Vietnam Proposes Amendments to Decrees 24, 25 and 26/2026 under the Law on Chemicals

The Three Draft Amendments at a Glance

Decree 24: Draft Chemical Lists Would Be Reframed

Decree 24 functions as the classification engine of Vietnam's new chemicals regime. The draft would replace all four appendices covering: (i) key basic chemicals eligible for investment incentives; (ii) conditional chemicals; (iii) chemicals requiring special control; and (iv) chemicals requiring a Chemical Incident Prevention and Response Plan.

A Narrower Incentives List

The draft would reduce the Appendix I list of basic chemicals eligible for preferential investment treatment from 39 to 27. MOIT states that the change is intended to avoid overly broad incentives and better align the list with Vietnam's development priorities and resource conditions.

Risk-Based Movement Between Controlled Lists

According to the draft appendices, Appendix II would contain 725 substances. The proposed changes include removing 86 substances considered to present relatively low toxicological risk, moving 26 Group 1 specially controlled chemicals into the conditional-chemicals list, transferring two substances in the opposite direction following a regulatory proposal, adding xylene (CAS No. 1330-20-7), and adding Harmonized System (HS) codes.

Draft Appendix III would contain 220 substances, including 97 Group 1 and 123 Group 2 chemicals. The proposed restructuring would move 33 Group 1 substances into Group 2 and add three chemicals controlled under the Rotterdam and Stockholm conventions to the Group 2 list, among other changes.

Incident-Plan List Remains Risk-Led

The draft would retain a dedicated Appendix IV for chemicals requiring a Chemical Incident Prevention and Response Plan. MOIT indicates that the list is intended to reflect risk-management needs and the entities presenting risks. The draft also takes the EU Seveso III Directive into account and contemplates future additions linked to major-accident hazards and substances for which incident prevention and response plans should be developed.

Decree 26: Scope, Exemptions and Procedures Would Change

Decree 26 contains many of the operational rules that determine how chemicals are manufactured, traded, imported, exported and reported. Its draft amendment is therefore likely to have the most immediate procedural impact on businesses.

For related operational guidance, see Vietnam Chemical Import Declaration Requirements.

Clearer Boundary with Sector-Specific Legislation

The draft would clarify that specified finished products already governed by specialized legislation are outside the relevant chemical-management provisions of Decree 26. The listed categories include pharmaceuticals, disinfectants, food and food ingredients, cosmetics, chemicals in medical devices, animal feed, veterinary medicines, plant-protection products and certain fertilizers, radioactive substances, specified household products, petroleum-related products, batteries and accumulators, firefighting equipment, construction materials, paints and printing inks.

The exemption is not unlimited. The draft distinguishes finished goods supplied directly to consumers or end users from products used in industrial production, and it would continue to regulate the chemical production processes used to manufacture excluded products.

Draft Mixture Thresholds

Article 21 would be comprehensively revised to introduce or clarify concentration-based exemptions. Where a mixture contains chemicals falling into more than one regulatory category, the highest applicable control would apply.

Fewer Dossier Components and Shorter Timelines

The draft would create a return-export exemption for conditional chemicals where the applicant can prove that the transaction is a non-profit return rather than a conventional sale. A comparable rule would apply to chemicals requiring special control when an export license is sought for return-export.

For licenses covering the production or trading of chemicals requiring special control, the safety data sheet (SDS) would be removed from the application dossier. The SDS would remain required for import and export license applications. The general processing time for several chemical licenses would be reduced from 16 to 14 working days, while the deadline for import and export licenses would be five working days after receipt of a complete and valid dossier.

The draft would also reduce the assessment period for a new chemical from 90 days to 50 days. This is a proposed change only; the current 90-day assessment period continues to apply until an amendment is adopted and becomes effective.

More Database-Based Reporting and Disclosure

The proposal would place greater reliance on the National Chemical Database and post-inspection. Manufacturers and users of chemicals requiring special control would need to disclose the relevant chemical types and intended uses before the first import and whenever the intended use changes. State authorities would also be required to update and share chemical-management data, including real-time exchange of customs import and export data with the specialized chemical database.

At enterprise level, the annual chemical-activity reporting deadline would move forward to January 15. The draft would also require annual reporting on products and goods containing hazardous chemicals, including quantities produced or imported and information on the products and hazards involved.

Transition for Existing Licenses

Existing licenses for scheduled chemicals, industrial precursors and chemicals subject to restricted production or trading would remain valid until their stated expiration date or until a new license is issued, whichever occurs first.

Decree 25: Safety, Responsibilities and Consultancy Rules Would Be Adjusted

The Decree 25 proposal would refine rules on chemical industry development, chemical safety and chemical security. It would generally exclude finished products already regulated under sector-specific legislation, while preserving safety and security obligations for the chemical production processes used to manufacture those products.

The draft would also clarify the responsibilities of the Ministry of Science and Technology, the Ministry of Education and Training, provincial authorities and specialized institutions. Chemical projects involving state-secret information would not be required to update that information in the specialized chemical database.

Consultancy Certification and Staffing

Eligibility requirements for consultancy organizations would be revised, including experience criteria for lead consultants and streamlined procedures for issuing, revising or revoking consultancy certificates. Consultancy organizations would need to employ appropriately certified consultants on a full-time basis and assign certified individuals to work within the relevant class and scope.

Facilities, Training and Incident Response

The proposal would clarify the meaning of workshops, warehouses and personnel, including treatment of facilities located within science and technology organizations and educational institutions. It would revise specialized chemical-safety training provisions and clarify which entities must prepare Chemical Incident Prevention and Response Plans, together with the dossier and review requirements. A replacement appendix would update the eligible disciplines and introduce an equivalence mechanism where an academic program does not exactly match a listed discipline.

The Decree 25 draft includes transitional provisions for existing consultancy certificates, incident response plans and specialized safety training. The broader implementation schedule anticipates that relevant legal documents will enter into force before March 1, 2027, but companies should rely on the promulgated texts for final dates and obligations.

What Companies Should Review Now

Although the amendments are still in draft form, companies operating in or supplying Vietnam can use the proposals as a practical readiness checklist:

• Map products and substances by CAS number, concentration and HS code against the current and proposed Decree 24 appendices.

• Reassess product exclusions under specialized legislation and determine whether the manufacturing process remains subject to chemical-safety controls.

• Review existing licenses, certificates and exemptions against the proposed mixture thresholds, return-export relief and transitional rules.

• Prepare for earlier annual reporting and expanded disclosure through the National Chemical Database, including intended-use and hazardous-chemical-in-product data.

• Track the final decrees for changes to lists, supporting documents, processing times and effective dates before changing operational procedures.

How REACH24H Can Support

REACH24H supports companies navigating Vietnam's chemical regulatory framework through:

• Regulatory applicability and list screening;

• New chemical and National Chemical Inventory pathway assessment;

• Import declaration and licensing support; and

• Ongoing compliance monitoring.

Our team can help compare product portfolios and operational workflows against both the current rules and the draft amendments, then identify the actions that should wait for final promulgation and those that can begin immediately. For tailored support, visit Vietnam Chemical Registration and Compliance Services or contact REACH24H to discuss your Vietnam market-entry and compliance needs.

Recommended Reading

• Vietnam’s New Law on Chemicals: What Businesses Need to Know

• Vietnam Chemical Import Declaration Requirements

• Vietnam Chemical Registration and Compliance Services

Official References

• MOIT: Draft Amendment to Decree No. 24/2026/ND-CP

• Government Portal: Decree No. 25/2026/ND-CP

• Government Portal: Decree No. 26/2026/ND-CP