Vietnam Chemical Import Declaration Requirements: Customs Reviews 100% Component Disclosure Practices

Vietnam Customs Reviews Local Chemical Import Declaration Practices

The GDVC review followed concerns raised by the US-ASEAN Business Council (USABC) on March 19, 2026. According to the materials reviewed, certain customs units had started requesting detailed chemical composition information for import clearance, including:

• Full component information;

• CAS numbers;

• Exact percentage content of components;

• Supporting technical documents where customs authorities consider additional verification necessary.

Previously, such requests were generally handled through targeted review, inspection, or case-by-case verification. The current issue is not merely the existence of chemical declaration obligations, but the possibility that some local customs offices may be applying broader or stricter disclosure expectations without consistent national guidance.

Inconsistent Enforcement Across Customs Offices

A report submitted by the Customs Sub-Department of Region II under Official Letter No. 3824/HQKV2-NVHQ, dated April 20, 2026, indicates that implementation practices are not uniform.

According to the report, Hi-tech Park Customs has required importers to provide 100% component information, including CAS numbers and composition details, since January 2026. Where importers fail to provide sufficient information, shipments may be subject to physical inspection, sampling, or further analysis.

By contrast, Region II and several other border inspection stations reportedly stated that they had not issued new mandatory instructions requiring 100% component disclosure for chemical imports.

For importers and overseas suppliers, this inconsistency creates operational uncertainty. The level of documentation required for the same product may vary depending on the customs office, port of entry, product classification, and the perceived risk of controlled substances.

Legal Context Behind Stricter Chemical Controls

The stricter approach adopted by certain customs offices is linked to Vietnam's broader chemical control framework. The legal basis cited in the materials includes the Law on Customs, Decree No. 08/2015/ND-CP, Decision No. 1921/QD-TCHQ, and recent chemical regulatory updates, including Decree No. 24/2026/ND-CP, Decree No. 26/2026/ND-CP, and Decree No. 28/2026/ND-CP. These instruments relate to customs declaration accuracy, product classification, controlled chemicals, specially controlled chemicals, restricted chemicals, and narcotic precursors.

In practice, customs authorities may request additional product information where they need to verify whether imported goods contain controlled chemicals or narcotic precursors. This is especially relevant for chemical mixtures, formulated products, and products whose SDS/MSDS does not disclose full composition details.

However, the materials do not indicate that Vietnam has formally adopted a unified nationwide requirement requiring all chemical imports to disclose 100% composition information in every case. The current development should therefore be understood as an enforcement clarification and compliance-risk signal, rather than a confirmed blanket disclosure obligation.

Trade Secret Protection Remains a Key Compliance Challenge

The most significant practical challenge is the conflict between customs transparency and protection of confidential business information.

Many overseas manufacturers and formulation owners do not disclose complete composition data to importers because such information may reveal proprietary formulations or commercially sensitive know-how. At the same time, Vietnamese customs authorities may require sufficient technical information to determine whether a product falls under chemical control requirements.

This creates several practical difficulties:

• Importers may not have access to full formulation data;

• Standard SDS/MSDS documents may not include exact component percentages;

• Overseas suppliers may be reluctant to disclose trade secrets to local importers;

• Incomplete information may lead to inspection, sampling, or clearance delays;

• Products involving controlled chemicals or narcotic precursor risks may face closer review.

Vietnam's Law on Chemicals provides for confidentiality protection in certain circumstances, but the materials also indicate that enterprises may still need to provide necessary confidential information to competent authorities for compliance purposes.

Proposed Streamlining Measures Remain Under Discussion

The Customs Sub-Department of Region II proposed that relevant authorities consider compiling a list of low-risk goods that are unlikely to contain narcotic precursors. For products included on such a list, enterprises would only need to declare the product name and CAS number, while customs authorities would conduct checks against the list.

This proposal may help streamline clearance for certain low-risk goods. However, it should not be treated as an implemented exemption or confirmed national procedure at this stage. The approach may also have limitations because:

• Chemical products and formulations are highly diverse;

• A low-risk list cannot cover every legitimate product;

• Some mixtures or proprietary blends may not have a single CAS number;

• Newly developed substances may not yet have assigned CAS identifiers;

• Products outside the list may still face additional review.

The materials also suggest that Vietnam Customs could consider a secure confidential information channel, potentially through the National Single Window, allowing overseas suppliers to submit sensitive composition data directly to customs without disclosing full formulas to importers. This remains a recommended approach rather than an adopted mechanism.

Impact & Actionable Advice for Multinational Companies

Review Products That May Trigger Customs Scrutiny

Companies should identify products that may require closer documentation review, including:

• Chemical mixtures;

• Proprietary formulations;

• Products with incomplete SDS/MSDS composition disclosure;

• Products involving controlled chemicals or narcotic precursor risks;

• Products imported through customs offices known to apply stricter review practices.

Prepare a Strong Technical Documentation Package

Importers and overseas suppliers should prepare documentation that can support customs review where required, such as:

• SDS/MSDS;

• Product composition statement;

• CAS numbers where available;

• Concentration ranges or exact composition data where disclosure is possible;

• Product specification sheet;

• Intended use description;

• Controlled chemical or narcotic precursor screening results;

• Explanation of confidential business information claims.

Establish a Confidential Disclosure Protocol

Where full composition data is commercially sensitive, companies should define in advance:

• What information can be shared with the local importer;

• What information should be submitted only to competent authorities;

• Whether sealed, restricted-access, or confidential documents can be used;

• How trade secret claims should be documented;

• Who will respond to additional customs information requests.

Coordinate with Vietnam Importers Before Customs Declaration

Overseas suppliers should not assume that a standard SDS/MSDS will always be sufficient for Vietnam customs clearance. Before shipment, companies should confirm with local importers:

• Port of entry;

• Product classification;

• Applicable chemical control status;

• Whether local customs has requested 100% component information;

• Whether additional documents may be needed before declaration.

Monitor Further Guidance from Vietnam Customs

Because GDVC is reviewing local implementation practices, companies should closely monitor whether Vietnam issues unified guidance on chemical import declarations. Future clarification may determine whether full component disclosure remains limited to certain local practices or becomes more clearly targeted at high-risk chemicals and controlled substances.

How REACH24H Can Help

REACH24H supports global companies in assessing chemical regulatory risks and preparing import compliance documentation for Vietnam and other Asia-Pacific markets.

Our services include:

• Vietnam chemical registration and compliance;

• Global GHS / SDS/MSDS review and gap analysis;

• CAS registry number and component declaration support;

• Transport of Dangerous Goods (TDG) classification and screening;

• Import documentation review for Vietnam customs clearance;

• Confidential business information protection strategy;

• Communication support with local importers and regulatory stakeholders;

• APAC chemical regulatory monitoring.

If your company exports chemical substances, mixtures, or proprietary formulations to Vietnam, early documentation review can help reduce customs delays and protect confidential formulation data.

Not sure where to start? Our regulatory experts are ready to help.
Email: customer@reach24h.com