When does Circular 26/2026/TT-BCT take effect?

In principle from 29/5/2026, but certain provisions follow separate schedules: 1/7/2026 (provincial authority over industrial explosives import/export licensing), 1/8/2026 (khoản 3, Điều 19, on C/O), and 1/1/2027 (provincial authority over Laos/Cambodia transit permits).

Does C/O decentralization apply to all types of C/O?

Yes. Điều 19 (amending Thông tư 40/2025/TT-BCT) is the general framework, splitting C/O types between Phụ lục I (issued by the Import-Export Department, now Mẫu số 17) and Phụ lục II (issued by provincial People's Committees, now Mẫu số 18). Điều 20 adds a specific rule only for the UAE-VN C/O form.

Why does China transit have a different effective date than Laos and Cambodia?

Because khoản 3 of Điều 27 specifically names only Điều 15 and Điều 16 (covering Laos and Cambodia) as delayed until 1/1/2027. Điều 14 (China) is not mentioned in that clause, so it applies immediately from the general effective date of 29/5/2026.

Circular 26/2026/TT-BCT: Full Picture of Decentralization Across 8 Sectors of the Ministry of Industry and Trade

On 20/5/2026, Vietnam's Ministry of Industry and Trade issued Circular 26/2026/TT-BCT, effective from 29/5/2026 — one of the sector's largest administrative-procedure reforms this year, with 28 articles spanning 8 fields: industrial explosives and explosive precursors, minerals, tobacco, petroleum trading, e-commerce, import-export, chemicals, and transport of dangerous goods. The consistent theme is shifting many licensing powers from ministries/departments down to provincial People's Committees, in line with the rollout of the two-tier local government model. For import-export businesses, the most notable change is the decentralization of Certificate of Origin (C/O) issuance — not just the UAE-VN form as some early reports suggested, but the entire general C/O framework under Nghị định 146/2025/NĐ-CP.

Full picture: 8 sectors and 28 articles

The Circular is organized into 8 chapters matching the 8 sectors, plus general implementation provisions (see the diagram above):

Chapter I – Industrial explosives, explosive precursors (Điều 1-3): three-tier authority split between the Department of Technical Safety and Industrial Environment, the Chemicals Department, and provincial People's Committees.
Chapter II – Minerals (Điều 4-5): shortens the review/approval timeline for underground mining risk-management plans to 7 working days.
Chapter III – Tobacco (Điều 6-9): shifts dossier-receiving authority to provincial People's Committees, repeals dozens of old appendices/forms.
Chapter IV – Petroleum trading (Điều 10-11): repeals several provisions rendered obsolete by earlier amendments.
Chapter V – E-commerce (Điều 12-13): repeals periodic reporting requirements for website/app management.
Chapter VI – Import-export (Điều 14-22): the largest chapter, covering decentralization of transit permits for goods from China, Laos, Cambodia, and the entire C/O issuance framework.
Chapter VII – Chemicals (Điều 23-24): decentralizes licensing for production, trading, and import-export of specially controlled chemicals to provincial People's Committees.
Chapter VIII – Dangerous goods transport (Điều 25-26): provincial People's Committees receive and license transport of Type 5 and Type 8 dangerous goods.
Điều 27-28: implementation and transitional provisions.

A closer look at C/O decentralization — Điều 19, not just Điều 20, is what matters most

Many early reports mentioned only the decentralization of the UAE-VN C/O form, but that is actually the smaller piece. The underlying policy, per khoản 6 Điều 28 of Nghị định 146/2025/NĐ-CP, is to decentralize the entire C/O issuance and self-certification approval process to provincial People's Committees. Circular 26/2026/TT-BCT implements this through two separate articles:

Điều 19 amends Thông tư 40/2025/TT-BCT — the original regulation governing C/O issuance in general. The Import-Export Department continues to issue the C/O types listed in Phụ lục I (now replaced by Mẫu số 17), while provincial People's Committees issue the C/O types listed in Phụ lục II (now replaced by Mẫu số 18).
Điều 20 amends Thông tư 24/2026/TT-BCT — specifically for the UAE-VN C/O form under the Vietnam–UAE CEPA, shifting issuing authority to provincial People's Committees, with signature/seal specimens registered through the Import-Export Department.

Effective dates: not everything kicks in on the same day

Điều 27 sets the Circular's general effective date at 29/5/2026, but several provisions follow separate schedules: provincial People's Committees' authority to license import/export of industrial explosives takes effect from 1/7/2026; their authority over transit permits for goods from Laos and Cambodia (Điều 15, 16) takes effect from 1/1/2027; and khoản 3 of Điều 19 specifically (replacing Phụ lục I with Mẫu số 17 for C/O issued by the Import-Export Department) takes effect from 1/8/2026.

One easy point of confusion: khoản 3 of Điều 27 names only Điều 15 and Điều 16 (Laos, Cambodia) as delayed — Điều 14 (China transit) is not mentioned. This means decentralization of China transit permits to provincial People's Committees applies immediately from 29/5/2026, nearly 8 months ahead of Laos and Cambodia.

Official letters and notices putting C/O decentralization into practice

After the Circular took effect, a series of implementation documents followed:

Official Letter 552/XNK-XXHH (21/5/2026) from the Import-Export Department — initial guidance for implementing Circular 26/2026/TT-BCT.
Consolidated document 48/VBHN-BCT (4/6/2026) — merges Thông tư 40/2025/TT-BCT with the amendments from Circular 26/2026/TT-BCT into a single reference text.
Official Letter 870/XNK-XXHH (21/7/2026) from the Import-Export Department — guidance for re-registering C/O-issuing bodies on the eCoSys system (co.moit.gov.vn) before 1/8/2026.
Notice 1370/TB-SCT (27/7/2026) from the Ho Chi Minh City Department of Industry and Trade — officially begins receiving and processing C/O and self-certification approval applications from 1/8/2026.

What businesses and local authorities should do

Exporters: proactively log into eCoSys, review current C/O application dossiers ahead of the 1/8/2026 deadline to avoid disruption when filing.
Businesses with transit operations through Vietnam: note the different effective dates for China (29/5/2026) versus Laos and Cambodia (1/1/2027).
Businesses in explosives, chemicals, tobacco, or petroleum: confirm that the new receiving authority is now the provincial People's Committee rather than the ministry/department as before, to avoid filing with the wrong office.
For issues that arise: know which office to contact — origin-related questions go to the Import-Export Department, eCoSys technical issues go to the E-commerce and Digital Economy Department.