Energy and Infrastructure - Andersen in Cambodia

Final Reminder: Foreign Work Permit Compliance Deadline

We would like to once again draw your attention to Notification No. 038/25 dated December 22, 2025 issued by the Ministry of Labor and Vocational Training, which outlines the requirements for obtaining and renewing foreign work permits for the 2026 calendar year.

The deadline for renewal—March 31, 2026—is fast approaching. Those who have yet to process their work permit renewal should do so now to ensure timely compliance and avoid potential fines or other penalties as specified under the Cambodian labor law.

Key information is provided below.

Work permit application processing

In alignment with the government’s digital transformation initiatives, all applications must be processed through the Foreign Workers Central Management System at www.fwcms.mlvt.gov.kh.

Renewal of existing work permits

Foreign nationals currently holding a valid 2025 work permit are required to apply for a renewal (extension). The renewal process is currently open and will close on March 31, 2026.

New work permit applications

Foreign nationals who have recently entered Cambodia for employment or to engage in a self-employed occupation must apply for their initial work permit within 90 days of their arrival date.

Additional compliance requirements

We would also like to highlight that, pursuant to Instruction No. 110/23 dated December 28, 2023, the following individuals are also required to obtain a work permit, regardless of their physical presence in Cambodia:

Foreign national employers if their name appears on a patent tax certificate
Foreign national employees if their name appears on a patent tax certificate or who is a self-employed person

If you have questions or would like assistance with the above, please do not hesitate to contact us.

0% Customs Duty on Certain Goods Imported from the USA

On August 8, 2025, the Ministry of Economy and Financeissued Prakas No. 632 establishing a 0% customs duty on eligible goods imported into Cambodia from the United States of America. On the same date, the General Department of Customs and Excise (“GDCE”) issued Prakas No. 3724/25 on the Customs Formality Procedures for Goods Originating from the United States of America and Imported from the United States of America. Taken together, these two related Prakas establish the legal basis and customs procedures for applying a 0% customs duty rate on qualifying US-origin goods. Any existing regulations or provisions that contradict these Prakas are considered null and void.

Key Provisions

0% customs duty rate: A customs duty rate of 0% will apply to eligible goods originating from the US and directly consigned to Cambodia.
Eligibility requirements: To be eligible for the 0% customs duty, the goods must originate from the US and be shipped directly to Cambodia without transshipment. This exemption does not apply to used goods, which are explicitly excluded from the scope of the Prakas. The specific criteria for identifying used goods will be determined and clarified by the GDCE.
Proof of origin: Importers must submit appropriate proof of origin using the forms and procedures prescribed by the GDCE to benefit from the 0% customs duty rate.
Effective date: The 0% customs duty rate applies to goods that are loaded onto the means of transport in the US on or after August 8, 2025.

GDCE Procedural Requirements and Eligibility Conditions

The GDCE has outlined specific procedural requirements and eligibility conditions, especially for motor vehicles.

Eligible vehicle criteria

Cars must meet the following conditions to be eligible for the 0% customs duty rate:

Be manufactured in the US;
Be vehicles with a model year of: one year before the current year; the current year; or one year after the current year;
Have less than 5,000 kilometers on the odometer; and
Be in good condition, with no signs of collision, damage, or alteration.

Motorcycles, tricycles, and ATVs must meet the following conditions to be eligible for the 0% customs duty rate:

Be manufactured in the US;
Be vehicles with a model year of: one year before the current year; the current year; or one year after the current year;
Have less than 2,000 kilometers on the odometer; and
Be in original, undamaged condition.

Customs formalities to access the 0% customs duty rate

Importers or representatives must submit a declaration of origin using Form US, via the CVDS electronic system at https://value.customs.gov.kh/CV/Login2.aspx?ReturnUrl=%2fCV%2f.
Supporting documents or evidence of US origin must be available for verification upon request.
Customs verification and approval will follow existing free trade agreement procedures.
Declarants must complete the following in the customs declaration (single administrative document or “SAD”) in ASYCUDA:
- Enter code “KHUSPT” (KH and US preferential tariff) in Box 36 (Preference) of the SAD.
- Enter the number and date of the approved declaration of origin by using “862” as the document name code when lodging the SAD.
Customs officers and declarants can review and verify documents directly through the ASYCUDA system.

Online Labor Inspection Self Declaration Deadline Set for June 30, 2025

On May 30, 2025, the Ministry of Labor and Vocational Training (“MLVT”) issued Notification No. 018/25 on the requirement for entities to submit their labor inspection self-declaration by June 30, 2025.

Effective immediately, all entities that fall within the purview of the Labor Law are required to submit their labor inspection self-declaration through the MLVT’s online system at https://sicms.mlvt.gov.kh. The self-declarations must be completed twice annually June 30 and December 31.

Failure to submit these declarations by the stipulated deadlines will result in the imposition of fines and direct enforcement action by the MLVT’s labor inspectors. Entities should be sure to fully comply with this requirement to avoid any penalties.

