Accounting and Reconciling Consumption Norms for Tax Refunds on Raw Materials for Export Production

 23/10/2026

In mid-October, when the customs authority issued an operational guidance document sent to the Vietnam Association of Seafood Exporters and Producers (VASEP) to resolve obstacles in refunding duties on imported goods used for export production, the noteworthy message lay not only in reaffirming the rights of businesses — which have already been specifically prescribed by law — but in a key principle: the fact that products have actually left the national border does not substitute for the requirement of fully proving the legal conditions and quantitative basis for a tax refund.

The Gap Between Legal Rights and Enforcement Condition

For businesses processing agricultural and seafood products and textile-garment enterprises operating under the export production model, the right to request a refund of import duties on raw materials is established at point d, clause 1, Article 19 of the Law on Export and Import Duties No. 107/2016/QH13. Accordingly, taxpayers who have paid import duties on goods used for production and business, but have subsequently brought those goods into the production of exported goods and completed the export, fall under the category eligible for refund consideration. However, this right is tied to a chain of stringent technical conditions, and this very chain of links is where the most obstacles arise.

Based on Article 36 of Decree No. 134/2016/ND-CP (as amended and supplemented in Decree No. 18/2021/ND-CP and Circular 86/2026/TT-BTC), the quantity of raw materials and supplies approved for refund must be the quantity actually incorporated into the exported product; that product must register its customs declaration under the correct declaration type code; at the same time, the business is obliged to prepare a detailed statement of exported products manufactured from the corresponding import declarations, together with the actual consumption norm (through Form No. 15, Appendix I of Circular 86/2026/TT-BTC). This means that the refund amount does not depend on nominal export output but depends on the capability to specifically prove which batch of finished goods each unit of imported raw material was allocated to and which market it was exported to.

• For the seafood processing industry: The finished-product recovery ratio fluctuates by season, by raw material size, and by processing procedure, while also generating large proportions of scrap and by-products (heads, bones, shells, fat, etc.). Therefore, the actual consumption norm does not remain at a fixed figure. If a business does not separate out the value of by-products consumed domestically to deduct from the refundable tax amount as prescribed, the documentation set is likely to be questioned by the customs authority.
• For the garment industry: Managing thousands of raw and auxiliary material codes simultaneously, together with fabric cutting loss rates and design changes with each order, means that the technical norm table between production cycles frequently shows deviations from what actually arises.

When the consumption norm on the refund application does not align with the actual import-export-inventory figures at the workshop and the accounting books, the documentation set will be shifted from the “Refund first, inspect later” category to the “Inspect first, refund later” category. In this channel, the customs authority has a processing period of up to 40 working days from the moment of receiving the complete and valid documentation set. Many cases of documentation being rejected arise simply because the initial export declaration was filed under the wrong specialized declaration type code, causing the business’s tax amount to remain stuck in the budget for a prolonged period, eroding working capital.

A distinction must be made between the duty exemption mechanism for imported raw materials used for export production meeting legal conditions, and the refund mechanism for imported goods that have already been taxed but are subsequently used to produce products that are actually exported. The two cases have different conditions of application and different documentation management requirements.

Standardizing Consumption Norms and Synchronizing Declaration Type Codes

The method for addressing this bottleneck does not begin at the moment of submitting the refund application set, but must be standardized early at the management stage. In its advisory services for businesses in the seafood and textile-garment industries, U&I Logistics approaches this equation through a reconciliation process:

• Reviewing each initial import declaration in detail to precisely determine the declaration type code (A12 or E31), establishing the correct category for refund or exemption under current regulations.
• Cross-checking actual consumption norms against production operation data and actual inventory data to detect discrepancies early, before the customs authority conducts inspection work.
• Rebuilding the actual consumption norm table based on technical foundations and technological processes, replacing estimates based on intuition.
• Consolidating data into the Customs Final Settlement Report and the Form No. 10 statement, ensuring consistent logic among the indicators: imported raw material volume, consumed volume, volume incorporated into products, and by-product volume generated

When the documentation system is established on a synchronized data foundation, subsequent operational stages — including documentation classification, cross-referencing import-export declarations on the VNACCS system, and justification during specialized inspection — become precise, instead of having to passively handle justification requests as they arise.

Tax Refund Cash Flow Is a Competitive Advantage

A consistent documentation set from the very beginning will minimize the risk of prolonged inspection time, helping the refund capital be released into the business’s account on schedule, rather than being frozen across multiple financial periods.

For sub-sectors such as seafood processing and garment exports — where short-term borrowing costs directly affect competitiveness — import duty refund cash flow needs to be positioned as a working capital source that can be planned and managed periodically. Businesses that approach tax refunds as administrative paperwork processed seasonally will continue to face the risk of delayed funds; conversely, businesses that build the operational capability to link factory technical norms, warehousing data, and customs declarations will transform a statutory right into a liquidity advantage.

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