VIETNAM CHEMICAL REGULATORY UPDATE
Vietnam's Ministry of Industry and Trade (MOIT) issued Circular No. 33/2026/TT-BCT on June 30, 2026, updating the lists of medium-risk and high-risk products under its management. Effective July 1, 2026, the Circular replaces Circular No. 41/2023/TT-BCT. Chemical manufacturers, exporters, importers, and supply-chain teams should check the relevant appendix entry, HS code, QCVN, and conformity-assessment route. Products governed by chemical legislation may also require a separate review under Vietnam's chemical rules, supported where relevant by REACH24H's Vietnam Chemical Registration and Compliance Services.
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At a Glance: What Companies Should Watch
| Item | What It Means |
|---|---|
| Regulatory instrument | Circular No. 33/2026/TT-BCT replaces Circular No. 41/2023/TT-BCT. |
| Risk classification | The appendix lists six medium-risk product groups; the published high-risk section contains no listed products. |
| Chemical-related scope | Specified fluorescent lamps, industrial sodium hydroxide, PAC, industrial ammonia at 10%-35%, and certain paints and textiles. |
| Assessment routes | The applicable appendix entry may assign Method 1, 5, 7, or 8 under the relevant product-quality framework. |
| Priority action | Verify the exact product description, composition or concentration, intended use, HS code, QCVN, and responsible local entity. |
What Changed under Vietnam Circular 33/2026?
Circular No. 33/2026/TT-BCT implements Vietnam's risk-based product-quality framework under the amended Law on Product and Goods Quality and Decree No. 37/2026/ND-CP. The Decree classifies products and goods according to three risk levels:
High risk: Products or goods that may cause serious or particularly serious consequences if appropriate controls are not applied.
Medium risk: Products or goods that may cause a significant impact if appropriate controls are not applied.
Low risk: Products or goods that are unlikely to cause a significant impact under controlled or normal conditions of use.
The Circular's appendix identifies listed products by product description, HS code, applicable QCVN, and quality-management requirement. The high-risk section contains no listed products in the published appendix, while the medium-risk section covers six product groups.
Which Products Are on the Medium-Risk List?
| Medium-Risk Product Group | Examples or Scope Relevant to Chemical Supply Chains |
|---|---|
| Paper towels and toilet paper | Paper products subject to the corresponding appendix entry and QCVN |
| Chemicals and chemical-containing products | Fluorescent lamps; industrial sodium hydroxide; poly aluminium chloride (PAC); industrial ammonia at 10%-35%; and specified paints and textiles containing formaldehyde or aromatic amines released from azo dyes |
| Industrial explosives and high explosives | Products matching the descriptions and HS codes in the appendix |
| Industrial explosive accessories | Accessories covered by the applicable appendix entries |
| Industrial machinery, equipment, and materials | Specified industrial products under MOIT's product-quality remit |
| Explosive precursors | Listed precursor products subject to the corresponding quality-management requirements |
The category heading alone is not enough to determine applicability. Companies should compare the exact product description, composition or concentration, intended use, HS code, and referenced QCVN against the relevant appendix row.
For example, the ammonia entry is limited by the concentration range stated in the list. A product described commercially as ammonia, PAC, sodium hydroxide, paint, or textile material should not be assumed to be in or out of scope without checking the detailed entry.
What Conformity-Assessment Requirements Apply?
For products that fall within a listed medium-risk entry, conformity must be demonstrated according to the corresponding QCVN and assigned quality-management measure. The supporting legal framework allows a conformity declaration to rely on one of the following evidence routes, where applicable:
Certification results issued by a legally accredited certification body;
Certification results issued by a conformity-certification body designated by MOIT or by a provincial or municipal People's Committee for state-management purposes; or
A self-assessment by the responsible organization or individual, supported by test results from an accredited or designated testing body.
The appendix assigns one or more of the conformity-assessment methods provided under Circular No. 14/2026/TT-BKHCN:
Method 1: Type testing of representative samples;
Method 5: Type testing plus assessment of the production process or management system, followed by surveillance through sample testing and production-process or management-system assessment;
Method 7: Testing and assessment of a product or goods shipment; and
Method 8: Testing or inspection of all products or goods.
The applicable method is determined by the individual appendix entry. Companies should not select a method based only on convenience. They should also confirm whether the responsible entity is the domestic manufacturer, importer, supplier, or another local organization under the applicable product-quality rules.
