Price management

Medical-device pricing in Vietnam follows a market-mechanism approach: businesses set prices freely, but Decree 98/2021/NĐ-CP and its amendments impose transparency obligations to deter overpricing in hospital procurement.

Core obligations:

• Price posting at the place of sale and on the business's electronic channels.
• Public price posting on the MOH-operated electronic information portal — applies to medical devices that fall within the scope of price-declaration rules. The MAC holder or authorised distributor is responsible for keeping the posted price current.
• No selling above the posted price — selling at a price higher than the publicly posted price is a violation subject to administrative penalty.

For products procured by public hospitals, the price posted on the MOH portal is the reference point for tender bid evaluation and for the Vietnam Social Security audit of facility purchases. Posting an unjustifiably high price exposes the seller to reputational and tender-eligibility risk even before formal penalty.

Foreign-manufactured devices: the importer responsible for the product in Vietnam is the posting party. The posting must reconcile with import-value declarations to Customs.

Cross-reference: for public procurement of medical devices including IVD reagents, see Medicine → Tendering & Market Access (Article 55 of the 2023 Bidding Law has medicine and medical-equipment provisions in a single framework).

Core framework:

• Decree 98/2021/NĐ-CP — Chapter on price management; mandates price posting and the role of the public MOH price portal.
• Decree 07/2023/NĐ-CP — issued 3 March 2023. Amends Decree 98/2021, including refinements to the price-posting rules and grace periods after the post-pandemic shortage.
• Circular 05/2022/TT-BYT — implementation details, including posting format.

Related (procurement):

• Law on Bidding 22/2023/QH15 (Article 55) — special procurement regime for medicines and medical devices in public healthcare. See Medicine → Tendering & Market Access.
• Decree 24/2024/NĐ-CP — implements the Bidding Law for contractor selection, with chapter on pharmaceutical and medical-device procurement.

Penalties:

• Decree 117/2020/NĐ-CP and Decree 124/2021/NĐ-CP — administrative penalties in the health sector including failure to post or correctly maintain medical-device prices.

2024 — Bidding Law and Decree 24/2024 in force: Article 55 of the 2023 Bidding Law (effective 1 January 2024) and implementing Decree 24/2024/NĐ-CP (27 February 2024) created a unified medicines-and-devices procurement regime; medical-device price posting feeds directly into public-tender evaluation.

2023 — Decree 07/2023 price-posting refinements: Clarified posting responsibilities and provided transitional relief where shortage-driven price changes risked violation of the prior posting rule.

Standing — Cross-checking on tender pages: VFA, Vietnam Social Security, and the National Centralized Drug Procurement Center cross-check posted prices against winning tender prices for medical equipment; significant gaps trigger scrutiny.