Official Document 105/CHQ-GSQL: Guidance on affixing import stamps and storing goods in warehouses.

Official Document 105/CHQ-GSQL The guidelines on import labeling and warehousing are important legal documents issued by the Customs Department to address difficulties in labeling procedures and warehousing management. In the context of increasingly stringent import and export regulations, understanding the contents of this document helps businesses avoid legal risks and unnecessary late payment penalties.

In reality, many businesses are still confused about distinguishing between original and supplementary labels, as well as the conditions for bringing goods into storage to optimize the customs clearance process. Below is a detailed analysis of Circular 105/CHQ-GSQL guiding the application of import labels and storage of goods, along with important notes for accounting and import/export departments.

The main content of Official Letter 105/CHQ-GSQL is the guidance on affixing import stamps and storing goods in warehouses.

The legal basis of Official Letter 105/CHQ-GSQL, which provides guidance on affixing import stamps and managing goods storage, is based on current decrees on goods labeling and customs management circulars. This document focuses on two main aspects: the transparency of information on goods labels and technical standards for warehouses storing goods awaiting customs clearance.

Strict adherence to Circular 105/CHQ-GSQL guiding the affixing of import stamps and the storage of goods helps management agencies control the flow of goods, while also supporting businesses in moving goods to their own warehouses for storage while awaiting specialized inspections.

Regulations on labeling of imported goods (Import labels)

According to the guidelines, the original label of the goods must be displayed the first time the producing organization or individual affixes it to the product packaging. This content strictly complies with Clause 3, Article 3. Decree 43/2017/ND-CP and the amendments in Decree 111/2021/ND-CP.

Official document 105/CHQ-GSQL, providing guidance on affixing import stamps and storing goods in warehouses, emphasizes the mandatory information on the original label during customs clearance, including:

• The exact name of the goods as stated in the contract and declaration.
• Origin of goods (Made in…).
• Information about the organization or individual responsible for the goods located abroad.

Summary of regulations on labeling of imported goods (Import labels)

Content of the test	Detailed regulations	Note the facts
Language	Foreign language or Vietnamese	A Vietnamese supplementary label is required if the original label is in a foreign language.
Placement	On goods or commercial packaging	Easily visible, not obscured by other components.
Accuracy	Match 100% with customs documents	Incorrect origin information can lead to heavy administrative penalties.

The permitted location for goods to be brought in for storage (Storage warehouse)

Regarding location, businesses must meet the standards set forth in Circular 39/2018/TT-BTC. Warehouses must have a clear address and be completely separated from the surrounding area to ensure the "original condition" of the goods. Properly applying Circular 105/CHQ-GSQL guiding the affixing of import stamps and the storage of goods in this stage helps businesses reduce the burden of warehousing fees at the port.

Responsibilities of the customs declarant under the Customs Law 2014

In addition to complying with Official Letter 105/CHQ-GSQL guiding the affixing of import stamps and the storage of goods, customs declarants must adhere to the responsibilities stipulated in Article 21 of the 2014 Customs Law. This is the foundation for businesses to affirm their compliance and credibility with tax and customs authorities.

Customs declarants are responsible for truthfully and completely declaring all criteria on the declaration form. Any discrepancies between the actual affixing of stamps and the declaration directly affect the declaration's classification result. If businesses properly apply Circular 105/CHQ-GSQL on affixing import stamps and storing goods in warehouses, this process will run more smoothly.

Financial obligations and documentation procedures

• Submit the declaration form: Comply with the deadlines and submit the required documents as stipulated in Article 24 of the Customs Law.
• Fact check: Bring the goods to the designated location for customs officials to inspect the design, labels, and stamps in accordance with Official Letter 105/CHQ-GSQL guiding the affixing of import stamps and the storage of goods in warehouses.
• Tax obligations: Complete all import duties, VAT, and excise taxes before releasing the goods.

On-site inspection and monitoring of imported and exported goods.

One new point updated in this article is the regulation on on-site import and export under the amended Law of 2025. Goods delivered and received in Vietnam but as specified by foreign traders are still subject to strict supervision. The affixing of stamps and warehousing for these goods must also refer to Circular 105/CHQ-GSQL on Guidance on affixing import stamps and warehousing of goods.

Coordination among domestic businesses in on-site import and export transactions requires accurate documentation. Businesses need to ensure that goods are always in a state ready for inspection and that labels are transparent, as stated in Circular 105/CHQ-GSQL on Guidance on affixing import stamps and storing goods in warehouses.

Risks and penalties for violating regulations on affixing labels and proper storage.

Failure to comply with Official Letter 105/CHQ-GSQL guiding the affixing of import stamps and the storage of goods in warehouses may result in fines ranging from VND 500,000 to tens of millions of VND, depending on the value of the shipment. In particular, the most serious offense is "violating the original condition of goods" upon arrival at the warehouse for storage.

Below is a table summarizing common errors based on the spirit of Official Letter 105/CHQ-GSQL guiding the affixing of import stamps and the storage of goods in warehouses:

Summary of risks and penalties for violations of regulations on affixing labels and proper storage.

Violation	Level of influence	Remedial measures
No original label	Suspension of customs clearance, fines.	Re-export or add labels in the supervised area.
Unauthorized opening of the warehouse seal.	Severe penalties, revocation of the right to bring goods to the warehouse.	We are only allowed to open for business after receiving the results of the specialized inspection.
Original label indicates incorrect origin.	Forced re-export, administrative penalties imposed.	Carefully check the Certificate of Origin (C/O) before affixing the stamp.

Applying Circular 105/CHQ-GSQL guiding the affixing of import stamps and the storage of goods is not only an obligation but also a way for businesses to protect themselves from post-clearance inspections by state management agencies.

Conclude

Circular 105/CHQ-GSQL, providing guidance on affixing import stamps and managing goods storage, serves as a "compass" for businesses' customs logistics operations. Understanding and correctly implementing these guidelines not only speeds up the flow of goods but also builds a solid and transparent accounting and tax foundation before tax settlements and customs inspections.

However, with the complexity of constantly updated circulars and decrees, businesses are very prone to making mistakes in the documentation process. MAN – Master Accountant Network is proud to be a leading provider of comprehensive solutions:

• Auditing services and tax accounting: Verify the validity of import documents in accordance with Official Letter 105/CHQ-GSQL guiding the affixing of import stamps and the storage of goods in warehouses.
• Tax consulting services: Addressing issues related to labeling, origin, and preferential tax rates.
• Tax settlement services and tax reporting: Ensuring all import figures are accurately reflected in the accounting system minimizes the risk of expenses being disallowed when calculating corporate income tax.

Frequently Asked Questions about Official Document 105/CHQ-GSQL

Can I use a Vietnamese supplementary label instead of the original label?

No. According to Official Letter 105/CHQ-GSQL guiding the affixing of import stamps and storage of goods, the original label is mandatory. The supplementary label is only additional content to explain the original label in a foreign language.

Does the storage facility need prior approval from Customs?

Businesses are responsible for warehouse conditions as stipulated in Circular 39. However, when processing the procedures for bringing goods into storage, you must provide documentation proving your right to use the warehouse and commit to maintaining the goods in their original condition in accordance with Official Letter 105/CHQ-GSQL guiding the affixing of import stamps and the storage of goods in warehouses.

Can goods currently in storage be sold?

Absolutely not. Goods are only permitted to circulate after official customs clearance has been received from the Customs authorities. Selling goods before customs clearance is a serious violation of Circular 105/CHQ-GSQL guiding the affixing of import stamps and the storage of goods in warehouses.