”chùng" means "loose, baggy", so these are definitely non-cognate. It is acceptable to unify non-cognate characters with identical appearance, such as U+7551 畑 (Japanese 'field', Vietnamese 'lamp') or VN-F1BD7 and the variant of U+8B49 證 in #11650. However, VN-F1BD7 should be encoded separately from U+28CA2 and U+30FD3
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▲ 《字彙補》, 彙賢齋本, 酉集