With the entry into force of Vietnam’s new Law on Chemicals, requirements for import declaration, new chemical registration, and controlled chemical licensing have all been comprehensively upgraded. As a professional consulting team in the field of Vietnam chemical compliance, REACH24H provides full-process support for global manufacturers, exporters, and multinational enterprises, from in-depth regulatory interpretation to the practical implementation of compliance certificates and licenses.
What is Vietnam’s Law on Chemicals?
On January 1, 2026, Vietnam’s new Law on Chemicals (No. 69/2025/QH15) officially came into force. It replaced the previous law (No. 06/2007/QH12), which had been in effect for nearly 20 years, marking a new phase of digitalized and internationalized chemical regulation in Vietnam.
Key changes: This revision introduced a new chemical registration system and established a National Chemical Inventory (NCI, Vietnam National Chemical Inventory) management framework.
Supporting legal framework: To build a clear enforcement system, Vietnam simultaneously issued three decrees (Decree 24/2026/ND-CP, 25/2026/ND-CP, and 26/2026/ND-CP) and two circulars (Circular 01/2026/TT-BCT and 02/2026/TT-BCT), which together form the new regulatory framework for chemical management in 2026.
Main competent authorities:
Ministry of Industry and Trade (MOIT): Responsible for industrial chemical management, new chemical registration, and approval of Group 1 licenses for chemicals requiring special control.
Vietnam Chemicals Agency (Vinachemia): A technical body under MOIT, responsible for the compilation and maintenance of the NCI, management of the inventory inclusion window, and administration of the chemical industry database.
Provincial People’s Committees (PPC): Responsible for local chemical management, issuance of certificates for conditional chemicals, and Group 2 licenses for chemicals requiring special control.
What Obligations Do Companies Exporting Chemicals to Vietnam Need to Address?
Under the new law, chemicals are subject to tiered management based on toxicity, flammability and explosiveness, environmental persistence, and international conventions such as the Stockholm Convention and the Rotterdam Convention. The higher the risk, the stricter the control and the more licensing requirements apply.
At the same time, the new law introduces a registration system requiring new chemicals not listed in the National Chemical Inventory (NCI) to complete registration assessment before being placed on the market.
| Product Category | Regulatory Approach | Core Obligation | Validity Period | |
| Category I | General chemicals | General management | Import declaration (Chapters 28/29) | - |
| Category II | Conditional chemicals | Certificate-based management | Certificate of eligibility for trading (PPC) | 5 years |
| Group 1 chemicals requiring special control | License-based management | License (MOIT) + shipment-by-shipment import | 5 years / 6 months | |
| Group 2 chemicals requiring special control | License-based management | License (PPC) + shipment-by-shipment import | 5 years / 6 months | |
| Prohibited chemicals | Prohibition-based management | Special-use license | 12 months | |
| Hazardous chemicals subject to emergency response plan requirements | Emergency response plan management | Preparation, approval/filing of chemical incident prevention and response plans, with regular training and drills | Ongoing compliance; plans must be updated and drilled regularly | |
| Category III | New chemicals | Registration management | Pre-market registration → 5-year special-control period | 5-year transitional management and reporting period |
Category I: General Chemicals (Import Declaration)
General declaration requirements
All imported chemicals falling under HS Chapter 28 (inorganic chemicals) and Chapter 29 (organic chemicals) are subject to mandatory electronic declaration.
Declaring entity: Importing organization or individual
Timing: Must be completed before customs clearance
Platform: Vietnam National Single Window (vnsw.gov.vn)
Required documents: Commercial invoice, Vietnamese Safety Data Sheet (SDS), and other relevant documents
Chemicals meeting any of the following conditions may be exempt from import declaration:
Licensed chemicals: Chemicals requiring special control or prohibited chemicals that already have a valid import license.
Small-volume imports: Chemicals under HS Chapters 28/29 with an import quantity of less than 10 kg per shipment.
R&D purposes: New chemicals imported for testing or evaluation in quantities of less than 1 kg.
