National Chemical Inventory and National Chemical List
Position of the inventory in Vietnam’s chemicals framework
Vietnam has historically operated a draft National Chemical Inventory (NCI) on the Ministry of Industry and Trade’s chemicals database platform. In practice, this draft NCI has been used as the main screening reference to distinguish “existing” substances from substances treated as “new” for regulatory purposes, particularly when deciding whether a “new chemical” type submission is needed before placing a substance on the market.
From 1 January 2026, the system is formally modernised under the Law on Chemicals 2025 and the new implementing framework, which shifts Vietnam away from a nomination driven “draft inventory” concept toward a legally anchored National Chemical List and a defined “recognised foreign list” mechanism.
What changes from 1 January 2026
Law on Chemicals 2025 (effective 1 January 2026) makes the inventory concept a legal benchmark through the concept of the National Chemical List, and it introduces a structured new chemical regime linked to that list.
Decree 26/2026/ND-CP (dated 17 January 2026) operationalises this direction and sets the roadmap for list development and the new chemical system. In particular, it requires the competent authority to develop and submit the National Chemical List before 2028, together with a roadmap for applying the new chemical assessment regime after the list is issued.
Practical meaning: the compliance question becomes less about whether a substance was nominated previously and more about whether the substance is recognised under the new “list logic.”
Recognised foreign lists
The new implementing framework also clarifies what Vietnam treats as recognised foreign chemical lists for recognition purposes.
Under Decree 26/2026/ND-CP (Article 23), the recognised foreign lists referenced are:
This is relevant because a substance may be treated as not “new” if it is covered under the National Chemical List (once issued) or falls within the recognised foreign lists used for recognition in the implementing system.
Who can submit and how overseas manufacturers typically handle it
The legal duty holder is the organisation or individual conducting chemical activities in Vietnam and using the official database workflows. In practice, overseas manufacturers typically act through a Vietnam based channel, such as:
The 2026 framework also anticipates confidentiality handling where a foreign manufacturer may provide coded or protected information through a Vietnam representative office or a designated local representative in Vietnam.
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