Although the phrase “Made in Vietnam” appears widely on product packaging, Vietnam has yet to establish an official set of criteria to determine the origin of goods circulated within the domestic market. This reality not only causes confusion for businesses and regulatory agencies but also poses risks of trade fraud, affecting consumer rights and the reputation of Vietnamese goods. The Ministry of Industry and Trade is currently working to develop a set of criteria to resolve this issue.

Confusion over “Made in Vietnam” According to the Ministry of Industry and Trade, Vietnam has issued several regulations on the origin of goods, but these mainly apply to exports and imports to fulfill tariff preferences under free trade agreements (FTAs) or for foreign trade management purposes. Meanwhile, for goods produced for domestic consumption—whether made from local or imported materials—there is still no official set of criteria for determining origin. As a result, seemingly simple phrases such as “Made in Vietnam,” “Vietnamese products,” or “products of Vietnamese origin” are in fact causing headaches for many businesses and regulatory bodies. At a recent workshop on the criteria for determining the Vietnamese origin of domestically circulated goods, Trinh Thi Thu Hien, deputy director of the Import-Export Department at the Ministry of Industry and Trade, noted that there is currently only Decree No. 31/2018/ND-CP on rules of origin for exports and imports. In contrast, for goods sold within the domestic market, there are still varying interpretations. In fact, many products labeled “Made in Vietnam” do not actually have a Vietnamese certificate of origin (C/O). The lack of clear regulations on how to define what constitutes a “Vietnamese product” or “made in Vietnam” product leaves many organizations and individuals uncertain about how to accurately indicate the origin or source of products in accordance with Decree No. 43/2017/ND-CP on product labeling. For example, consider an electronics company assembling TVs from both imported and domestic components, designing the software and circuit boards in-house, and selling the product in the Vietnamese market. Can this product be labeled “Made in Vietnam”? Similarly, a toy company performs the initial cutting and sewing stages in China, then transfers the items to Vietnam for stitching, labeling, and stuffing. Does this process meet the requirements for the “Made in Vietnam” label? Or, if a product has over 30% local content, can it be considered Vietnamese goods? On the other hand, many goods that only go through simple steps like packaging or labeling in Vietnam are still branded as “Made in Vietnam,” causing confusion among consumers, while regulatory authorities lack a basis for enforcement. This issue is not just about labeling correctly. Dau Anh Tuan, head of the Legal Department and deputy secretary general of the Vietnam Chamber of Commerce and Industry (VCCI), stated: “Clearly and transparently identifying the origin of goods not only helps combat counterfeit and fake products but also builds consumer trust and motivates businesses to improve domestic production capacity.” A framework of criteria is being developed At the request of the Government, the Ministry of Industry and Trade is developing a set of criteria to determine the origin of goods circulating domestically. According to the leadership of the Import-Export Department, based on these criteria, businesses will be able to accurately identify products made in or originating from Vietnam. This will serve as a foundation for building brand value and reputation for “Vietnamese products,” preserving domestic market share, and avoiding disputes between distributors and users of domestic goods that could harm competitiveness. The proposed method for determining the Vietnamese origin of goods in domestic circulation includes six criteria:

1. Goods with pure origin, such as those derived entirely from cultivation, livestock, mining, fishing, or recycling activities conducted in Vietnam.
2. Goods produced entirely from raw materials originating in Vietnam.
3. Goods processed or manufactured in a way that results in substantial transformation—for example, imported raw materials are used, but the final processing step in Vietnam changes the customs code (HS code) or meets a prescribed Vietnamese value-added ratio.
4. Simple processing or manufacturing activities, such as packaging, labeling, basic assembly, or simple mixing, are not accepted as qualifying processes.
5. Raw materials that do not result in a change in the HS code or substantial transformation can still be considered as Vietnamese if the value of the non-originating materials is less than or equal to 15% of the ex-factory price.
6. Factors not considered in determining origin include fuel, catalysts, testing tools, uniforms, and safety equipment.

Bui Thi Thuy Duong, from the National Committee for Standards, Metrology, and Quality, said that building a common criteria system applicable to all types of goods to determine when a product can be labeled “Made in Vietnam” is essential. However, the framework should be designed flexibly, with a phased approach and classification by industry or risk level. Broad consultation with businesses, industry associations, and relevant regulatory bodies is needed to ensure feasibility and high consensus in practical implementation. According to Dau Anh Tuan, proving origin is often difficult and costly. “There are products whose hardware is imported, while the software is developed by Vietnamese people—but proving that the software is of Vietnamese origin is not easy.” Therefore, he proposed a gradual approach: “Initially, we can clearly define the criteria for products that are entirely produced in Vietnam. Then, we can move toward requiring disclosure of the localization rate. Anyone making false claims must be held accountable.” In particular, Tuan emphasized that the Government should not hastily introduce mandatory regulations for all goods circulating domestically, as that could place heavy burdens on both businesses and regulators. Instead, the process should begin with guidelines, and only if effectively implemented should it be expanded.