The Vietnam Chamber of Commerce and Industry (VCCI) has issued written comments on the draft Circular of the Ministry of Finance regulating information indicators and declaration forms used in exit, entry, and transit procedures for vehicles crossing border gates by air, sea, rail, road, and inland waterways, replacing Circular No. 50/2018/TT-BTC.

According to VCCI, the draft contains two notable improvements. First, it for the first time introduces regulations on electronic declaration information indicators for road, rail, and inland waterway transport, thereby ensuring consistency across transport modes and supporting the implementation of the National Single Window mechanism. Second, it retains stable provisions currently applied to ships and aircraft, while only amending what is strictly necessary.

However, VCCI noted that several provisions still need further refinement to ensure clarity, feasibility, and convenience for enterprises.

Regarding transitional provisions, VCCI recommended that the drafting agency clearly define the criteria for determining whether the information technology systems of ministries and sectors meet technical requirements. Without clear guidance, enterprises may struggle to determine whether to proceed with electronic declarations or continue submitting paper documents. At the same time, a clear roadmap for applying electronic declaration indicators should be published on the customs electronic portal.

Customs officers inspect documents and supervise goods at the border gate. Illustrative image.

For the maritime sector, VCCI recommended ensuring consistency between declaration forms used by customs authorities and maritime authorities, to avoid situations where enterprises must declare the same information multiple times in different formats. In addition, the mechanism for data integration between the National Single Window portal and electronic port authority systems should be clarified to reduce duplication.

For aviation, VCCI agreed with the addition of detailed passenger information declaration requirements to improve immigration control efficiency. However, it proposed clearly defining the roadmap for transitioning from the current declaration mechanism to the National Single Window system, as well as specifying when airlines must provide passenger data in line with international practice.

For inland waterway transport across borders, VCCI proposed developing a simplified set of declaration indicators for vessels engaged in same-day cargo transport, to avoid full declarations for each border crossing. It also suggested allowing the use of registered tonnage or actual carrying capacity where deadweight tonnage (DWT) information is unavailable.

For road transport, VCCI assessed that the addition of the “self-driving vehicle” indicator is necessary for developing smart border gate models. However, it proposed allowing driver-related fields to be left blank for autonomous vehicles and adding an “operating entity” field for management purposes.

It also recommended clarifying the scope of application for vehicles entering and exiting border gate areas without actually crossing borders, to avoid requiring ordinary transport vehicles to submit customs declarations. For logistics enterprises frequently handling goods at border gates, VCCI proposed a one-time registration mechanism allowing vehicles to enter and exit multiple times per day, similar to the “shuttle vehicle” model currently applied at some key border gates.

For international rail transport, VCCI proposed integration with international consignment standards such as FIATA and CIM/SMGS, to avoid manual data conversion between systems. It also called for clarification of declaration responsibilities between rail operators and logistics enterprises when a train carries cargo belonging to multiple shippers.

In addition, VCCI recommended adding a suitable declaration mechanism for vehicles eligible for single customs clearance valid for 30 days under current regulations, by introducing a “declaration type” field in the electronic system.

According to VCCI, improving these provisions would enhance the effectiveness of digital transformation in customs administration, while reducing compliance costs and facilitating import-export, logistics, and cross-border transport activities.