Vietnam Tables Three Draft Decrees to Implement New Chemicals Law

Hanoi — October 2025. The Ministry of Industry and Trade (Vietnam Chemicals Agency) has issued three coordinated draft decrees to operationalize Law on Chemicals No. 69/2025/QH15. Together they establish: (1) policy and planning for chemical-industry development and chemical safety–security; (2) operational rules for chemical activities and for hazardous chemicals in products and goods; and (3) consolidated annexed lists of managed chemicals that trigger licensing, declarations, training, and emergency-planning duties.

Decree 1 — Chemical-Industry Development & Chemical Safety–Security

Scope and structure. Spanning eight chapters and 44 articles, this decree translates high-level policy into practical levers for planning, approving, and supervising chemical projects. It defines national strategy processes, assigns roles across central ministries and provincial authorities, and sets expectations for professional consultancy, training, emergency preparedness, and security.

Core policy mechanisms

• Planning & siting: Project approvals tied to safety-distance and spatial-risk criteria; layouts that fail separation standards must be redesigned.
• Green-chemistry integration: Technology selection, feedstocks, and process design must evidence pollution prevention, safer alternatives where feasible, and energy/resource efficiency.
• Data & oversight: Periodic reporting into a national chemicals database to support supervision, benchmarking, and policy review.

Decree 2 — Management of Chemical Activities & Hazardous Chemicals in Products/Goods

Scope and structure. Organized into five chapters and 32 articles, this decree governs lifecycle controls for production, trade, storage, and use, and extends explicit oversight to hazardous chemicals contained in finished goods—aligning industrial regulation with market surveillance.

Operational mechanics

• Licensing and declarations: Risk-proportionate conditions (fit-and-proper, facility controls, competence, recordkeeping) tied to the national lists.
• Digital administration: Applications, renewals, declarations, and incident reporting handled via a centralized platform with standardized identifiers (e.g., CAS/HS) and supply-chain traceability.
• Inspections and enforcement: Risk-based scheduling prioritizing higher-hazard processes and operators with adverse histories; measures aimed at preventing loss/misuse or diversion (including to narcotics or weapons).
• Incident prevention and response: Formal accident-prevention and emergency-response plans required where listed chemicals and thresholds apply.
• Products and goods: Importers, manufacturers, and distributors must maintain evidence files (composition, safety data, conformity evidence) and cooperate with targeted checks and corrective actions.

Decree 3 — Consolidated Lists of Chemicals (Annex System)

Purpose of the annexes. The companion decree publishes five annexes that anchor obligations across the regime:

• Annex I: Basic chemicals in prioritized sectors (strategic planning lens).
• Annex II: Chemicals under conditional production/trade (licensing and competence triggers).
• Annex III: Special-control chemicals (heightened security, handling, and reporting).
• Annex IV: Chemicals requiring a Chemical Accident Prevention and Response Plan (threshold-based emergency-planning duties).
• Annex V: Recognized training disciplines (qualification standards for chemical-safety roles).

Timeline and Outlook

With comments open until 16 November 2025, authorities are moving on an accelerated but synchronized schedule. The three decrees are intended to be adopted together on 1 December 2025 and to take effect on 1 July 2026, ensuring that policy, operational controls, and annexed lists align on day one. For industry, this means a predictable transition to a lifecycle-based system that links spatial risk, licensing and declarations, product oversight, and digital reporting, while setting clearer expectations for competence and emergency readiness.