News Details

Hanoi, March 2026. Vietnam’s Ministry of Health has issued a new Circular establishing a mandatory list of chemicals prohibited in insecticidal and bactericidal preparations, as well as a list of hazardous chemicals subject to information disclosure requirements. The measure implements key provisions under the 2025 Law on Chemicals and introduces a structured framework combining prohibition, restriction, and transparency obligations for products placed on the market.

Relevant background and regulatory context

The Circular is issued pursuant to Clause 4, Article 15 and Clause 2, Article 31 of the Law on Chemicals No. 69/2025/QH15. These provisions empower ministries to define sector-specific prohibited chemicals and to issue lists of hazardous chemicals in products requiring disclosure where technical regulations are not yet established. The measure also aligns with Decree No. 26/2026/NĐ-CP, which provides detailed rules on hazardous chemicals in products and goods, including disclosure obligations, and with Circular No. 01/2026/TT-BCT on chemical classification principles. Importantly, the new Circular replaces Circular No. 11/2020/TT-BYT, which previously governed prohibited and restricted chemicals in insecticidal and bactericidal products.

What the Circular does

The Circular establishes two core regulatory lists.

First, it introduces a list of chemicals that are fully prohibited from use in insecticidal and bactericidal preparations for household and medical applications.

Second, it defines a list of hazardous chemicals that may still be used but are subject to mandatory information disclosure requirements, including restrictions on use conditions, user groups, or concentrations.

Together, these lists form a dual regulatory mechanism combining outright bans with controlled use subject to transparency obligations.

List of prohibited chemicals

Appendix I of the Circular sets out a list of 40 chemicals that are not permitted for use in the relevant product categories. As shown in the tables on pages 4 and 5, the list includes substances such as organochlorine pesticides, organophosphates, and other high-risk chemicals, along with their CAS numbers. Examples include substances like DDT, Aldrin, Chlordane, Heptachlor, and Polychlorinated Biphenyls, as well as certain biological agents and heavy metal compounds such as cadmium and lead compounds. The inclusion of both legacy persistent pollutants and certain active substances indicates a continued tightening of chemical safety controls in consumer and healthcare-related applications.

List of hazardous chemicals requiring disclosure

Appendix II introduces a broader list of 87 hazardous chemicals that require information disclosure when used in insecticidal and bactericidal preparations. The detailed table on pages 6 to 8 specifies each chemical together with its CAS number and applicable restrictions on use. These restrictions vary depending on the substance. Some chemicals are limited to specific applications, such as larvicidal use only and not for water intended for domestic use. Others include restrictions on concentration levels or target user groups, such as prohibitions on use for children under a certain age. The structure of this list reflects a risk-based regulatory approach, allowing continued use of certain chemicals while imposing conditions to mitigate potential health and environmental risks.

Principles of chemical classification

The Circular confirms that chemical classification must follow the principles set out in Article 7 of Circular No. 01/2026/TT-BCT. This includes alignment with the Globally Harmonized System of Classification and Labelling of Chemicals.

This ensures consistency between hazard classification, labelling, and downstream regulatory obligations such as disclosure and risk communication.

Information disclosure obligations

A key feature of the new framework is the operationalization of disclosure requirements for hazardous chemicals.

For products containing chemicals listed in Appendix II, organizations and individuals must disclose information prior to placing the product on the market. This includes declaring information in the national chemical database and making it publicly available through websites, electronic platforms, or at points of sale.

The disclosure must cover the identity of the hazardous chemicals, their hazard characteristics, concentration levels, and any restrictions on use. The information must also be reflected on product labels.

Producers and importers are required to maintain documentation supporting the accuracy of disclosed information and must present such records upon request by competent authorities.

Transitional provisions

The Circular includes a transition mechanism for products already authorized before its entry into force. For insecticidal and bactericidal preparations containing hazardous chemicals listed in Appendix II and already holding valid circulation registration numbers, manufacturers and importers must comply with the new disclosure requirements in accordance with the Law on Chemicals and Decree No. 26/2026/NĐ-CP. This ensures continuity of market access while requiring alignment with the updated transparency framework.

Implementation responsibilities

The Circular assigns specific responsibilities to regulatory authorities and industry stakeholders.

The Department of Preventive Medicine is tasked with proposing updates to the lists where necessary based on regulatory needs. Local health departments must report new product registrations involving chemicals not yet listed within 10 days of issuance, supporting ongoing regulatory monitoring and updates.

Manufacturers and importers bear primary responsibility for compliance with disclosure obligations and for ensuring the accuracy of the information provided.

Entry into force

The Circular will take effect on 15 May 2026. From this date, the previous Circular No. 11/2020/TT-BYT will cease to apply, marking a transition to the updated regulatory framework.

Business implications

For companies operating in Vietnam’s household and medical insecticidal and bactericidal product markets, the new Circular introduces a more structured and stringent compliance environment. Businesses must assess product formulations against the prohibited list, verify whether any ingredients fall under the disclosure list, and implement systems for regulatory declaration and public disclosure. Label updates, database submissions, and documentation management will become critical compliance steps. Overall, the measure reflects Vietnam’s broader shift toward increased transparency and lifecycle management of hazardous chemicals in products, with direct implications for market access, product design, and compliance operations.