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On August 19, 2022, Vietnam’s Ministry of Industry and Trade (MoIT) released a circular on the draft of a new RoHS (Restriction of hazardous substances) regulation called National Technical Regulation on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment. If adopted, this regulation will take effect from January 1, 2026, replacing the existing RoHS regulation (Circular No.30/2011/TT-BCT). The draft is open for consultation until October 17, 2022.
Based on the European Commission Delegated Directive (EU) 2015/863, four phthalates, including DEHP, BBP, DBP and DIBP, are proposed to be added to the existing list of restricted hazardous substances in electrical and electronic equipment (EEE). If approved, there will be 10 hazardous substances subject to RoHS regulation.
| No. | Chemical name | Limit (mg/kg) | Limit (mass%) | |
| 1 | Lead (Pb) | 1,000 | 0.1% | Already regulated under Vietnam RoHS |
| 2 | Mercury (Hg) | 1,000 | 0.1% | |
| 3 | Cadmium (Cd) | 100 | 0.01% | |
| 4 | Hexavalent Chromium | 1,000 | 0.1% | |
| 5 | Polybrominated Biphenyls (PBB) | 1,000 | 0.1% | |
| 6 | Polybrominated Diphenyl Ethers (PBDE) | 1,000 | 0.1% | |
| 7 | Bis (2-Ethylhexyl) phthalate (DEHP) | 1,000 | 0.1% | To be added |
| 8 | Benzyl butyl phthalate (BBP) | 1,000 | 0.1% | |
| 9 | Dibutyl phthalate (DBP) | 1,000 | 0.1% | |
| 10 | Diisobutyl phthalate (DIBP) | 1,000 | 0.1% |
* Unit (mg/kg) is equivalent to parts per million (ppm).
Annex 1 listed 11 categories of EEE subject to the regulation:
Large household appliances
Small household appliances
IT and telecommunications equipment
Consumer equipment and photovoltaic panels
Lighting equipment
Electrical and electronic tools (except large-scale stationary industrial tools)
Toys, leisure and sports equipment
Medical devices (except all implanted and infected products)
Monitoring and control instruments
Automatic dispensers
Miscellaneous types of EEE that don’t fall under the previous categories
As stipulated by Annex 2, the following goods are exempt from the regulation:
Electrical and electronic components, batteries and storage batteries;
Spare parts used to repair, reuse or upgrade electrical and electronic equipment;
EEE that belong to the following categories: gifts, exhibits and souvenirs; luggage or belongings of an organization or a person; goods temporarily imported for export or transit goods;
EEE for military purposes or used in satellites;
Fluorescent light specified in the Appendix of National technical regulation QCVN 02:2020/BCT regulates mercury content in fluorescent lamps;
Children's toys specified in Appendix 1 of the National Technical Regulation QCVN 3:2019/BKHCN;
EEE circulated in the Vietnamese market before this circular takes force.
Under the proposed regulation, domestic producers and importers of EEE are required to submit a declaration of conformity before putting their products on the market. The declaration of conformity must be based on the assessment results of a certification body that has registered its operation fields in accordance with relevant regulations. The certificate of conformity is valid for no more than 3 years.
