Vietnam’s Ministry of Industry and Trade (MOIT) has opened consultations on proposed amendments to Decree No. 24/2026/NĐ-CP and Decree No. 25/2026/NĐ-CP, two important implementing measures under the 2025 Chemicals Law. Both consultations opened on 20 August 2026, and comments must be submitted by 7 September 2026. The drafts were prepared by MOIT’s Chemicals Agency as part of a broader review of chemical controls, administrative procedures and business conditions.

Decree No. 24/2026/NĐ-CP establishes the chemical lists used to determine whether substances are subject to conditional production and trading, special controls or chemical-incident planning requirements. Decree No. 25/2026/NĐ-CP addresses chemical-industry development and chemical safety and security, including requirements affecting chemical facilities, specialist consultants, training and incident preparedness. Neither amendment has been adopted, so companies must continue complying with the existing decrees while the consultations remain underway.

Proposed Changes to Chemical Lists

The draft amendment to Decree No. 24/2026/NĐ-CP would replace Annexes I, II and III and amend Annex IV. These annexes cover basic chemicals in priority chemical-industry sectors, chemicals subject to conditional production and trading, specially controlled chemicals, and chemicals requiring an accident prevention and response plan. Changes to these lists may affect licences, eligibility certificates, import and export controls, safety planning and customer documentation.

One expressly identified change is the proposed addition of xylene, CAS 1330-20-7, to the conditional production and trading list. The draft includes a transitional arrangement for companies that already hold conditional-chemical certificates covering all three individual isomers: ortho-xylene, meta-xylene and para-xylene. These companies could continue producing or trading mixed xylene under their existing certificates until those certificates expire.

The draft also proposes transitional arrangements for chemicals moving between regulatory categories. Existing licences and certificates would generally remain valid until expiry, while businesses handling chemicals newly placed in the specially controlled category would have until 31 December 2027 to meet the corresponding requirements under the amended implementing framework. Where a chemical is removed from the conditional list, businesses would no longer need to continue meeting the associated conditional-chemical requirements after the amendment takes effect.

These changes remain proposals and should not yet be used as a basis for altering licences or discontinuing existing compliance activities. Companies should compare their portfolios against the current and proposed annexes using chemical names, CAS numbers and applicable mixture thresholds. Particular attention should be given to chemicals moving between the conditional and specially controlled categories.

Proposed Changes to Chemical Safety Requirements

The separate amendment to Decree No. 25/2026/NĐ-CP is intended to address implementation difficulties and support government measures to reduce, decentralize and simplify administrative procedures and business conditions. The Decree covers chemical-industry development, safety distances, specialist chemical consulting, safety training and chemical-incident prevention and response. The amendments may therefore affect chemical facilities as well as organizations and individuals providing regulated chemical-safety services.

The draft addresses qualification and experience requirements for individuals providing chemical safety and security consulting. The covered activities include chemical classification and labelling, preparation of safety data sheets, new-chemical registration, safety training and development of chemical-incident prevention and response plans. The required professional qualifications and experience would depend on the nature and complexity of the consulting activity.

The proposal should not automatically be interpreted as a regulatory relaxation. Although administrative simplification is a stated objective, certain provisions may redistribute responsibilities or revise qualification, documentation and safety requirements. Companies should therefore compare the draft against their existing facility arrangements, safety documentation, licences, training programmes and use of external consultants.

Consultation and Industry Impact

Comments on both drafts are due by 7 September 2026. The relatively short consultation period makes early portfolio screening important, particularly for companies handling substances that may move into or out of conditional or specially controlled categories.

The proposals are relevant to chemical manufacturers, importers, exporters, distributors, downstream users, chemical facilities and specialist service providers operating in Vietnam. Companies should identify proposed changes affecting their substances and assess the potential consequences for licensing, import and export procedures, reporting, customer communication and incident-response planning. Where the changes would create a material compliance or supply-chain impact, businesses should consider submitting comments before the deadline.