With the entry into force of Vietnam's new Law on Chemicals, requirements for chemical import declaration, new chemical registration, and controlled chemical licensing have all been comprehensively upgraded.
For manufacturers, exporters, importers, formulators, and multinational companies placing chemicals on the Vietnamese market, confirming whether a substance is covered by the National Chemical Inventory (NCI), whether import declaration is required, and whether additional qualifications or licenses apply has become a critical step before market entry.
REACH24H provides full-process support for Vietnam chemical compliance, from regulatory interpretation and obligation assessment to NCI status checking, import declaration, new chemical registration, Vietnamese SDS and label preparation, controlled chemical licensing, and post-registration compliance management.
Key takeaway: Companies exporting chemicals to Vietnam should assess product classification, NCI status, import declaration obligations, controlled chemical licensing requirements, Vietnamese SDS and GHS label readiness, and post-registration duties before shipment or market launch.
Vietnam Chemical Compliance at a Glance
| Compliance Topic | What Companies Need to Check | Relevant Section |
|---|---|---|
| Legal framework | Whether the product is subject to Vietnam's updated chemical regulatory framework and the competent authority involved | Vietnam's Law on Chemicals |
| Import declaration | Whether HS Chapter 28/29 import declaration through the Vietnam National Single Window applies before customs clearance | General chemicals |
| Controlled chemicals | Whether qualification certificates, manufacture/trade licenses, or import/export licenses are required | Controlled chemicals |
| New chemical registration | Whether the substance is listed on Vietnam's National Chemical Inventory and whether full or simplified registration applies | New chemicals |
| SDS and GHS label | Whether Vietnamese SDSs and GHS-compliant labels are prepared for import declaration and market access | New compliance requirements |
| REACH24H support | Regulatory assessment, document preparation, submission support, authority communication, and ongoing compliance maintenance | REACH24H services |
Quick Navigation
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.
| Topic | Key Points |
|---|---|
| Key changes | The revision introduced a new chemical registration system and established a National Chemical Inventory (NCI, Vietnam National Chemical Inventory) management framework. |
| Supporting legal framework | 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. |
| 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.
| Chemical Category | Typical Compliance Trigger | Main Obligation | What Companies Should Prepare |
|---|---|---|---|
| Category I: General chemicals | Imported chemicals falling under HS Chapter 28 or Chapter 29. | Electronic import declaration before customs clearance. | Commercial invoice, Vietnamese SDS, and other required declaration documents submitted via the Vietnam National Single Window. |
| Category II: Controlled chemicals | Chemicals subject to conditional management, special control, restriction, or import/export control. | Qualification certificates, manufacture/trade licenses, or import/export licenses, depending on the chemical type and activity. | Product classification, applicable chemical list screening, license route assessment, and supporting documents. |
| Category III: New chemicals | Substances not yet listed in Vietnam's National Chemical Inventory (NCI). | Full registration or simplified registration before being placed on the Vietnamese market. | NCI status check, foreign inventory evidence where applicable, chemical assessment report, CAS/UN information, and post-registration management plan. |
Category I: General Chemicals (Import Declaration)
| Item | Requirement |
|---|---|
| Scope | 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. |
| 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.
| Controlled Chemical Scenario | Typical Qualification / License Requirement | Key Compliance Focus |
|---|---|---|
| Conditional chemicals | Certificate or qualification for manufacture and/or trading of conditional chemicals, where applicable. | Confirm whether the product falls within the conditional chemical scope and whether the local importer or operator holds the required qualification. |
| Chemicals requiring special control | Manufacture/trade license or other special-control license, depending on the chemical group and activity. | Assess whether MOIT or local competent authorities are involved, and prepare technical, safety, storage, and operational documents. |
| Import/export controlled chemicals | Import or export license may be required before shipment or customs clearance. | Confirm the controlled chemical list, shipment purpose, importer qualification, and document readiness before import or export. |
| Restricted or high-risk chemicals | Additional approval, licensing, or risk management obligations may apply depending on the chemical and use scenario. | Conduct case-by-case applicability review before contract signing, shipment, or local market placement. |
| Storage and safety management | Chemical incident prevention and response plan, storage service qualification, training, or safety management documentation may be required. | Review warehouse, storage, transport, emergency response, and traceability obligations together with product-level licensing requirements. |
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 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.
