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Vietnam's National Assembly has recently enacted Law No. 69/2025/QH15 on Chemicals, effective January 1, 2026. This new legislation significantly overhauls the country's chemical management, introducing key changes to bolster safety, sustainable and synchronous industry development.
Regulated Chemicals and Administrative Procedures
Chapter III (Articles 9 to 19) of the new Chemical Law introduces a more refined and streamlined approach to managing various categories of chemicals and chemical processes.
Compared to the previous version, the new law is replacing the “restricted chemicals” with “chemicals requiring special control”. This designation applies to hazardous substances and mixtures identified by the Government, especially those subject to international treaties signed by Vietnam, and chemicals posing potential threats to national defense, security, social safety, human health, facilities, property, or the environment.
Notably, the concept of "toxic chemicals", which is clearly defined by specific GHS criteria, is now replaced by "toxic substances" with a broad definition. The regulation for purchase and sale of "toxic chemicals" is now integrated into the regulation of "chemicals requiring special control" group.
In addition, the list of "chemicals subject to declaration" is omitted. Instead, all imported chemicals will need to be declared upon custom clearance, except for the already licensed "chemicals requiring special control", "restricted chemicals" and other exemptions granted by the government.
Overall, the law adopts a tiered management approach for controlled chemicals: conditional chemicals face the most lenient regulations, followed by chemicals requiring special control, with banned chemicals under the strictest control.
The regulatory status of chemicals under the new Law on Chemicals is summarized below:
| Regulated chemicals | Requirement | Issuing authority | Validity (production/trade/storage） | Validity (import/export) |
| Conditional chemicals | Certificate of eligibility for production/trade/storage service | Provincial People’s Committees | 5 years | Permitted after production/trade certificate granted |
Chemicals requiring special control | Production/trade license; Import/export License | Ministerial- level agencies | 5 years | 6 months (per import/export invoice) |
Banned chemicals | Production license; import/export license | Ministerial-level agencies | 12 months | 6 months (per import/export invoice) |
Chemicals requiring plans for chemical incident prevention | Develop plans for chemical incident prevention and response | / | / | / |
| Declarable chemicals | Abolished | |||
| Toxic chemicals | Abolished | |||
New Chemicals
The definitions for new chemicals under the new law are consistent with the previous version, which refer to "chemicals that are not named under national lists of chemicals and foreign lists of chemicals recognized by Vietnamese authorities".
So far, Vietnam has not promulgated its national chemical list, which is known as National Chemical Inventory (NCI). While Vietnam's NCI is still in draft form, with approximately 41,881 entries, the inclusion of recognized foreign lists (currently from the USA, EU, and Japan) on the national database significantly expands the total to 175,481 entries. This is good news for businesses that have already registered their chemicals in these countries, as those substances may be considered existing chemicals in Vietnam and won't require new registration.
For new chemicals, the registration process will require both written documentation and risk assessment data from officially recognized bodies. Once registered, these new chemicals will be managed as "chemicals requiring special control".
Hazardous Chemicals in Products and Goods
The new Law will strengthen regulations regarding hazardous chemicals contained in products and goods. So far, Vietnam has or has planned to issue various QCVN (National Technical Regulations) for specific products, for example:
QCVN on hazardous chemicals in electrical and electronic products: There was a Draft National Technical Regulation QCVN....:2022/BCT expected to take effect from January 1, 2026, replacing Circular No. 30/2011/TT-BCT.
QCVN for Food Contact Materials (FCM): The Ministry of Health has issued QCVNs (e.g., QCVN 12-1:2011/BYT, QCVN 12-2:2011/BYT, etc.) outlining safety and hygiene requirements for materials in direct contact with food.
In addition to existing technical regulations, ministries will promulgate list of hazardous chemicals in products and goods. Manufacturers and importers have the obligations to declare content of hazardous chemicals in products and goods prior to market circulation on national chemical database, or on their websites, or at locations where products and goods are sold.
Transitional Provisions
The Law enters into force from January 1, 2026. However, provisions on certificate of eligibility for chemical storage service for chemicals requiring special control applies from July 1, 2026.
Other transitional provisions include:
License to produce or trade chemicals issued before January 1, 2026 shall continue to operate until expiry.
Certificate of eligibility for production or trade issued before January 1, 2026 shall continue to operate until December 31, 2027.
Plans for chemical incident prevention that have been approved before January 1, 2026 shall remain effective.
In case a new chemical is listed as "conditional chemicals" or "chemicals requiring special control", which is not listed under the original Law on Chemicals (No.06/2007/QH12), the requirements under the new law must be satisfied before December 31, 2026.
External Resources
ChemLinked Translation for Law on Chemicals No. 69/2025/QH15 is available here.
Click the link below to know more about chemical management in Vietnam:
