Request a Demo
On September 5, 2025, Vietnam's Department of Chemicals under the Ministry of Industry and Trade (MOIT) released three draft decrees detailing the implementation of the Law on Chemicals No. 69/2025/QH15, which was passed earlier on June 14, 2025 (set to take effect from January 1, 2026).
The drafts are now seeking public consultation. Opinions may be sent to the Department of Chemicals via [email protected] before September 14, 2025.
These draft documents include:
Expanded Regulatory Scope
In addition to regulating chemical activities, hazardous chemicals in products and goods are now also under the regulatory scope. Companies are required to disclose information on hazardous chemical content, including product name, chemical name, content, and product usage. The submitted information must be authenticated by a recognized testing lab. The ministries in charge of different sectors will promulgate a list of hazardous chemicals in products requiring information disclosure.
Revised Declaration Scope
One of the most significant shifts is the revised scope of chemical declaration. Under the new regulations, all imported chemicals falling under Chapters 28 and 29 of the Vietnamese Export and Import Goods List (Promulgated under Circular 31/2022/TT-BCT) will require declaration before customs clearance through the National Single Window Information Portal.
This means that all inorganic or organic chemicals (Chapters 28 and 29) will be subject to the regulatory scope, a substantial expansion compared to the previous regime, which had a more limited scope (only for listed chemicals and mixtures with GHS classifications).
New Regulated Chemical Lists
A cornerstone of the new regulatory framework is the establishment of new regulated chemical lists. The draft decree designates five key annexes that categorize chemicals for various management purposes:
Annex I: List of Basic Chemicals in the Chemical Industry: This is an entirely new list designed to promote the development of key chemical industries. It identifies 91 chemicals based on criteria such as basic chemicals, pharmaceuticals used in many industries and fields where domestic production is insufficient or non-existent, or those derived from mineral processing.
Annex II: List of Conditional Chemicals for Production and Trading: This list largely inherits from Decree 113/2017/ND-CP(as amended by Decree 82/2022/ND-CP) but has been expanded to include 914 chemicals. These chemicals are identified based on their hazard levels according to the Globally Harmonized System (GHS). Notably, 95 chemicals previously under the restriction list (Annex II in Decree 113/2017/ND-CP as amended) have been reclassified to this conditional list.
Annex III: List of Chemicals Requiring Special Control for Production and Trading: This is a new inventory that focuses on chemicals subject to international treaty controls and those posing risks to national defense, security, social safety, human health, infrastructure, property, and the environment. It includes 126 chemicals, encompassing chemicals listed under CWC Convention, Rotterdam Convention and Stockholm Convention, industrial precursors(previously under the conditional chemical list), and other hazardous substances.
Annex IV: List of Chemicals Requiring Chemical Incident Prevention and Response Plans: This list is fully inherited from Annex IV of Decree 113/2017/ND-CP, drawing reference from the Seveso-III Directive (Directive 2012/18/EU) on controlling major accident hazards involving dangerous substances.
Annex V: List of Training Disciplines for Chemical Safety Activities: This is another new list, defining relevant academic disciplines (primarily chemistry-related) that qualify individuals for chemical safety roles, aiming to ensure competent personnel in chemical operations.
Enhanced Management Procedures
MOIT is the competent authority for managing lists of regulated chemicals. However, certain tasks such as issuance of license or certificate of eligibility are now delegated to provincial or commune governments. (ChemLinked has covered Vietnam’s decentralization work in the state management of chemicals).
The draft decree details the procedures for the application, issuance, re-issuance, and adjustment of various licenses and certificates, including those for conditional chemicals, chemicals requiring special control, and banned chemicals.
It largely inherits the exemption criteria for licenses and certificate requirements from Decree 113/2017/ND-CP. However, the new regulations are now introducing exemption from licensing for banned chemicals with a concentration of less than 0.1%, which was previously only allowed for special purposes like R&D.
New Chemical Registration
The new regulation also introduces a more detailed process for the registration of new chemicals, which are substances not yet listed in the National Chemical Inventory or any other recognized foreign chemical inventories (ECHA chemical inventory, TSCA Inventory, and Japan ENCS Inventory).
Companies intending to produce or import new chemicals must undergo a registration process. The registration dossier requires comprehensive information for chemical evaluation, including the chemical’s identity, physical and chemical properties, hazard classification.
For new chemicals already listed in at least two foreign inventories, companies may submit a simplified registration dossier by only providing summary report of chemical evaluation in those foreign inventories, as well as previous production and business information.
According to the regulation, MOIT will develop the registration forms and the National Chemical Inventory by 2028.
Transitional Period
For chemicals newly subject to the list of chemicals requiring special control but not previously listed under the list of restricted chemicals promulgated in Decree 113/2017/ND-CP, the compliance deadline is December 31, 2026.
For chemicals newly subject to the list of conditional chemicals, the compliance deadline is December 31, 2026.
Existing certificates for conditional chemicals are valid until December 31, 2027.
