Vietnam’s Ministry of Industry and Trade and General Department of Vietnam Customs jointly issued the Implementation Rules for the Green Ship Import Incentive Program (Circular No. 18/2026) effective May 1, 2026. The policy grants a 15% import tariff reduction for Selective Catalytic Reduction (SCR) and open/mixed-type exhaust gas cleaning systems (scrubbers) compliant with IMO Tier III emission standards — but only if accompanied by a dual-parameter test report issued by a China National Accreditation Service for Conformity Assessment (CNAS)-accredited laboratory. This development directly affects Chinese environmental equipment exporters, third-party testing service providers, and Vietnamese shipowners or importers engaged in green maritime infrastructure upgrades.

Event Overview

On May 1, 2026, Vietnam’s Ministry of Industry and Trade and the General Department of Vietnam Customs published Circular No. 18/2026, titled Implementation Rules for the Green Ship Import Incentive Program. The circular specifies that a 15% import tariff reduction applies to SCR systems and open/mixed-type scrubbers meeting IMO Tier III emission requirements. To qualify, importers must submit a test report from a CNAS-accredited laboratory confirming two technical parameters: (1) SO₂ removal efficiency ≥98%, and (2) low-temperature activity decay ≤5% after 100 hours at −10°C. The rule is effective immediately as of May 1, 2026, and no transitional provisions or exemptions are stated in the publicly released text.

Which Subsectors Are Affected

Chinese Environmental Equipment Exporters
These manufacturers supply SCR units and scrubber systems to Vietnamese shipyards, operators, or trading intermediaries. They are now required to coordinate closely with CNAS-accredited labs to generate compliant test reports prior to shipment — not just for certification, but as a mandatory customs clearance document. Impact manifests in extended pre-shipment lead times, added documentation costs, and potential delays if test reports lack full alignment with the dual-parameter requirement.

CNAS-Accredited Testing Laboratories (China-based)
Labs accredited under CNAS must now validate their existing SO₂ removal and low-temperature stability test protocols against the specific performance thresholds and test conditions stipulated in Circular No. 18/2026. Absence of documented capability for −10°C/100h decay testing may limit their eligibility to issue accepted reports — affecting their service scope for marine emission control equipment.

Vietnamese Shipowners and Import Agents
Entities importing green ship technologies into Vietnam face new compliance gatekeeping at customs. The tariff benefit is conditional and non-automatic: failure to present the CNAS report — even with otherwise compliant hardware — results in full tariff application. This introduces operational risk in procurement planning, contract negotiation (e.g., who bears testing cost and timeline), and customs classification accuracy.

What Relevant Enterprises or Practitioners Should Focus On — And How to Respond

Monitor official Vietnamese customs guidance on report format and lab eligibility

The circular mandates a CNAS report but does not yet publish an approved template, nor does it list eligible CNAS labs by scope. Enterprises should track updates from Vietnam’s General Department of Customs and verify whether reports require notarization, translation into Vietnamese, or additional attestation.

Verify current test capabilities of partner labs against the −10°C/100h decay requirement

Not all CNAS-accredited labs currently perform low-temperature aging tests for scrubber catalysts or scrubbing media. Exporters and labs should jointly confirm whether existing test methods (e.g., ISO 11843, GB/T 38747, or proprietary protocols) satisfy the exact duration, temperature, and measurement criteria in the circular — especially the ≤5% activity decay threshold.

Distinguish between policy intent and enforceable procedure

The 15% tariff cut is framed as an incentive, not a right. Its practical availability depends on consistent customs officer interpretation and system-level integration of the CNAS report check in Vietnam’s electronic customs platform (VNACCS). Early adopters should treat initial filings as process validation — not assumed approval — and prepare contingency plans (e.g., provisional tariff payment and refund claim).

Align commercial contracts to allocate responsibility for testing, timing, and report validity

Supply agreements involving SCR or scrubber imports into Vietnam should explicitly assign responsibility for obtaining the CNAS report — including cost, timeline, version control, and retest liability in case of customs rejection. Clauses should reference Circular No. 18/2026 and define acceptable evidence of CNAS accreditation status.

Editorial Perspective / Industry Observation

Observably, this measure signals Vietnam’s shift from broad environmental aspiration to targeted, evidence-based regulatory enforcement in maritime decarbonization. It does not introduce new technical standards — IMO Tier III and SO₂ removal metrics are internationally recognized — but it does impose a specific, traceable verification mechanism anchored in China’s national accreditation infrastructure. Analysis shows this is less a standalone trade policy and more a calibration step: it tests domestic customs capacity to enforce green import criteria while reinforcing reliance on mutually recognized conformity assessment pathways. From an industry perspective, it reflects growing interoperability pressure between ASEAN environmental policy frameworks and upstream testing ecosystems in Northeast Asia — particularly where Chinese lab accreditation serves as a de facto technical gateway.

Current implementation remains narrow in scope (only SCR and open/mixed scrubbers; only two performance parameters), and its scalability to other green ship components (e.g., shore power interfaces or battery propulsion systems) is unconfirmed. Therefore, it is better understood as a procedural pilot than a comprehensive regulatory model — one whose durability will depend on enforcement consistency and feedback from early filers.

Conclusion
This circular marks a concrete step toward conditionally incentivizing low-emission maritime technology imports in Vietnam — but its real-world impact hinges on documentation rigor, cross-border lab coordination, and customs execution fidelity. For affected stakeholders, the priority is not broad strategic recalibration, but precise operational alignment: validating test protocols, clarifying contractual obligations, and treating the CNAS report not as a formality, but as a time-bound, parameter-specific customs credential. It is best interpreted not as a market-opening event, but as a tightening of technical due diligence at the import interface.

Source Attribution
Main source: Vietnam Ministry of Industry and Trade and General Department of Vietnam Customs, Implementation Rules for the Green Ship Import Incentive Program, Circular No. 18/2026, effective May 1, 2026.
Note: Ongoing observation is required regarding (1) Vietnam’s official list or database of CNAS labs accepted for this purpose, and (2) any subsequent amendments or administrative guidance issued by Vietnam Customs on report submission procedures.