspect and supervise the implementation of energy labeling for vehicles and equipment within their localities, in accordance with the list and roadmap stipulated in this Circular.
Article 5. Effect and enforcement responsibilities
1. This Circular takes effect from 1 January 2026.
2. During implementation, if any difficulties arise, agencies, organizations, and individuals shall promptly report them to the Ministry of Industry and Trade for consideration and amendment or supplementation of this Circular.
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Recipients:
| For the Minister
Nguyễn Hoàng Long |
