|
THE
MINISTRY OF TRADE
-------
|
SOCIALIST REPUBLIC
OF VIET NAM
Independence - Freedom - Happiness
----------
|
|
No:
11/2001/TT-BTM
|
Hanoi
, April
18, 2001
|
CIRCULAR
GUIDING THE IMPLEMENTATION OF THE PRIME MINISTER’S DECISION
NO. 46/2001/QD-TTG OF APRIL 4, 2001 ON THE MANAGEMENT OF GOODS EXPORT AND
IMPORT IN THE 2001-2005 PERIOD
Pursuant to the Government’s Decree
No.57/1998/ND-CP of July 31, 1998 detailing the implementation of the
Commercial Law’s provisions on export, import, processing and goods sale and
purchase agency activities with foreign countries;
Pursuant to the Prime Minister’s Decision No.46/2001/QD-TTg of April 4, 2001 on
the management of goods export and import in the 2001-2005 period;
After exchanging opinions with the Ministry of Industry, the Ministry of
Construction, the General Department of Customs and a number of concerned
ministries and branches,
The Ministry of Trade hereby guides in detail a number of points for
implementation of the Prime Minister’s Decision No.46/2001/QD-TTg as follows:
1. Goods banned from export and
import:
Goods banned from export and import shall comply
with the lists in Appendices 1A and 1B to this Circular.
2. Goods exported and imported
under permits of the Ministry of Trade:
2.1. Goods exported and imported under permits
of the Trade Ministry shall comply with the list in Appendix 2 to this
Circular.
2.2. For goods specified in Appendix 2 to this
Circular, foreign-invested enterprises and parties to business cooperation
contracts may import them in service of the capital construction to form fixed
assets according to their import plans approved by the Trade Ministry.
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2.3. For goods being supplies and raw materials
specified in Appendix 2 to this Circular, domestic enterprises,
foreign-invested enterprises and foreign parties to business cooperation
contracts that wish to import them for the production of export goods or for
the performance of processing contracts with foreign traders shall have to send
written requests to the Trade Ministry for consideration and settlement.
Enterprises’ written requests must clearly state
names and addresses of importers or processees, quantity of products to be
exported, supplies and raw materials norms for a product unit, quantity of
supplies and raw materials that needs to be imported. Enterprises’ directors
shall be responsible for determining the norms of supplies and raw materials
for production.
Within 5 working days after receiving the
requests, the Trade Ministry shall have to reply the requesting enterprises.
3. Export and import of timber
and wood products:
3.1. Except for the products banned from export
specified in Appendix 1A to this Circular, all kinds of timber and wood
products can be exported and with procedures being carried out at border-gate
customs, and without any application for the Trade Ministry’s permits.
3.2. Raw materials timber (log timber, sawn
timber, planks) shall be imported without the Trade Ministry’s permits and have
to go through only the customs procedures at border-gate customs. Particularly,
raw materials timber imported from Cambodia (including those temporarily
imported for re-export) shall comply with the Trade Ministry’s Circular
No.08/2000/TT-BTM of April 12, 2000.
3.3. Timber of a lawful import origin can be
exported in all forms without any application of the Trade Ministry’s permits.
3.4. Raw material timber and wood products,
except for those temporarily imported for re-export from Cambodia as specified
at Point 3.2 above can be temporarily imported for re-export without any
application for the Trade Ministry’s permits.
4. Export of textiles and
garments into markets with quotas to be agreed with foreign countries:
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4.1. The allocation of textile and garment
quotas in the 2001-2002 period shall comply with Joint Circular
No.19/2000/TTLT/BTM/BKHDT/BCN of October 16, 2000 of the Trade Ministry, the
Ministry of Planning and Investment and the Industry Ministry;
4.2. The bidding for the 2001 textile and
garment quotas shall comply with the Bidding Regulation promulgated together
with Decision No.35/2001/QD/BTM of January 11, 2001 of the Chairman of the
Bidding Council;
4.3. The rewarding of textile and garment quotas
in 2001 shall comply with Joint Circular No.07/2001/TTLT/BTM/BKHDT/BCN of March
16, 2001 of the Trade Ministry, the Ministry of Planning and Investment and the
Industry Ministry.
