Vietnam Forced Labor Import Ban: What Decree No. 292/2026/ND-CP Changes on September 5, 2026
From September 5, 2026, Vietnam bans the import of goods made wholly or partly with forced labor. The Vietnam forced labor import ban is a new entry on the country’s prohibited-import list, introduced by Decree No. 292/2026/ND-CP.
The ban turns on how goods were made rather than what they are. For most importers, it is now not only about HS codes that need attention but the company now need to also name the factory that actually made the goods.
Vietnam’s largest export customers already restrict forced-labor goods. The United States applies a rebuttable presumption to goods with a stated regional connection, and an importer there must produce evidence to release a detained shipment. The European Union has adopted its own forced-labor regulation, which applies from December 2027. Vietnam’s labor commitments under the CPTPP and the EVFTA sit behind the new rule, which is written to follow them.
For a foreign-invested manufacturer, inbound materials now meet a Vietnamese control while finished exports continue to meet a foreign one. Both look at the same supply chain. A company that already answers customer questionnaires on forced labor holds much of the underlying information.
The ban reaches goods where forced labor was used at any stage, whether by the supplier, a subcontractor or a raw-material producer. It is tied to the labor commitments Vietnam has signed internationally. Responsibility for the category sits with the Ministry of Home Affairs, not the trade ministry, which is where an importer would normally look.
The ban does not apply itself to every product immediately. The responsible ministry must first publish which goods are covered, with product descriptions and customs codes. A product is caught once it appears on that published list. As of September 3, 2026, no such list had been issued. Check again before each shipment.
Two things the new rules do not contain are a country blacklist and any assumption of guilt. This is where the Vietnamese approach differs from the United States model. A US importer builds a file to rebut an assumption attached to a region or a named company. A Vietnamese importer works out whether a product sits on the published list. Existing supply-chain files help, because they trace the same suppliers, but they answer a different question.
Check the Vietnamese importer, foreign seller, trader and actual manufacturer for each main product. They may be different companies.
If a distributor or local commercial partner in Vietnam imports the goods, the contract should say so, and should say who keeps the supplier and factory records.
A trader may buy from several factories. A factory may use a subcontractor for finishing, packing or part of the work. Ask the supplier to identify the production site and any important upstream producer.
Keep the purchase order, invoice, packing list, factory address and transport record. Product specifications, material statements and batch information may also help.
A certificate of origin can support the product’s origin under customs law in Vietnam. It may not show labor conditions at a raw-material or component supplier.
Ask the supplier to confirm that forced labor was not used to extract, produce or manufacture the goods, covering relevant materials and subcontracted work. The supplier should report any later change.
There is no official forced-labor certificate to obtain. A supplier statement is a contract record between the parties, not a government document.
For a new or renewed contract, ask for correct production information, notice of changes and reasonable access to records. The contract can allow the buyer to delay a shipment, ask for another source or end the order if a serious concern is not answered.
Start with a document check. A factory visit may be useful if a specific concern remains. Some of the same records already exist for ESG for exporters in Vietnam. A supplier audit is not compulsory.
Give one person responsibility for the final check. Before the goods are dispatched, check the latest official list and the product’s HS code and description. Confirm the factory and the supplier statement, and resolve any important gap before loading.
Keep each batch’s records together and preserve the original documents. If the goods are already moving, confirm the customs position before asking the carrier or broker to change the shipment.
Factories that have reviewed prevention of illegal child labor may already hold useful supplier, subcontractor and batch records.
A prohibited-import problem is handled under Vietnam’s customs penalty rules, which were updated in July 2026. Fines there rise with the value of the goods rather than sitting at one fixed amount, and the goods themselves can be seized or ordered back out of the country.
Q1: Does every importer now have to audit every foreign supplier?
No. The new rules set no general audit duty and no single audit process. Checks should fit the product, the supplier, the current official list and any request from the authorities.
Q2: Does a certificate of origin prove that forced labor was not used?
No. It helps show customs origin. It may not show labor conditions at the factory, mine, farm or upstream supplier.
Q3: Does a US or EU supply-chain file satisfy the Vietnamese rule?
Not by itself. The supplier tracing behind it is useful and should be reused. The Vietnamese test still turns on the published list of products and HS codes, so the file should be organized by product as well as by supplier.
The Vietnam forced labor import ban starts on September 5, 2026 and turns on how goods were made, not what they are. An official list of covered products is still to come. Until then, importers should identify the actual factory, keep the supplier, production and origin records, and treat an existing customer compliance file as a starting point rather than an answer.
Written by Hanh Pham, Specialist at ANT Lawyers, and reviewed by Tuan Nguyen, Lawyer at ANT Lawyers. This alert is general information on Vietnamese law and is not legal advice for a particular company or transaction.
Founded in 2012, ANT Lawyers is a Vietnam law firm with offices in Hanoi, Ho Chi Minh City and Da Nang. Our employment lawyers advise on hiring, work permits, internal labour regulations and termination disputes in Vietnam. We combine legal analysis with practical understanding of Vietnam’s regulatory environment and local administrative practice.
This article is for general informational purposes only, does not constitute legal advice, and does not create a lawyer-client relationship. Vietnamese laws, regulations and administrative practice change over time, and the correct position for any matter depends on its specific facts and the rules in force when action is taken. Verify the current position before relying on anything stated here, and consult qualified counsel on your specific situation.
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