Vietnam Public Procurement: Bid Prices and Public Hospital Access
Updated: 2026-11-05 · GRZAN Regulatory Team · Verification date 2026-10-20
Q: What is required to enter Vietnamese public hospitals?
A: Three things, all of them necessary: (1) product access — a circulation registration number for Class C/D, a completed Declaration of Applicable Standards for Class A/B; (2) price declaration — declared and updated on the MOH portal (Part 39); (3) company qualifications — a Trading Eligibility Declaration for Class B/C/D trading (Parts 32 and 33).
Q: What evidence must be submitted in a tender?
A: In channel practice, a local distributor submitting a bid must provide one of an import licence, an MA licence or a classification document, depending on the requirement at the time. From 1 July 2025, the “classification document” option no longer works for routine commercial import, and the strongest evidence a bid can contain is the circulation registration number.
Q: Why are winning bid prices published?
A: Because Decree 98 expressly requires the publication of winning bid prices for devices in public healthcare institutions and lists devices and biological products among the price declaration categories. The design intent is to let the same device’s winning price be compared across institutions, so that price anomalies surface. For suppliers this means one award is visible across the market, so pricing strategy has to take the whole picture into account.
Q: What can be seen on the portal?
A: The medical device publication portal provides market price information, including the holder’s selling price, the selling prices of distributors and agents, and the winning bid prices of state-owned healthcare institutions, for reference by organisations and individuals. This transparency mechanism is one of the significant changes Decree 98 introduced compared with the previous system.
Q: What should be noted on pricing?
A: Two hard rules: (1) only the circulation number holder, or a distributor it has authorised, may publish the ceiling price; (2) sales may not exceed the price published on the MOH website. Once the published price is set, the price ceiling for the whole channel is fixed, and any later increase requires an updated declaration first.
Practical note: for the Vietnamese public channel, set the pricing strategy before the tender strategy. The published price becomes a market-wide ceiling once online, and winning bid prices are also made public, so a low-price award compresses the price room in every later channel. Work out the price path for the next two to three years before the first price declaration, rather than chasing volume with a low price first.
Verification checklist (26 October 2026): (1) Decree No. 98/2021/NĐ-CP, price management provisions (declaration before circulation, publication of winning bid prices, prohibition on sales above the published price, only the holder or an authorised distributor may publish the ceiling price); (2) Decree 98/2021/NĐ-CP, Article 22 (circulation conditions); (3) Decree No. 04/2025/NĐ-CP (transitional arrangements ended on 30 June 2025); (4) the price and winning bid price sections of the MOH device publication portal; (5) Law on Prices No. 16/2023/QH15 and Decree 85/2024/NĐ-CP.
Disclaimer
Prepared by GRZAN from publicly available regulation. It is provided for general information only and does not constitute legal advice. Legislation and official fees are subject to change by the competent authority.
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