5. Export of rice:
5.1. For markets with the Government’s
intervention or consents, the Trade Ministry shall designate enterprises for
implementation and direct the transactions (including participation in bidding)
with partners designated by the governmental agencies of the goods-purchasing
countries. Apart from the above-said contracts and partners performing the
governmental contracts, the rice-exporting enterprises may conduct transactions
on rice sale with other partners.
5.2. The mechanism of performing contracts for
export of rice into markets requiring agreements between our Government and the
importing countries’ governments (the governmental contracts) shall comply with
the provisions at Point 2, Article 6 of the Prime Minister’s Decision
No.46/2001/QD-TTg of April 4, 2001.
6. Export of petrol, oil and
fertilizer with import origin:
6.1. Enterprises wishing to export fuel petrol
and oil, including those to be supplied to foreign sea-going ships and
fertilizers of import origin shall have to send their written requests to the
Trade Ministry for consideration and settlement. Enterprises’ directors shall
have to secure that exported goods shall be paid for in freely convertible
foreign currencies.
6.2. The Trade Ministry shall only consider and
approve plans for supply of petrol and oil from imported sources to foreign
sea-going ships of enterprises with the function of providing sea-going ship
supply services.
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6.4. To annul the Trade Ministry’s Document
No.0110/TM-XNK of January 15, 2001 on the management of petrol and oil supply
for foreign sea-going ships.
7. Implementation provisions:
This Circular takes effect as from May 1, 2001.
The previous stipulations which are contrary to the provisions of this Circular
are now all annulled.
MINISTER OF TRADE
Vu Khoan
APPENDIX 1A
LIST OF GOODS BANNED FROM EXPORT AND IMPORT IN THE
2001-2005 PERIOD
(Issued together with the Trade Ministry’s Circular No. 11/2000/TT-BTM of
April 18, 2001)
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Goods
description
Application
duration
I. GOODS BANNED FROM
EXPORT
1
Weapons, ammunitions,
explosives (except for industrial explosives), military technical equipment
2001-2005
2
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2001-2005
3
Narcotics
2001-2005
4
Toxic chemicals
2001-2005
5
Log, sawn timber from domestic
natural forests; charcoal from timber or firewood originated from domestic
natural forests
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6
Wild animals and natural rare
and precious plants and animals
2001-2005
7
Special-use coding machines
and coded software programs used to protect the State secrets
2001-2005
II. GOODS BANNED FROM
IMPORT
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Weapons, ammunitions, explosives
(except for industrial explosives specified
by the Prime Minister in the
Government’s Document No.1533/CP-KTTH of
December 28, 1998), military
technical equipment
2001-2005
2
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2001-2005
3
Toxic chemicals
2001-2005
4
Debauched and reactionary
cultural products; children’s toys with adverse
impacts on personality
education, social order and safety
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5
Assorted firecrackers (excluding
assorted signal fireworks for maritime safety and other needs according to
separate regulations of the Prime Minister in Document No.1383/CP-KTTH of
November 23, 1998).
2001-2005
6
Cigarettes, cigars and other
forms of finished cigarette
2001-2005
7
Used consumer goods, including
the following commodity groups:
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- Textiles and garments,
footwear, clothes
- Electronic appliances
- Electro-refrigerative goods
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- Interior decoration articles
- Consumer goods made of
ceramics, porcelain, crockery, glass, metal, resin, rubber, plastics and
other materials.
The specific goods list is in
Appendix 01B
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8
Right-hand drive transport
means (including those in knock-down form and those with drives already
switched before their import into Vietnam), excluding special-use means
operating for limited purposes, including: crane trucks, canal and ditch
diggers, road sweepers, road-sprayers; garbage dumpers, road surface building
vehicles, passenger transfer vehicles at airports and forklifts at warehouses
and ports.
2001-2005
9
Used supplies and means,
including:
- Used engines, frames, tires and
inner tubes, accessories and motors of automobiles, tractors, motorbikes and
motor-tricycles;
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- Used internal combustion
engines with a capacity of 30 CV or under; used machines fitted with internal
combustion engines with a capacity of 30 CV or under;
- Used chassis mounted with
used engines; used chassis mounted with new engines; new chassis mounted with
used engines
- Used bicycles;
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- Used ambulances;
- Used passenger cars of 16
seats or less (including those of a type designed for transportation of both
goods and passengers with the passenger compartment and the goods hold in the
same cabin);
- Used passenger cars of over
16 seats, with the period from the manufacturing year to the importing year
exceeding 5 years (for example, in 2001 only those manufactured from 1996
onward may be imported);
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- Used trucks of a tonnage of under
5 tons (including those of a type designed for the transportation of both
goods and passengers with the passenger compartment and the goods hold not in
the same cabin; garbage dumpers, self-loading crane trucks, tippers,
semi-trailers for liquids and gases, refrigerator trucks), with the period
from the manufacturing year to the importing year exceeding 5 years (for
example, in 2001 only those manufactured from 1996 onward may be imported).
