Vietnam’s Customs Department has instructed regional customs offices not to routinely require importers and exporters to disclose the full composition of chemical products or submit technical documents beyond those prescribed by law. The clarification was issued through Dispatch No. 18114/CHQ-GSQL on 26 June 2026 following concerns that requests for 100% composition data could expose manufacturers’ trade secrets and intellectual property.

The dispatch addresses customs procedures under Vietnam’s new chemical-management framework, including the Chemical Law No. 69/2025/QH15, Decrees No. 24/2026/ND-CP and No. 26/2026/ND-CP, and Circular No. 01/2026/TT-BCT. It is directed to regional customs sub-departments and applies to customs handling of chemicals imported into or exported from Vietnam.Dispatch No. 18114/CHQ-GSQL

Limits on Routine Customs Documentation Requests

Customs procedures should generally be based on the declarant’s submission and the supporting documents required under customs and chemical legislation. Customs officers must not request additional technical information or documents outside these requirements as a routine condition of clearance. Declarants remain responsible for the completeness, accuracy and authenticity of the information and documents submitted.

Additional composition data, technical documents or chemical-related certificates may nevertheless be requested where customs has grounds to believe that a shipment contains declarable chemicals, conditional chemicals, specially controlled chemicals, or chemicals prohibited from import or export, despite being declared otherwise. Such grounds may include information about previous violations, warnings from other competent authorities, or non-compliance associated with the importer or exporter.

If the declarant does not provide the requested information, customs may arrange an analysis or expert examination to establish the nature of the goods. Where a shipment presents risks or suspected violations but the available information is insufficient to justify additional document requests, customs may refer the matter to the Chemicals Agency under the Ministry of Industry and Trade or the Ministry of Public Security’s drug-crime investigation authority for coordinated checks and closer post-clearance supervision.

Protection of Confidential Composition Information

The instruction responds directly to representations from the US–ASEAN Business Council and several international chemical-industry associations. These organizations reported that some customs units were demanding disclosure of 100% of imported chemical compositions, creating potential risks to confidential business information and manufacturers’ intellectual property.

The dispatch does not establish a blanket exemption from composition disclosure. Instead, it distinguishes routine clearance—where only legally required information should be requested—from risk-based cases in which customs has a documented basis for seeking further technical evidence.

Businesses relying on confidential formulations should therefore ensure that customs declarations and mandatory supporting records contain sufficient information to establish the product’s identity and regulatory status. They should also maintain more detailed technical evidence so it can be supplied where customs makes a legally supported request.

Conditional-Chemical Certificates

For chemicals subject to conditional production or trading controls, the required eligibility certificate is treated as a specialized regulatory licence. Importers and exporters must hold the applicable certificate before registering the customs declaration and must declare its information in the customs filing.

The dispatch bases this position on Article 10(4) of Decree No. 26/2026/ND-CP and Vietnam’s customs declaration rules. Consequently, obtaining or submitting the certificate after declaration registration would not satisfy the stated timing requirement. The government’s official database records that Decree No. 26/2026/ND-CP took effect on 17 January 2026. Government legal database

Specially Controlled Chemical Thresholds

The dispatch also addresses mixtures containing chemicals listed in Appendix III to Decree No. 24/2026/ND-CP. For mixtures containing exactly 1% of a Group 1 specially controlled chemical or exactly 5% of a Group 2 specially controlled chemical, customs offices are directed to apply the exemption provisions referenced in Resolution No. 19/2026/NQ-CP.

The dispatch itself does not reproduce the exemption wording or expressly state the resulting treatment of every mixture at these exact thresholds. Companies should therefore verify their products against the cited resolution, the applicable Appendix III entry and the final concentration calculation rather than relying on the percentages in isolation. Decree No. 24/2026/ND-CP, which establishes chemical lists within the scope of the Chemical Law, has applied since 17 January 2026. Decree No. 24/2026/ND-CP, Resolution No. 19/2026/NQ-CP

Outstanding Implementation Issues

Customs is working with the Chemicals Agency to connect chemical-licence and declaration information with the electronic customs system. The planned data exchange would allow customs officers to retrieve licence information through the National Single Window, but the dispatch does not provide a confirmed operational date.

Two additional matters remain under consideration: the identification of qualified organizations capable of determining chemical concentration and the application of specialized management rules to chemical transactions involving bonded warehouses or separate customs zones. Further guidance is expected after consultation between the Ministry of Finance and the Ministry of Industry and Trade.

Industry Impact

The clarification may reduce unnecessary disclosure of confidential formulations during routine customs clearance. However, manufacturers, importers and exporters should not interpret it as preventing customs from requesting composition or technical evidence in substantiated risk cases.

Companies should confirm whether their products contain declarable, conditional, specially controlled or prohibited chemicals; obtain required certificates before registering customs declarations; and ensure that declared product identities are consistent with SDSs, technical specifications and licences. Internal records should also support concentration calculations and explain why a particular control or exemption does or does not apply.