Vietnam Issues New Subsidiary Regulations for Chemicals Law

By Thuy Dang, Senior Regulatory Specialist, Supply Chain Team, UL Solutions

Following the issuance of the Law on Chemicals No. 65/2025/QH15, which became effective on January 1, 2026, the Vietnamese Government recently published three new decrees to further elaborate the Law, as follows:

• Decree No. 24/2026/ND-CP providing the regulated chemical lists;
• Decree No. 25/2026/ND-CP providing management details and measures towards the development of green chemical industry and chemical safety and security;
• Decree No. 26/2026/ND-CP providing management requirements for chemical-related activities and hazardous substances in products and goods.

The Ministry of Industry and Trade also issued two circulars to further detail the Law and its decrees, namely:

• Circular No. 01/2026/TT-BCT guiding Decree No. 26/2026/ND-CP requirements for chemical-related activities and hazardous substances in products and goods;
• Circular No. 02/2026/TT-BCT providing guidance for Decree No. 25/2026/ND-CP.

All five regulations became effective on January 17, 2026, and replaced Decree No. 113/2017/ND-CP and Circular 32/2017/ND-CP.

Decree No. 24/2026/ND-CP

This Decree contains four lists of chemical substances:

• Annex I: Primary chemicals in key chemical industry sectors;
• Annex II: Chemicals subject to conditional production and trading;
• Annex III: Chemicals subject to special control;
• Annex IV: Chemicals subject to developing an incident prevention and response plan.

Decree No. 25/2026/ND-CP and Circular No. 02/2026/TT-BCT

This Decree provides the principles and strategies for the national development of chemical industry and chemical safety and security. The Circular provides new documentation requirements for chemical industry consulting certificates and preparation of the incident prevention and response plans and measures.

The Decree demonstrates Vietnam’s efforts to develop more sustainable chemical industrial activities, focusing on applying the principles of green chemistry to minimize or eliminate the use and generation of hazardous chemicals. Green chemistry principles must be applied in the design and selection of technologies and equipment for any chemical projects. Individuals working in developing chemical projects or in consulting on incident prevention and response measures must obtain a Certificate in Chemical Industry Consulting.

Decree No. 26/2026/ND-CP and Circular No. 01/2026/TT-BCT

This Decree further clarifies several articles of the Law on Chemicals 2025, including criteria for “toxic substances,” assessment, registration and management of “new chemicals,” confidential business information (CBI) and mandatory disclosure requirements.

Some highlights of the regulations are as follows:

1. Declaration of imported chemicals:
   • Declaration requirements apply to chemicals listed under Chapter 28 and Chapter 29 of Vietnam’s Nomenclature of Exports and Imports by the Minister of Finance.
   • Exemptions include:
     • Import of chemicals subject to special control or prohibited chemicals with issued import licence; 
     • Import of less than 10 kg of chemicals subject to declaration;
     • Import of less than 1 kg of new chemicals for experiment or evaluation of physical and chemical properties; 
     • Import of mixtures that do not fall under Chapter 28 and Chapter 29 but contain chemicals listed under Chapter 28 or Chapter 29.
2. New requirements for chemicals subject to special control, conditional chemicals and prohibited chemicals
   • Decree No. 26/2026/ND-CP promulgates the eligibility requirements for production, trading, and licensing of conditional chemicals and chemicals subject to special control.
   • Circular No. 01/2026/TT-BCT promulgates details and forms to be used in different procedures.
   • Entities using chemicals subject to special control for production must publicly disclose the type of chemicals and their use purposes on the national chemical database 30 days before the chemicals are used for the first time or upon changes of the initially declared use purposes.
3. Control of hazardous chemicals in products and goods
   • Manufacturers and importers of products and goods containing hazardous chemicals must disclose required information on the national chemical database before introducing the products and goods into market circulation. For each production or import consignment, the following information is required:
     • Name of the products and goods containing hazardous chemicals;
     • Hazardous chemical names;
     • Hazardous properties of the chemicals;
     • Concentration content;
     • Fields in which the products are used.
   • Information on hazardous chemical contents and compositions and use restrictions of the products and goods containing hazardous chemicals must be disclosed and displayed on information portal or website of manufacturers and importers or in physical sale locations, and on labels of the products and goods.
4. Transition periods
   • Existing licenses to produce, trade, export and import Schedule chemicals, industrial precursors, and restricted chemicals for production and trading in industrial sector issued before January 17, 2026 shall continue to be used until expiry of the licenses.
   • Existing certificates of conditional chemicals issued before January 17, 2026 shall continue to be used until December 31, 2027.
   • Entities involved in manufacturing and trading any chemicals subject to special control (Annex III of Decree 24/2026/ND-CP) which were not previously classified as either restricted chemicals and industrial precursors in Decree No. 13/2017/ND-CP or Schedule chemicals in Decree No. 33/2024/ND-CP must adhere to Decree No. 26/2026/ND-CP before December 31, 2026. Importers and exporters of these chemicals are exempted from presenting newly required licenses until December 31, 2026.
   • For import and export of any chemicals subject to special control (Annex III of Decree 24/2026/ND-CP) which were previously classified as either restricted chemicals in Decree No. 13/2017/ND-CP or Schedule chemicals in Decree No. 33/2024/ND-CP, existing licenses can be used until their expiration dates.
   • Entities dealing with any conditional chemicals (Annex II of Decree 24/2026/ND-CP) which were not previously listed as conditional or restricted chemicals in Decree No. 13/2017/ND-CP and its amendments must adhere to Decree No. 26/2026/ND-CP before December 31, 2026.
   • Disclosure requirements of chemical types and use purposes for import of chemicals subject to special control and information on content of hazardous chemicals in products and goods must be followed by Mar 1, 2026.

Recommended action items

• Review new licensing requirements of chemicals that apply to your companies. Check if your companies hold any licenses and certificates that can be affected by the new transition clauses.
• Check if the new declaration requirements apply to your companies. 
• Review the disclosure requirements to stay compliant.

References

Decree 24/2026/ND-CP
Decree 25/2026/ND-CP
Decree 26/2026/ND-CP
Circular 01/2026/TT-BCT 
Circular 02/2026/TT-BCT