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In recent years, Vietnam is rapidly overhauling its chemical management framework, starting with a new chemical law (Law on Chemicals No. 69/2025/QH15) passed in June 2025, and ensued the supporting implementation decrees and circulars published on January 17, 2026 for guidance (Click here for more).
Despite the National Chemical Inventory (NCI) being in its draft status, a firm target set by the new law is to finalize NCI by 2028. This means that any unlisted chemical substance will be considered "new chemicals" and shall be registered before production or placing on the Vietnamese market.
However, many companies are operating under a dangerous misconception: that having a substance listed in the current draft NCI guarantees its future as an "existing chemical." This is far from the truth.
The "No Evidence" Trap: A Looming Regulatory Gap
The current draft NCI contains over 40,000 substances, but a staggering 25,000+ substances—more than half of the total—are marked red as "no evidence." This status indicates that the Vietnam Chemicals Agency (Vinachemia) has no proof that these substances are actually circulating in the Vietnamese market.
The last NCI nomination concluded in 2021. If the nomination window reopens, companies dealing with these substances will likely need to resubmit concrete evidence of market circulation (e.g., commercial invoice, sales contract)
Should these substances be struck from the finalized NCI due to a lack of evidence, they will revert to "new chemical" status. This forces companies into a gauntlet of expensive and exhaustive registration and approval procedures. While Vietnam does offer a simplified registration path for chemicals already recognized by major foreign inventories like ECHA, TSCA, and ENCS, the administrative burden remains far higher than maintaining an existing listing on the NCI.
Compounding this risk is the lack of transparency for international stakeholders. Currently, the NCI substance query function is strictly limited to accounts registered as Vietnam-based entities and approved by Vinachemia. Visitor can only access NCI listing status without further details.
For global companies without a direct local presence, verifying the status of their substances—and identifying if they are caught in the "no evidence" trap—is challenging and time-consuming.
What We Can Provide
To avoid being blindsided by the finalized NCI, companies must act now to verify their substance status and prepare for potential re-nominations.
REACH24H, through its local subsidiary in Vietnam, provides one-stop professional compliance service. We offer:
Direct Status Queries: Leveraging our local presence to verify if your substances are listed and, crucially, if they are marked as "no evidence."
NCI Nomination: Expert consulting on gathering the necessary import/export records, sales contracts, and production data required to secure a permanent spot in the NCI.
Other Local Compliance Support: From import declarations and new chemical registration to SDS authoring, and controlled chemicals license applications, we cover the full spectrum of regulatory compliance needs.
For more information, please feel free to contact us at [email protected].
