Reference source : Vietnam Ministry of Industry and Trade (MOIT)
Hazardous chemicals Chemical Compliance Vietnam Chemicals Law Chemicals Law No. 69/2025/QH15 Implementing Decrees Chemical Regulation Vietnam Chemical Import Requirements
On 17 January 2026, Vietnam’s Ministry of Industry and Trade (MOIT) issued Notice No. 363/BCT-HC, confirming that the key implementing instruments under Chemicals Law No. 69/2025/QH15 were issued and took effect from the same date. These include Decrees 24/2026/ND-CP, 25/2026/ND-CP, and 26/2026/ND-CP, as well as MOIT Circulars 01/2026/TT-BCT and 02/2026/TT-BCT. The MOIT also indicated that, until online systems are fully operational, authorities should accept and process dossiers in paper form to avoid disruptions, in particular for chemical import and export licensing.
What Changes for Companies
1) List-based scoping is now formalized
Decree 24 sets the core list-based architecture through annexes covering basic chemicals, chemicals subject to conditional manufacture/trade, specially controlled chemicals, and chemicals requiring a chemical incident prevention/response plan. The Decree also introduces an annual review mechanism for updating these lists.
2) Imports: NSW declarations are a key operational trigger
Decree 26 establishes a pre-clearance import declaration requirement via the National Single Window (NSW) for chemicals under HS Chapters 28–29. Typical dossier components include the commercial invoice (and Vietnamese translation where relevant) and SDS. NSW feedback is intended to support customs clearance workflows.
3) Products: hazardous-chemical information disclosure is reinforced
For products and goods containing hazardous chemicals, the framework strengthens expectations around information declaration in the sector database before market placement as well as public disclosure/label communication. Circular 01 provides procedural details and templates, including an SDS content structure.
4) Safety and security controls are more procedural
Decree 25 and Circular 02 introduce more structured requirements for operational governance, including periodic chemical safety training (every 2 years), chemical incident prevention/response plans (with defined appraisal steps and timelines), and consultant certification mechanics (with standardized forms and documentation expectations, including record retention for drills).
Outlook for Industry
For importers, manufacturers, and downstream distributors, the immediate priority is execution readiness. This includes screening substances against the new lists, confirming NSW declaration readiness (including Vietnamese SDS/invoice translation controls), and ensuring EHS documentation (training, incident plans, drills) aligns with the new templates and processes. In the near term, companies should also be prepared for interim paper-based filings while digital systems stabilize.
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