According to the document, for domestically sourced raw materials without value-added tax invoices, traders can use a declaration form for exported goods that meets the "WO" (Wholly Obtained) criteria, as prescribed in Appendix II of Circular No. 44/2023/TT-BCT. This declaration form is self-declared by the trader and does not require confirmation from the local authorities.
The Ministry of Industry and Trade stated that, according to Article 15 of Decree No. 31/2018/ND-CP, applications for Certificates of Origin (C/O) are not required to include a local confirmation document. However, if necessary, the issuing authority may conduct on-site inspections at the production facility or request the enterprise to provide additional documents such as invoices, customs declarations, sales contracts, or confirmation minutes from industry associations, cooperatives, or production groups… to prove the origin of the raw materials.
Previously, on June 24, 2025, the Vietnam Pepper and Spice Association (VPSA) sent Official Letter No. 63/CV-VPSA to the Government Office , the Ministry of Industry and Trade, and relevant agencies, requesting the removal of obstacles in verifying raw material purchase lists without invoices for the purpose of issuing Certificates of Origin (C/O).
According to VPSA, many pepper exporting businesses are facing difficulties as local authorities in some areas refuse to certify the declarations for reasons such as: doubts about the authenticity of the raw materials; concerns about potential forgery; difficulties due to administrative changes; or lack of verification information from the people.
The association argues that these reasons are not entirely appropriate for the specific characteristics of the agricultural sector, where purchasing activities mainly take place between businesses and small-scale farmers – those who do not issue invoices. This significantly hinders the process of obtaining Certificates of Origin (C/O), affecting the export capacity of the entire industry.
VPSA has petitioned the Ministry of Industry and Trade to issue unified guidelines consistent with production practices, and also proposed considering the abolition of the requirement for product lists for some key agricultural products such as pepper, coffee, and coconut. In the short term, the Association also suggested allowing the application of flexible solutions, such as on-site verification, or using confirmation records from industry organizations, cooperatives, and production groups in cases where local authorities do not provide confirmation.
According to experts, the new guidelines from the Ministry of Industry and Trade are considered timely and appropriate to the production and business practices of agricultural enterprises, especially in the context where many farmers do not issue invoices and traditional channels for purchasing raw materials still account for a large proportion in key production areas.
The Ministry of Industry and Trade's issuance of specific and clear guidelines has promptly resolved practical bottlenecks, creating a more transparent and open legal framework for businesses in completing origin documentation. The flexible mechanism, which does not require local confirmation and allows the use of alternative confirmations in special cases, is expected to reduce administrative procedures and boost exports of key agricultural products.
Source: https://doanhnghiepvn.vn/kinh-te/bo-cong-thuong-huong-dan-cu-the-ve-su-dung-bang-ke-thu-mua-nguyen-lieu/20250728082403912






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