Vietnam’s New Chemicals Framework: The 2026 Regulatory Reset
This blog was originally posted on 9th February 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.
AUTHORED BY VALENTINA MARCHETTI, SENIOR REGULATORY COMPLIANCE SPECIALIST & TEAM LEAD, COMPLIANCE & RISKS
A Rebuilt Legal Architecture for Chemicals Management in Vietnam
With the entry into force of Vietnam’s Law on Chemicals No. 69/2025/QH15 on 1 January 2026, Vietnam has formally transitioned to a new national chemicals regulatory system. The new law fully replaces the former Law on Chemicals No. 06/2007/QH12 and its implementing instruments, bringing an end to a regulatory regime that had governed chemical activities for nearly two decades.
Implementation of the new framework is supported by a coordinated package of secondary legislation, including Government Decrees No. 24/2026/ND-CP, No. 25/2026/ND-CP, and No. 26/2026/ND-CP, together with Circulars No. 01/2026/TT-BCT and No. 02/2026/TT-BCT issued by the Ministry of Industry and Trade (MOIT). These instruments entered into force on 17 January 2026 and together form the operational backbone of Vietnam’s chemical compliance requirements.
Rather than revising the former framework incrementally, the 2026 reform introduces a rebuilt regulatory architecture. It formalises list-based chemical controls, establishes a market-access mechanism for new chemicals, introduces explicit regulatory obligations for hazardous chemicals in products and goods, and embeds the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) as a binding standard. Across the framework, greater weight is placed on information management, digital reporting systems, and lifecycle-based oversight.
Regulatory Scope and Structure
The Law on Chemicals regulates chemical activities across the entire chemical lifecycle, including production, trading, import, export, storage, transport, use, and disposal. Importantly, its scope extends beyond substances and mixtures as such to include hazardous chemicals contained in products and goods placed on the Vietnamese market.
At the baseline level, chemicals that are not prohibited and not subject to specific control mechanisms remain regulated under the general provisions of Vietnam’s chemicals regulation framework, including requirements for classification, information provision, reporting, and recordkeeping.
Beyond this general layer, the framework differentiates obligations through defined control mechanisms, including:
- Chemicals subject to conditional production and trading
- Chemicals subject to special control, including licensing requirements
- Chemicals requiring accident prevention and response plans, as specified in dedicated regulatory lists
In parallel, the Law establishes the legal basis for chemicals prohibited from production, trading, import, export, and use, with specific substances identified through implementing decrees and related appendices.
Chemical Regulatory Lists and Categorization
A defining feature of the new system is the formalisation and restructuring of Vietnam’s list-based regulatory approach. Decree No. 24/2026/ND-CP organises regulatory controls across multiple appendices with clearly differentiated functions.
These appendices cover:
- Basic chemicals used in key industrial sectors
- Chemicals subject to conditional production and trading
- Chemicals subject to special control
- Chemicals requiring accident prevention and response plans
Each list is legally binding and directly linked to specific compliance obligations under Vietnam’s chemical regulatory framework.
The decree also clarifies how mixtures are regulated, referencing component substances and applicable concentration thresholds. As a result, Vietnam chemical regulatory lists apply not only to single substances, but also to mixtures containing regulated components above defined levels.
In parallel, the Law formalises the Vietnam National Chemical Inventory as a central regulatory reference point. Substances listed in the inventory are treated as existing chemicals, while substances not listed are regulated as new chemicals, subject to a dedicated new chemical notification and market-access mechanism.
Chemical Import Declarations and the Customs Interface
Vietnam chemical import declaration requirements have been significantly expanded through a principle-based approach linked to customs classification. Chemicals falling under Chapters 28 and 29 of Vietnam’s import and export nomenclature must be declared through the National Single Window prior to customs clearance.
This approach replaces reliance on a limited list of declarable substances and enables centralised collection of chemical information across regulatory authorities. Defined exemptions apply, including low-concentration components in mixtures and limited quantities imported for testing or evaluation.
Hazardous Chemicals in Products and Goods
Introduction of Product-Level Chemical Regulation
One of the most consequential changes under the 2026 framework is the introduction of explicit regulatory requirements for hazardous chemicals in products and goods. These provisions apply to organisations involved in the production and import of products containing hazardous chemicals, decisively shifting Vietnam’s chemical regulation downstream.
Manufacturers and importers must establish and maintain a control process covering hazardous chemicals throughout production, including monitoring chemical composition and concentrations in raw materials, during production, and in final products, as well as preventing chemical loss during manufacturing.
For each production or import batch, companies must submit information through a specialised national chemical database, including:
- Product name
- Hazardous chemical present
- Hazard properties and concentration
- Intended field of use
Declared information must be supported by test results issued by qualified laboratories.
In addition, companies are required to publicly disclose chemical composition information, including concentrations of hazardous chemicals and any applicable restricted-use recommendations. Disclosure may be provided via product labels or electronic information channels.
Circular No. 01/2026/TT-BCT specifies declaration formats and includes Annex XIX, identifying hazardous chemicals in industrial products subject to disclosure, such as:
- Lead and cadmium in batteries and electronic equipment
- Mercury in lighting products
- Chromium (VI) compounds in coatings
- Toluene in paints and printing inks
New Chemicals and Market Access in Vietnam
The Law on Chemicals establishes a formal market-access mechanism for new chemicals, defined as substances not listed in Vietnam’s National Chemical Inventory. Substances listed in the Inventory are treated as existing chemicals, while substances that are not listed are subject to registration and technical assessment prior to being placed on the Vietnamese market.
Before being placed on the market, new chemicals must undergo a technical assessment, coordinated by the competent authority, based on a structured dossier covering physicochemical properties, health hazards, environmental hazards, and risk management information.
The framework also recognises that certain substances may already be listed in foreign chemical inventories recognised by Vietnam. Where a substance is listed in such a recognised foreign inventory (for example, inventories published by EU ECHA, the US EPA, or Japan’s METI), the authorities will still require the substance to participate in assessment in Vietnam. In conducting that assessment, relevant information and existing evaluations from the foreign inventory may be referenced, and dossier requirements may be adjusted accordingly in line with the implementing regulations.
Following registration, new chemicals are subject to ongoing reporting obligations and inclusion in national chemical databases, with the possibility of regulatory reclassification over time, including inclusion in conditional or special-control lists where applicable.
GHS as a Binding Classification and Communication Framework
Vietnam’s 2026 framework embeds the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) as the mandatory basis for hazard classification and communication. Chemicals must be classified in accordance with GHS Revision 2 or later, with classification outcomes reflected in Safety Data Sheets (SDS) and used across the regulatory framework to trigger obligations, including import declarations, product-level disclosures, and reporting requirements. This alignment strengthens consistency between Vietnam chemical compliance requirements and international hazard communication practices.
Digitalisation and Chemical Information Systems
Across the framework, strong emphasis is placed on digital reporting systems and national chemical databases, supporting chemical registration, import declarations, and disclosures for hazardous chemicals in products and goods. This shift reinforces information-driven oversight and enhances regulatory traceability across the chemical lifecycle.
Key Regulatory Takeaways
Vietnam’s 2026 chemicals framework establishes a comprehensive, list-based, and information-driven regulatory system that fully replaces the former chemicals law. For both chemicals and chemicals in products, the framework introduces clearly defined obligations grounded in classification, declaration, disclosure, and ongoing information management.
Rather than an incremental revision, the reform represents a structural reorganisation of Vietnam’s chemical regulatory architecture, embedding lifecycle oversight, digital reporting, and differentiated controls at the core of national chemicals regulation.
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