Introduction to Vietnam REACH Regulation

Vietnam Chemical Inventory Notification is open till 15th April 2021

Chemical Regulation in Vietnam

The main chemical law in Vietnam is the Law on Chemicals 06/2007/QH12 issued in Nov. 2007. The Chemical Law provides regulations on chemical handling, safety in chemical handling, right and obligations of organizations and individuals engaged in chemical handling, and state management of chemical handling. The main authority in charge of chemical management is the Ministry of Industry and Trade (MOIT). The chemical law in Vietnam is supported by various decrees. The Decree No. 113/2017/ND-CP Specifying and providing guidelines for implementation of certain articles of the law on chemicals in which updated on 2017 provides detailed regulations on chemical lists on licenses, classification, plans/measures for chemical incident, safety training, declaration, etc. The Circular 32/2017/TT-BCT provides forms and guidelines of labeling, MSDS, declaration, reports, license application, plans/measures, etc.

National Chemical Inventory (NCI)

Vietnam began to compile the national chemical inventory (NCI) in 2012. Substances that are not listed on the inventory will be considered as new substances and require registration before they can be used, imported, or produced in Vietnam. So far, there are 5 times where companies can nominate substances to the inventory. The inventory contains about 40,000 substances. The new deadline for substance submission is April 15th, 2021. The final draft of the inventory is expected to be released by the end of this year.

Nominating Substance to the NCI

Nominating Substances to the NCI requires the following information:

Chemical Name (IUPAC)
CAS No.
Safety Data Sheet (SDS) - as per Vietnamese Decree No. 113/2017/ND-CP and Circular no. 04/2012/TT-BCT in Vietnamese language
Document that showing the chemicals are being used in Vietnam (such as purchase contract, invoices, etc)

The Vietnamese authority will evaluate the substances and decide if they should be included in the inventory.

GPC through its Vietnamese affiliates can help you with the NCI nomination for Vietnam regulatory compliance.

Steps for Nominating Substances to the NCI

Identify substances that export to Vietnam and check if it is listed in the NCI
Prepare information (CAS No.) and documents for substance nomination to the NCI
Check if the SDS is updated and prepare SDS in Vietnamese
Consult with regulatory compliance companies to fulfill your responsibilities as manufacturers and suppliers and ensure the access to the Vietnamese market

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Vietnam Amends Hazardous Chemical Safety Regulation: Amendment 1:2024 Highlights

Dec-06-2024

On October 10, 2024, the Minister of Industry and Trade (MOIT) officially issued Amendment 1:2024 QCVN 05A:2020/BCT, which amends the National Te...

On October 10, 2024, the Minister of Industry and Trade (MOIT) officially issued Amendment 1:2024 QCVN 05A:2020/BCT, which amends the National Technical Regulation on Safety in Production, Commerce, Use, Storage, and Transportation of Hazardous Chemicals (QCVN 05A: 2020/BCT), through Circular No. 19/2024/TT-BCT. The amendment, developed by the Drafting Team to address practical challenges in hazardous chemical management, was evaluated by the Ministry of Science and Technology and approved by the Vietnam Chemicals Agency.

Background on QCVN 05A: 2020/BCT and Amendment Process

The management of chemical activities in Vietnam has generally improved since December 21, 2020, when Circular No.48/2020/TT-BCT promulgated QCVN 05A: 2020/BCT. However, the practical implementation has shown that some of the provisions are incorrect or impractical, thus necessitating the amendment.

After consulting on a proposed amendment to the National Technical Regulation, MOIT submitted it to the Vietnam Chemicals Agency for approval on March 22, 2024. Only a few of the provisions of QCVN 05A:2020/BCT were amended in Amendment 1:2024. The remaining elements of QCVN 05A:2020/BCT, which was issued in conjunction with the Minister of Industry and Trade's Circular No. 48/2020/TT-BCT on December 21, 2020, are retained.

Key Provisions and Compliance Deadlines

This Circular comes into force on April 15, 2025. All factories and warehouses containing hazardous chemicals that are put into operation before April 15, 2025, must meet the requirements laid down in Amendment 1:2024 QCVN 05A:2020/BCT by April 15, 2026, at the latest.

Appropriate leak and spill warning devices must be installed in factories and warehouses handling hazardous chemicals in liquid and gaseous form. Surveillance cameras are required for solid poisons. Hazardous gas collection and treatment equipment or automatic sprinklers must be installed to respond to accidents involving hazardous substances that can be released into the environment in gas form.

Chemical collecting systems are required in factories and warehouses containing liquid corrosive chemicals. The minimum capacity of the collecting system must be at least 110% of the capacity of the largest container. Water-reactive chemicals must be placed on pedestals or racks at least 0.3 m above the ground. The storage capacity of the dike system must be at least 110% of the capacity of the largest container.

Safety Measures for Incident Response

Every individual in the vicinity of a fire or explosion incident is required to wear personal protective equipment (PPE) in order to assist in victim rescue and incident response. Participation in incident response is prohibited for those without personal protective equipment to ensure safety. Additionally, the amendment requires the use of personal protective equipment (PPE) in the event of a fire or explosion.

For more details, see Circular No. 19/2024/TT-BCT here.

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ASEAN Cosmetic Directive Amendments: Grace Period Ended on 21 November 2024

Dec-05-2024

On 21 November 2024, the two-year grace period for cosmetic products to comply with the updated ASEAN Cosmetic Directive...

On 21 November 2024, the two-year grace period for cosmetic products to comply with the updated ASEAN Cosmetic Directive (ACD) ended. The updates were introduced during the 36th ASEAN Cosmetic Committee (ACC) meeting and its related sessions in November 2022. Products that do not meet the updated standards must be withdrawn immediately. The amendments reflect the ASEAN region’s approach to aligning with global safety standards and protecting the health of consumers in its 10 member states.

Key Updates to the ACD

Annex II – List of substances which must not form part of the composition of cosmetic products

A consolidated list of 37 substances previously banned in the EU, has been added to Annex II of the ACD. These include entries from EU regulations (2019/831, 2019/1966, 2021/850, 2021/1902) that are not currently used in ASEAN countries. Specific compounds such as perboric acid, sodium perborate, boron compounds, octamethylcyclotetrasiloxane (D4), and p-BMHCA have also been included in Annex II.

Titanium Dioxide Regulation

Revised safety criteria for the use of titanium dioxide as a colouring agent (Annex IV) and as a UV filter (Annex VII) have been adopted as per EU standards.

Salicylic Acid Regulation

New limits have been introduced for salicylic acid in the Restricted Substance List (Annexes III) and in the Preservatives list (Annex VI), used in body creams, lotions, and other specific applications.

Implications for Industry

Cosmetic manufacturers, traders, and distributors were granted a two-year grace period to reformulate, test and phase out non-compliant products. With the end of this period concluded, compliance is now mandatory, ensuring that products meet updated safety requirements.

Detailed guidelines for compliance can be found here.