Key Changes Under Circular 29/2025/TT-BKHCN: What Importers and ICT Distributors Must Know

Key Changes Under Circular 29/2025/TT-BKHCN: What Importers and ICT Distributors Must Know

Vietnam’s Ministry of Science and Technology (MOST) has officially issued Circular 29/2025/TT-BKHCN, introducing a new list of Group-2 products—products with the potential to cause safety risks—within the fields of Information Technology and Telecommunications. This Circular establishes new conformity requirements for a wide range of ICT equipment distributed, manufactured, or imported into Vietnam.

The regulation has become one of the most impactful compliance changes for ICT importers in recent years.

1. Introduction to Circular 29/2025 and Key Highlights

Circular 29/2025/TT-BKHCN provides the updated regulatory framework for:

• The List of Group-2 ICT and Telecommunications products under MOST’s management

• The applicable National Technical Regulations (QCVN)

• The conformity assessment obligations: Certification (CR) and Declaration of Conformity (DoC)

• The responsibilities of manufacturers, importers, and distributors

• The rules for checking quality at importation and market circulation

Key Highlights

• A comprehensive, updated list of ICT equipment that may pose safety risks

• Clear separation between products requiring Certification + Declaration and those requiring Declaration only

• Inclusion of many modern wireless technologies such as Wi-Fi 6E, Wi-Fi 7, and 5G

• A unified framework that replaces earlier, fragmented management from other ministries

• Full alignment with the national system of technical regulations

• Stronger controls on wireless devices to reduce risks relating to interference, EMC, and user safety

  
  

2. Effective Date

Circular 29/2025/TT-BKHCN takes effect on 31 December 2025.

All ICT equipment imported or distributed in Vietnam from this date must comply with the new conformity requirements. Certificates and declarations issued before this date remain valid until their stated expiry.

3. Impact on Wireless Networking Equipment

Wireless devices experience the largest changes under Circular 29 — particularly Access Points, Wi-Fi routers, mesh systems, IoT gateways, home gateways, and wireless CPEs.

3.1. Wireless devices are now classified as high-risk (Group-2)

This means:

• Certification of Conformity (CR) is mandatory, followed by

• Declaration of Conformity (DoC) before market circulation.

This applies to any device integrating:

• Wi-Fi

• Bluetooth

• ZigBee

• LoRa

• Sub-GHz wireless modules

• Cellular (4G/5G) modules

3.2. Wi-Fi 6E and Wi-Fi 7 face stricter control due to the 6 GHz band

Manufacturers and importers must ensure:

• Compliance with 6 GHz power limits (EIRP)

• Restrictions on specific channels depending on Vietnam’s spectrum allocation

• Control of firmware to prevent unauthorized band operation

This results in:

• Longer testing timelines

• Higher testing costs

• Increased risk of non-compliance if global firmware is not adjusted for Vietnam

3.3. Devices with multiple wireless technologies require full testing for each module

A single product may need to meet multiple QCVNs simultaneously (Wi-Fi + Bluetooth + 5G + EMC + safety), with no exemptions even if modules already have international approvals.

This is a major change affecting routers, gateways, IoT hubs, and industrial wireless devices.

4. Impact on Computers: Desktop PCs, Industrial PCs, Laptops

Circular 29 introduces clearer and more predictable rules for computing devices.

4.1. Desktop PCs and Industrial PCs

These device categories fall under Group-2 but require Declaration of Conformity (DoC) only, not Certification.

They must comply with:

• EMC technical regulations

• General ICT electrical safety requirements

• Product-specific QCVNs depending on design

Industrial PCs with wireless modules (Wi-Fi, Bluetooth, 4G/5G) must test and comply with all related wireless QCVNs.

4.2. Laptops

Laptops are treated similarly to desktops:

• Only DoC is required, not CR.

However, there are important exceptions:

Laptops with Wi-Fi (most models)

Must meet QCVNs on:

• Wi-Fi operation

• Bluetooth (if applicable)

• EMC

• Safety

Laptops with Wi-Fi 6E or Wi-Fi 7

They must comply with Vietnam’s strict rules over the 6 GHz band. Importers must ensure the device firmware restricts channels and power limits to Vietnam’s permitted spectrum.

Laptops with integrated 4G/5G modules

These are treated similarly to wireless CPEs, meaning:

• Mandatory testing for LTE/5G QCVNs

• Higher compliance complexity

• More documentation during import inspection

5. Impact on Networking Equipment (Routers, Switches, Gateways)

Networking products fall into two major categories under Circular 29:

5.1. Routers, wireless routers, and gateways

These devices undergo the highest level of regulatory control, including:

• Full CR certification

• Full DoC

• Testing across all wireless and non-wireless functions

Particularly affected are:

• Wi-Fi 6/6E/7 routers

• Enterprise APs

• Mesh systems

• Broadband home gateways

• 4G/5G routers and CPEs

• Industrial routers

5.2. Non-wireless switches and Ethernet-only networking equipment

Ethernet switches without Wi-Fi or wireless radios are treated as lower-risk ICT devices.

They typically require:

• Declaration of Conformity (DoC)

• Compliance with EMC and electrical safety QCVNs

Managed switches, PoE switches, and L2/L3 switches remain in this lower-risk category unless they integrate wireless radio modules.

Reference

• Circular 29 - 2025 / BKHCN in Vietnamese

• Full content in English