Vietnam to Germany Import Duty 2026: EVFTA Preference and the CBAM Layer

Vietnam-to-Germany is one of the fastest-growing trade lanes in 2026, driven by the EU-Vietnam Free Trade Agreement (EVFTA) progressive tariff elimination and the China-substitution sourcing wave. EVFTA preference makes most Vietnamese exports to Germany duty-free, but the CBAM steel and aluminum layer, German VAT, and a few active EU AD orders still produce real landed cost.

This guide covers the EVFTA framework, the CBAM impact on covered categories, worked examples for the top import categories (apparel, footwear, furniture, electronics, machinery, steel), and the documentation German Zoll wants.

EVFTA in brief

Entered into force August 1 2020. Progressive tariff elimination over a 10-year schedule with some 0-year (immediate) elimination and some 10-year staged elimination. As of 2026:

• Approximately 99 percent of Vietnamese exports to the EU qualify for zero MFN duty under EVFTA.
• The remaining 1 percent (mainly sensitive products: rice, certain processed food, eggs) still have quotas or staged elimination.
• Vietnam is one of the few Asian countries with a comprehensive bilateral FTA with the EU.

Rules of origin

EVFTA Protocol 1 Annex II specifies the per-product rule of origin. Common patterns:

• Chapter 61 to 62 apparel: must be made from origin yarn or fabric (yarn-forward rule similar to USMCA chapter 62), with cutting and sewing in Vietnam.
• Chapter 64 footwear: assembly in Vietnam from non-originating uppers and soles, with detailed minimum value requirements.
• Chapter 84 to 85 machinery: tariff shift to the heading typically, plus regional value content where assembly is the major value-add.
• Chapter 72 to 73 steel: manufacturing from substantial transformation with melt-and-pour in EVFTA-territory equivalent. Vietnam-melt steel qualifies; Chinese-substrate finished in Vietnam does not.
• Chapter 90 to 92 instruments: mixed rules by subheading.

The producer issues an EVFTA proof of origin (REX system registered exporter declaration). The importer claims preference at customs entry with the REX declaration attached.

Worked example: Vietnamese furniture to Germany

100,000 EUR of HTS 9401.61 (upholstered seats with wooden frames) from a Ho Chi Minh furniture producer. Vietnamese-grown rubberwood frame, Vietnamese fabric upholstery.

EVFTA preference applies. Furniture chapter 94 rules require origin in the chapter or in chapters 44 to 49 (wood and wood products) for the frame and origin in chapter 50 to 60 (textiles) for the upholstery. Both Vietnamese-origin.

Effective rate 19 percent (entirely VAT, recoverable for VAT-registered importer).

For a VAT-registered importer, the recoverable VAT means the effective duty cost is approximately 0 percent. EVFTA plus VAT recovery is the cleanest tariff path possible.

Worked example: Vietnamese apparel to Germany

50,000 EUR of HTS 6109.10 cotton T-shirts from Vietnam. Vietnamese-spun cotton yarn, Vietnamese-knit fabric, Vietnamese cutting and sewing.

EVFTA yarn-forward rule satisfied (yarn made in EVFTA territory). Origin Vietnam.

Effective rate 19 percent (recoverable VAT). Without EVFTA the MFN duty on cotton T-shirts is 12 percent, so EVFTA saves 6,000 EUR per shipment.

Critical risk: if the yarn was sourced from China (typical for cheap commodity tees), the Vietnamese fabric and assembly do not satisfy EVFTA yarn-forward. EVFTA preference denied. MFN duty of 12 percent applies. Documentation of yarn origin is essential.

Worked example: Vietnamese steel into Germany

200,000 EUR of HTS 7208.39 hot-rolled steel coil from a Vietnamese steel producer (Vietnam-melt, not Chinese-substrate).

EVFTA preference requires melt-and-pour in EVFTA territory. Vietnamese-melt qualifies.

For the CBAM component, assume 1,000 tonnes shipment, supplier-verified 2.0 tCO2e per tonne:

CBAM on this shipment is 176,000 EUR. Vietnamese steel into Germany pays no MFN duty under EVFTA but pays 88 percent of invoice value in CBAM certificates. The carbon cost has now eclipsed the historical tariff cost.

The strategic implication: EVFTA preference is structurally useful for non-CBAM categories (furniture, apparel, electronics, machinery). For CBAM-scope steel and aluminum, the preference is far less valuable because CBAM is the binding cost.

Worked example: Vietnamese electronics into Germany

200,000 EUR of HTS 8517.62 smart-home devices.

EVFTA chapter 85 rule requires tariff shift to 8517 and RVC equivalent. Vietnamese ODM assembly from Vietnamese PCBs and Vietnamese-origin components.

Effective rate 19 percent (recoverable VAT). Vietnamese electronics into Germany are essentially duty-free post-VAT-recovery.

German VAT mechanics

19 percent German VAT applied to customs value plus duty. For CBAM-scope goods, the CBAM cost is part of the duty base.

Postponed VAT accounting available to VAT-registered German importers. Instead of paying VAT at the border and recovering later, the importer self-assesses the import VAT on the next VAT return as both an input and output (net zero on the return). Removes the cash flow drag.

Eligibility: VAT-registered German importer with a Zollbevollmachtigter (customs power of attorney).

Documentation German Zoll wants

• Commercial invoice (per the standard 18 US fields plus EU additional EORI, TARIC, CN code).
• Packing list.
• Bill of lading or airway bill.
• EVFTA REX declaration (registered exporter declaration from the Vietnamese producer).
• CBAM certificate for steel, aluminum, cement, fertilizer if applicable.
• Insurance certificate for CIF or higher Incoterms.
• For UFLPA-equivalent EU Forced Labor Regulation: due diligence documentation when EU FLR enters into force (currently proposed for 2027 to 2030).

Run your Vietnam to Germany shipment now

The LandedFees calculator handles EVFTA preference checks, the CBAM stack with supplier-verified or default emissions, the German VAT calculation, and the EU AD/CVD posture. Useful for sourcing comparisons across Vietnam, China, Bangladesh, India for EU-destined supply chains.

Calculate a Vietnam to Germany shipment

Section 122 status as of June 20 2026

The May 7 2026 Court of International Trade ruling in Oregon v. United States (consolidated with Burlap and Barrel v. United States) struck down the Section 122 proclamation. The Federal Circuit issued an administrative stay on May 12 2026, so CBP is still collecting the duty pending appeal. Importers paying now should preserve protest rights and refund claims in case the government loses on the merits. The underlying Section 122 authority sunsets July 24 2026 under the statutory 150-day ceiling, regardless of the appeal outcome, unless Congress extends or a fresh proclamation restarts the clock.

Citations

• EU-Vietnam Free Trade Agreement (EVFTA): https://trade.ec.europa.eu/access-to-markets/en/content/eu-vietnam-agreement
• EVFTA Protocol 1 (rules of origin): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:22020A0612(02)
• EU REX registered exporter system: https://taxation-customs.ec.europa.eu/online-services/online-services-and-databases-customs/rex-registered-exporter-system_en
• EU CBAM regulation (EU) 2023/956
• EU Trade Defence Investigations database: https://trade.ec.europa.eu/access-to-markets/en/content/eu-trade-defence-investigations
• German Zoll EORI registration: https://www.zoll.de/EN/Businesses/Movement-of-goods/Import/Duties-and-taxes/duties-and-taxes_node.html