Vietnam has notified the WTO of a draft Circular establishing the list of medium-risk and high-risk products and goods under the state management responsibility of the Ministry of Industry and Trade. The measure is relevant for companies placing certain chemicals, chemical-containing products, explosives, explosive precursors, and related industrial products on the Vietnamese market.

The draft Circular is proposed for adoption on 1 June 2026, with entry into force on 1 July 2026. Comments may be submitted until 26 June 2026.

Key regulatory scope

The notified list covers seven product groups:

1. Tissue paper and toilet paper
2. Chemicals and chemical-containing products
3. Industrial explosives
4. High explosives
5. Industrial explosive accessories
6. Industrial machinery, equipment, and materials
7. Explosive precursors

For chemical and chemical-containing products, the list includes mercury-containing fluorescent lamps, industrial sodium hydroxide, poly aluminium chloride, industrial ammonia, paints, and textile products containing formaldehyde or aromatic amines derived from azo dyes.

The explosive-related scope covers industrial explosives, high explosives such as Hexogen, TNT, Octogen and Pentrit, industrial explosive accessories, and explosive precursors such as ammonium nitrate, sodium nitrate, sodium chlorate, potassium nitrate, potassium chlorate and potassium perchlorate.

Compliance requirements

Products listed in the draft Circular are subject to quality management requirements linked to the applicable Vietnamese national technical regulations, including relevant QCVNs under MOIT management.

For imported goods, the draft repeatedly requires conformity declaration before market circulation. Depending on the product category, conformity assessment may be based on accredited certification, testing, self-assessment, or other applicable conformity assessment methods under Circular No. 14/2026/TT-BKHCN.

The draft Circular would also replace Circular No. 41/2023/TT-BCT from the effective date of the new Circular.

Industry impact

The measure is particularly relevant for exporters and importers of chemicals, paints, textile products, explosives, explosive precursors, and chemical-related industrial goods into Vietnam. Companies should map affected products against the HS codes and applicable QCVNs, confirm testing and certification routes, and ensure that Vietnamese importers are prepared to complete conformity declaration before placing products on the market.