Vietnam Publishes Implementation Regulations for Law on Chemicals Effective January 17, 2026

The Vietnamese government has officially implemented comprehensive regulatory guidance for the Law on Chemical No. 69/2025/QH15, with three government decrees and two ministerial circulars taking effect on January 17, 2026. Upon its entry into force, the existing implementation Decree No. 113/2017/ND-CP (as amended by Decree 82/2022/ND-CP) and Circular No. 32/2017/TT-BCT (as amended by Circular 17/2022/TT-BCT) shall be abolished.

The Chemical Law No. 69/2025/QH15 was passed by the National Assembly during its 9th session and came into force on January 1, 2026. To ensure effective implementation, the government has issued five implementing documents that provide detailed guidance on various aspects of chemical management.

Government Decree:

1. Decree No. 24/2026/ND-CP Stipulating the list of chemicals governed by the Law on Chemicals.

2. Decree No. 25/2026/ND-CP Detailing and solutions to organize and guide the implementation of a number of articles of the Law on Chemicals on development of the chemical industry and chemical safety and security.

3. Decree No. 26/2026/ND-CP Detailing and guiding the implementation of a number of articles of the Law on Chemicals on management of chemical activities and hazardous chemicals in products and goods. 

Ministry of Industry and Trade's Circulars:

1. Circular No. 01/2026/TT-BCT Detailing and guiding the implementation of a number of articles of the Law on Chemicals and the Government's Decree No. 26/2026/ND-CP, including GHS requirements (chemical classification, labeling, and SDS), procesures for issuance, adjustment, revocation of licenses.

2. Circular No. 02/2026/TT-BCT Detailing and guiding the implementation of a number of articles of the Law on Chemicals and Decree No. 25/2026/ND-CP, including forms for issuance, re-issuance, adjustment and revocation of chemical consultancy certificates, forms for appraisal and approval of chemical incident prevention and response plans.

Regulated Chemical Lists 

Decree No. 24/2026/ND-CP establishes comprehensive chemical lists that define the scope of regulatory control. These lists include:

• List of basic chemicals in key chemical industries (Annex I): it identifies 39 fundamental chemicals critical to Vietnam's chemical industry development, including ethylene, propylene, benzene, ammonia, sulfuric acid, and various other industrial chemicals.

• List of chemicals subject to conditional production and trading (Annex II): An extensive list of 786 substances requiring certificate of eligibility for production and trading activities.

• List of chemicals requiring special control (Annex III): A list of 241 substances requiring license for production, trading, import/export, including industrial precursors previously regulated as conditional chemicals and newly introduced chemicals listed under Stockholm Convention and Rotterdam Convention.

• List of chemicals requiring incident prevention and response plans (Annex IV): A list of 271 substances that necessitate comprehensive emergency preparedness planning.

The list of banned chemicals is omitted from the existing Decree No. 24/2026/ND-CP. However, it is still explicitly regulated under the new Law on Chemicals and can be found under the Law on Investment (Annex II). 

Decree No. 26/2026/ND-CP provides detailed procedures for obtaining a license to produce or import Banned Chemicals for specific non-prohibited purposes (such as research or security).

In addition, the original list of declarable chemicals under Annex V are abolished. Instead, all imported chemicals under Chapters 28 and 29 of the Vietnamese Export and Import Goods List must declare chemical imports through the National Single Window. 

Hazardous Chemicals in Products and Goods

A major addition in Decree 26/2026/ND-CP is the regulation of hazardous chemicals in products and goods (Chapter IV). 

Organizations and individuals that manufacture or import products or goods containing hazardous chemicals must declare specific information (in a prescribed form) before placing them on the market. This declaration is required for the first production batch or import consignment. 

In addition, relevant businesses must also meet public dislosure and recordkeeping requirements.

Circular No. 01/2026/TT-BCT also designated a list of 10 hazardous chemicals in products under Appendix XIX that are subject to mandatory declaration. 

The  Department of Chemicals  is responsible for receiving, reviewing, and assessing public comments on the list to determine the necessity of updates, before submitting recommendations to MOIT for the final revision of the hazardous chemicals list. 

New Chemical Storage Service

Decree 26/2026/ND-CP officially regulates chemical storage services as a conditional activity. Providers must now obtain a Certificate of Eligibility for Chemical Storage Services. This obligation shall take effect from July 1, 2026.

Chemical Safety Management

The Decree No. 25/2026/ND-CP details the corresponding contents of the Law on Chemicals, clarifying:

• Responsibilities for state management of the development of the chemical industry;

• Requirements for safe distances, chemical safety training;

• Measures to prevent and respond to chemical incidents in the civil sector.

GHS Requirement

The Circular No. 01/2026/TT-BCT rules that chemicals shall be classified according to the rules and technical guidance of UN GHS Rev.2 (2007) onwards. Building blocks from GHS Rev.2 onwards can be adopted for chemical classification in Vietnam.

General instructions and criteria for chemical classification shall be referred to Appendix XV. 

Implementation Timeline

All issued 5 documents shall take effect from January 17, 2026. 

For specific list of chemicals already issued licenses/certificates or newly listed chemicals, the Decree No. 26/2026/ND-CP provides transitional period as follows: