ICT Conformity Compliance Strategy: 2025–2026

Hanoi, Vietnam – June 6, 2025 – As of now, the Ministry of Science and Technology has yet to issue an amended or replacement Circular for Circular No. 02/2024/TT-BTTTT, although a draft version had previously been introduced. This is expected to significantly impact the certification, declaration of conformity, and importation of ICT equipment into Vietnam. Let’s review key issues and compliance strategies for the upcoming period with expert Mr. Trần Thanh Phương from ExtendMax.

Context, Issues, and Relevant Legal Documents

How will conformity declaration for locally produced goods be handled?

According to  Circular No. 23/2024/TT-BTTTT from the Ministry of Information and Communications, Circular 30/2011/TT-BTTTT has been partially annulled, including procedures for the declaration of conformity for domestically manufactured goods. In such cases, conformity declarations are typically carried out under Circular 28/2012/TT-BKHCN via local Departments of Standards, Metrology and Quality. However, this conflicts with the fact that the Authority of Telecommunications remains the state regulatory body for ICT products (as per Circular 30/2011/TT-BTTTT). Therefore, it remains unclear where exactly conformity declarations for locally manufactured products should be submitted.

End of Technical Regulation Suspension Period on July 1, 2025

Under Circular 02/2024/TT-BTTTT, many technical regulations were temporarily suspended in whole or in part (e.g., testing under extreme or limit conditions), effective only until June 30, 2025. From July 1, 2025, these regulations will regain full force, even though domestic testing labs still lack adequate capacity—particularly in testing for maritime equipment standards.

Is WiFi 6E Now Officially Allowed in Vietnam?

As per Circular No. 01/2025/TT-BKHCN, the public and businesses are allowed to use WiFi 6E in Vietnam starting May 15, 2025. However, implementation issues remain.

One case recorded on May 23, 2025, involved a state quality inspection registration for a product with WiFi 6E support, which was rejected by the Authority of Telecommunications because the company failed to submit a manufacturer’s letter of commitment to disable the 6GHz band upon import. This is in accordance with Circular 02/2024/TT-BTTTT, which stipulates:

“Devices integrating WiFi 6E or WiFi 7 functions may only be certified and declared conforming if the manufacturer provides a written commitment that the 6GHz band is disabled and cannot be activated without manufacturer support.”

Important Technical Regulations Taking Effect Soon

Starting January 1, 2026, several new mandatory technical regulations will take effect. Notably:

• QCVN 135:2025/BTTTT – Basic cybersecurity requirements for IP cameras using Internet protocols. This regulation becomes mandatory on January 1, 2026. However, as of now, no testing lab has been designated or recognized to perform the required tests. This could create testing bottlenecks, risking import delays.
• QCVN 134:2024/BTTTT – Specific Absorption Rate (SAR) requirements for mobile phones, effective July 1, 2026. This test is both costly and time-consuming—up to 30 days per test.

Compliance Strategy for 2025–2026 Transition Period

Given the current uncertainty, overlaps, and discrepancies in regulation—and even the government agencies’ inconsistent guidance—ExtendMax recommends the following strategic compliance approach:

1. Build a phased testing and certification roadmap

Due to uneven timing in the lifting of suspensions and implementation of new regulations, businesses should plan according to the following milestones:

• Before July 1, 2025: Expedite testing and conformity certification for products affected by temporarily suspended standards. This helps avoid risks when stringent testing resumes.
• July 1 – December 31, 2025: Plan to import products (e.g., IP Cameras) not yet covered by QCVN 135:2025/BTTTT while the new standards are not mandatory. If possible, begin early testing to prepare for the 2026 mandate.
• From January 1, 2026 onward: Only import or manufacture products that have completed testing in accordance with the new regulations—particularly IP Cameras and mobile phones subject to QCVN 135:2025 and QCVN 134:2024.

2. Maximize use of MRA-recognized international labs

With domestic labs lacking capacity—especially for SAR and other complex tests—large enterprises and manufacturers should:

• Proactively work with international labs recognized under MRA agreements for QCVN 134:2024/BTTTT to conduct SAR testing for mobile devices.
• Advocate for the Ministry of Information and Communications (MIC) and the Authority of Telecommunications to accept foreign test reports or designate more international labs to meet demand.

Note: Since QCVN 134:2024/BTTTT relates to cybersecurity, few or no international labs may be recognized for testing under this standard.

3. Proactively drive WiFi 6E/WiFi 7 product importation

For companies aiming to promote WiFi 6E/7 products, it is advisable to:

• Engage with the Ministry of Science and Technology for guidance on conformity certification and declaration procedures for 6GHz WiFi products.
• Continue disabling the 6GHz band on imports until official regulatory updates provide clearer implementation guidelines.

4. Use specialized consulting services to optimize costs and time

For businesses lacking internal resources to track legal changes and handle documentation:

• Partnering with a professional consultancy like ExtendMax offers a strategic advantage:
• Comprehensive support from product classification, applicable standard identification, test capability assessment to submission.
• Regular updates on the latest changes from MIC and related authorities.
• Minimization of delays and cost risks thanks to extensive experience across hundreds of successful projects.

Starting July 1, 2025, the legal landscape for ICT conformity certification in Vietnam will enter a period of major transition. While it poses challenges, it also offers opportunities for well-prepared businesses. A structured, proactive, and well-informed compliance strategy is essential.

ExtendMax is a leading provider of conformity certification and declaration services, trusted by top multinational companies. We are internationally recognized with awards like SME100 Asia and Stevie Awards. Our CEO, Mr. Trần Thanh Phương, is acknowledged as Vietnam’s leading legal expert in ICT conformity and licensing, with extensive experience supporting global clients like IBM, Dell, LEGO, Fujitsu, and Lenovo.

We are committed to delivering #1 trusted service, excellent quality, and transparent legal processes.