Vietnam’s Ministry of Industry and Trade (MOIT) updated Technical Regulation No. 28/2026/TT-BCT on May 13, 2026, mandating that all imported biometric readers must be accompanied by anti-liveness attack test reports—certified to ISO/IEC 30107-3 Level 3—issued by laboratories accredited by China’s National Accreditation Service for Conformity Assessment (CNAS). This requirement takes effect June 1, 2026. Exporters and importers in the biometric hardware, access control, and smart identity sectors should monitor implementation closely, as it directly affects compliance timelines, cost structures, and supply chain coordination between China and Vietnam.

Event Overview

On May 13, 2026, Vietnam’s Ministry of Industry and Trade (MOIT) issued an amendment to Technical Regulation No. 28/2026/TT-BCT. Effective June 1, 2026, the regulation requires all imported biometric readers to be accompanied by a test report verifying resistance to presentation attacks (i.e., anti-liveness testing) at ISO/IEC 30107-3 Level 3. The report must be issued by a laboratory accredited by China’s CNAS. The regulation specifies no alternative accreditation bodies or equivalency pathways. Three CNAS-accredited labs—in Shenzhen, Suzhou, and Hangzhou—have reported surging demand for this specific test.

Which Sub-Sectors Are Affected

Direct Exporters and Trading Companies

Companies exporting biometric readers from China to Vietnam will face mandatory documentation requirements prior to customs clearance. Non-compliant shipments may be delayed or rejected. The requirement adds 7–10 working days to delivery cycles due to testing lead times, and increases per-batch compliance costs by approximately USD 1,200.

Original Equipment Manufacturers (OEMs) and Contract Manufacturers

OEMs producing biometric readers for Vietnamese distribution must now integrate CNAS-level anti-liveness validation into their product qualification process—even if the same model has passed equivalent tests elsewhere (e.g., under UL 2900 or IEC 62443). This may necessitate retesting existing SKUs, affecting time-to-market for new product launches targeting Vietnam.

Distribution and Channel Partners in Vietnam

Local distributors and system integrators importing readers for resale or integration must verify documentation authenticity before accepting goods. They bear operational risk if reports are incomplete, outdated, or issued by non-CNAs-accredited labs. Inventory planning must now account for extended lead times and potential customs hold-ups.

Supply Chain and Compliance Support Providers

Third-party compliance consultants, freight forwarders, and lab coordination services handling China–Vietnam biometric hardware trade are seeing increased demand for CNAS report verification, test scheduling, and regulatory interpretation support—particularly around acceptable report formats and validity periods.

What Relevant Enterprises or Practitioners Should Monitor and Do Now

Track official MOIT guidance on report validity and submission format

The regulation does not yet specify whether reports must be dated within a certain window (e.g., 6 or 12 months prior to import), nor whether bilingual (Chinese–English or Chinese–Vietnamese) versions are required. Enterprises should monitor MOIT’s official portal and customs circulars for clarifications ahead of June 1.

Confirm CNAS lab authorization scope before scheduling tests

Not all CNAS-accredited labs are authorized for ISO/IEC 30107-3 Level 3 anti-liveness testing. Only labs with explicit scope coverage—including presentation attack testing using 2D/3D masks, silicone fingers, or screen replays—qualify. Verify each lab’s current CNAS certificate annex listing this capability.

Distinguish between regulatory signal and enforceable requirement

This is a formal technical regulation—not a draft or notice—and carries legal force upon entry into effect. However, enforcement ramp-up (e.g., random document checks vs. 100% verification) remains unconfirmed. Enterprises should treat the requirement as binding but prepare for phased implementation based on actual customs practice in early June.

Adjust procurement and logistics planning for added lead time and cost

Factor in minimum 7–10 additional working days for testing turnaround, plus USD 1,200 per batch. For high-volume SKUs, consider batching multiple units under one report where permitted by lab policy and MOIT rules. Reassess safety stock levels and order timing for Q2–Q3 2026 shipments.

Editorial Perspective / Industry Observation

Observably, this requirement signals Vietnam’s tightening of technical gatekeeping for security-critical hardware—not just as a conformity measure, but as a de facto market filter favoring suppliers with established CNAS-aligned quality infrastructure. Analysis shows it is less about harmonizing with international standards (since ISO/IEC 30107-3 is globally recognized) and more about anchoring verification authority to a specific national accreditation body (CNAS), thereby increasing traceability and administrative control over imports originating from China. From an industry perspective, this reflects a broader regional trend: Southeast Asian regulators increasingly layer country-specific certification prerequisites atop global standards—making cross-border compliance more procedural and less interoperable. It is currently best understood as a binding regulatory outcome—not merely a warning signal—with immediate implications for shipment readiness and cost modeling.

In summary, this update marks a material shift in Vietnam’s import regime for biometric readers: it introduces a mandatory, jurisdictionally bounded compliance checkpoint that reshapes lead times, cost allocation, and documentation workflows for Chinese exporters and their Vietnamese partners. Rather than indicating a temporary adjustment, it represents a structural addition to the market access pathway—one that prioritizes verifiable, lab-based anti-spoofing assurance over self-declaration or third-country certifications.

Source: Vietnam Ministry of Industry and Trade (MOIT), Technical Regulation No. 28/2026/TT-BCT, effective June 1, 2026; public notices issued May 13, 2026. Note: Enforcement details—including inspection frequency, penalties for non-compliance, and acceptance criteria for report translations—remain pending official clarification and are under observation.