Vietnam’s New Law on Chemicals (No. 69/2025/QH15): Key Regulatory Changes and Compliance Implications

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. Companies may also refer to REACH24H's Vietnam Chemical Registration and Compliance Services for route assessment and implementation support.

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The repealed old regulations include: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:

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 Vietnam 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 TSCA Inventory, 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.

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:

1. 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.

2. Adjust import processes: Ensure all imported chemicals under Chapter 28 and Chapter 29 are declared via the National Single Window.

3. 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.

How REACH24H Can Help

REACH24H provides Vietnam chemical regulatory compliance support for companies manufacturing, importing, trading, storing or using chemicals in Vietnam. Our services cover regulatory applicability assessment, NCI status verification, new chemical registration pathway assessment, import declaration, controlled chemical licensing, Vietnamese SDS and GHS label review, and ongoing compliance monitoring.

Conclusion

Vietnam's New Law on Chemicals and its implementing regulations mark a major step toward a more structured, risk-based, and internationally aligned chemical management system. The reform affects chemical lists, import declaration, hazardous chemicals in products and goods, chemical storage services, new chemical registration and post-registration monitoring.

Companies supplying chemicals to Vietnam should take early action to verify substance status, review import and licensing obligations, assess new chemical registration risks, update SDS and documentation systems, and establish ongoing compliance monitoring mechanisms.

Recommended Reading

• Vietnam Chemical Registration and Compliance Services

• Compliance Alert: Being Listed in Vietnam's Draft NCI Does Not Guarantee Long-Term Market Access

• Vietnam Drafts Technical Regulation to Restrict Persistent Organic Pollutants in Products

• Vietnam National Assembly Voted to Approve Law on Chemicals

• Global GHS/SDS/MSDS/Label Compliance

• Global Regulatory Compliance Services

Official References

• Vietnam Chemicals Agency (Vinachemia), Ministry of Industry and Trade

• Vietnam National Chemical Database

• Vietnam National Single Window

• Ministry of Industry and Trade of Vietnam

• UNECE: Globally Harmonized System of Classification and Labelling of Chemicals