INFORMATION ABOUT DOCUMENTS AND TERMS OF USE
1. Purpose of issuance of documents and scope of application
This handbook is compiled by HM&P to systematize the legal regulations on chemicals in Vietnam that are in force, assist enterprises in identifying legal obligations, administrative procedures and the risk of being sanctioned for administrative violations in chemical activities. The document is aimed at enterprises producing, trading, exporting, importing, storing, transporting and using chemicals and enterprises producing and importing products and goods containing hazardous chemicals.
2. When to update
The contents of the Handbook reflect legal documents effective as of September 16, 2026. Transitional contents (especially Resolution No. 19/2026/NQ-CP, which expires no later than March 1, 2027) and draft documents introduced in the Handbook may be changed after this time. Users need to check the validity status and amended, supplemented and replaced documents at the time of application.
3. Copyright and Conditions of Use
© 2026 HM&P. All rights reserved. Organizations and individuals are permitted to copy, quote and use the Handbook for internal reference, study and research purposes provided that the content remains and the source is clearly stated: "Vietnam Chemical Law Compliance Handbook 2026 – HM&P". The content may not be modified for redistribution, commercial use or presentation in a form that causes confusion as to the origin of the material without the written approval of HM&P.
4. How to Use the Handbook
- Enterprises should start from the Guidelines for Defining the Role of Enterprises to identify Items that need to be prioritized for research, then implement the Chemical Self-Classification Process in Section 3.
- Paragraphs marked as ⚑ practical notes or risk warnings should be given special attention.
- The contents referring to Resolution No. 19/2026/NQ-CP are transitional; the draft documents mentioned in Section 1 are not yet valid.
- Sections 14 and 16 provide an obligation checklist and a compliance self-review roadmap; Sections 17 and 18 summarize common reference situations and errors.
5. Contact
For any suggestions, suggestions for updates or in-depth advice, please contact HM&P using the information below:
Our Managing Partner:
Lawyer Nguyen Van Phuc
Phone: 0932 768 630
Email: phuc.nguyen@hmplaw.vn
HM&P Law Firm
Address: 10th Floor, ITAXA House, 126 Nguyen Thi Minh Khai, Xuan Hoa Ward, HCMC
Phone: +84 28 73080839
Email: counsel@hmplaw.vn
Website: hmplaw.vn
GUIDANCE ON DETERMINING THE ROLE OF ENTERPRISES
The legal obligations of enterprises under the Law on Chemicals depend simultaneously on three factors: (i) the type of chemical (which management group belongs to); (ii) the type of activity (production, trading, export, import, storage, transportation, use); and (iii) the size and volume of inventory. An enterprise can simultaneously assume many roles; then, the enterprise must fully meet the obligations corresponding to each role. The table below helps businesses identify the Items to be prioritized for research:
|
The role of businesses |
Signs of recognition |
Priority items |
|---|---|---|
|
Chemical production |
Creating chemicals through chemical reactions, mixing, blending, refining... to supply to the market |
Sections 2, 3, 4, 7, 8, 9, 10, 15 |
|
Trading and distributing chemicals |
Buying and selling chemicals, including purely commercial activities without a separate warehouse |
Sections 2, 3, 4, 7, 9.2, 10, 15.2 |
|
Chemical Imports |
Importing chemicals for business or serving the production needs of the enterprise itself |
Sections 3, 5, 7, 11, 13.3, 15.2 |
|
Chemical Exports |
Export of chemicals produced or traded by enterprises |
Sections 3, 5, 15.6 (if Chemical Table is present) |
|
Use of chemicals in the production of other products |
Using chemicals as raw materials, additives, solvents, treatment agents... in factories; do not resell chemicals |
Sections 3, 5, 8, 9.2, 10, 14, 15.4 |
|
Production and import of Products/Goods containing hazardous chemicals |
Products/Goods is on the list regulated by the Ministry of Industry and Trade containing hazardous chemicals |
Section 6, 15.3 |
|
Providing chemical storage services |
Lease of warehouses with facilities for storing chemicals of other organizations and individuals |
Sections 4, 12, 13.1, 13.3 |
|
Transportation of hazardous chemicals |
Self-transport or hire a hazardous chemical transport unit |
Sections 8, 10, 13.1, 15.4 |
|
Activities related to table chemicals, industrial precursors |
There are chemicals in Appendix III of Decree 24 that are Schedule chemicals under the CWC or industrial precursors |
Sections 3, 4, 5, 11, 15.6 |
|
Chemical Consulting |
Consulting on the selection of technology and equipment for chemical projects; consulting on chemical safety and security |
Sections 9.1, 15.1 |
⚑ Enterprises that only use chemicals for their production (not selling) often think that they are not governed by the chemical law. In fact, depending on the type and volume of chemicals, enterprises may still have to fulfill the obligations of declaration of imported chemicals, import licenses and declaration of the purpose of use of Chemical that need the Chemical Safety Regulation, Chemical Safety Training, Chemical Incident Prevention and Response Plan/Measures and reporting.
