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On March 5, 2025, Vietnam Chamber of Commerce and Industry (VCCI) initiated a public consultation on the second draft of the amended Law on Chemicals, which was submitted to the National Assembly in October 2024 for legislative review.
The second draft comprises of 11 chapters and 95 articles, aiming to modernize Vietnam’s chemical regulatory framework, addressing critical gaps in safety, sustainability, and lifecycle management while aligning with global standards.
In general, it adheres to the following core policies:
Sustainable development of the chemical industry into a modern, fundamental industry
Synchronous management of chemicals throughout the entire life cycle
Management of hazardous chemicals in products
Improving the effectiveness of ensuring chemical safety
Regulated chemicals
The draft introduces significant changes to the concepts of regulated chemicals. In particular, the “restricted chemicals” are now replaced by “chemicals requiring special control". The previous category of“Chemicals subject to declaration” is eliminated; instead, all chemicals—including newly developed substances—must now be declared upon import. In addition, the draft also adjusts the concept of “hazardous chemicals” and deleted the concept of “toxic chemicals”.
The management of regulated chemical activities is now separated into production, trading, transportation, storage and preservation, use, treatment and disposal according to the entire life cycle. The licensing requirements for different regulated chemicals basically inherits the 2007 Law on Chemicals.
The regulatory status of chemicals under the amended Law on Chemicals is summarized below:
| Regulated chemicals | Regulated activities | Administrative requirements |
Conditional chemicals | Production, trading, transport, storage and preservation, use, treatment and disposal | Production and trading requires a certificate of eligibility issued by the competent authority |
Chemicals requiring special control | Production, trading, transport, storage and preservation, use, treatment and disposal | Production and trading requires a license issued by the competent authority |
Banned chemicals | Production, import, transport, storage, treatment and disposal | Banned for all activities, unless a license is granted by the competent authority for the purposes of scientific research, national defense, disease prevention and control |
| Chemicals requiring elaboration of chemical incident prevention and response plans | Production, import, transport, storage, treatment and disposal | Approval of chemical incicident prevention and response plans |
All chemicals (including the abovementioned) | Import | Declare through the National Single Window |
Chemicals in products
The draft introduces separate regulations for chemicals in products, distinct from standalone chemicals. Specifically, hazardous chemicals in products with technical regulations shall comply with relevant legal provisions. On top of this, the government will promulgate a list of hazardous chemicals in products without technical regulations.
As part of their obligations, manufacturers and importers are responsible for disclosing the content of hazardous chemicals in their products. The time, form and order of information disclosure is yet to be determined by the government after the enactment of this draft amendment. The information will need be disclosed on the National Chemical Database.
Manufacturers are also responsible for developing management procedures for controlling hazardous chemicals during manufacturing process, in accordance with the guidelines issued by the government. Any violation of these obligations will be facing administrative sanctions and forced to recall the products.
In addition, the draft also:
Introduces the concept of "chemical projects", "chemical industrial park", "chemical industrial cluster", "chemical works", "chemical complex", "green chemistry", "basic chemicals", "petrochemicals", "pharmaceuticals", "rubber products", "energy chemicals"
Creates a legal basis for implementing the international conventions on chemical management
Allows additional new chemical information announced by a country that has mutual recognition with Vietnam in the registration dossier
Adds additional regulations on technical facilities conditions and professional qualifications for activities such as sanitizing, extracting, storing, transporting, using and treating chemicals
Introduces provisions for chemical safety training
