Key points on the production, trade, use of chemicals when the Law on Chemicals 2025 and its guiding regulations come into effect
February 10th, 2026
On June 14, 2025, the Law on Chemicals No. 69/2025/QH15 was passed by the National Assembly of the Socialist Republic of Vietnam and officially came into effect on January 1, 2026, with many major changes aimed at sustainable development, enhanced risk management, and comprehensive digital transformation in the chemical industry.
On January 17, 2026, the Government and the Ministry of Industry and Trade simultaneously issued Decrees and Circulars guiding the Law on Chemicals 2025, providing a legal basis for chemical activities in Vietnam, including:
(i) Decree No. 24/2026/ND-CP stipulating the List of Chemicals within the scope of the Law on Chemicals;
(ii) Decree No. 25/2026/ND-CP detailing and providing measures to organize and guide the implementation of some articles of the Law on Chemicals concerning the development of the chemical industry and chemical safety and security;
(iii) Decree No. 26/2026/ND-CP detailing and guiding the implementation of some articles of the Law on Chemicals regarding the management of chemical activities and hazardous chemicals in products and goods;
(iv) Circular No. 01/2026/TT-BCT detailing and guiding the implementation of some articles of the Law on Chemicals and Decree No. 26/2026/ND-CP; and
(v) Circular No. 02/2026/TT-BCT stipulating some measures for the implementation of the Law on Chemicals and Decree No. 25/2026/ND-CP.
Accordingly, the following points should be noted when carrying out production, trade, and use of chemicals:
A. MANAGEMENT OF PRODUCTION, TRADE, EXPORT, AND IMPORT ACTIVITIES OF CHEMICALS
1. Procedures for declaring imported chemicals
According to Article 6 of Decree No. 26/2026/ND-CP, organizations, individuals importing chemicals listed in Chapter 28 and Chapter 29 of the Vietnamese Export and Import Goods List issued by the Minister of Finance must declare imported chemicals before customs clearance through the Vietnam National Single Window.
2. Procedures for chemicals subject to conditional production, trade
The List of chemicals subject to conditional production, trade is stipulated in Appendix II issued with Decree No. 24/2026/ND-CP.
2.1. The production and trading
Law on Chemicals 2025 separates the Certificate of Eligibility for Conditional Chemical Production and the Certificate of Eligibility for Conditional Chemical Trade. Accordingly:
- Organizations, individuals that have been granted a Certificate of Eligibility for the production and trade of conditional chemicals in the industrial sector before January 17, 2026, may continue to operate under the issued certificate until December 31, 2027.
- Chemicals listed in Appendix II – List of chemicals subject to conditional production and trade as issued under Decree No. 24/2026/ND-CP, which are not included in the List of chemicals subject to conditional production, trade and the List of chemicals with restricted production and trade as issued under Decree No. 113/2017/ND-CP and Decree No. 82/2022/ND-CP, they must comply with the regulations of Decree No. 26/2026/ND-CP before December 31, 2026.
2.2. The export and import activities: According to the provisions of Article 10 of Decree No. 26/2026/ND-CP:
- Organizations are only permitted to export conditional chemicals according to Certificate of Eligibility for the Production/Trade of Conditional Chemicals.
- Organizations are permitted to import conditional chemicals if:
· For trading purposes: imports are only permitted under a Certificate of Eligibility for the Trade of Conditional Chemicals issued by the competent authority.
· For use by organizations and individuals: the purpose of using the chemical must be publicly declared in the Specialized Chemical Database and a Certificate of Eligibility for the Production and Trade of Conditional Chemicals is not required.
- In addition to the legally required customs documents, when exporting or importing conditional chemicals for trading purposes, organizations must have a Certificate of Eligibility for the Production/ Trade of Conditional Chemicals.
3. Procedures for chemicals requiring special control
Law on Chemicals 2025 replaces the term “restricted chemicals in production and trading” with “chemicals requiring special control”.
The List of chemicals requiring special control is stipulated in Appendix III issued with Decree No. 24/2026/ND-CP.
A mixture containing components from the List of chemicals subject to conditional production and trade, and also containing components from the List of chemicals requiring special control, is considered a mixture requiring special control and must comply with the regulations applicable to mixtures requiring special control.
3.1. The production and trading activities
- Circular 01/2026/TT-BTC mandates the application of control forms for the purchase and sale of chemicals requiring special control from January 1, 2026, through a system for identifying and tracing the origin of chemicals requiring special control on an electronic identification and authentication platform managed by the Ministry of Public Security.
- Transitional provisions:
· Organizations, individuals that were granted Licenses for the production and trade of Schedule chemicals, industrial precursors, restricted chemicals for production and trading in industrial sector before January 17, 2026, may continue to operate under the issued licenses until expiry of the license.
· The production and trade of chemicals listed in Appendix III – List of chemicals requiring special control issued in Decree No. 24/2026/ND-CP, but not included in the List of restricted chemicals for production and trading, the List of industrial precursors, or the List of Schedule chemicals issued under Decree No. 113/2017/ND-CP, Decree No. 82/2022/ND-CP, and Decree No. 33/2024/ND-CP, they must comply with the regulations of Decree No. 26/2026/ND-CP before December 31, 2026.