MOIT issued Circular No. 34/2026/TT-BCT alongside Circular No. 33. It sets out the broader quality-management framework for products and goods under MOIT, including requirements relevant to domestically manufactured, imported, marketed, digitally traded, and exported goods. The two Circulars should therefore be read together with Decree No. 37/2026/ND-CP and the applicable QCVN.
Transitional Arrangement for Existing Conformity Documents
Organizations that completed conformity assessment and declaration before July 1, 2026 may continue using the relevant conformity certificate until it expires. Based on the transition described in the supplied materials, they are not required to re-register the conformity declaration solely because Circular No. 33/2026/TT-BCT took effect.
Companies should nevertheless check whether the existing certificate and declaration cover the same product, model, composition, concentration, production site, and QCVN now referenced in the appendix.
Product-Quality Compliance and Chemical Compliance Are Separate Checks
Inclusion in Circular No. 33/2026/TT-BCT is a product-quality risk classification. It does not, by itself, determine whether a substance is listed in Vietnam's National Chemical Inventory (NCI), whether new chemical registration applies, or whether chemical import declaration, controlled-chemical licensing, Vietnamese SDS, GHS labelling, database registration, or post-registration reporting is required.
For affected chemicals and chemical-containing products, companies may need to run two parallel assessments:
Product-quality track: Confirm the Circular No. 33 appendix entry, HS code, QCVN, conformity-assessment method, conformity evidence, and local declaration responsibilities.
Chemical-regulatory track: Assess obligations under Vietnam's Law on Chemicals and its implementing instruments, including chemical import declaration, NCI status, new chemical registration, controlled-chemical licensing, Vietnamese SDS and labels, and ongoing reporting.
This distinction is particularly relevant for industrial sodium hydroxide, PAC, industrial ammonia, paints, and other products whose market access may depend on both their finished-product characteristics and the regulatory status of their chemical constituents.
For the broader chemical-regulatory framework, read REACH24H's overview of Vietnam's New Law on Chemicals and review the available Vietnam Chemical Registration and Compliance Services.
Recommended Actions for Manufacturers, Exporters, and Importers
Map the product to the appendix. Compare the product description, composition or concentration, use, HS code, and QCVN against the relevant entry rather than relying only on a commercial product name.
Confirm the responsible local entity. Determine which manufacturer, importer, supplier, or other organization must complete the applicable conformity procedure and maintain supporting records.
Identify the assigned assessment method. Check whether Method 1, 5, 7, or 8 applies and confirm that the proposed certification or testing body is properly accredited or designated.
Review existing evidence. Check the scope and validity of conformity certificates, test reports, and declarations issued before July 1, 2026.
Run a separate chemical compliance review. For chemicals and chemical-containing products, assess NCI status, import declaration, licensing, SDS, labelling, and reporting obligations under Vietnam's chemical legislation.
Align supply-chain documents. Ensure that product specifications, composition data, SDSs, test reports, certificates, invoices, customs classifications, and importer records describe the product consistently.
Monitor implementation. Track future MOIT updates to the risk lists, relevant QCVNs, designated conformity-assessment bodies, and implementation guidance.
How REACH24H Can Support Vietnam Chemical Compliance
For chemicals affected by the new medium-risk list, REACH24H can support the parallel chemical-regulatory assessment needed for Vietnam market access. Its Vietnam Chemical Registration and Compliance Services cover:
Regulatory screening: Vietnam chemical regulatory applicability and controlled-list screening;
Inventory and registration: NCI status checks and new chemical registration pathway assessment;
Import compliance: Chemical import declaration support;
Controlled chemicals: Qualification and licensing assessment;
Hazard communication: Vietnamese SDS and GHS label preparation or review;
Submission support: Data-gap analysis, dossier preparation, and submission support; and
Ongoing compliance: Regulatory monitoring and post-registration compliance support.
Product-specific conformity obligations under Circular No. 33 should be confirmed separately against the appendix, the applicable QCVN, and the product-quality procedures administered by the competent Vietnamese authorities.
Need support with Vietnam chemical compliance?
REACH24H can help assess chemical-regulatory applicability, confirm registration and import-declaration pathways, prepare compliant SDSs and labels, and manage follow-up obligations for the Vietnam market.
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