Table of Contents
- 1. What the Circular 36/2019 list says about forklifts
- 2. Electric and semi-electric trucks: a grey area to ask an inspection body about
- 3. The inspection procedure for trucks that must be inspected
- 4. Penalties if a truck is on the list but not inspected
- 5. Trucks outside the inspection list: what records and checks to keep
- Frequently asked questions
- Contact us about hand pallet trucks
- References
Reviewed and updated by ICD - Week 43/2026
Under the wording of Circular 36/2019/TT-BLDTBXH, a hand pallet truck operated entirely by human effort (manual hydraulic pump, hand pushed or pulled) is not named on the list of machinery that must be inspected, at any capacity. The list only says “motorised forklifts with a lifting capacity of 1,000 kg or more”. Electric and semi-electric trucks are a grey area, so ask an inspection body before drawing a conclusion.
This guide answers the question of inspecting hand pallet trucks based on Circular 36/2019, QCVN 25:2015, procedure QTKD 17-2016 and Decree 12/2022 on penalties. We separate clearly where the documents say something outright and where it is our own reading, so you know which points to confirm with the competent authority.
1. What the Circular 36/2019 list says about forklifts
Circular 36/2019/TT-BLDTBXH was signed on 30 December 2019, took effect on 1 March 2020 and replaced Circular 53/2016. Item 18 of the list reads, verbatim: “Motorised forklifts with a lifting capacity of 1,000 kg or more.” Two conditions go together: the truck uses an engine, and its lifting capacity is 1,000 kg or more.
| Truck type | Basis | Conclusion |
|---|---|---|
| Low-lift hand pallet truck, manual high-lift stacker, any capacity | No engine, not named in item 18 | Not on the inspection list (by the wording of the document) |
| Motorised forklift (diesel, petrol) with pneumatic tyres, 1,000 kg and above | Circular 36/2019 item 18; QCVN 25:2015 section 1.1.1 (1,000 to 10,000 kg) | Must be inspected before use and periodically |
| Electric and semi-electric trucks of 1,000 kg and above (electric pallet trucks, electric stackers) | Has a motor, but QCVN 25:2015 section 1.1.3 excludes certain groups | Grey area, ask an inspection body |
| Motorised trucks under 1,000 kg | Below the item 18 threshold | Not on the list |
In the same list, manual equipment is named explicitly when it is regulated: hand chain hoists and hand winches with a lifting capacity of 1,000 kg or more (items 14 and 17). Hand pallet trucks have no similar line. That is why we read a hand-pumped, human-powered pallet truck as outside the list; this is a reading of the wording, not an official guidance document.
2. Electric and semi-electric trucks: a grey area to ask an inspection body about
Read literally, item 18 says “motorised”, and an electric motor is also a motor. But QCVN 25:2015/BLDTBXH, issued with Circular 51/2015/TT-BLDTBXH, lists in section 1.1.3 four groups the regulation does not cover: low-lift trucks without loading, high-lift trucks of the loading type (per ISO 5053:1987 terminology), natural-gas forklifts and single-axle industrial trucks.
Forklift inspection bodies you can contact include the Regional Safety Technical Inspection Centre I under the Ministry of Labour, Invalids and Social Affairs (based in Hanoi, lists forklifts in its inspection scope) and QUATEST 2 in Da Nang (lists forklifts among its inspection services under Circular 36/2019). Each body publishes its own scope, so ask first whether they accept your type of truck. The full list of licensed bodies, by province, is available from the Department of Labour, Invalids and Social Affairs where the truck is located.
Section 1.3.1 of the regulation defines self-propelled industrial trucks to include types where the operator walks with the truck. So electric pallet trucks and electric stackers can fall on either side, depending on construction. On single-axle trucks, the Ministry of Home Affairs replied on chinhsachonline.chinhphu.vn on 4 October 2025 that this type does not have to be inspected under QTKD 17-2016.
3. The inspection procedure for trucks that must be inspected
The procedure is set by QTKD 17-2016/BLDTBXH, issued with Circular 54/2016/TT-BLDTBXH (28 December 2016, effective 1 June 2017). It applies to forklifts of 1,000 kg and above with pneumatic tyres and lifting along a guide mast. The steps:
- Review the file and inspect the exterior: mast, forks, chain, brakes, welds.