3.2. The export and import activities:
- Organizations, individuals exporting or importing chemicals requiring special control must have a License issued by the competent authority.
- Organizations, individuals must create an account on the Specialized Chemical Database and declare the purpose of use when importing chemicals requiring special control for use in the production of other products or goods.
- Export and import licenses for chemicals requiring special control are issued for each export and import invoice and are valid for 06 months from the date of issuance.
- Export and import licenses for chemicals requiring special control may be extended if the validity period stated in the license expires but the export or import has not been implemented or has not been completed. The license can only be extended once and for a period not exceeding 06 months from the date of the extension.
- Transitional provisions:
· The export and import of chemicals listed in Appendix III – List of Chemicals Requiring Special Control issued under Decree No. 24/2026/ND-CP, and not included in the List of Restricted Chemicals for Production and Trade, the List of Industrial Precursors, or the List of Schedule Chemicals issued under Decree No. 113/2017/ND-CP, Decree No. 82/2022/ND-CP, and Decree No. 33/2024/ND-CP, the submission of documents regarding the License for Production and Trade of Chemicals Requiring Special Control is waived until December 31, 2026.
· The export and import of chemicals that are industrial precursors and are included in the List of Chemicals Requiring Special Control issued under Decree No. 24/2026/ND-CP, the previously issued Certificate of Eligibility for Production and Trade of Conditional Chemicals in the industrial sector may be used as a substitute for the License for Production and Trade of Chemicals Requiring Special Control until December 31, 2027.
· The export and import of Schedule chemicals; and restricted chemicals for production and trade that are included in the List of Chemicals Requiring Special Control issued under Decree No. 24/2026/ND-CP, the previously issued Production and Trade License may be used as a substitute for the License for Production and Trade of Chemicals Requiring Special Control until the expiration of the License.
4. Procedures for prohibited chemicals
Prohibited chemicals are hazardous chemicals specified in the List of Prohibited Chemicals and Minerals issued with the Law on Investment No. 61/2020/QH14.
4.1. The production activities
- Organizations producing prohibited chemicals are those established in accordance with the law.
- To be granted a License to produce prohibited chemicals, organizations must meet the conditions regarding (i) the entity, (ii) production purpose (scientific research, national defense, security, disaster prevention, disease control, or performing tasks assigned by the Government or the Prime Minister), (iii) technology, (iv) factory, (v) storage facilities, and (vi) plans for controlling and preventing the loss of prohibited chemicals, etc., as stipulated in Article 16 of Decree No. 26/2026/ND-CP.
4.2. The export and import activities
- Importing prohibited chemicals:
· Organizations importing prohibited chemicals must meet the conditions regarding the entity, purpose (scientific research, national defense, security, or carrying out tasks assigned by the Government or the Prime Minister), equipment, means for incident response, plans or measures for preventing and responding to chemical incidents, and plans for controlling and preventing the loss of prohibited chemicals, etc., as stipulated in Article 18 of Decree No. 26/2026/ND-CP.
· Import permits for prohibited chemicals are issued for each imported consignment and are valid for 06 months from the date of issuance.
- Exporting prohibited chemicals:
· The export of prohibited chemicals is only permitted if the importing organization does not use up all the prohibited chemicals after the expiration date specified in the issued Import License, and must comply with relevant laws and international treaties to which the Socialist Republic of Vietnam is a signatory.
· Conditions for exporting prohibited chemicals:
o The organization does not use up the prohibited chemicals within the expiration date specified in the Import License for prohibited chemicals issued by the competent authority;
o Export is only permitted with the approval of the competent authority;
o If not exported, the organization importing the prohibited chemicals must destroy them. The destruction must ensure environmental safety, occupational safety, and be documented.
B. MANAGEMENT OF HAZARDOUS CHEMICALS IN THE PRODUCT MANUFACTURING PROCESS
1. Responsibility to disclose information about the levels of hazardous chemicals in products and goods
- Organizations and individuals producing or importing products and goods containing hazardous chemicals are obligated to disclose information on the hazardous chemical content in their products and goods before circulation on the market, using the Specialized Chemical Database; and to publicly disclose this information on the electronic portal, website of the organization or individual, or at the point of direct supply of the products and goods to the buyer.
- The List of hazardous chemicals in products and goods that must be disclosed is specified in Appendix XIX issued with Circular 01/2026/TT-BTC.
- Organizations and individuals disclosing information on the level of hazardous chemical in products and goods must comply with the regulations of Decree 26/2026/ND-CP before March 1, 2026.
2. Control of hazardous chemicals during the production of products and goods containing hazardous chemicals
Organizations and individuals producing products and goods containing hazardous chemicals are responsible for developing and issuing Procedures for controlling hazardous chemicals during the production process, based on actual operating conditions and ensuring the following objectives:
- Monitoring the composition and levels of hazardous chemicals in raw materials;
- Monitoring the composition and levels of hazardous chemicals emitted during the production process;
- Monitoring the composition and levels of hazardous chemicals in the final product;
- Preventing the loss of hazardous chemicals.
