Lubricating oils are not dangerous goods in most cases, but they are regulated products in Vietnam, Malaysia and Thailand. The documents below are what importers most often ask us for — and, in our experience, what most often arrives incomplete on a first shipment.
Common to all three markets
- Commercial invoice and packing list — grade-by-grade, with net and gross weight per pallet. Vague descriptions such as "lubricants, assorted" cause classification disputes.
- Bill of lading — consignee must match the importer's registration exactly.
- Certificate of origin — Form E under the ASEAN–China FTA reduces duty substantially for Chinese-origin goods. Confirm origin rules with your broker before booking.
- MSDS in English, GHS format — 16 sections, with the correct UN number where applicable (most finished lubricants are not classified as dangerous goods).
- Certificate of analysis per batch — increasingly requested at port, and always requested by the distributor's own customers.
Vietnam
Lubricants fall under the chemicals regime administered by the Ministry of Industry and Trade. Importers typically need the product declared with HS heading 2710.19 and, for products making environmental or performance claims, supporting test data. Vietnamese-language labelling is required on retail packs; we supply the artwork template and can print bilingual labels at the factory if the quantity justifies a plate change.
Malaysia
Labelling must carry the product name, net content, and manufacturer or importer identification. SIRIM certification is not generally required for lubricants, but performance claims referencing an OEM approval should be backed by a document from that OEM — a claim printed on a label without evidence is a compliance risk the importer carries, not the factory.
Thailand
The Thai Industrial Standards Institute administers TIS standards for some lubricant categories, and the Revenue Department applies excise treatment to certain oil products. Confirm the HS code and any excise position with your Thai customs broker before the first shipment — this is the single most common surprise in the market.
Practical advice from the factory side
- Send us your importer's document checklist before production. Adding a certificate after the container has sailed is slow and expensive.
- Order labels in the destination language from the start. Reprinting labels and re-labelling a container in a bonded warehouse costs more than the labels ever will.
- Ask for the MSDS before you register the product, not after. Section 3 (composition) is what regulators ask about first.
We prepare the standard export document set for every shipment and can issue destination-language MSDS translations on request. Contact the export team with your market and HS code, and we will tell you what we can supply.