Background
In recent years, Vietnam has been rapidly restructuring its chemical management framework. Following the official adoption of the Law on Chemicals (No. 69/2025/QH15) in June 2025, the supporting implementation decrees and circulars entered into force on January 17, 2026, providing clearer compliance guidance for chemical companies operating in Vietnam.
Although the National Chemical Inventory (NCI) is still in draft form, the new law has set a clear timeline: the NCI is expected to be fully finalized by 2028. This milestone is critical, because any substance not included in the final NCI will be regarded as a “new chemical” and must be registered before manufacture in, or placing on, the Vietnamese market.
However, many companies have fallen into a high‑risk misconception: assuming that once a substance appears in the current draft NCI, it has automatically secured its future status as an “existing chemical.” REACH24H would like to stress to companies targeting the Vietnamese market that this is not the case.
The "No Evidence" Trap: Hidden Compliance Risks
The current draft NCI contains more than 40,000 substances, yet over 25,000 of them—more than 60%—are flagged as “no evidence.” This designation indicates that the Vietnam Chemicals Agency (Vinachemia) currently lacks sufficient proof that these substances are genuinely circulating in the Vietnamese market.
So far, Vietnam has not opened a new NCI nomination window, and the last nomination round dates back to 2021. If the nomination window reopens in the future, companies dealing with these substances will likely be required to resubmit concrete evidence of market circulation, such as commercial invoices and sales contracts.
If these substances are removed from the finalized NCI due to a lack of evidence, they will be reclassified as “new chemicals.” This would force companies into costly and time‑consuming registration and approval processes.
Although Vietnam provides simplified new chemical registration routes for “new chemicals” that are already listed on major international inventories such as ECHA, TSCA, or ENCS, the administrative workload and compliance costs remain significantly higher than maintaining an existing listing on the NCI.
Transparency Challenges for Multinational Companies
In addition, multinational companies face serious transparency barriers. Access to the NCI search function is strictly controlled and limited to user accounts that are both registered in Vietnam and approved by the competent authority. Even for approved users, the system typically only displays basic listing status, with little visibility into more detailed information.
For companies without a local legal entity in Vietnam, this restriction makes it difficult and time‑consuming to verify the status of their substances—particularly to determine whether they are currently tagged as “no evidence.”
To better prepare for the compliance challenges that may arise once the final NCI is published, REACH24H recommends that companies take the following steps:
If a substance is not included in the draft NCI: Companies should proactively plan for future nominations and potential new chemical registrations to ensure legal market access.
If a substance is already included in the draft NCI: It is essential to confirm its status in the inventory. If it is marked as “no evidence,” companies should immediately start compiling documentation that demonstrates real market circulation (e.g., invoices, contracts), in order to safeguard ongoing compliance.
REACH24H: One‑Stop Vietnam Chemical Compliance Support
Through its local subsidiary in Vietnam, REACH24H offers one‑stop chemical regulatory compliance services to companies exporting chemicals to Vietnam. Our services include:
Direct Status Verification: Leveraging our local presence to verify whether your substances are listed in the NCI and, critically, whether they are labeled as “no evidence.”
NCI Nomination Support: Providing expert consulting to help you collect and consolidate the necessary import/export records, sales contracts, and production data required to secure inclusion in the finalized NCI.
Comprehensive Local Compliance Services: Covering the full spectrum of regulatory needs, from import declarations and new chemical registrations to SDS authoring and controlled chemical license applications.
REACH24H stands ready to support your company in navigating Vietnam’s evolving chemical regulatory landscape and in securing sustainable, compliant access to the Vietnamese market.
For more information or assistance, please feel free to contact us at customer@reach24h.com.
