Introduction: Vietnam’s New Chemicals Law Takes Effect in 2026
Effective from January 1, 2026, Vietnam’s Law on Chemicals (No. 69/2025/QH15) has officially entered into force. To ensure the effective implementation of the Law, the Vietnamese government has simultaneously enforced three Government Decrees and two Ministerial Circulars starting from January 17, constituting the core detailed implementing regulations of the Law.
The prominent highlight of this reform is the establishment of a new chemical assessment and notification mechanism centered on “strict access, expert review, and long-term tracking.” Under the new regulations, all new chemical substances must pass a national-level technical assessment before entering the Vietnamese market and will be incorporated into a continuous monitoring system.
This move not only strengthens the risk management of new substances throughout their full life cycle but also marks the comprehensive alignment of Vietnam’s chemical regulatory system with high international standards.
Key Implementing Regulations and Legal Framework
The five core supporting documents released this time, while fully replacing the original implementing regulations, provide a clear, systematic, and actionable execution framework and technical guidelines for the effective implementation of the Law on Chemicals.
The repealed old regulations include:
Government Decree No. 113/2017/ND-CP and its amendment, Decree No. 82/2022/ND-CP;
Ministerial Circular No. 32/2017/TT-BCT and its amendment, Circular No. 17/2022/TT-BCT.
Key Regulatory Changes under Vietnam’s Law on Chemicals
Vietnam’s newly released chemical regulatory regulations have systematically reconstructed the existing management system, profoundly affecting the entire life cycle of chemicals from production and importation to use and storage.
Through five core supporting documents, this reform establishes a clearer, stricter regulatory framework aligned with international standards, primarily reflected in the following four aspects:
Establishment of a New Chemical List System
Decree No. 24/2026/ND-CP establishes a brand-new chemical list system, clarifying the scope of different regulatory categories:
List of Chemicals Subject to Conditional Production and Trade (Appendix II): Contains 786 substances, requiring eligibility certificates for production and trading activities.
List of Chemicals Subject to Special Control (Appendix III): Contains 241 substances, requiring licenses for production, trading, and import/export activities. This list adds industrial precursors previously regulated as conditional chemicals, as well as chemicals newly listed under international conventions.
List of Chemicals Requiring the Development of Incident Prevention and Response Plans (Appendix IV): Contains 271 substances, requiring enterprises to develop comprehensive emergency preparedness plans.
Expansion of the Scope for General Chemical Import Declaration
The new regulations abolish the previously limited “List of Declarable Chemicals,” shifting to a broader principle of coverage: Any imported chemical falling under Chapter 28 (Inorganic Chemicals) and Chapter 29 (Organic Chemicals) of the Vietnam Nomenclature of Exports and Imports, regardless of whether it is listed in specific control lists, must complete mandatory import declaration via the National Single Window, achieving unified collection and dynamic monitoring of source information.
First-time Clarification of Regulatory Obligations for Hazardous Chemicals in Products/Goods
Decree No. 26/2026/ND-CP sets out detailed provisions for the regulation of hazardous chemicals in products and goods for the first time, requiring manufacturers or importers to perform mandatory declaration before placing them on the market for the first time, and to meet information disclosure and record-keeping requirements.
Appendix XIX of Circular No. 01/2026/TT-BCT designates 10 “substances subject to special control” for priority monitoring.
Chemical Storage Services Included in Regulation for the First Time
Decree No. 26/2026/ND-CP officially includes chemical storage services as a conditional activity subject to regulation, requiring service providers to obtain eligibility certificates. This obligation will take effect from July 1, 2026.
Market Access Mechanism for “New Chemicals”
Under the framework of the “Management Regulations” of the Ministry of Industry and Trade (MOIT), the new chemical assessment and notification mechanism has been formally established as an access and continuous regulatory system aligned with international standards.
Its core philosophy is: All new chemical substances must pass a national-level technical assessment before entering the Vietnamese market and accept dynamic tracking supervision for five years, thereby achieving front-loaded risk prevention and control and full life-cycle management.
