Market access requirement for firewall device

A network firewall device is a device that requires specialized import permits, which in the case of enterprises not knowing in advance, may cause cases of failure to customs clear the goods, causing an increase in transportation costs. Especially when the firewall is in a large shipment of many different products, the consequense could be a tragedy. Within the scope of this article, ExtendMax will provide detailed instructions on the market access requriements and procedure for importing network firewall devices so that enterprises can have a complete overview and well-prepared before importing.

1. What is network firewall

In computing, a firewall is a network security system that monitors and controls incoming and outgoing network traffic based on predetermined security rules. A firewall typically establishes a barrier between a trusted network and an untrusted network, such as the Internet.

The modern firewall provides a wider range of inspection at the application layer, extending deep packet inspection functionality to include, but is not limited to:

→ Web filtering
→ Intrusion prevention systems
→ User identity management
→ Web application firewall

2. Existing forms of firewalls.

Firewalls can exist in the form of specialized hardware, or software integrated into a computing appliance. Usually, when a software firewall is integrated into the appliance, it gives more flexibility, but the overall performance is lower than that of a dedicated firewall.

Firewall exists in the form of hardware that can be easily found on the market, provided by famous security equipment manufacturers such as Cisco, Fortinet, Palo Alto, WatchGuard, Secui... Popular firewall cases are appliance with high security features (high value) provided by reputable manufacturers.

3. What kind of license or permit is required to import firewalls?

According to the cyberinformation security law, there are two types of import licenses applicable to cyberinformation security products, including:

a. License and permit to import cybersecurity products

Cybersecurity licenses and permit are granted by the Ministry of Information and Communications based on Circular No. 13/2018/TT-BTTTTT (amended and supplemented by Circular 10/2022/TT-BTTTT) for the following types of products:

(1) Cyber security evaluation product group: hardware or software to evaluate or scan or analisy or detect cyber sercurity threats

(2) Network monitoring and warning product group: Hardware or software to monitor data transfering detect and give warning about cyber security threats

(3) Attack or hack protection product group: Hardware or software to protec network from being attacked or hacked.

b. License and permit to import civil cryptographic products

Civil cryptographic licenses are granted by the Government Cipher Committee based on Appendix 2 of Decree 53/2018/ND-CP for the following types of products:

(1) The product generates a cryptographic key, manages or stores the cryptographic key.

(2) Cryptographic component in PKI system.

(3) Product security data retention

(4) Network data exchange security products

(5) IP and channel security products

(6) Analogue and digital voice security products

(7) Radio security products

(8) Fax, telegraph security products

c. So what kind of license do you need to import firewalls?

In fact, ExtendMax has checked and evaluated the technical documentation of hundreds of firewall models from different manufacturers. These models all have in common that all have encryption function (civil cryptographic function) such as VPN, IPS, there is no firewall model without encryption function.

→ Pursuant to Point c, Clause 6, Article 38 of the Law on Cyberinformation Security No. 86/2015/QH13, civil cryptographic products are not within the scope of responsibility of the Ministry of Information and Communications

→ Pursuant to Clause 1, Article 42 of the Law on Cyberinformation Security No. 86/2015/QH13, civil cryptographic products are not within the scope of licensing for trading in cybersecurity products and services.

Thus, when the firewall product has both civil cryptographic features (encryption) and the characteristics of a network information security product (anti-attack and intrusion), the type of license required to import the product is the license to import civil cryptographic products (CCP).

4. Dossier and procedure to apply for an import permit for firewall

Since the firewall devices all have "VPN" or "IP Security" features, and Customs is applying HS code 85176229, so they are on the list of required CCP import permits. To apply for a permit to import civil cryptographic products for firewall equipment, an enterprise must first obtain a CCP trading license (dealer license) in advance. Normally, firewall devices have IP security features using IPSec or TLS technology, so importing enterprises must also carry out procedures for civil cryptographic conformity certification for firewall devices. In case you are going to import products having trade mark protected by IP Law, you may want to see our instructions on a separate articles

You may need to know: a complete set of shipping documents for Vietnam

5. What can ExtendMax help you in market access?

With many years of experience in applying for business licenses and import and export licenses of civil cryptography products for many organizations, we can assist you:

→ Classify products into groups that do not require a license, require a license but do not have to certify for conformity, and require both a license and certification of conformity

→ Support clients to prepare documents in the fastest time according to the requirements of the authorities

→ Representing enterprises in carrying out testing and certification procedures for civil cryptography products

→ Support other legal procedures related to imported products such as applying for licenses and certificates of conformity from the Ministry of Information and Communications

→ In case the business is not yet eligible to apply for a license to trade in civil cryptography products, ExtendMax can provide Importer of Record (IOR) services to support.

Learn more: IOR and EOR service for Vietnam

Contact us for inquiry:

EXTENDMAX VIETNAM COMPANY LIMITED

Hotline: 0915 836 555 | Hanoi: 024 6666 3066

Email: consultant@extendmax.vn | phuong.tran@extendmax.vn

HO: ExtendMax Villa, C01-L18 An Vuong, Duong Noi urban area, Duong Noi ward, Ha Dong district, Hanoi City, Vietnam

Test laboratory: BT02-21, An Hung urban area, To Huu street, La Khe ward, Ha Dong district, Hanoi City, Vietnam

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