Category II: Controlled Chemicals (Qualification / License Acquisition)
Relevant compliance entities must meet different qualification and licensing requirements depending on the type of controlled chemical involved:
| Category | Applicable Entity | Main Competent Authority | Qualification / License Requirement | Validity Period | Management Requirements |
| Conditional chemicals | Manufacturers and traders | PPC | Certificate issued by PPC | 5 years | * Plant / warehouse
* Safe operating procedures
* Production technology
* Segregated storage
* Personnel qualifications |
| Chemicals requiring special control (Group 1 / Group 2) | Manufacturers and traders | MOIT or PPC | License issued by MOIT or PPC Import/export license required for each shipment | License: 5 years Import/export license: 6 months (renewable once) | * Prepare a loss prevention and control plan
* Limited to non-prohibited uses |
| Prohibited chemicals | Entities for scientific research, national defense, or government-designated missions | Relevant competent authority | Special-use license | 12 months | * Import eligibility is strictly restricted
* Unused chemicals must be exported with approval or lawfully destroyed |
| Hazardous chemicals subject to emergency response plan requirements | Enterprises or facilities reaching specified storage thresholds | Emergency management authority and relevant approval bodies | A chemical incident prevention and response plan must be prepared and approved | Valid on a long-term basis after approval (re-approval required if changes occur) | The plan must include: * Risk forecasting
* Emergency response forces
* Personal protective measures
* Evacuation and remediation measures |
Category III: New Chemicals (Full Registration / Simplified Registration)
New chemicals are substances not yet listed in Vietnam’s National Chemical Inventory (NCI). Work on the NCI began in 2020 and is expected to be completed by 2028, in order to distinguish “existing chemicals” from “new chemicals.”
Depending on whether the substance is already listed in other foreign inventories, such as the ECHA CHEM, the TSCA Chemical Substance Inventory, or Japan’s Existing and New Chemical Substances (ENCS) Inventory, Vietnam provides two registration routes for new chemicals: full registration and simplified registration.
Full registration (Article 23.1 of Decree 26/2026)
Applicable scope: New chemicals not listed in any foreign inventory
Application dossier:
Registration form for new chemicals (Form 12a)
Chemical assessment report (Form 12b), issued by a laboratory designated by MOIT or an OECD-recognized foreign laboratory, including:
Physicochemical property data
Human toxicological data
Ecotoxicological data
Risk management measures
Vietnam explicitly accepts OECD GLP test data, meaning EU REACH registration data may be used directly.
Review procedure:
After submission, MOIT conducts a completeness review within 3 working days.
A chemical appraisal council composed of 7–9 members is established to conduct the technical review, with a review period of 90 working days.
Approval requires 100% unanimous consent of the appraisal council.
Simplified registration (Article 23.2 of Decree 26/2026)
Applicable scope: New chemicals listed in at least two foreign inventories (ECHA CHEM / TSCA / ENCS)
Application dossier:
Registration form for new chemicals
Summary chemical assessment report
CAS number / UN number
Proof of commercial circulation in foreign markets
Review procedure: Same as full registration
Post-registration management (Article 25 of Decree 26/2026)
Transitional management: After registration is completed, all new chemicals—whether through full or simplified registration—will be managed as chemicals requiring special control for 5 years. During this period, enterprises must fully perform the applicable compliance obligations, including obtaining the relevant license for chemicals requiring special control.
Annual reporting: Enterprises must submit annual operational reports to MOIT covering the manufacture, import, and use of the new chemical.
Final categorization: After the 5-year period, MOIT will, based on the assessment results and annual reports, propose to the government that the chemical be permanently categorized into the conditional chemical list, the chemicals requiring special control list, or the restricted list.
What New Compliance Requirements Have Been Added under Vietnam’s Law on Chemicals?
In addition to the obligations above, Vietnam’s Law on Chemicals also requires enterprises to address the following compliance requirements:
| Compliance Area | Applicable Entity | Core Actions and Requirements | Key Indicators / Notes |
| Chemical storage services | Enterprises providing chemical storage services | Must obtain a Certificate of eligibility for chemical storage services (issued by MOIT or PPC) | • Effective from July 1, 2026 • Valid for 5 years • Facility, segregation, and personnel qualification requirements apply |
| Digital compliance | All enterprises engaged in chemical-related activities | 1. Register and submit information in the Vinachemia database 2. For chemicals requiring special control, connect to the Ministry of Public Security’s electronic traceability platform | • Electronic purchase and sales records must be established • Traceability of movement must be ensured |
| Hazardous chemicals in products | Manufacturers / importers of products containing hazardous chemicals | 1. Monitor ingredient content and declare batch by batch 2. Publicly disclose information (website / sales premises / database) 3. Label the product accordingly | • A source-control mechanism must be established • Dual obligations of “back-end declaration + front-end disclosure” apply |
REACH24H’s One-Stop Compliance Services for Vietnam Chemicals
REACH24H provides one-stop Vietnam chemical compliance services for Chinese and global enterprises exporting chemicals to Vietnam, covering the full compliance chain from import declaration to new chemical registration, and from GHS classification and SDS preparation to applications for controlled chemical licenses. This helps enterprises systematically respond to compliance challenges arising from the upgrade of Vietnam’s chemical regulatory framework.
