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Vietnam MIC Circular 10/2020/TT-BTTTT: New certification systems, Type Approval certificate granted for oversea manufacturer

  13/05/2020

EXTENDMAX - Vietnam MIC has officially released Circular 10/2020/TT-BTTTT amending and supplementing Circular 30/2011/TT-BTTTT (together with Circular 15/2018/TT-BTTTT). Circular 10/2020/TT-BTTTT of Vietnam MIC has made some major changes in certification method for products and goods of "Group 2" under its management scope. The new Circular shall enter in force since July 01, 2020.

 

Key features of Circular 10/2020/TT-BTTTT:

1. MIC shall grant type approval certificate for oversea manufacturer directly.

2. Oversea manufacturers are allowed to signed self-assessment declaration of conformity which is needed for "Product Quality Inspection Registration" (PQIR) process which is a part of customs clearance process. Self-assessment DoC must be based on the test report which oversea manufacturer is "test applicant" (test report holder).

3. In order to use "Type Approval certificate" and "Self-assessment DoC" granted under name of oversea manufacturer(s), local importer shall need to submit a "notification on list of product models and importers allowed" to VNTA during PQIR process. This "notification on list of product models and importers allowed" must be issued by the oversea manufacturer itself or the local representative offices / subsidiaries in Vietnam.

4. Conformity certification organizations can be VNTA or any other certification bodies which are designated by MIC Vietnam for certification activities.

5. New certification systems (methods) has been officially introduced, which now includes three methods:

- Certification system 1: Certification based on typical sample testing, applicable for products manufactured by ISO 9001 certified factory(ies) (or equivalent certificate for management system). Certificate granted under this system shall be valid for maximum 03 years.

- Certification system 5: Certification based on typical sample testing combined with factory inspection applicable for products manufactured by factory that has not obtain ISO 9001 certificate yet. Certificate granted under this system shall be valid for maximum 03 years but factory audit shall be required anually to maintain certificate validity.

- Certification system 7: Consignment approval (per-lot approval), applicable when system 1 or system 5 are not applicable. Certificate granted under this certification system shall be valid for a single import lot / consigment only.

6. Type Approval certificate or Letter of Acceptance of Declaration of Conformity granted before enforcement date of this circular shall keep its validty.

 

Other doubts and comments:

7. MIC has terminated Article which list of documents required for Type Approval certification application, it means now VNTA or other designated certification authority (if available) can make decision on its own for list of documents requried to apply for a Type Approval certificate. In ExtendMax's opinion, oversea applicant should prepare one of below documents in advance for application:

(1) Business registration license

(2) Foundation certificate

In certification practice for Safety and EMC CR approval for overea manufacturers, certain MOST designated certification authorities accept scan copy of Business Registration Certificate of applicant. But this is the first time VNTA accept certification for oversea manufacturer so VNTA may not accept scan copy of business registration certificate sent via email, a hard copy will be a safe way.

According to the law, for oversea organization or individual, consulate notarize copy made by Vietnam Consulate or Vietname Embassy in the country which the applicant is located shall have the most legal power and must be accepted for MIC Type Approval application in any cases.

8. A copy of ISO 9001 certificate (or equivalent certificate for management system) of manufacturing factory shall be needed if applicant apply under "Certification system 1". In case the product is OEM / ODM type or applicant is not the same with factories, a document to prove the connection between applicant and factory should be needed.

9. Self-assesment DoC (made by oversea manufacturer) must be based on test report which oversea manufacturer is "test applicant" (test report holder). So in case imported product is Laptop or Tablet or Mobile Phone, the local importer shall need SDoC made by both end-device manufacturer and battery manufacturer. 

10. Some oversea manufacturers may not issue Self-assessment DoC or authorization letter to use Type Approval certificate for local importer due to their internal procedure issue, in such cases, test reports and certificate should be obtained under name of local importer

11. It is not clear that MIC allows oversea applicants to register an ICT Mark for their own or ICT Mark is still bound to local importer as existing regulation.

12. The new Circular 10/2020/TT-BTTTT leads to understanding that now Certification Authority can decide to grant voluntary type approval certificate for the standards which belongs to Self-assessment DoC scheme.

Please find the Circular 10/2020/TT-BTTTT below:

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