C. PREVENTION AND RESPONSE TO CHEMICAL INCIDENTS
Enact regulations to tighten the responsibilities of businesses in preparing on-site response plans:
- The List of chemicals requiring a chemical incident prevention and response plan is issued in Appendix IV attached to Decree No. 24/2026/ND-CP.
- A Chemical incident Prevention and Response Plan must be approved by the competent authority, or Chemical incident Prevention and Response Measures must be issued in accordance with Articles 33, 34, 35, 36 of Decree No. 25/2026/ND-CP.
- The obligation to update the Chemical Incident Prevention and Response Plan/Measures to the national database within 30 days from the date of approval or issuance is added.
- Specific regulations are established regarding the content, organizational procedures, and documentation of chemical incident response drills. Units must update exercise records on the specialized chemical database and store exercise records for a minimum of 03 years from the date the exercise concludes.
- Organizations and individuals that issued Measures for preventing and responding to chemical incidents before January 17, 2026, but fall under the provisions of point b, Clause 2, Article 33 of Decree No. 25/2026/ND-CP, must develop a Plan for preventing and responding to chemical incidents and submit it to the competent authority for appraisal and approval before December 31, 2026.
D. REQUIREMENTS FOR SAFETY AND SECURITY IN CHEMICAL WORKS
1. Professional requirements for the person responsible for chemical safety
- Decree No. 25/2026/ND-CP stipulates the conditions for organizations and individuals participating in consulting activities for chemical project development and specifies the procedures for issuing specialized chemical consulting certificates.
- Organizations and individuals producing chemicals must have a person responsible for chemical safety with a bachelor’s degree or an equivalent or higher qualification in a chemistry-related field listed in Appendix III - List of chemistry training fields attached to Decree No. 25/2026/ND-CP.
- Organizations and individuals trading in chemicals, storing chemicals, using chemicals, treating chemical waste, disposing of chemicals, and disposing of chemicals must have a person responsible for chemical safety with a vocational diploma or higher in chemistry from Appendix III - List of chemistry training fields attached to Decree No. 25/2026/ND-CP.
2. Requirements for safety training in the chemical industry
- Applicable to organizations and individuals involved in chemical activities. Chemical safety training can be conducted by the organization or individual themselves, or through a consulting organization.
- Frequency: Every 02 years.
- Decree No. 25/2026/ND-CP expands the scope of those required to participate in chemical safety training and adjusts the conditions for chemical safety trainers:
· Target trainees:
o Group 1: Heads of organizations; Heads of departments, divisions, affiliated branches, workshop managers or equivalents responsible for chemical operations; Deputy heads.
o Group 2: Persons responsible for chemical safety; Persons directly supervising chemical safety at the workplace; Warehouse keepers involved in chemical operations or equivalents.
o Group 3: Employees directly involved in chemical-related work; Medical staff at facilities conducting chemical activities (if any).
· Training content must be appropriate to the trainee's job position; the nature, type, and level of hazard of chemicals at the chemical facility as stipulated in Article 30 of Decree No. 25/2026/ND-CP. Organizations, individuals, and consulting organizations are legally responsible for the quality of chemical safety training.
· Trainers:
o If the organization conducts the training itself: Trainers must have a bachelor’s degree or an equivalent or higher qualification in a chemistry-related field listed in Appendix III of Decree 25/2026/ND-CP and have relevant work experience in chemical safety activities.
o If training is conducted through a consulting organization: Trainers from the consulting organization must have a professional chemical consulting Certificate.
E. OTHERS
1. Chemical storage services
- Chemical storage services involve leasing facilities for storing chemicals to other organizations or individuals.
- Organizations providing chemical storage services for conditional chemicals or chemicals requiring special control must obtain a Certificate of eligibility for chemical storage services.
- Organizations providing chemical storage services must meet the requirements regarding the entity, storage facilities, chemical preservation, professional capacity, and safety requirements in storage operations, as stipulated in Article 19 of Decree 26/2026/ND-CP.
- Storage is only permitted for the scale and types of chemicals specified in the Certificate issued by the competent authority.
2. Information provision mode
Organizations and individuals engaged in chemical activities are obligated to provide and update complete, timely, and accurate information into the Specialized Chemical Database as stipulated in point b Clause 3 Article 27 of Decree No. 26/2026/ND-CP, including providing information on: the chemical activity situation of the previous year, periodically before February 15th of each year.
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With the changes to the Law on Chemicals taking effect from January 01, 2026, businesses need to update information promptly to ensure compliance with legal regulations and minimize risks during operations, inspections, and audits.
In order to receive legal support and advice, enterprises can contact us with the following information:
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Address: Room D14, floor 2, 40 Ba Huyen Thanh Quan, Xuan Hoa Ward, Ho Chi Minh City
Phone number: 028 3930 6949
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Phone number: 028 3930 6949
Email: thaianh.luong@la-vn.com