2001-2005
10
Products and materials
containing asbestos of amphibole group
2001-2005
11
Special-use coding machines
and coded software programs used to protect the State secrets
2001-2005
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APPENDIX 1B
LIST OF USED CONSUMER GOODS BANNED FROM IMPORT
(Issued together with the Trade Ministry’s Circular No. 11/2001/TT-BTM of
April 18, 2001)
This list was drawn up in compatibility with the
codes in the Import Tariff promulgated together with the Finance Ministry’s
Decision No.1803/1998/QD-BTC of December 11, 1998.
The following are principles for using this
list:
1. In cases where only 4-digit codes are
enumerated, all goods items under 8-digit codes which belong to such 4-digit
codes shall be banned from import.
2. In cases where only 6-digit codes are enumerated,
all goods items under 8-digit codes belonging to such 6-digit codes shall be
banned from import.
3. In cases where 4-digit and 6-digit codes are
extended to 8-digit codes, only goods items under such 8-digit codes shall be
banned from import.
4. Other cases shall comply with the
stipulations in the list.
5. Used spare parts and components (if any) of
used consumer goods items banned from import shall also be banned from import.
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7. This list shall be used only for
implementation of Section 7, Part II, Appendix 1 of the Prime Minister’s
Decision No.46/2001/QD-TTg of April 4, 2001.
Chapter
Heading
Subheading
Description
of goods items
Chapter
39
3918
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3922
Bathtubs, showers,
wash-basins...
3924
...
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3925
Builders’ ware of plastics...
3926
...
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nails and nets impregnated
with mosquito killer)
Chapter
42
4201
00
00
...
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4202
Trunks, suitcases, vanity
cases
4203
...
...
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Chapter
43
4303
Articles of apparel and
clothing accessories...
4304
...
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Chapter
44
4414
00
00
Wooden frames for paintings,
photos... similar products
4419
00
00
...
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4420
Wood marquetry and inlaid
wood; caskets and cases for jewelry...
4421
...
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Chapter
46
The whole chapter 46
Chapter
48
4815
00
00
...
...
...
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Chapter
50
5007
Woven fabrics of silk or fiber
from silk waste
Chapter
51
5111
...
...
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5112
Woven fabrics of combed wool
or of combed fine animal hair...
5113
00
00
...
...
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Chapter
52
5208
Woven fabrics of cotton,
containing 85% or more by weight of cotton, weighing not more than 200g/m2
5209
...
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5210
Woven fabrics of cotton,
containing less than 85% by weight of cotton... weighing not more than
200g/m2
5211
...
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5212
Other woven fabrics of cotton
Chapter
53
5309
...
...
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5310
Woven fabrics of jute or other
textile bast fibers...
5311
00
00
...
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Chapter
54
5407
Woven fabrics of synthetic
filament yarn,...
5408
...
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Chapter
55
5512
Woven fabrics of synthetic staple
fibers, containing 85% or more by weight of synthetic staple fibers
5513
...
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5514
Woven fabrics of synthetic staple
fibers, containing less than 85%..., exceeding 170g/cm2
5515
...
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5516
Woven fabrics of recycled
staple fibers
Chapter
57
...
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Chapter
58
The whole Chapter 58
Chapter
60
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Chapter
61
The whole Chapter 61, except
subheadings No.61143010 and 61149010
Chapter
62
...
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Chapter
63
6301
Blankets and traveling rugs
6302
...
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6303
Curtains (including drapes)
and window interior blinds...
6304
...
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6307
10
00
- Floor cloths, dish cloths,
duster and similar cleaning cloths
6308
00
00
...
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6309
00
00
Worn clothing and other worn
articles
Chapter
64
...
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Chapter
65
6503
00
00
Felt hats and other felt
headgear...
6504
00
00
...
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6505
Hats and other headgear,
knitted or crocheted...
6506
...
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6506
91
00
- Of rubber of plastics
6506
92
00
...
