Vietnam consults on new requirements for chemicals and chemical products
Ha Noi, Vietnam - On 30 October 2025, the Vietnam Chemicals Agency (Vinachemia) released a draft Circular implementing the new Law on Chemicals (No. 69/2025/QH15), which was approved in June 2025. This draft follows the Implementing Decree published in September 2025 and a Decree on administrative penalties (“Penalty Decree”) in October 2025. Together, these three documents form the new regulatory framework for chemical management under the Chemical Law in Vietnam.
Public consultation on the two Decrees has now ended, but companies may still submit comments on the draft Circular until 30 November 2025.
New Chemical Notification
Starting in 2028, all new chemicals – substances not listed on the National Chemical Inventory (NCI) – must be notified to Vietnam Chemical Agency (Vinachemia). A notification dossier must include:
Application form for new chemical notification
Testing data on physical, chemical, and hazardous properties
Chemicals already listed or evaluated by at least two foreign authorities (e.g., U.S. EPA TSCA Inventory, Japan METI ENCS, or EU ECHA/ REACH registrations) may use existing summary data as supporting documents instead of new test reports. Vinachemia will review submissions and approve the nofication within 90 days (excluding time for additional information requests). During the first five years after introduction to the market, manufacturers must also submit an annual report by 15 February each year, providing on the activities and volume for the previous year.
Proposed new penalties:
Failure to notify – VND 30 – 40 million (≈ USD 1 139 –1 518)
Failure to submit follow-up information – VND 20 – 30 million (≈ USD 760 to 1 139)
Non-notified chemicals and products – subject to confiscation and destruction
The National Chemical Inventory must be finalized before 2028. Industry has proposed over 40 000 substances, but the final NCI has yet to be published—potentially delaying implementation.
Approval for Domestically Manufacture, Storage, or Transport of Chemicals
Companies manufacturing, storing or transporting chemicals in Vietnam must obtain approval from Vinachemia and submit:
Site plan of manufacturing/storage areas or information on the transportation means
Accident prevention and emergency plan
SDSs for all chemicals used or produced
Proof of trained personnel
Under the draft Penalty Decree, violations will be subject to specified fines:
Posting incorrect hazard information: VND 5–10 million (≈ USD 189–375)
Failing to post hazard information or lacking prevention equipment: VND 10–20 million (≈ USD 380 to 760)
Failing to report hazard data to the national chemical database: up to VND 20 million (≈ USD 760)
Chemical Reporting for Imports
Importers must report all chemical information to Vinachemia through the National Single Window (NSW), including:
Invoice or bill of lading (original or Vietnamese translation)
Vietnamese-language Safety Data Sheet
Some exemptions may apply for:
Shipments < 10 kg per invoice
Imports for testing or evaluation
Concentration < 0.1 %
Products already published in the National Chemical Database
Proposed new penalties:
Failure to report: VND 20–30 million (≈ USD 760 to 1 139)
Incomplete or non-Vietnamese documentation: VND 5–10 million
Late report (more than 30 days after import): VND 3–5 million
Labelling and Disclosure for Products Containing Chemicals
Manufacturers and importers must disclose hazardous chemicals to the National Chemical Database, providing:
Product name
Chemical name and concentration
Hazard properties
Sector or intended use
This information and specialized warnings must also appear on the product label or company website, verified through chemical testing before market release.
Affected product groups include:
Adhesives, cleaners, disinfectants containing acetone, formaldehyde, methanol
Electronics containing cadmium, lead, chromium (VI) compounds
Paints, inks containing toluene
Batteries containing cadmium, lead, chromium (VI), sulfuric acid
Lamps containing mercury
Industrial cleaners containing hydrochloric acid
Wood panels containing formaldehyde
Penalties:
Failure to disclose – VND 10–20 million (≈ USD 380 to 760)
Incorrect or undocumented information – VND 5–10 million (≈ USD 190 to 380)
Definition of “Toxic Chemical”
The draft aligns with the UN GHS by defining “toxic chemicals” as those classified in Category 1 for hazards such as acute toxicity, carcinogenicity, reproductive toxicity, or environmental hazard. Designation as “toxic” enables additional controls from Vinachemia and other ministries (e.g., MOH, MONRE). However, the draft Implementing Decree does not clarify whether mixtures containing < 1 % of these substances are exempted.
GHS Implementation
Vietnam will continue recognizing GHS Version 2 or later per the draft Implementing Decree; however, the draft Circular introduces three potential new hazard classes:
Desensitized explosives
Bioaccumulation (BCF ≥ 1 000 L/kg)
Persistent Organic Pollutants (POPs)
However, neither document provides clear classification guidelines for the three classes.
“Specialized Control” Chemicals
The 2025 Chemical Law introduces a new category of chemicals requiring specialized control, consolidating restrictions for high-risk substances. Companies trading or using these chemicals must obtain certification and approval, maintain safety systems, and report volumes to the National Chemical Database.
Penalties:
Selling to unauthorized users – VND 10–20 million (≈ USD 380 to 760)
Selling to unqualified traders – VND 20–25 million (≈ USD 760 to 950)
Import/export without approval – VND 20–30 million (≈ USD 760 to 1 139)
Repeated violations may lead to license suspension or revocation.
Increased Administrative Penalties
The draft Penalty Decree also significantly raises fines across multiple areas:
Failure to classify or label chemicals – VND 30–40 million (a 167 % increase)
Incorrect GHS classification – VND 20–30 million (a 500 % increase)
Incomplete SDS – VND 2–3 million (a 200 % increase)
Next Steps and Implications for Products and Brands Owners or Traders
Once finalized, the new Decrees and Circular will replace Vietnam’s current chemical control regime under the 2007 Law on Chemicals. Some of the requirements are new while some existing requirements are being strengthened.
Manufacturers, importers, and brand owners should begin:
Reviewing their chemical inventories against the draft NCI
Ensuring SDS and labeling conform to updated GHS categories, where applicable
Verifying import reporting workflows via the National Single Window
Communicating with suppliers and/or conduct testing to obtain complete chemical composition data
Proactive preparation will be critical to ensure compliance once the new framework enters into force.
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