News Brief
On 31 March 2026, the Vietnam Ministry of Health (MoH) issued Circular 05/2026/TT-BYT, introducing a List of chemicals not allowed for use and a List of hazardous chemicals requiring information disclosure in insecticidal and disinfectant preparations used in the household and medical fields.
The Circular will take effect on 15 May 2026, upon which MoH Circular 11/2020/TT-BYT on banned and restricted chemicals in such products will be repealed in full.
This regulatory update will significantly impact companies manufacturing, importing, or placing household and medical insecticidal and disinfectant products on the Vietnamese market, especially with respect to active substance selection, formula review, and labelling compliance.
What Is Circular 05/2026/TT-BYT?
Circular 05/2026/TT-BYT is an important supplement to Vietnam’s evolving chemical management framework and is primarily based on the following legal instruments:
Government Decree No. 26/2026/ND-CP detailing the management of chemical activities and hazardous chemicals in products and goods
Under Clause 4, Article 15 of the Law on Chemicals, ministers and heads of ministerial-level agencies are authorized to promulgate lists of chemicals prohibited from use within their areas of competence.
Furthermore, Clause 2, Article 31 requires the issuance of lists of hazardous chemicals in products and goods that are subject to information disclosure where no existing technical regulations are in place.
These provisions form the legal basis for MoH to establish both the banned list and the disclosure list for insecticidal and disinfectant preparations for household and medical use.
Scope of Vietnam Circular 05/2026/TT-BYT: Annex I and Annex II
Circular 05/2026/TT-BYT introduces a harmonized chemical list system for household and medical insecticidal/disinfectant preparations, consisting of two key components:
List of chemicals not allowed for use (Annex I)
List of hazardous chemicals requiring information disclosure (Annex II)
The Circular applies to insecticidal and disinfectant preparations that are manufactured, imported, or placed on the market in Vietnam for household or medical use.
Depending on whether a substance falls under Annex I or Annex II, companies must comply with either a strict “not allowed for use” requirement or an “allowed with mandatory disclosure and conditions of use” regime.
Annex I – Chemicals Not Allowed for Use
Annex I sets out a list of 40 chemicals (or groups of chemicals) that are strictly not allowed for use in insecticidal and disinfectant preparations for household and medical use.
The list covers various high-concern substances, including persistent organochlorine insecticides, POPs and other banned pesticide active substances.
Representative examples include:
Acephate
Aldrin
DDT
Lindane (BHC)
Chlordane
Chlorpyrifos ethyl
Pentachlorophenol (PCP) and its salts
Perfluorooctane sulfonic acid (PFOS) and its salts
Key Compliance Implications
From the effective date of the Circular, insecticidal/disinfectant preparations containing any Annex I chemical must not be manufactured, imported, or marketed in Vietnam for household or medical use.
Annex II – Hazardous Chemicals Requiring Information Disclosure
Annex II contains 87 hazardous chemicals (or groups of chemicals) that may still be used in insecticidal and disinfectant preparations for household and medical use, but are subject to mandatory information disclosure and specific use restrictions.
Unlike Annex I, substances in Annex II are not outright banned, but their use is conditional and must be accompanied by enhanced transparency and labelling controls.
Typical Substances and Use Restrictions
Examples of commonly used substances and their key restrictions include:
DEET (N,N-Diethyl-m-toluamide): Not allowed for use in products intended for children under 4 years of age.
Flubendiamide and etofenprox (and similar larvicidal substances): Only permitted for killing mosquito larvae (larvicidal use) and must not be used in drinking or domestic water.
Picaridin (Icaridin): Not allowed for children under 4 years of age and the concentration in preparations must not exceed 30%.
Companies using Annex II substances must therefore carefully evaluate target users (e.g. children), exposure scenarios (e.g. direct skin application, proximity to water sources) and concentration limits when designing, registering and marketing products in Vietnam.
Information Disclosure Obligations for Preparations Containing Annex II Substances
For insecticidal and disinfectant preparations containing hazardous chemicals listed in Annex II, Circular 05/2026/TT-BYT imposes specific information disclosure and labelling obligations.
Submission to the National Chemical Database
Producers and importers must disclose the following information in the National Chemical Database in accordance with Law on Chemicals No. 69/2025/QH15 and Decree No. 26/2026/ND-CP:
Product name
Hazardous chemical name
Hazardous characteristics
Content (concentration)
Field of use
This database submission is a key element of Vietnam’s new integrated chemical management system, which will consolidate data from the Ministry of Industry and Trade, the Ministry of Health, the Ministry of National Defense, the Ministry of Agriculture and Rural Development, the Ministry of Natural Resources and Environment, and other authorities.
Labelling and marketing communication
In addition to database submission, hazardous information must also be:
Displayed on the product label and in the instructions for use, including clear indication of hazardous chemicals and applicable use restrictions (e.g. age limits, prohibition of use in domestic water).
Disclosed on the official website and other online promotional materials to ensure purchasers and end-users can easily identify chemical hazards and safe use conditions.
Companies should ensure consistency of information across packaging, technical documentation and digital content, and avoid any omissions or contradictory statements.
Transitional arrangements for existing products
For insecticidal and disinfectant preparations that:
Already hold a valid circulation registration number before 15 May 2026, and
Contain hazardous chemicals listed in Annex II,
producers and importers are still required to complete information disclosure in line with the Law on Chemicals and Decree 26/2026/ND-CP and to update labels, instructions and promotional materials within a reasonable transition period.
“Existing products” are not exempt from disclosure obligations simply due to their prior approval status.
Recommended Actions for Companies
In light of Vietnam’s tightened regulatory requirements on household and medical insecticidal/disinfectant preparations, REACH24H recommends that companies take the following steps as early as possible:
Build a Vietnam-specific compliance substance list
Integrate Annex I and Annex II into internal compliance checklists and workflows for product development, registration and market management.
Conduct a “formula + label” compliance health check
Review existing products for the presence of Annex I/Annex II substances and examine labels and instructions, with particular focus on products intended for children, medical settings and scenarios involving contact with domestic water.
Align with local partners on implementation
Communicate with Vietnamese distributors, registrants and local consultants to clarify regulatory interpretation, National Chemical Database submission requirements and labelling review expectations to ensure timely and consistent implementation.
Embed compliance in R&D for future products
For new products or planned market entries into Vietnam, incorporate Annex I/Annex II requirements and disclosure obligations at the R&D stage to minimize subsequent reformulation and re-labelling costs.
Conclusion
As Vietnam’s National Chemical Database continues to evolve and additional sectoral chemical disclosure lists are issued by different ministries, companies placing chemical-containing products on the Vietnamese market are advised to closely monitor regulatory developments and update their compliance strategies accordingly.
If you need ingredient screening, risk assessment or label compliance review for your specific insecticidal or disinfectant products in Vietnam, REACH24H can provide one-stop regulatory consulting and compliance solutions. Learn more about our Vietnam chemical registration compliance services to help you successfully navigate the changing regulatory landscape and seize growth opportunities in the Southeast Asian market.
For more information or assistance, please feel free to contact us at customer@reach24h.com.
