EM – The new regulation abolishing the recognition of elevator test results from abroad, which takes effect from 1st February, 2025, is putting businesses in a difficult position, as each elevator unit is expected to bear an additional testing cost of at least 63 million VND (2,419 USD, 1 USD = 26.037 VND). Furthermore, the test results are only valid for each shipment and cannot be applied on a mass scale or for a set duration.
Circular No. 13/2024/TT-BLĐTBXH (hereinafter referred to as “Circular No. 13”), issued on 5th December 2024 and effective from 1st February 2025, officially repeals Article 6 of Circular No. 26/2018/TT-BLĐTBXH. This provision had previously allowed for the “recognition or application of test results given by overseas laboratories.”
Accordingly, instead of being eligible for conformity assessment based on the manufacturer’s overseas testing results as in the past, all elevator equipment must now be retested at a domestic testing laboratory. The situation becomes even more challenging given that, as of now, there is only one designated testing laboratory nationwide – operated by Vinacontrol and located in Hanoi.
Specifically, under Decision No. 496/QĐ-BLĐTBXH issued by the Ministry of Labour, Invalids and Social Affairs on 27th February 2025 regarding the designation of testing organizations, Vinacontrol Certification and Inspection Joint Stock Company has been designated to perform testing in accordance with national technical regulations for Group 2 products and goods under the management of the Ministry of Labour, Invalids and Social Affairs.
According to the List of Designated Testing Scope for Group-2 Products and Goods enclosed with Decision No. 496/QĐ-BLĐTBXH, under Section VI: Elevators; Elevator Safety Components (Types of elevators with a maximum speed of up to 6 m/s), this organization shall conduct testing on five elevator safety components, including:
Accordingly, Vinacontrol Certification and Inspection Joint Stock Company is currently designated to perform testing on 5 out of the 6 mandatory elevator safety components subject to conformity certification. The shut-off valve/check valve of hydraulic elevators remains outside the scope of authorized testing at present.
The category “Elevators; elevator safety components (types of elevators with a maximum speed of up to 6 m/s)” has been designated for testing at the laboratory of Vinacontrol Certification and Inspection Joint Stock Company.
Previously, the cost of elevator conformity certification ranged only in the millions of VND. However, the abolition of recognition and acceptance of foreign testing results has potentially increased the cost of testing and certifying conformity for a single elevator to 63 million VND (approximately 2,419 USD, 1 USD = 26.037 VND), excluding the additional expense of purchasing extra equipment and components specifically for testing purposes.
According to the National Technical Regulation QCVN 02:2019/BLĐTBXH, Section 3.2.1.2, to be granted a Certificate of Conformity, the elevator safety devices must pass testing, including the following:
Mr. Ngô Hồ Á, representative of INCOSAF (Technical Inspection, Safety and Construction Consulting Joint Stock Company), stated that some of these elevator device tests involve destructive testing. For example, overspeed governors and brakes must be tested according to TCVN 6396-50:2017, and landing door locks must endure at least one million opening/closing cycles. After such testing, the components’ safety and normal operation can no longer be guaranteed, requiring companies to purchase replacement safety parts.
This raises a critical concern: once destructive testing is performed, the tested component can no longer be safely used. As a result, companies are forced to purchase a second set of safety components to replace those tested. This issue has also been acknowledged by the testing body Vinacontrol.
A further question arises: What happens if the device sent for testing is compliant, but the replacement device, used for actual installation and operation, is not? This represents a significant regulatory loophole.
Ms. Vũ Thị Nghi, a representative of Laco Engineering Joint Stock Company, explained that this situation means each elevator must now be equipped with two sets of safety devices (one set for testing, one set for actual use), rather than a single set as before. She estimated: “The total cost of testing has reached 63 million VND (2,419 USD) per elevator, and the combined cost of additional equipment for testing and the testing itself may exceed 200 million VND (7,681 USD) per elevator.”
This is an extremely high expense, especially since these safety devices are all core, high-value components of the elevator.
