Vietnam Chemical Compliance | National Chemical Inventory
Vietnam is rapidly restructuring its chemical management framework. Following the adoption of the Law on Chemicals (No. 69/2025/QH15) in 2025, companies exporting chemicals to Vietnam should pay close attention to the future finalization of the National Chemical Inventory (NCI).
Although a substance may already appear in Vietnam's current draft NCI, this does not automatically guarantee long-term “existing chemical” status. Substances marked as “no evidence” may still face removal from the finalized NCI if sufficient proof of circulation in Vietnam is not provided.
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, 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 that this is not the case. Companies exporting chemicals to Vietnam should verify the substance’s draft NCI status, evidence status, and possible future new chemical registration obligations under Vietnam chemical registration and compliance requirements.
Compliance note: A substance’s inclusion in the draft NCI should be treated as a temporary status, not a final market access guarantee. Companies should verify whether the substance is marked as “no evidence” and prepare supporting documentation in advance.
The “No Evidence” Trap: Hidden Compliance Risks
The current draft NCI contains more than 40,000 substances. However, over 25,000 substances, representing more than 60% of the draft inventory, are flagged as “no evidence.” This designation indicates that the Vietnam Chemicals Agency currently lacks sufficient proof that these substances are genuinely circulating in the Vietnamese market.
Vietnam has not yet opened a new NCI nomination window since the last round in 2021. If the nomination window reopens in the future, companies dealing with “no evidence” substances may be required to resubmit concrete evidence of market circulation, such as commercial invoices, sales contracts, import records and customer transaction documents.
| Draft NCI Status | What It Means | Potential Compliance Risk |
|---|---|---|
| Listed with evidence | The substance has supporting evidence indicating circulation in Vietnam. | Lower risk, but companies should still monitor final NCI confirmation and future regulatory updates. |
| Listed as “no evidence” | The authority lacks sufficient proof of actual market circulation in Vietnam. | May be removed from the finalized NCI if no evidence is provided, triggering new chemical status. |
| Not listed in draft NCI | The substance is not currently recognized in the draft inventory. | May require future nomination or new chemical registration before manufacture or import. |
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 additional registration and approval processes before continuing manufacture, import or placing on the Vietnamese market.
Why Removal from the Final NCI Matters
Once the final NCI is published, substances not included in the final inventory are expected to be treated as new chemicals. Companies may need to complete new chemical registration before manufacture, import or commercial use in Vietnam. Even where simplified new chemical registration routes are available for substances listed on major international inventories such as ECHA, TSCA or ENCS, the administrative workload, documentation requirements and compliance costs are still significantly higher than maintaining an existing chemical listing.
| Compliance Route | Typical Situation | Business Impact |
|---|---|---|
| Existing chemical status | The substance is retained in the final NCI with sufficient market circulation evidence. | Lower market access risk, though import declaration, SDS, labeling and controlled chemical obligations may still apply. |
| New chemical registration | The substance is not included in the final NCI or is removed due to insufficient evidence. | Registration, dossier preparation, review timeline and additional compliance costs may affect import and market launch. |
| Simplified new chemical route | The new chemical is already listed on certain recognized international inventories. | May reduce some burden, but still requires administrative work and regulatory confirmation. |
Transparency Challenges for Multinational Companies
Multinational companies face serious transparency barriers when trying to verify NCI status. Access to the NCI search function is strictly controlled and generally limited to user accounts registered in Vietnam and approved by the competent authority. Even for approved users, the system typically displays only basic listing status, with limited visibility into more detailed information.
For companies without a local legal entity in Vietnam, this restriction makes it difficult and time-consuming to verify whether substances are listed, whether they are tagged as “no evidence,” and what supporting documents may be needed to secure future listing in the final NCI.
Practical implication: Companies should not wait until the final NCI is published. If a high-volume or strategically important substance is listed as “no evidence,” evidence collection should begin as early as possible.
What Companies Should Do Now
To better prepare for the compliance challenges that may arise once the final NCI is published, companies exporting chemicals to Vietnam should establish a proactive NCI verification and evidence management strategy.
| Company Situation | Recommended Action | Documents to Prepare |
|---|---|---|
| Substance is not included in the draft NCI | Plan for future nomination and assess potential new chemical registration obligations. | Substance identity, composition, CAS/EC information, international inventory status, import plan and use information. |
| Substance is listed in the draft NCI | Verify whether the substance is marked as “no evidence.” | NCI status confirmation, substance identifiers, supplier/customer information and trade history. |
| Substance is marked as “no evidence” | Immediately compile evidence of real market circulation in Vietnam. | Commercial invoices, sales contracts, import/export records, production data and customer use evidence. |
| Substance may be new chemical after 2028 | Conduct a registration pathway assessment and prepare a market continuity plan. | New chemical registration gap analysis, hazard data, SDS, GHS classification, international inventory status and intended use. |
Verify NCI status early: confirm whether each key substance is listed in the draft NCI and whether it is marked as “no evidence.”
Prioritize high-risk substances: focus first on high-volume, high-value, sole-sourced or strategic substances.
Compile circulation evidence: collect invoices, contracts, import documents and customer use records that demonstrate actual market circulation in Vietnam.
Assess new chemical registration risk: prepare a fallback strategy if the substance is removed from the final NCI.
Review local compliance obligations: confirm import declaration, controlled chemical licensing, Vietnamese SDS and GHS labeling requirements.
Maintain regulatory monitoring: track future NCI nomination windows, implementation decrees, circulars and final inventory publication.
Need to verify whether your substances are safely listed in Vietnam’s draft NCI?
REACH24H can help you check draft NCI status, identify “no evidence” risks, prepare circulation evidence, and assess new chemical registration obligations in Vietnam.
Contact Our Regulatory SpecialistsREACH24H: 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 support covers NCI status checks, new chemical registration pathway assessment, import declaration, controlled chemical licensing, Vietnamese SDS and GHS label review, and ongoing compliance strategy.
| Support Area | REACH24H Services |
|---|---|
| Direct NCI Status Verification | Leverage local presence to verify whether substances are listed in Vietnam’s draft NCI and whether they are tagged as “no evidence.” |
| NCI Nomination Support | Help collect and consolidate import/export records, sales contracts, production data and other supporting evidence required to secure inclusion in the finalized NCI. |
| New Chemical Registration Assessment | Assess whether a substance may require new chemical registration and identify possible registration or simplified registration pathways. |
| Import Declaration and Controlled Chemical Licensing | Support import declaration review, controlled chemical licensing assessment and communication with relevant local authorities. |
| Vietnamese SDS and GHS Label Review | Prepare or review Vietnamese SDSs and GHS labels in line with local requirements and Global GHS/SDS/MSDS/Label Compliance practices. |
| Ongoing Compliance Strategy | Monitor Vietnam’s evolving chemical regulatory landscape and help companies maintain sustainable market access. |
Conclusion
Being listed in Vietnam's draft NCI should not be regarded as a permanent compliance guarantee. Substances marked as “no evidence” remain vulnerable to future removal if companies cannot demonstrate real circulation in the Vietnamese market.
As the final NCI is expected by 2028, companies should use the current window to verify substance status, collect market evidence, assess new chemical registration risks, and establish a practical Vietnam compliance roadmap before market access risks materialize.