The Ministry of Interior Announces Full Implementation of its Personal Identity Data Services

On April 25, 2025, the Ministry of Interior issued Notification No. 1373 on the full implementation of personal identity administrative services starting on May 1, 2025. These services are as follows:

Verification of personal identity data through the Cambodian Data Exchange (“CamDX”) system.
Personal identity attestation.
Confirmation of the accuracy of personal identity data.

Administrative fees

Fees for these services will be implemented in accordance with the Ministry of Interior and the Ministry of Economy and Finance’s Inter-Ministerial Declaration No. 601 dated September 27, 2024 and Council of Ministers’ Letter No. 357 dated March 5, 2025.

Application to use services

To access these services, an application must be submitted through the CamDX system with the necessary technical information to connect to the system in accordance with the Ministry of Interior’s Prakas No. 3922 dated June 19, 2024.

Of particular note is that anyone that has been using these services before full implementation must resubmit their application to ensure compliance with the updated technical standards specified in Prakas No. 3922 to avoid a suspension of services.

Uses for the services

The identity-related services can be used for various purposes, including:

School enrollment
Employment applications
Real estate registration
Vehicle registration
Bank account opening
Business registration
Contract signing
Other administrative services, unless otherwise specified

Further Extension of the Application Period for Work Permit and Employment Card Renewal

On May 6, 2025, the Ministry of Labor and Vocational Training (“MLVT”) issued a notification further extending the deadline for renewing work permits and employment cards for foreign employees. Details are below.

Extension of deadline: Due to delays in the submission of applications for the extension of work permits and employment cards for the year 2025, the MLVT has decided to extend the application period. The new deadline for submission is May 31, 2025.
Online application: All applications for work permits and employment cards must be submitted through the official MLVT website at www.fwcms.mlvt.gov.kh before the stated deadline.
Legal consequences for non-compliance: Failure to renew work permits and employment cards by the deadline will be considered in violation of Chapter 16 of the Labor Law and Joint Prakas No. 498 dated July 31, 2023, and subject to fines, imprisonment, or both.

U.S. Department of Commerce Issues Final Determinations in Antidumping and Countervailing Duty Investigations of Solar Panels from Cambodia, Vietnam and other Southeast Asian Countries

On April 22, 2025, the U.S. Department of Commerce announced its final affirmative determinations in the antidumping duty (AD) and countervailing duty (CVD) investigations of crystalline silicon photovoltaic cells (solar panel cells) from Cambodia, Malaysia, Thailand, and Vietnam. For Cambodia, Commerce determined that imports of solar cells are being dumped into the U.S. market at an average rate of 125.37% and receiving countervailable subsidies at an extraordinarily high rate of 3,403.96%, notably including transnational subsidies from the Government of China. These findings mark a significant trade remedy action against Cambodia, with the U.S. International Trade Commission (ITC) scheduled to make its final injury determination by June 2, 2025. If the ITC confirms material injury to the U.S. industry, Commerce will impose AD and CVD orders at these rates, significantly increasing the cost of Cambodian solar cell imports.

Cambodia and Countervailing Measures

Cambodia has rarely been the subject of U.S. countervailing measures, with the current solar panel investigation being a notable instance due to its alleged focus on transnational subsidies from China. Under the Agreement on Subsidies and Countervailing Measures (ASCM), a subsidy is defined as a financial contribution from a Government or a public body or price or income support which confers a benefit on a producer. In the WTO system, certain subsidies on goods are prohibited, notably when they are contingent on export or the use of domestic rather than imported goods. Subsides are also actionable if they cause injury on a domestic industry of a WTO Member.

Cambodia and Anti-Dumping Measures

Cambodia has faced U.S. anti-dumping measures in a few instances, often alongside other countries. In the 2021 AD investigation of mattresses from Cambodia and six other countries, Commerce found that Cambodian exporters were dumping mattresses at margins up to 45.34%, leading to the imposition of AD duties after affirmative ITC injury determinations. Similarly, in the 2020-2021 AD investigation of passenger vehicle and light truck (PVLT) tires from Cambodia, Korea, Taiwan, Thailand, and Vietnam, Commerce determined dumping margins for Cambodian exporters, resulting in AD duties to counteract unfair pricing practices. These cases highlight Cambodia’s inclusion in broader regional trade remedy actions targeting specific industries.

Cambodia’s Tariff Challenges Amid Trump’s Reciprocal Tariffs

The imposition of steep AD and CVD duties on Cambodian solar cells exacerbates Cambodia’s existing trade challenges, particularly in light of the Trump administration’s reciprocal tariff policies. These policies, which impose mirror tariffs on countries based on their duties against U.S. goods, were paused for 90 days as of early 2025, offering Cambodia temporary relief from additional tariff burdens. However, the combination of high AD/CVD rates and the potential resumption of reciprocal tariffs threatens Cambodia’s export-driven economy, particularly in sectors like solar manufacturing, where it has sought to expand its global market presence.