Vietnam Distributor Pilot
A distributor pilot checklist for German suppliers entering Vietnam: test sales capability, roles and support before granting exclusivity.
Useful updates for brands, manufacturers and partners moving between Vietnam, Europe and global markets.
Last updated: Sep 9, 2026
A distributor pilot checklist for German suppliers entering Vietnam: test sales capability, roles and support before granting exclusivity.
Do not assume the Vietnamese factory is automatically the only responsible party, or that a German importer automatically carries every packaging duty. Current guidance from Germany's Central Agency Packaging Register distinguishes the packaging manufacturer from the producer responsible in the country where the packaging becomes waste. In a cross-border chain, the producer depends on who first makes the packaging available in Germany; a foreign company shipping directly to German end users can be the producer. For a company based abroad without a German branch that sells empty packaging or packaged products directly to German end users, current German guidance says an authorised representative must be appointed from 12 August 2026, while registration in the LUCID Packaging Register remains the company's own personal duty. A sale to a German importer can produce a different role allocation. The parties should therefore agree the Incoterms and delivery model, packaging layers, brand shown, first German market actor, LUCID and system-participation responsibilities, document owner and correction path before accepting the order.
Treat Digital Product Passport readiness as a shared buyer-supplier information project. The Vietnamese manufacturer controls much of the material, production and facility evidence. The German importer, distributor or brand owner needs to determine the applicable EU role, monitor product-specific rules and decide how the data will connect to its market and compliance systems. Before signing a technology contract, agree the product identifier, model-versus-batch granularity, data owners, evidence standard, access boundaries, update process, retention expectation and correction route. Keep public product information separate from confidential formulas, supplier terms and personal data. Most importantly, do not claim that a Digital Product Passport is already mandatory for every product. The exact requirement only becomes clear through the relevant product-specific measure and its transition period.
For a manufacturer outside the EU, product evidence and listing evidence must meet at the same handover point. Before placement on the EU market, identify the EU-established economic operator responsible for the tasks assigned by Article 16 and record that party's name, postal address and electronic address in the required product, packaging, parcel or accompanying-document location. For a German online offer, prepare a listing pack that clearly connects the offer to the manufacturer; the EU responsible person when the manufacturer is outside the Union; a product picture, type and identifier; and required warnings or safety information in a language consumers can easily understand as determined by the destination Member State. Do not treat a marketplace form as the underlying safety file. The German importer or seller needs the evidence behind the fields, while the Vietnamese manufacturer needs a controlled way to keep the product version, label, instructions, tests and listing copy aligned. The handover should also name the owners for complaints, accidents, corrective action and recall communication. A certification mark or test report can support the assessment when relevant, but it does not replace checking the actual product, legal scope and role allocation.
Treat the choice between default and actual values as a joint pre-contract decision. Default values can reduce the producer's verification workload, but they do not remove the importer's other CBAM obligations. Actual values may be useful when the producer has mature installation data and can complete accredited verification, but they are not automatically the better commercial route. The authorised declarant on the German side controls the declaration and certificate obligation; the Vietnamese producer controls much of the production evidence. Their contract should therefore name the data route, owner, format, deadline, correction process and confidentiality boundary. Do not advertise a low-carbon advantage or quote a CBAM cost benefit until the exact goods, calculation and verification path support it.