The Ministry of Science and Technology (MST) has issued Circular No. 52/2025/TT-BKHCN regarding the technical standard on Electromagnetic Compatibility (EMC) for mobile communications equipment. Along with Circular Letter No. 52/2025/TT-BKHCN, the National Technical Standard on Electromagnetic Compatibility for Terminal and Auxiliary Equipment in Mobile Communication Systems has also been issued with number QCVN 86:2025/BKHCN. As already informed during its draft technical standard, the Circular Letter No. 52/2025/TT-BKHCN along with technical standard QCVN 86:2025/BKHCN shall take effect in early 2026, which specifically on 15 February 2026.
In this article we will discuss all important notes from the new Circular No. 52/2025/TT-BKHCN and the EMC technical standard of QCVN 86:2025/BKHCN for EMC standard on mobile communications equipment.
Key notes of new Circular No. 52/2025/TT-BKHCN
There are some important notes from the issuance of Circular No. 52/2025/TT-BKHCN. Therefore, here are some important notes to understand:
- The National Technical Standard on Electromagnetic Compatibility for Terminal and Auxiliary Equipment in Mobile Communication Systems QCVN 86:2025/BKHCN was issued as an attachment to Circular Letter No. 52/2025/TT-BKHCN.
- The Circular Letter No. 52/2025/TT-BKHCN is effective from 15 February 2026. Therefor, the Circular Letter No. 10/2019/TT-BTTTT dated 4 October 2019 regarding the National Technical Standard on Electromagnetic Compatibility for Terminal and Auxiliary Equipment in Mobile Information Systems is no longer valid.
- For devices with HS codes 8517.13.00; 8517.14.00; 8517.62.59 listed in Appendix I and devices with HS code 8517.62.59 listed in Appendix II of Circular No. 29/2025/TT-BKHCN dated 13 November 2025, must apply QCVN 86:2025/BKHCN replacing QCVN 86:2019/BTTTT from 1 January 2027.
- Businesses, organizations, and individuals may choose to conduct testing according to QCVN 86:2025/BKHCN or QCVN 86:2019/BTTTT for the purpose of declaring conformity from the effective date of this Circular until 31 December 2026.
- The technical requirements for GSM technology (2G and 2.5G) in QCVN 86:2025/BKHCN and QCVN 86:2019/BTTTT shall not apply from 16 September 2026.
- If difficulties arise during the implementation process, institutions, organizations and individuals must immediately report them in writing to the Ministry of Science and Technology for guidance or consideration of appropriate amendments and additions.
Technical standard of QCVN 86:2025/BKHCN
The technical standard of QCVN 86:2025/BKHCN specifies the Electromagnetic Compatibility (EMC) requirements for terminal equipment and related ancillary equipment operated in mobile telecommunication systems according to the following technologies:
- GSM
- UTRA FDD (W-CDMA FDD)
- E-UTRA
- NR (5G)
Technical specifications related to antenna ports and emissions from the enclosure ports of radio equipment that are not within the scope of this technical standard shall be stipulated in corresponding product regulations and standards of the radio frequency spectrum.
The technical standard of QCVN 86:2025/BKHCN applies only to public terrestrial mobile communication terminal equipment listed in the Circular No. 29/2025/TT-BKHCN dated 13 November 2025. The HS codes of equipment within the scope of this technical standard are specified in table below:
| Product Name | HS Code | Product Description |
| Tertiary mobile communication terminal equipment | 8517.13.00; 8517.14.00 | – Smartphone – Other telephones for other wireless cellular mobile networks |
| 8517.62.59 | Terrestrial mobile communication terminal equipment other than mobile phones (transmission equipment combined with receiving equipment), using one or more technologies: E-UTRA (4G); W-CDMA FDD (3G); GSM (2G and 2.5G) | |
| Fifth-generation (5G) mobile communication terminal | 8517.13.00; 8517.14.00 | Terrestrial mobile phone using fifth-generation (5G) mobile communication technology |
| 8517.62.59 | Terrestrial mobile communication terminal not a mobile phone (transmitter combined with receiver), using fifth-generation (5G) mobile communication technology | |
| E-UTRA narrowband IoT terminal | 8517.14.00 | Terrestrial mobile communication terminal using narrowband IoT technology designed to operate in E-UTRA bands |
| SIM Box Device | 8517.62.59 | A SIM box with multiple (more than 2) SIM card slots, with an antenna for terrestrial mobile communication using one or more technologies: E-UTRA (4G); W-CDMA FDD (3G); GSM (2G and 2.5G), 5th generation mobile communication (5G) and operating as an IP network device |
Impact on Vietnam Type Approval
Implementation of Circular No. 52/2025/TT-BKHCN for EMC standard of mobile communications equipment with HS Code codes 8517.13.00; 8517.14.00; 8517.62.59 and 8517.62.59 will require manufacturers, suppliers and importers to comply with the new technical standard QCVN 86:2025/BKHCN.
Conformity with the technical standard of QCVN 86:2025/BKHCN will take effect on 15 February 2026 and will be fully implemented by 1 January 2027. Therefore, starting from 1 January 2027, test reports under the technical standard QCVN 86:2025/BKHCN will be required for Type Approval in Vietnam.
Conclusion
As informed earlier, the implementation of Circular Letter No. 52/2025/TT-BKHCN will impact the process of Type Approval and SDoC in Vietnam. Therefore, it is crucial to prepare for the conformity activities of mobile communications equipment (2G, 3G, 4G and 5G) before the equipment being marketed in Vietnam. During this transitional period, applicants and manufacturers can consult with our expert team. Therefore, feel free to send an email to info@narmadi.com if you have any questions about this new Circular.
