September 2026 feels like a real turning point for anyone managing import-export operations .

For years, we got by focusing mostly on basic HS codes and tax rates . That playbook won't cut it anymore . Moving forward, customs compliance is shifting to a much deeper matrix: HS codes + complete product specs + technical traits + trade control policies .

With the September 12 and 15 effective dates hitting back-to-back, getting ahead of this isn't optional . Taking the time right now to review your HS codes, audit controlled item lists, and clean up internal compliance files is the single best move you can make to protect your business and keep shipments moving smoothly .

Looking at what’s hitting us mid-September, it feels like mid-September is going to be a real reality check for supply chain, customs, and finance teams .

We’ve got three big regulatory shifts dropping practically at the same time, and if you haven't started mapping them out internally, now’s the time .

Here’s a quick breakdown of what’s changing and where the pain points are going to be :

Regulation	Effective Date	What’s Changing	The Real-World Hit
Circular 85/2026/TT-BTC	September 15, 2026	A total overhaul of how import-export goods are classified and analyzed, alongside a newly standardized reference database.	This directly impacts your HS Codes, tariff schedules, and trade controls. If you’ve been copying and pasting HS codes from previous years without verifying specs, this circular is going to break those habits fast.
Circular 42/2026/TT-BCT	September 12, 2026	The Ministry of Industry and Trade is rolling out a detailed control list specifically for Dual-use goods.	High friction for anyone moving tech, industrial machinery, or electronic components. If your items lean technical, you need to check them against the new parameter lists before shipments get stuck at customs.
Circular 110/2026/TT-BTC	September 12, 2026	A massive regulatory cleanup repealing 22 outdated Circulars and 3 older Decisions across the tax domain.	While it sounds administrative, the heavy lifting falls on your internal systems. Every team needs to audit and update their internal tax reference sheets, SOPs, and ERP legal citations so you aren't pointing to dead regulations.

Circular 85/2026/TT-BTC – Changing the Framework for HS Code Determination and Governance

Circular 85/2026/TT-BTC is coming, and it completely changes how we deal with HS codes . To see why this matters, you have to look at how we used to do things .

The old way (Circulars 14/2015 & 17/2021)
For years, classification relied way too much on past customs declaration habits . The reference database was fragmented . Whenever a dispute popped up or a complex product had multiple components, the legal grounding felt shaky . In practice, teams usually leaned on domestic descriptions—which constantly created friction with international standards .

What changes with Circular 85
The reference database and legal grounds for HS classification are now fully standardized . If you hit a grey area where a single HS Code isn't obvious, the rules explicitly point you to the official sources: WCO Explanatory Notes, WCO Classification Opinions, AHTN Supplementary Notes, and Vietnam’s Import-Export Classification Database .

Here's the biggest takeaway: whenever there's a discrepancy, international standards (HS/AHTN) now take precedence over Vietnamese text descriptions .

If you’re running an SME, the new HS code rules are going to catch a lot of teams off guard .

• Stop copying old customs declarations: Seriously, change this mindset today . Just copy-pasting HS codes from previous shipments without double-checking them against the new reference database is a massive trap . What passed last month might not fly now .
• Put an 8-step check in place: Don't rush the classification . Walk every product through a clear process: Product spec → Chemical or material makeup → Actual intended function → Device structure → Tech sheet or catalog check → Cross-reference with HS/AHTN → Identify tariff rates → Check special management policies .
• Run priority audits where it hurts most: Don't try to fix everything at once . Focus your time and energy first on the highest-risk categories: agricultural goods, processed foods, raw industrial materials, chemicals, and any complex machinery with multiple components .

Get ahead of it now—re-checking things today is way cheaper than dealing with customs holds tomorrow .

Circular 42/2026/TT-BCT – Controlling Risks in Dual-Use Goods

Dual-use goods are where so many businesses get caught off guard . Honestly, most people don't realize just how broad the term actually is until a shipment gets flagged .

How we used to handle it: Screening was mostly voluntary . You'd run a quick, surface-level check against basic civil product names, and if nothing jumped out, you were good to go . No deep technical parameter checks .

What changes with Circular 42: That old, relaxed approach won't work anymore . The Ministry of Industry and Trade is enforcing much stricter controls now . They aren't just looking at the name—they’re checking HS codes, exact technical specs, and specific tech traits, heavily referencing EU ECCN codes .

The catch-all rule: If a 4-digit or 6-digit HS heading gets flagged on the control list, every single 8-digit code sitting under it automatically gets pulled into dual-use control . The only time an 8-digit code escapes is if the list explicitly spells out a narrower restriction .