...
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6506
99
00
- Of other materials
Chapter
66
6601
...
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6602
00
00
Walking sticks, seat sticks...
Chapter
67
6702
...
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6704
Wigs, false beards,
eyebrows...elsewhere specified
Chapter
69
6910
...
...
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6911
Tableware, kitchenware, other
household articles and toilet articles, of porcelain or chine
6912
00
00
...
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6913
Statuettes and other
ornamental articles of ceramic, porcelain or china
6914
...
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Chapter
70
7013
Tableware and kitchenware...
of glass
Chapter
71
7117
...
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Chapter
73
7321
Stoves, ranges, grates,
cookers...
7323
...
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7324
Sanitaryware and parts
thereof, of iron or steel
Chapter
74
7417
00
00
...
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7418
Tableware, kitchenware... of copper;
sanitaryware
Chapter
76
7615
...
...
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Chapter
82
8210
00
00
Hand-held mechanical
appliances... used in the preparation of food or drink
8212
...
...
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8214
20
00
- Manicure or pedicure sets...
8215
...
...
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Chapter
83
8306
Bells, gongs,...frames for
photos, pictures,...mirror
Chapter
84
8414
51
00
...
...
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8414
59
- - Other types (other than
industrial fans)
8414
90
...
...
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8414
90
90
- - Other types (including only
parts of those under above HS codes)
8415
...
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8415
10
00
- Window or wall type,
self-containing
8415
20
00
...
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8415
81
10
- - - Of a capacity of 90,000
BTU/h or less
8415
82
10
...
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8415
83
10
- - - Of a capacity of 90,000
BTU/h or less
8415
90
...
...
...
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8415
90
19
- - Other types (including
only parts of those under above HS codes)
8418
...
...
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- Refrigerators, household
type
8418
21
00
...
...
...
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8418
22
00
- - Absorption type, electrically
operated
8418
29
00
...
...
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8418
30
- Freezers of the chest type
and with capacity not exceeding 800 liters
8418
30
10
...
...
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8418
40
00
- - With a capacity of up to
200 liters
...
...
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8418
99
00
- - Other types (including
only parts of those under above HS codes)
8421
12
...
...
...
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8421
12
10
- - - Electrically operated
8421
12
20
...
...
...
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- Parts
8421
91
...
...
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8422
Dish washers...
8422
11
00
...
...
...
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8422
90
- Parts
8422
90
10
...
...
...
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8450
Household washing machines...
...
...
...
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8450
11
00
- - Fully-automatic washing
machines
8450
12
00
...
...
...
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8450
19
00
- - Other
8450
90
00
...
...
...
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Chapter
85
8509
Electro-mechanical domestic
appliances, fitted with electric motor
8510
...
...
...
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8516
Electric instant water
heaters... (excluding subheadings No.85164010, 851680 and 85169000)
8518
...
...
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- Loudspeakers, whether or not
mounted in their enclosures
8518
21
00
...
...
...
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8518
22
00
- - Multiple loudspeakers,
mounted in the same enclosures
8518
30
...
...
...
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8518
30
10
- - Headphones and earphones
8518
40
00
...
...
...
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8518
50
00
- Electric sound amplifier
sets
8518
90
00
...
...
...
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8519
Turntables,...cassette
recorders and other sound reproducing apparatus...:
8520
...
...
...
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8520
32
00
- - Digital audio type
8520
39
00
...
...
...
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8520
90
00
- Other
8521
...
...
...
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8522
Parts and accessories...for
apparatus of headings from 8519 to 8521 (including only parts of those under
above HS codes)
8527
...
...
...
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8528
Television receivers...
8528
12
00
...
...
...
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8528
13
00
- - Black and white type...
8528
30
90
...
...
...
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8529
Parts used solely or principally
for apparatus of headings from 8525 to 8528 (including only parts of those
under HS codes of above headings No.8527 and 8528)
8539
...
...
...
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8539
22
90
- - - Other
8539
29
20
...
...
...
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8539
31
10
- - - For decorative
purpose...
8539
31
90
...
...
...
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Chapter
87
8711
Motorcycles (including mopeds)
and cycles fitted with motor
8712
...
...
...
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8714
Parts and accessories of
vehicles of headings from 8711 to 8713 (except parts and accessories of those
of heading 8713)
Chapter
90
9004
10
00
...
...