- Static load test: 125% of rated load, lifted 100 to 200 mm off the floor, held for 10 minutes.
- Dynamic load test: 110% of rated load, lift and lower three times, then drive forward, reverse and turn.
- Parking brake test: 100% load, truck placed on a slope of 20% or more, held for 1 minute.
- Draw up the record and issue the inspection certificate within 5 working days.
The periodic inspection interval is 2 years; for trucks used for over 10 years it is 1 year. The inspector may shorten the interval if the reason is stated.
4. Penalties if a truck is on the list but not inspected
Article 24, clause 4 of Decree 12/2022/ND-CP penalises using machinery or equipment with strict requirements that has not been inspected before being put into use or is past its periodic inspection date. The fine rises with the number of items in breach. The amounts below are for individuals; organisations are fined double (Article 6, clause 1 of the decree).
| Items in breach | Individual | Organisation (double) |
|---|---|---|
| 1 to 3 | VND 20 to 30 million | VND 40 to 60 million |
| 4 to 10 | VND 30 to 50 million | VND 60 to 100 million |
| 11 to 20 | VND 50 to 75 million | VND 100 to 150 million |
| 21 or more | VND 75 million | VND 150 million |
Clause 5 of the same article fines individuals VND 50 to 75 million (double for organisations) for continuing to use equipment that failed inspection. The legal basis for inspection is Article 31 of the 2015 Occupational Safety and Health Law and Chapter II of Decree 44/2016/ND-CP (amended by Decree 140/2018 and Decree 04/2023).
5. Trucks outside the inspection list: what records and checks to keep
A truck that does not need inspection is not one to neglect. When a labour-safety inspection team visits the warehouse, a company should have ready the invoice, certificates of origin and quality (CO, CQ), the manufacturer’s manual, and a log of periodic checks and maintenance. Operators should be instructed according to the manufacturer’s manual. An internal check should include these points:
- Oil leaks at the hydraulic pump unit and lift cylinder.
- Play in the joints and handle.
- Wear or cracks in the wheels.
- Load holding by the check valve: lift and leave, and the forks do not sink.
ICD Vietnam distributes Xilin hand pallet trucks with a 12-month warranty. Related product: ICD BF-III 2.5-tonne low-lift hand truck. Besides selling trucks, ICD Vietnam also repairs forklifts, rents them out and supports instalment purchases.
Frequently asked questions
1. Does a 2-tonne hand pallet truck need an inspection certificate?
If it is a hand-pumped truck driven entirely by human effort, then by the wording of Circular 36/2019 it is not named on the list, because item 18 only mentions motorised forklifts. If the truck has an electric motor it falls in the grey area in section 2 above; if it is an internal-combustion forklift of 1,000 kg and above, it must be inspected.
2. What is the fine for not inspecting a forklift that must be inspected?
Under Article 24, clause 4 of Decree 12/2022/ND-CP, individuals are fined VND 20 to 30 million for 1 to 3 items, rising to VND 75 million for 21 or more items; organisations are fined double.
3. How long is a forklift inspection valid?
The periodic interval under QTKD 17-2016 is 2 years; for trucks used for over 10 years it is 1 year. The inspector may shorten it if the reason is stated.
4. Can a company inspect its own trucks?
A company may check its trucks internally for maintenance, but an inspection certificate with legal value must be issued by a licensed inspection body, under the 2015 Occupational Safety and Health Law.
Contact us about hand pallet trucks
Hotline: 0983 797 186 | 090 345 9186 | 090 5859 186
Zalo: icdvietnam | Email: sales@icdvietnam.com.vn
References
- List of machinery and equipment with strict requirements, items 14, 17, 18: Circular 36/2019/TT-BLDTBXH.
- Inspection procedure, interval and load tests: Circular 54/2016/TT-BLDTBXH, issuing QTKD 17-2016/BLDTBXH.
- Scope and excluded groups of the regulation: QCVN 25:2015/BLDTBXH, sections 1.1.1, 1.1.3, 1.3.1.
- Single-axle trucks need no inspection: Ministry of Home Affairs reply, Chinh sach online, 4 October 2025.
- Penalties, Article 24 clauses 4 and 5: Decree 12/2022/ND-CP.
- 2015 Occupational Safety and Health Law (Article 31); Decree 44/2016/ND-CP, amended by Decree 140/2018 and Decree 04/2023/ND-CP.
