Domestic companies buy fabric as raw materials to produce clothes and export them to foreign countries, both fabric materials and clothes produced by Vietnamese people do not use.

Ms. Huong asked, does the company that sells the excess raw materials have to declare the conformity and affix the conformity mark (CR mark) to the fabric before taking the goods out of the factory to deliver to the customer? Those surplus raw materials when sold have been converted for purposes and issued a VAT invoice.

The Ministry of Industry and Trade responded to this issue as follows:

On October 23, 2017, the Ministry of Industry and Trade issued together with Circular No. 21/2017/TT-BCT stipulating national technical regulations on the limit of formaldehyde and aromatic amines converted from azo dyes in textile products (QCVN: 01/2017/BCT). QCVN: 01/2017/BCT stipulates:

In Appendix I: List of textile products (with HS codes) governed by the Regulation;

At 1.3.1: "Bringing to the Vietnamese market: means an organization or individual that manufactures, imports and trades textile and garment products conducts the act of buying, selling, exchanging and marketing with organizations and individuals. other";

At 3.1: "Products and goods before being put on sale on the Vietnamese market must be declared regulation-conformity in accordance with the provisions of this Regulation and affixed with the regulation conformity mark (CR mark)".

Based on the above provisions, according to the information provided by her, the Ministry of Industry and Trade guides as follows:

Textile products listed in Appendix I, when put on sale in the Vietnamese market, must be announced in conformity with regulations; affix the conformity mark (CR mark). Organizations and individuals producing and trading in textile and garment products are responsible for announcing the regulation conformity. QCVN: 01/2017/BCT does not specifically stipulate that organizations and individuals must make the announcement of regulation conformity.

Textile products in Appendix I, which are not sold on the Vietnamese market (for export), are not required to declare conformity; affix the conformity mark (CR mark).

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