...
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Chapter
91
9101
Wrist watches, pocket
watches...
9102
...
...
...
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9103
Clocks with watch movements...
9105
...
...
...
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Chapter
94
9401
Seats...
9401
30
00
...
...
...
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9401
40
00
- Seats ... convertible into
beds
9401
50
00
...
...
...
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- Other seats, with metal
frames
9401
61
00
...
...
...
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9401
69
00
- - Other
...
...
...
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9401
71
00
- - Upholstered
9401
79
00
...
...
...
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9401
80
00
- Other seats:
9403
...
...
...
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9403
10
00
- Metal furniture used in
offices
9403
20
00
...
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9403
30
00
- Wooden furniture used in
offices
9403
40
00
...
...
...
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9403
50
00
- Wooden furniture used in
bedrooms
9403
60
00
...
...
...
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9403
70
00
- Plastic furniture
9403
80
00
...
...
...
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9404
Mattress supports; bedding
articles...
9405
...
...
...
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9405
10
- Chandeliers and other
electric ceiling or wall lighting fittings...
9405
10
20
...
...
...
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9405
10
90
- - Other
9405
20
...
...
...
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9405
20
90
- - Other
9405
30
00
...
...
...
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9405
50
- Non-electric lamps and
lighting fittings
9405
50
20
...
...
...
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9405
50
30
- - Other oil-burning lamps
9405
50
90
...
...
...
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Chapter
95
9504
Entertainment articles
9505
...
...
...
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Chapter
96
9603
21
00
- - Tooth brushes
9603
29
00
...
...
...
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9603
90
00
- - Other
9605
00
00
...
...
...
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9613
Cigarette lighters and other
lighters...
9614
...
...
...
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9615
Combs, hair-slides and the
like...
9617
00
10
...
...
...
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APPENDIX 2
LIST OF GOODS EXPORTED AND IMPORTED UNDER THE TRADE
MINISTRY’S
PERMITS IN THE 2001-2005 PERIOD
(Issued together with the Trade Ministry’s Circular No.11/2001/TT-BTM of
April 18, 2001)
Ordinal
number
Goods
description
Application
duration
I. EXPORT GOODS
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Textiles and garments exported
under quotas agreed upon between Vietnam and foreign countries, which are
publicized by the Trade Ministry for each period
2001
- 2005
2
Goods subject to export
control under the international agreements which Vietnam has signed or
acceded to, and which are publicized by the Trade Ministry for each period
2001
- 2005
II. IMPORT GOODS
1
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2001
- 2005
2
Portland cement, black and
white:
Till
December 31, 2002
- White cement:
+ Standard: TCVN 5691: 2000
+ Code: 2523 21 00
- Black cement:
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(Portland cement)
TCVN 6260: 1997
(Mixed Portland cement)
+ Code: 2523 29 10
3
Construction sheet glass:
Standard: TCVN 5776: 1993
- Flat white glass of a thickness of between
1.5 mm and 12 mm:
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- Brownish yellow glass of a thickness of
between 5 mm and 12 mm; blackish green glass of between 3 mm and 6 mm:
Code 7004 20 90; 7005 21 90
Till
December 31, 2001
4
A number of categories of
construction steel:
Quality standards of categories of
domestically produced steel:
· Rolled steel:
TCVN 1765-75; TCVN 1651-85;
GOST 380-94; GOST 5781-82; JIS G3112 (1987).
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TCVN 1765-75; TCVN 1651-85;
GOST 380-94; GOST 5781-82; JIS G3112 (1987);
BS 4449: 1997; AS 1302-1991.
· Rifled steel rods:
TCVN 6285: 1997 (ISO6935-2:1991); GOST 380-94;
GOST 5781-82;
ASTM A615/A615M; ASTM A706/A706M;
BS 4449: 1997; AS 1320-1991; JIS G3112 (1987).
· Shaped steel:
+ Angle steel: TCVN 1656-85; 1656-93
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+ U-shape steel: 1654-75.
- Plain and rough round steel (nodded, rifled,
veined, twisted) in coils of a diameter of up to 40 mm:
Codes: 7213 10 10, 7213 10 20, 7213 91 00,
7213 99 00.
- Plain and rough round steel (nodded, rifled,
veined, twisted) in rods, of a diameter of up to 40 mm:
Codes: 7214 10 20, 7214 20 20, 7214 91 00,
7214 99 00.
