Instead of generally classifying products and goods with potential safety risks as Group 2 products and goods as previously stipulated, the classification method in this Draft Circular is adjusted according to risk level, including high risk and medium risk, with corresponding management requirements.
Notably, in this Draft, the Ministry of Home Affairs proposes classifying electric elevators and escalators into the medium-risk goods category; elevator and escalator safety components are classified into the high-risk goods category.
Previously, according to Circular No. 22/2018/TT-BLĐTBXH dated December 6, 2018, on the List of products and goods with potential safety risks under the state management responsibility of the Ministry of Labour, Invalids and Social Affairs (now the Ministry of Home Affairs) issued on December 25, 2018, elevators, escalators, and their safety devices were classified as Group 2 products and goods, meaning they have the potential to cause safety risks.

Specifically, the Draft stipulates the following for the List of high-risk products and goods related to elevators and escalators:
a) Elevator safety components include:
• Landing door locking device and car door locking device;
• Safety gear;
• Braking system of the driving machine;
• Overspeed governor;
• Buffer;
• Shut-off valve/check valve of hydraulic elevator
These components apply the corresponding national technical regulations, including:
• QCVN: 02/2019/BLĐTBXH issued under Circular No. 42/2019/TT-BLĐTBXH dated December 30, 2019
• QCVN 32: 2018/BLĐTBXH issued under Circular No. 15/2018/TT-BLĐTBXH dated October 12, 2018
Management requirements for elevator safety components include:
- Declaration of conformity based on the certification results of a certification body designated according to legal regulations.
- Conformity assessment method: Apply Method 5 and Method 7 according to Circular No. 14/2026/TT-BKHCN
- Imported goods shall undergo state quality inspection as prescribed.

b) Safety components of escalators and passenger conveyors include:
• Control braking system to stop the escalator or conveyor;
• Safety braking system;
• Drive machine (motor, gearbox)
National technical regulation applicable to escalator safety components: QCVN 11: 2012/BLĐTBXH issued under Circular No. 32/2012/TT-BLĐTBXH dated December 19, 2012.
Management requirements for escalator safety components:
- Declaration of conformity based on the certification results of a certification body designated according to legal regulations.
- Conformity assessment method: Apply Method 5 and Method 7 according to Circular No. 14/2026/TT-BKHCN
- Imported goods shall undergo state quality inspection as prescribed.
- For QCVN 11: 2012/BLĐTBXH, suspend the implementation of conformity certification, declaration of conformity, and state quality inspection of imports until the Ministry of Home Affairs designates or recognizes a testing organization according to legal regulations.
Thus, the draft removes Method 8 from conformity assessment activities (i.e., conformity) for safety components of elevators, escalators, and passenger conveyors.
Elevators and escalators proposed for the medium-risk category
A notable point in the draft is that electric elevators and escalators are proposed by the Ministry of Home Affairs to be included in the medium-risk product and goods category.
Accordingly, electric elevators are governed by the national technical regulations:
- QCVN: 02/2019/BLĐTBXH issued under Circular No. 42/2019/TT-BLĐTBXH dated December 30, 2019
- QCVN 32: 2018/BLĐTBXH issued under Circular No. 15/2018/TT-BLĐTBXH dated October 12, 2018
Escalators are governed by the national technical regulation: QCVN 11: 2012/BLĐTBXH issued under Circular No. 32/2012/TT-BLĐTBXH dated December 19, 2012.
This draft provides the following state management regulations for the medium-risk category:
- Declaration of conformity with the corresponding technical regulation based on: Conformity certification results from a certification body accredited according to legal regulations; Self-assessment results of organizations or individuals based on test results from a testing organization accredited or designated according to legal regulations.
- Conformity assessment method: Apply Method 1, Method 5, Method 7, and Method 8 according to Circular No. 14/2026/TT-BKHCN.
- Imported goods must declare conformity before being circulated on the market.
Thus, if the draft is issued, a notable new point is that electric elevators and escalators will be classified according to medium risk level, instead of being generally called Group 2 goods as before. The draft also proposes adding Method 1 in conformity assessment activities (i.e., conformity) for electric elevators and escalators.
At the same time, the draft supplements a mechanism for declaring conformity based on the self-assessment results of organizations or individuals in cases where there are test results from an accredited or designated testing organization.
However, it must be emphasized: classifying electric elevators and escalators into the medium-risk category does not mean that safety management requirements are relaxed. These products must still comply with the corresponding technical regulations, declare conformity before being circulated on the market, and be subject to quality management according to legal regulations.







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