It's a huge shift . If you haven't looked closely at your technical specs lately, now is definitely the time .

Action Plan for SMEs:

1. Transform your verification methods: Never clear dual-use items by their trade name alone—it’s a recipe for trouble . You have to build a multi-layered check: cross-reference the HS Code, exact technical specs, and actual intended use directly against the official control list .
2. Audit high-risk categories right now: If you deal in electronics, machine parts, telecom gear, precision tools, chemicals, or high-pressure valves, get in touch with your manufacturers immediately . You need the original technical data sheets so you can verify their true ECCN status before customs asks for them .
3. Get your permits out of the way early: If any of your products fall into dual-use territory, submit your license applications to the Ministry of Industry and Trade well before the shipment arrives at the port . Trying to handle this while your container sits at the docks leads to brutal delays and massive extra costs .

Circular 110/2026/TT-BTC – Comprehensive Clean-up of Tax Regulations

Tax rules have been piling up like clutter for years—just layers of overlapping circulars making everyone’s job harder .

Circular 110/2026/TT-BTC finally wipes the slate clean by killing off 22 outdated circulars and 3 old decisions . It’s a massive administrative reset for the tax database .

A quick heads-up from my end: don’t mistake this clean-up for a tax break . The underlying Tax Administration Laws are still very much alive . I’ve seen teams get burned simply because an expired clause was still tucked away in an internal file or ERP system . Citing old rules in your tax filings won't fly, and the penalties for bad declarations are no joke .

Action Plan for SMEs:

1. Run a total legal review: Check through everything stored across your customs, trade, and accounting teams . If a repealed circular is sitting on a checklist, pull it out today .
2. Clean out your software and spreadsheets: Check every detail formula through your internal Excel tax templates, SOPs, customs checklists, training decks, and ERP/SAP modules . Delete what is not applied after 15/09/2026 for the new replacement laws .
3. Retrain your people: Make sure your team actually knows which 22 circulars are gone . The last thing you want is someone quoting an invalid rule on an official customs declaration or a formal explanation letter to tax authorities .

Frequently Asked Questions (FAQs) Post-September 15, 2026

Q1: Our company has used the same HS Code for years without issue. Why do we risk having to change it after September 15, 2026?

Getting through customs easily in the past mostly came down to self-declaration, but the real legal risks usually surface years down the road during Post-Clearance Audits, which can look back up to 5 years . Now that Circular 85/2026/TT-BTC has strictly unified the reference database for HS classification, sticking to old self-filing habits without re-checking the new framework is a huge gamble that can easily trigger massive tax back-payments, misdeclaration fines, and years of accumulated interest .

Q2: Our products are purely for civilian use (e.g., standard electronics, industrial valves, cleaning chemicals). Why should we worry about dual-use rules under Circular 42/2026/TT-BCT?

It doesn't matter what you call the product on paper or what you intend to use it for—customs is looking strictly at the HS Code tied directly to its technical parameters . To make things tougher, the new "Catch-all" rule means if a general 4-digit or 6-digit heading shows up on the control list, every single 8-digit code sitting under it automatically falls under dual-use oversight . Skip the MOIT permit on even one of those codes, and your shipment is going to sit stuck at the port .

Q3: Circular 110/2026/TT-BTC repeals 22 tax circulars. Does this grant our business any tax exemptions or reductions?

No . This recent repeal is just routine legal maintenance—cleaning out old, overlapping text that built up over the years as government tax laws evolved . It isn't a tax break or a free pass, so your actual liabilities haven't changed one bit under the current statutes . What you need to do right now is get into your internal systems—your ERP, standard operating procedures, and everyday tax spreadsheets—and pull out those dead legal references before they cause real compliance headaches down the line .

Q4: How should SMEs prioritize their roadmap in September 2026 to optimize resources and minimize risk?

Here is a quick breakdown of how I’d prioritize things over the next couple of weeks if you want to stay ahead of these regulatory updates :

• Top Priority (Before Sept 12, 2026): First up: dual-use goods under Circular 42 . Audit every single export item that could even remotely fall into this category . Don't just rely on product names—get into the weeds with technical specs and cross-check them directly against EU ECCN guidelines .
• Top Priority (Before Sept 15, 2026): Next, take a hard look at your entire product portfolio's HS Codes under Circular 85 . Re-evaluate classification files and align everything with the new standardized reference database before shipping anything out .
• Medium/High Priority: Run a full legal sweep across your operations under Circular 110 . Clean out all references to repealed tax circulars from your internal SOPs, ERP modules, tax templates, and clearance checklists .