Furthermore, under the current regulations, the test result is only valid for individual products (if imported individually) or per shipment batch. This means each imported elevator, regardless of whether its components share the same model, design, and technical specifications, must be retested from scratch, and prior results may not be reused. This significantly inflates costs and creates a heavy financial burden for businesses.
Additional burdens from delays, contractual violations, and extended storage
In addition to the costs of testing and acquiring spare components, businesses are particularly concerned about the increased time required for testing and conformity certification. Previously, obtaining a certificate of conformity took just 3-5 days. However, after Circular No. 13 took effect, Vinacontrol has indicated that the expected testing period alone may now range from 5 to 15 days.
Many companies fear that the extended testing and certification process will lead to serious delays in fulfilling delivery commitments outlined in contracts with their clients. Certification bodies themselves are also struggling to adapt to the changes introduced by Circular No. 13, causing delays in the processing of company documentation.
Particularly concerning are cases involving elevator shipments that are currently en route and for which spare safety components have not yet been purchased. Even the designated testing organization, Vinacontrol, has not provided a definitive answer on how to address such situations.
Ms. Phạm Thị Hà Tĩnh, a representative of Mitsubishi Elevator Vietnam, shared that elevator components which had already cleared customs at the port are now stuck at the conformity certification stage, forcing Mitsubishi to temporarily suspend delivery.
Delayed conformity certification dossiers are causing enterprises to incur increasing storage and warehousing costs
“In the absence of a Certificate of Conformity, it is not possible to submit the certificate to the Department of Employment, register product quality, or complete customs clearance procedures for subsequent shipments. Naturally, without such certification, inspection procedures cannot be carried out,” emphasized Ms. Tinh, underscoring the cascading consequences that negatively impact the overall business operations of the enterprise.
The temporary suspension of product delivery also entails substantial additional costs, such as high container storage charges at seaports (22 USD/20-foot container per day; 88 USD/40-foot container per day). These represent a significant financial burden that enterprises must unexpectedly bear.
Transporting equipment from the Southern to the Northern regions for testing
Another cost-related issue of concern to enterprises is the transportation of products to the designated testing location. At present, there is only one recognized testing laboratory operated by Vinacontrol, located in Hanoi. Consequently, enterprises operating in other provinces and regions nationwide are required to transport their equipment to the Vinacontrol laboratory in Hanoi for testing purposes.
The designated testing laboratory for conformity assessment in accordance with the national technical regulations applicable to Group-2 products and goods of Vinacontrol Certification and Inspection Joint Stock Company is located at 25 – 27 Truong Dinh Street, Truong Dinh Ward, Hai Ba Trung District, Hanoi. (Photograph taken in December 2023)
Ms. Nguyen Thi Ngoc Lan from Thuan Anh Trading and Service Company Limited, an enterprise specializing in the importation of elevator auxiliary equipment, expressed her concern: “We recently imported a shipment of new traction machines and were required to send the products to Hanoi for testing. The shipment contained hundreds of traction machines across ten different models; it is simply unfeasible for us to pack and transport all of them to Hanoi for testing by Vinacontrol.”
A representative of Thuan Anh further noted that the testing cost for a single traction machine is 12 million VND (460 USD) per unit. For a large shipment such as hers, the total testing cost alone could reach nearly 200 million VND (7,681 USD), excluding any additional related expenses.
“Such costs have risen significantly, and enterprises are compelled to increase their selling prices. If all companies raise their prices, would that truly be a viable solution for the market as a whole?” emphasized Ms. Nguyen Thi Ngoc Lan.
Adjustments needed to strike a balance between regulation and development
With a multitude of costs arising from the new regulations, including testing fees, expenses for standby equipment, product transportation for inspection, and losses caused by project delays, elevator enterprises are currently facing severe financial pressure. In this context, raising product prices has become an almost unavoidable option to maintain operations.
The immediate consequence is that end consumers will bear the burden. Elevator prices, which already represent a substantial investment in construction projects – are expected to rise significantly, leading to higher overall costs for housing, apartment buildings, and other infrastructure, thereby increasing the financial strain on society at large.
Will the shortcomings of Circular No. 13 soon be reviewed and addressed to ensure a balanced approach between regulatory oversight and market development?
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