Just a few months after three important Decrees guiding the Law on Chemicals 2025 were issued, the Ministry of Industry and Trade proposed to amend all three documents simultaneously. The very short implementation period easily creates a sense of unstable policy. However, the Draft documents show that the main goal is not to change the management orientation established by the Law on Chemicals and these documents, but to handle unclear, overlapping and inappropriate points that arise when the new regulatory system begins to come into operation.
From January 1, 2026, the Law on Chemicals No. 69/2025/QH15 replaces the Law on Chemicals 2007 and establishes a new management mechanism for chemicals requiring special control. This list is divided into group 1 and group 2, with different management requirements.
This seemingly small difference is becoming a noteworthy problem for businesses operating in the chemical sector, especially in localities with many industrial parks and export processing zones such as Ho Chi Minh City, Dong Nai or Long An. The reason lies in the fact that the same transaction can be simultaneously governed by the law on chemicals, trade, foreign trade management and customs. If you only look at the concept of "export and import" without determining the correct point of departure, destination and legal regime of goods, it is very easy for businesses to carry out excess procedures or, more dangerously, miss mandatory procedures.
In chemical management, the biggest risk to a business sometimes does not start with a chemical incident, but from the gap between what the business is operating and what the legal records represent. A restockpile, a line that has been adjusted, chemical inventory has increased, a chemical safety sheet has not been updated or the declaration data no longer matches reality are all risks to the business of the business.
A business registration certificate issued in Vietnam that wants to be used abroad for a long time often has to go through many layers of certification. On the other hand, documents issued by foreign agencies that want to be accepted in Vietnam may also have to be certified in turn in the country of origin, diplomatic missions and competent agencies of the receiving country. Each layer of confirmation entails time, cost and risk of dossiers being returned just because of differences in seals, signatures or authority.
A factory has a certificate, the buyer has accepted the price and the current condition, but the transaction can still be stalled. Because in industrial parks, factories are not independent assets but are closely associated with land lease rights, investment projects, infrastructure contracts and operating conditions. If these factors are not transferred synchronously, businesses may fall into a situation where they have received money but cannot hand over, or have received factories but cannot produce yet.
A land plot worth trillions of VND, an operating factory or a dominant stake in an enterprise can all be very valuable assets. But when Vietnamese enterprises borrow capital from foreign banks, the economic value of the asset does not necessarily mean the ability to use the same asset to secure the loan.