What is a “New Chemical”?
According to the regulatory definition, a “new chemical” refers to a chemical substance that is not listed in the National Chemical Inventory (NCI) of Vietnam and is not in foreign chemical inventories recognized by Vietnam.
How New Chemicals Are Assessed: Expert Council System
The assessment of new chemicals is not a simple administrative approval but a deep technical review process, uniformly received and organized for assessment by the Vietnam Chemicals Agency (under MOIT).
Centralized Approval Authority: Administrative procedures are uniformly received and organized for assessment by the Vietnam Chemicals Agency under MOIT.
Assessment Council: The MOIT is responsible for forming the New Chemical Assessment Council, typically consisting of 7 to 9 members, including experts in relevant fields and departmental representatives.
Timeframe Requirements: The assessment work must be completed within 90 days of receiving a valid dossier.
Dossier and Technical Report Requirements
Appendix XII of Circular No. 01/2026/TT-BCT stipulates the specific file formats, emphasizing the completeness of technical data:
International Mutual Recognition and Reference Standards
To balance regulatory efficiency with international alignment, the management regulations demonstrate recognition of authoritative international inventories, which is very similar to the management approach in the Philippines:
Foreign Chemical Inventories: Although currently not falling under the “new chemical definition,” if a chemical is already listed in a foreign chemical inventory recognized by Vietnam (such as lists published by EU ECHA, US EPA, Japan METI, etc.), the authorities will still require such chemicals to participate in assessment, but will refer to these existing assessments and simplify dossier requirements during the process.
Classification Standards: The hazard assessment of new chemicals must follow the principles of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
Exemption Provisions for Special Circumstances
The management regulations set a small quantity exemption clause to support scientific research activities: New chemicals imported in quantities of less than 1 kg and used for experiments, assessment of physicochemical properties, or research and development (R&D) purposes may be exempt from import declaration procedures.
Post-Registration Obligations and Ongoing Compliance
Obtaining registration does not mean the end of regulation; new chemicals are managed similarly to “chemicals subject to special control,” reflecting the management logic of “long-term tracking”:
Five-Year Monitoring Period: Within 5 years after the new chemical completes registration, relevant organizations and individuals must submit an activity report regarding the chemical to the Chemicals Agency annually, commonly known as the annual report.
Dynamic Risk Adjustment: Based on assessment results and subsequent activity reports, the Chemicals Agency may recommend that the MOIT list the new chemical in the conditional, restricted, or special control chemical lists for stricter management.
Digitalization and Information Transparency: Registration and assessment information must be updated to the National Chemical Database to enable information interconnectivity among regulatory departments. At the same time, enterprises may apply for Confidential Business Information (CBI) protection, but in the event of environmental or health emergencies, relevant hazard information must be disclosed in accordance with the law.
REACH24H Compliance Insights and Recommendations
The implementing regulations for the Law on Chemicals released by Vietnam represent a comprehensive and deep reshaping of its chemical regulatory system. In particular, the management logic adopted for new chemicals—“strict access, expert review, international reference, long-term tracking”—has greatly increased market entry barriers and compliance costs.
For all domestic and foreign enterprises involved in chemical production, trading, import, and use activities in Vietnam, REACH24H suggests:
Check Against Existing Management Lists: Assess whether products in circulation are listed in the new “conditional” or “special control” lists, and apply for corresponding eligibility certificates or licenses in a timely manner.
Adjust Import Processes: Ensure all imported chemicals under Chapter 28 and Chapter 29 are declared via the National Single Window.
Monitor New Substances: Closely monitor Vietnam’s existing chemical inventory. For new chemicals planned for entry into the Vietnamese market, check if they are listed in recognized foreign national inventories and assess the status of existing test data, and be prepared to initiate technical work for new chemical dossier preparation at any time.
For more information on Vietnam’s Law on Chemicals (No. 69/2025/QH15), please feel free to contact us at customer@reach24h.com.
