September 28, 2026
On July 22, 2026, the government of Vietnam issued Decree No. 292/2026/ND-CP detailing the implementation of the Law on Foreign Trade Management (Decree 292). Decree 292 came into effect on September 5, 2026, replacing Decree No. 69/2018/NND-CP, and introduces several important changes to Vietnam’s foreign trade regime. Of particular relevance is the addition to the list of goods prohibited from importation of “products and goods extracted, produced, or manufactured wholly or partly through forced labor by enterprises, countries, or territories in accordance with relevant international treaties to which the Socialist Republic of Vietnam is a party.” This new prohibition introduces forced-labor considerations into Vietnam’s import compliance framework and may have practical implications for how businesses manage related risks across their operations and supply chains. Implementation of the New Prohibition According to Decree 292, the minister or head of the relevant ministerial-level agency is responsible for publishing the detailed list and corresponding harmonized system (HS) codes for each category of goods prohibited from export or import under its purview. Goods involving forced labor fall under the purview of the Ministry of Home Affairs. However, as of the date of this article, no corresponding list has been published specifying the goods to which the forced-labor prohibition applies, leaving businesses without official guidance on how the prohibition will be applied or enforced in practice. Nevertheless, this absence does not suspend the prohibition’s application. As Decree 292 has already taken effect, goods involving forced labor remain subject to the general legal framework applicable to goods prohibited from importation. In particular, Decree 169/2026/ND-CP provides for administrative penalties for the importation or transportation of prohibited goods into Vietnam. Depending on the nature and circumstances of the violation, criminal liability may also arise under the Criminal Code. In practice, enforcement is likely to depend on the