NCI Status Checking: Verify the NCI inclusion status, if not can provide necessary support to be included in the final NCI.
Regulatory consulting and interpretation: Provide the latest regulatory updates, in-depth interpretation, and compliance strategy recommendations for Vietnam’s chemical regulatory system.
Chemical GHS classification: Assist enterprises in accurately classifying products and determining their regulatory category under Vietnamese law.
Import declaration services: Complete chemical import electronic declarations through the Vietnam National Single Window, ensuring that declaration materials are accurate and complete, and reducing the risk of customs delays or cargo detention due to missing documents.
Applications for qualifications / licenses for controlled chemicals: Assist enterprises in applying for certificates for conditional chemicals, licenses for manufacture/trade of chemicals requiring special control, and import/export licenses.
Emergency response plan preparation and consulting: Assist enterprises in preparing, revising, and filing chemical incident prevention and response plans in accordance with regulatory requirements, and provide guidance on emergency drills.
New chemical registration services (NCI inventory inclusion): For new chemicals not listed in Vietnam’s National Chemical Inventory (NCI), help select the most suitable registration route (full registration / simplified registration), assist in preparing OECD GLP test data and chemical assessment reports, and follow up the MOIT approval process throughout.
SDS / label preparation: Prepare Vietnamese SDSs and GHS-compliant labels in accordance with Vietnam’s GHS standard (based on the 7th revised edition of GHS), ensuring accuracy and compliance with MOIT’s technical review requirements.
Chemical database registration and traceability: Assist enterprises in completing registration in the chemical industry database and establishing an electronic traceability system for chemicals requiring special control.
Chemical safety training: Provide Vietnam chemical regulatory compliance training to help enterprises improve employees’ regulatory awareness and operational capability.
Transitional compliance support: Provide customized transition solutions for the shift from the old system to the new one, helping enterprises complete the necessary preparations before the new compliance obligations fully take effect.
Customs clearance support for chemicals: Assist enterprises in liaising with Vietnam Customs to communicate and resolve special customs clearance issues.
Why Choose REACH24H? Professional, Authoritative, and Localized
Professional team: A senior regulatory expert team centered on REACH24H Vietnam, with strong expertise in chemical regulations and extensive project experience.
Efficient service: Familiar with Vietnam’s regulatory approval processes and maintaining good communication with institutions such as the General Department of Vietnam Customs and the Responsible Care Committee of the Vietnam Chemical Industry, ensuring efficient and accurate service delivery.
Customized solutions: Provide tailored compliance solutions based on each enterprise’s specific products and business needs, covering the full chain from general chemical import declaration to new chemical registration and hazardous chemicals in products compliance.
End-to-end support: Provide one-stop, full-process compliance support from regulatory consultation to document preparation, submission, and approval.
Risk alerts: Continuously monitor regulatory developments from MOIT and provide forward-looking risk alerts and response strategies, helping enterprises interpret regulatory changes at the earliest stage and receive timely compliance recommendations.
Frequently Asked Questions (FAQ) on Vietnam Chemical Regulatory Registration
Q1: What are the major changes under Vietnam’s new Law on Chemicals in 2026?
Vietnam’s new Law on Chemicals (69/2025/QH15) officially took effect on January 1, 2026. The main changes include:
Introduction of a new chemical registration system, under which chemicals not listed in the National Chemical Inventory (NCI) must be registered before being placed on the market;
After successful registration, new chemicals are managed as chemicals requiring special control for 5 years, and enterprises must obtain the corresponding license and submit annual operational reports;
Upgraded digital compliance obligations, requiring all chemical enterprises to register in the Vinachemia database, while chemicals requiring special control must connect to the Ministry of Public Security’s electronic traceability platform;
Further strengthening of mandatory requirements for GHS classification, labels, and Vietnamese SDSs;
New requirements for chemical storage service qualifications and third-party consulting services (effective from July 1, 2026).
Q2: How can a new chemical substance be registered in Vietnam (NCI inventory inclusion)?
New chemicals are substances not listed in Vietnam’s National Chemical Inventory (NCI). Depending on whether they are already listed in foreign chemical inventories (ECHA CHEM / TSCA / ENCS), two registration routes apply:
Full registration (Article 23.1 of Decree 26/2026): Applicable to chemicals not listed in any foreign inventory. A chemical assessment report supported by OECD GLP data is required, and the technical review period is 90 working days.
Simplified registration (Article 23.2 of Decree 26/2026): Applicable to chemicals listed in at least two foreign inventories. The dossier requirements are relatively simplified.
