Customs & Global Trade Alert | July 2025 | Focused areas potentially subject to post customs-clearance audit in 2025

In light of ongoing global trade turbulence and rising geopolitical tensions, the Customs Department has issued a directive (Official Letter No. 228/KTSTQ-P2 dated 7 May 2025) to its Regional Customs Divisions aimed at creating more favorable conditions for import-export activities and supporting business operations. Specifically, local customs authorities have been instructed to minimize unnecessary, repetitive, or prolonged post-clearance customs audits (PCA), thereby contributing to Vietnam’s broader economic development goals. 

While emphasizing trade facilitation, to contribute to maintaining trade security and honoring Vietnam’s international commitments, the directive has outlined a focused direction for PCA activities for the remainder of 2025. 

Audit principle

• Target selection and audit execution should be grounded in a risk-based management framework, prioritizing enterprises that have not undergone post-clearance audits by customs authorities within the past five years, as well as those identified as high-risk or potentially non-compliant. 

High-risk areas under scrutiny

Typical risk areas include the risks/violations in following specific subject matters: 

• Harmonized System (HS) code classification, customs valuation and origin of goods 
• Tax exemption/non-payment of export/import duties 

Potential priority audit targets

Potential targets may include: 

• Enterprises that have not been subject to post-clearance audit by customs authorities in the past five years 
• Investment projects with customs incentives 
• Businesses having raw materials imported for processing, manufacturing for export 
• Export processing enterprise 

The directive reflects a supportive posture by the customs authorities, aiming to reduce administrative burdens for most businesses. However, it also sends a clear message that non-compliance — whether intentional or not — may lead to substantial financial and reputational consequences. Current regulations still impose severe administrative penalties for significant violations, such as customs duty or tax evasion, which can negatively affect a company’s risk profile and eligibility for preferential programs (e.g. Authorized Economic Operator – AEO status). 

Recommended actions for businesses

Given the heightened focus on risk-based audits, all import-export businesses are strongly encouraged to proactively review their customs and trade compliance systems. Ensuring accurate classification, valuation, and documentation of goods is not only essential to mitigate exposure to penalties but also to maintain operational integrity and competitiveness in cross-border trade.