- Angle steel of a height of under 80 mm
Code: 7216 21 00
- Angle steel of a height of between 80 mm and
125 mm
Codes: 7216 40 10, 7216 50 10.
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Code: 7216 10 00.
- U-shape steel of a height of between 80 mm
and 140 mm
Code: 7216 31 10.
- I-shape steel of a height of between 80 mm
and 140 mm
Code: 7216 32 10.
- H-shape steel of a height of between 80 mm
and 140 mm
Code: 7216 33 10.
- Assorted black welded steel pipes with a
cross-section of between 14 mm and 127 mm
Code: 7306 30 91.
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Code: 7306 90 91.
- Various kinds of plated steel sheets of a
thickness of up to 1.2 mm, a width of under 1,250 mm and any length:
+ Corrugated zinc-plated steel sheets
Code: 7210 41 10
+ Flat zinc-plated steel sheets
Code: 7210 49 10
+ Aluminum-zinc alloy-plated steel sheets
Code: 7210 61 10
+ Non-ferrous metal-plated steel sheets
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- Various kinds of mild black and hard black
steel wires
Code: 7217 10
- Zinc-plated wire
Code: 7217 20
- Barbed wire
Code: 7313 00 00
- Zinc-plated nets
Code: 7314 41 00.
Till
December 31, 2001
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Refined vegetable oil in
liquid form
Quality standard:
· Free Fatty Acid
(FFA): 0.1% max
· Moisture and Impurities (MNI): 0.1% max
· Color (5.25 Inch Lovibond Cell): 3 Red max.
- Refined soya bean oil:
Code: 1507 90 10
- Refined groundnut oil:
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- Palm oil and fractions of refined palm oil
in liquid form:
Code: 1511 90 90
- Refined coconut oil:
Code: 1513 19 10
- Refined sesame oil:
Code: 1515 50 90
Till
December 31, 2001
6
Refined sugar and crude sugar
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7
Brand-new motorbikes and
motor-tricycles in complete units and sets of components for assembly without
registering the localization rates; engines and frames of assorted motorbikes
and motor-tricycles, excluding those of a type accompanying the component
sets with registered localization rates.
Till
December 31, 2002
8
Brand-new passengers transport
means of 9 seats or less (including those of a type designed for the
transportation of both passengers and goods with the goods hold and the
passenger compartment in the same cabin).
Technical standards of new-type automobiles of
9 seats or less:
- Irrespective of cylinder capacity or engine
(automobiles of all kinds),
- Irrespective of petrol or diesel engine
(spark or compression ignition)
· Vehicles with spark ignition internal
combustion pistol engine:
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+ With a seating capacity of 8 persons or
less, including driver
Code: 8703 21 20
+ With a seating capacity of 9 persons,
including driver
Code: 8703 21 30
- With a cylinder capacity exceeding 1,000 cc
but not exceeding 1,500 cc:
+ With a seating capacity of 8 persons or
less, including driver
Code: 8703 22 20
+ With a seating capacity of 9 persons,
including driver
Code: 8703 21 30
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+ With a seating capacity of 8 persons or
less, including driver
Code: 8703 23 20
+ With a seating capacity of 9 persons,
including driver
Code: 8703 23 30
- With a cylinder capacity exceeding 3,000 cc:
+ With a seating capacity of 8 persons or
less, including driver
Code: 8703 24 20
+ With a seating capacity of 9 persons,
including driver
Code: 8703 24 30
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- With a cylinder capacity not exceeding 1,500
cc:
+ With a seating capacity of 8 persons or
less, including driver
Code: 8703 31 20
+ With a seating capacity of 9 persons,
including driver
Code: 8703 31 30
- With a cylinder capacity exceeding 1,500 cc
but not exceeding 2,500 cc:
+ With a seating capacity of 8 persons or
less, including driver
Code: 8703 32 20
+ With a seating capacity of 9 persons,
including driver
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- With a cylinder capacity exceeding 2,500 cc:
+ With a seating capacity of 8 persons or
less, including driver
Code: 8703 33 20
+ With a seating capacity of 9 persons,
including driver
Code: 8703 33 30
· Other types of vehicles:
+ With a seating capacity of 8 persons or
less, including driver
Code: 8703 90 20
+ With a seating capacity of 9 persons,
including driver
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Till
December 31, 2002
(*) This translation is for reference
only