Both routes must be submitted to MOIT, which completes the completeness review within 3 working days. EU REACH data meeting OECD GLP standards may be directly used in Vietnam’s full registration process.
Q3: What are the main documents required for chemical import declaration in Vietnam?
All imported chemicals under HS Chapters 28/29 must be electronically declared through the Vietnam National Single Window (vnsw.gov.vn) before customs clearance. The main required documents include: the commercial invoice; Vietnamese Safety Data Sheet (SDS); and, for controlled chemicals, the corresponding certificates or import/export licenses.
Q4: Must the SDS in Vietnam be issued in Vietnamese?
Yes. Vietnamese regulations require that the Safety Data Sheet (SDS) for imported chemicals be provided in Vietnamese and submitted together with the import declaration documents. The SDS must be prepared in accordance with Vietnam’s GHS standard (based on the 7th revised edition of GHS) and include the 16 standard sections. REACH24H provides professional Vietnamese SDS translation and preparation services to ensure compliance with MOIT’s technical requirements and reduce customs clearance risks.
Q5: Is Decree 113/2017/ND-CP still valid?
No. Decree 113/2017/ND-CP has been repealed with the entry into force of Vietnam’s new Law on Chemicals (69/2025/QH15) in 2026. The supporting Decree 24/2026/ND-CP, Decree 25/2026/ND-CP, and Decree 26/2026/ND-CP have comprehensively replaced the previous decree framework. If you hold compliance certificates or documents issued under the previous regime, it is advisable to promptly assess whether updates or reissuance are required under the new law.
Q6: After the 5-year period of new chemical registration, will the substance be added to the NCI? Are there any significant new use management requirements?
After successful registration, a new chemical will be managed as a chemical requiring special control for 5 years. After this 5-year period, MOIT will, based on the assessment results and annual reports, propose that the chemical be permanently categorized into the conditional chemical list, the chemicals requiring special control list, or the restricted list, and ultimately included in the NCI. At present, Vietnam has not clearly established a significant new use management system in its legislation.
Q7: For Vietnam’s simplified registration of new chemicals, is it mandatory for the substance to be listed in two foreign inventories at the same time?
Yes. Vietnam’s simplified registration requires the substance to be listed in at least two foreign inventories (such as EC, TSCA, and ENCS), and corresponding proof of commercial circulation must also be provided.
Q8: “What compliance documents need to be prepared for exporting chemicals to Vietnam?”
The main compliance documents include: ① Vietnamese SDS (Safety Data Sheet); ② GHS label; ③ Commercial invoice; ④ Import electronic declaration for general chemicals (HS Chapters 28/29 through vnsw.gov.vn); and ⑤ For controlled chemicals, the relevant qualification certificates or import/export licenses.
How Can You Quickly Launch Your Vietnam Chemical Compliance Project?
The year 2026 is regarded as the “first year” of Vietnam chemical compliance. As the new Law on Chemicals and its supporting regulations continue to be implemented, companies that start early can not only better control compliance costs, but also secure market opportunities in advance and reduce the risk of supply chain disruptions.
Based on extensive experience in serving overseas markets, REACH24H has summarized a clear and practical launch pathway for Vietnam chemical compliance projects, helping enterprises move quickly into execution:
Initial consultation and needs diagnosis: Understand the enterprise’s product portfolio, business model, and timeline requirements, and identify the compliance scope.
Regulatory obligation assessment and analysis: Determine the compliance obligations of each substance in Vietnam and provide a concise assessment conclusion with risk alerts.
Customized solution and quotation: Design a phased compliance roadmap (prioritizing key substances), with a clear timeline and budget.
Project kickoff and contract signing: Define the scope of service, project cycle, and communication mechanism, and establish project coordination channels.
Document preparation and submission: Guide the enterprise in preparing the required materials according to the checklist, while the technical team compiles and submits the application documents.
Full-process follow-up and regulatory communication: Track acceptance and review progress, and promptly communicate with competent authorities regarding supplementary documents or clarification requests.
Delivery of certificates and licenses: Assist in obtaining registration certificates / filing numbers / licenses and establish the internal compliance archive.
Ongoing compliance and maintenance: Track regulatory changes as well as changes in tonnage and use, and advise whether additional registration or amendment is required.
You may leave a message through the REACH24H official website or contact us via email at customer@reach24h.com. Based on your product portfolio and export schedule, we can quickly provide you with a preliminary compliance assessment plan for Vietnam chemicals, helping you steadily complete your market layout in 2026, the “first year” of Vietnam chemical compliance.
