Is Official Letter 870/XNK-XXHH a legal normative document?

No — it is an administrative letter guiding the rollout of Circular 26/2026/TT-BCT, but C/O-issuing agencies/organizations and businesses still need to follow it to ensure consistency from August 1, 2026.

Does a C/O already issued before August 1, 2026 need to be reissued?

In principle, no, since this is a change to the issuance process going forward, with no retroactive effect on C/Os validly issued before that date. For applications still being processed across the August 1, 2026 cutoff, businesses should confirm specifics with their issuing agency.

Does this change affect origin criteria or C/O forms under each FTA?

No. Article 27 and Forms 17, 18 belong to the administrative-procedure group covering how applications are submitted/processed on the electronic system; they do not change origin-determination criteria (WO, CTC, RVC) or the C/O form templates under each agreement.

Official Letter 870/XNK-XXHH: Guidance for Electronic C/O Issuance under Circular 26/2026/TT-BCT from August 1, 2026

From August 1, 2026, every agency and organization authorized to issue Certificates of Origin (C/O) in Vietnam must operate under a new process on the Electronic C/O Management and Issuance System, following Official Letter No. 870/XNK-XXHH dated July 21, 2026, issued by the Import-Export Department (Ministry of Industry and Trade). This is the technical implementation step for Article 27 and Forms No. 17 and 18 in Part II of the Appendix to Circular 26/2026/TT-BCT. For exporting businesses, the August 1, 2026 milestone applies uniformly, with no separate transition period per entity — understanding the true nature of the change and preparing early matters more than waiting until an urgent shipment forces the issue.

Background: why another guidance letter was needed

The core regulation on C/O issuance currently follows Circular 40/2025/TT-BCT, consolidated in Consolidated Document No. 48/VBHN-BCT, which requires C/O-issuing agencies and organizations to connect to and operate stably on the Electronic Certificate of Origin Management and Issuance System (eCoSys), whose infrastructure is managed by the Agency of E-commerce and Digital Economy. Circular 26/2026/TT-BCT amends and supplements a number of administrative procedures under the Ministry of Industry and Trade's decentralization, reduction and simplification program — including Article 27 and Forms 17, 18, which relate directly to the C/O issuance process.

The issue is: a circular taking effect doesn't automatically mean the electronic system is ready to run the new process correctly. Official Letter 870 is precisely the link between the legal regulation and the operating infrastructure — the Import-Export Department coordinated with the Agency of E-commerce and Digital Economy to review and reconfigure eCoSys functions before publishing this guidance, to avoid a situation where a regulation takes effect but the system hasn't caught up, which has happened in some past rounds of electronic administrative reform.

Quick comparison: before and after August 1, 2026

Before August 1, 2026: C/O issuance follows the process in Circular 40/2025/TT-BCT (consolidated in Document 48/VBHN-BCT) on eCoSys, with no separate guidance for Article 27, Forms 17-18.
From August 1, 2026: Article 27 and Forms No. 17, 18 in Part II of the Appendix to Circular 26/2026/TT-BCT apply — together with detailed process guidance built by the Agency of E-commerce and Digital Economy, split into two groups: traders requesting C/O issuance, and the agencies/organizations that issue C/O.
In essence: this is a change to the process/procedure for operating the electronic system, not a change to the criteria for determining origin of goods or eligibility for FTA preferences.

What Article 27 and Forms 17, 18 actually cover

Because they sit within a circular amending administrative procedures (not a circular on rules of origin), Article 27 and the two forms 17, 18 focus on the technical/procedural side: how to log in, submit a C/O application, and how the issuing agency/organization receives and processes the application on the Electronic C/O Management and Issuance System. This is a distinction businesses need to keep clear, so as not to confuse it with changes to origin criteria (WO, CTC, RVC...) or C/O forms under each FTA — those are outside the scope of this amendment.

Where to direct questions: don't contact the wrong office

Official Letter 870 clearly separates two support contacts, depending on the nature of the issue that arises during rollout:

Issues related to origin-of-goods operations: contact the Import-Export Department – Ministry of Industry and Trade, 54 Hai Ba Trung, Hanoi; phone 024.2220.5444/2468/5361; email xnk-xxhh@moit.gov.vn or co@moit.gov.vn.
Issues related to the Electronic C/O Management and Issuance System (technical errors, login, configuration...): contact the Agency of E-commerce and Digital Economy, 25 Ngo Quyen, Hanoi; phone 024.2220.5395; email info@ecosys.gov.vn.

Checklist for businesses before August 1, 2026

Proactively log in to eCoSys as a test and check your account and the new application-submission interface, rather than waiting until an urgent shipment forces you to.
Review your current C/O application file, cross-checking against the new process guidance published by your issuing agency.
Notify your internal documentation and import-export team to avoid disruption when filing from the start of August 2026.
Confirm with the C/O-issuing unit you normally work with (VCCI, a regional import-export management office, an industrial park management board...) that they have updated their process according to the guidance accompanying Official Letter 870.
Route issues to the correct contact — origin-related questions to the Import-Export Department, system errors to the Agency of E-commerce and Digital Economy — to avoid wasting time being transferred between the two agencies.

Expert view: why it pays to act ahead of August 1

Rounds of electronic system migration by state management agencies, even when configured and tested beforehand, often still produce localized technical glitches in the first week of full real-world operation. Businesses planning to export a shipment that needs a C/O right at the start of August 2026 should try the system early rather than waiting until just before the shipping deadline — because if a technical issue arises exactly when a C/O is urgently needed, the business will both lose time resolving it and risk late delivery or losing the tariff preference because the C/O wasn't issued in time.