Export-processing and processing businesses need to know the 90-day mark and the updated Circular 121/2025/TT-BTC, effective from February 1, 2026.
Export-processing, processing, and export-manufacturing businesses that use duty-free imported materials and supplies must all file a periodic settlement report with the customs authority. Filing late or using the wrong form is a common error that gets businesses administratively penalized even without any fraud involved.
This is a periodic report (by financial year) showing the import–export–inventory position of imported materials/supplies and the corresponding exported goods, applicable to export-processing enterprises and processing/export-manufacturing enterprises that are exempt from duty on input materials under Article 60 of Circular 38/2015/TT-BTC (amended by Clause 39, Article 1 of Circular 39/2018/TT-BTC).
No later than the 90th day from the end of the financial year (usually March 31 if the financial year matches the calendar year), or before carrying out a merger, consolidation, division, dissolution, or business-type conversion that involves imported materials/supplies.
If an error is found after filing, the business may amend and supplement the report within 60 days of the filing date, or before the customs authority issues a decision to inspect or audit.
The report is prepared using Form No. 15/BCQT-NVL/GSQL (commonly called "Form 15a") issued with Circular 38/2015/TT-BTC. From February 1, 2026, Circular 121/2025/TT-BTC takes effect, amending several matters related to the settlement-report procedure — businesses need to update their form and declaration method per the new guidance rather than using the old form.
Businesses no longer have to resubmit the settlement report when changing the location where they process material-import procedures — a previous rule that created duplicate procedures for businesses managed by multiple customs branches. In addition, processing contracts where an export-processing enterprise hires a domestic enterprise to continue processing remain under the current rules until the end of the 2026 settlement period, creating a buffer for businesses to adapt to the new regulation.
Organizations and individuals engaged in processing or manufacturing for export must continuously track imported materials/supplies and the corresponding exported products — from the time of import until the product is exported or its intended use changes. This is the source data used to reconcile when preparing the settlement report, so a tight warehouse-tracking system from the start of the year is needed, rather than leaving everything to the end of the period.
No — this requirement applies to export-processing enterprises and processing/export-manufacturing enterprises with duty-free imported materials; it does not apply broadly to ordinary trading goods.
It can result in an administrative penalty under customs regulations (see also Decree 169/2026/NĐ-CP, effective from July 1, 2026).
It amends a number of procedures related to the settlement report and the management of materials/supplies for export-processing/processing enterprises, effective from February 1, 2026 — businesses should review their internal process to update in time.
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