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Is server, switch router, gateway imported close to 01 Sep 2019 still under EMC SDoC?

  19/07/2019

Ussually State Inspection Authorities and Customs Authorities will base on the regulations in effect at the time of import (the date that Product Quality Inspection Registration acknowleged by State Inspection Authority or the date of the import and export goods declaration). However, unlike other state quality inspection authority, the VNTA is currently based on regulations that are effective at the time of submitting Type Approval application or the time of submitting SDoC to VNTA. This implementation has several criticle points we can learn through the following example:

Case 1: PQIR acknoledged before July 1, 2019, submit TA application dossier or SDoC to VNTA after July 1, 2019
1. PQIR for imported server computer was submitted by importer to VNTA and acknoledged by VNTA on June 20 according to TCVN 7189: 2009 standard (standard in effect at that time).

2. After 2 days of customs clearance, the importer conducted testing according to TCVN 7189:2009 standard, the normal testing time is 02 weeks. TCVN 7189:2009 test report was obtained after July 1, 2019

3. On July 12, 2019, the importer submitted the Self-assessment Declaration of Conformity (SDoC) for the imported goods according to TCVN 7189:2009 and was rejected by the Telecommunications Department because at this time TCVN 7189:2009 has been replaced by QCVN 118: 2018/BTTTT from July 1, 2018.

4. Telecommunications Department instructs import enterprises to re-test according to QCVN 118: 2018/BTTTT and make SDoC according to QCVN 118: 2018 / BTTTT (although earlier PQIR for imported server computer was submitted by importer to VNTA and acknoledged by VNTA on June 20 according to TCVN 7189: 2009 standard)

Therefore, in fact, there have been cases where the test products meets requirement of TCVN 7189: 2009 but not QCVN 118: 2018/BTTTT as these standards are a bit different in requirements, limits and test method. It is still unclear how the VNTA shall judge this case and what will be the decision.

Case 2: PQIR acknoledged before September 1, 2019, submit TA application dossier or SDoC to VNTA after September 1, 2019

From 01/092019, Circular No. 05/2019 / TT-BTTTT of the MIC shall take effect and server computer, switch, gateway, router ... (without radio transceiver function) will no longer be underregulatory approval of MIC Vietnam.

1. For the listed imported products, the importer transmits customs declaration after September 1, 2019, of course, it is not necessary to carry out procedures for PQIR and SDoC.

2. In the case that importer submit PQIR and transmits customs declaration close to September 1, 2019. The interesting question is whether the VNTA shall apply the regulation in effect at the time PQIR acknowledged (requires testing and SDoC) or VNTA shall apply regulation in effect at the time of submission after September 1, 2019 (testing and SDoC not required)?

 

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  • EXTENDMAX VIETNAM COMPANY LIMITED
  • Tel: +84 24 32 009 753
  • Email: consultant@extendmax.vn
  • Head Office: 9F, Nam Cuong building, Km4 To Huu street, La Khe ward, Ha Dong district, Hanoi City, Vietnam
  • HCMC Branch: 1F, Kicotrans building, No.5 Dong Da street, Ward 2, Tan Binh district, Ho Chi Minh City, Vietnam