| Route | Applicable Scope | Application Dossier | Review Procedure |
|---|---|---|---|
| Full registration (Article 23.1 of Decree 26/2026) | New chemicals not listed in any foreign inventory. | 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, and risk management measures. Vietnam explicitly accepts OECD GLP test data, meaning EU REACH registration data may be used directly. | MOIT conducts a completeness review within 3 working days. A chemical appraisal council composed of 7-9 members conducts 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) | New chemicals listed in at least two foreign inventories (ECHA CHEM / TSCA / ENCS). | Registration form for new chemicals; summary chemical assessment report; CAS number / UN number; proof of commercial circulation in foreign markets. | Same as full registration. |
Post-registration Management
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 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 requires enterprises to address new compliance requirements related to digital compliance, database registration, traceability, GHS classification, Vietnamese SDSs, labels, storage service qualifications, and third-party consulting requirements.
| Requirement Area | Compliance Focus |
|---|---|
| New chemical registration system | Chemicals not listed in the NCI must complete registration before being placed on the Vietnamese market. |
| Digital compliance obligations | Chemical enterprises must register in the Vinachemia database; chemicals requiring special control must connect to the electronic traceability platform. |
| GHS classification, label, and Vietnamese SDS | Enterprises should prepare compliant chemical classification, GHS labels, and Vietnamese SDSs for regulatory review and customs clearance. |
| Storage service and consulting requirements | New requirements for chemical storage service qualifications and third-party consulting services are expected to take effect from July 1, 2026. |
REACH24H's One-Stop Compliance Services for Vietnam Chemicals
REACH24H provides one-stop Vietnam chemical compliance services for global companies 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.
| Service Module | How REACH24H Supports You |
|---|---|
| NCI status checking | Verify NCI inclusion status and provide support where the substance needs to be included in the final NCI. |
| Regulatory consulting and interpretation | Provide regulatory updates, in-depth interpretation, and compliance strategy recommendations for Vietnam's chemical regulatory system. |
| Chemical GHS classification | Assist companies 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, helping reduce customs delays or cargo detention caused by incomplete documents. |
| Controlled chemical licenses | Assist with certificates for conditional chemicals, licenses for manufacture/trade of chemicals requiring special control, and import/export licenses. |
| Emergency response plans | Assist in preparing, revising, and filing chemical incident prevention and response plans and provide guidance on emergency drills. |
| New chemical registration services | For new chemicals not listed in the NCI, help select the suitable registration route, prepare OECD GLP test data and chemical assessment reports, and follow up with MOIT throughout the approval process. |
| 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. |
| Database registration and traceability | Assist in chemical industry database registration and help establish an electronic traceability system for chemicals requiring special control. |
| Training and transition support | Provide Vietnam chemical regulatory compliance training and customized transition solutions from the old system to the new framework. |
| Customs clearance support | Assist companies in liaising with Vietnam Customs to communicate and resolve special customs clearance issues. |
Why Choose REACH24H?
REACH24H combines Vietnam-specific regulatory knowledge, local execution support, and global chemical compliance experience to help companies turn complex requirements into a practical market access roadmap.
Vietnam-based professional team
A senior regulatory expert team centered on REACH24H Vietnam, with chemical regulatory expertise and practical project experience.
Localized regulatory communication
Familiar with Vietnam's regulatory approval processes and able to support communication with relevant local institutions and stakeholders.
Product-specific compliance solutions
Tailored solutions based on product type, NCI status, business model, shipment plan, and whether import declaration, licensing, or registration applies.
End-to-end project support
Support from regulatory assessment, data gap review, document preparation, and submission to follow-up, approval, and post-registration maintenance.
Regulatory tracking and risk alerts
Continuous monitoring of MOIT and related regulatory developments to help companies identify upcoming risks and adjust compliance strategies in time.
Frequently Asked Questions (FAQ) on Vietnam Chemical Regulatory Registration
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 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.
How can a new chemical substance be registered in Vietnam?
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.
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 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.
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.
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. Companies holding compliance certificates or documents issued under the previous regime should assess whether updates or reissuance are required under the new law.
After the 5-year period of new chemical registration, will the substance be added to the NCI?
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.
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.
What compliance documents need to be prepared for exporting chemicals to Vietnam?
The main compliance documents include a Vietnamese SDS, GHS label, commercial invoice, import electronic declaration for general chemicals under HS Chapters 28/29 through the Vietnam National Single Window, and, 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 better control compliance costs, 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:
Initial consultation and needs diagnosis: Understand the company'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 company 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 communicate with competent authorities regarding supplementary documents or clarification requests.
Delivery of certificates and licenses: Assist in obtaining registration certificates, filing numbers, or 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.
Official References and Data Resources
Recommended Reading
Need to assess Vietnam chemical registration, import declaration, controlled chemical licensing, Vietnamese SDS, or NCI status? REACH24H can help evaluate your product portfolio, identify data gaps, prepare required documents, and support your Vietnam market access plan.
Contact REACH24H for Vietnam Chemical Compliance Support
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