1. SYSTEMATIC OVERVIEW OF DOCUMENTS IN THE FIELD OF CHEMICALS
Vietnam's current chemical legal system is mainly governed by the Law on Chemicals No. 69/2025/QH15 (replacing the Law on Chemicals 2007) which takes effect from January 1, 2026, including 7 chapters, 48 articles and the following guiding decrees, resolutions and circulars:
|
Legal documents |
Related content |
Effective Date |
|---|---|---|
|
Law on Chemicals No. 69/2025/QH15 dated 14/06/2025 of the National Assembly ("Law on Chemicals") |
Chemical Law - The main legal framework for Vietnam's chemical legal system |
01/01/2026 |
|
Decree No. 24/2026/ND-CP dated January 17, 2026 of the Government regulating the list of chemicals governed by the Law on Chemicals ("Decree 24") |
List of chemicals (Appendices I - IV) |
17/01/2026 |
|
Decree No. 25/2026/ND-CP dated January 17, 2026 of the Government detailing and measures to organize and guide the implementation of a number of articles of the Law on Chemicals on development of the chemical industry and chemical safety and security ("Decree 25") |
Chemical Industry Development & Chemical Safety and Security |
17/01/2026 |
|
Decree No. 26/2026/ND-CP dated January 17, 2026 of the Government detailing and guiding the implementation of a number of articles of the Law on Chemicals on management of chemical activities and hazardous chemicals in products and goods ("Decree 26") |
Management of chemical activities (licensing, import and export, declaration) and hazardous chemicals in products and goods |
17/01/2026 |
|
Decree No. 275/2026/ND-CP dated 08/07/2026 of the Government stipulating penalties for administrative violations in the field of chemicals and industrial explosives ("Decree 275") |
Sanctioning of administrative violations in the field of chemicals |
25/08/2026 |
|
Circular No. 01/2026/TT-BCT dated January 17, 2026 of the Ministry of Industry and Trade detailing and guiding the implementation of a number of articles of the Law on Chemicals and Decree No. 26/2026/ND-CP of the Government detailing and guiding the implementation of a number of articles of the Law on Chemicals on management of chemical activities and hazardous chemicals in products and goods ("Circular 01") |
Guidance on Decree 26: decentralization of procedures, licensing forms, SDS/GHS |
17/01/2026 |
|
Circular No. 02/2026/TT-BCT dated January 17, 2026 of the Ministry of Industry and Trade stipulating a number of measures to implement the Law on Chemicals and Decree No. 25/2026/ND-CP of the Government detailing and measures to organize and guide the implementation of a number of articles of the Law on Chemicals on development of the chemical industry and chemical safety and security ("Circular 02") |
Guidance Decree 25: consultancy certificate, Chemical Incident Prevention and Response Plan/Measures, appraisal form |
17/01/2026 |
|
Resolution No. 19/2026/NQ-CP dated 29/04/2026 of the Government on reducing, decentralizing and simplifying administrative procedures and business conditions under the management of the Ministry of Industry and Trade ("Resolution 19") |
Reducing and decentralizing administrative procedures in the field of chemicals |
29/4/2026 (Expires from 01/3/2027 or earlier) (Contents related to the chemical sector take effect from 29/5/2026) |
|
Circular No. 26/2026/TT-BCT dated 20/05/2026 of the Ministry of Industry and Trade amending and supplementing a number of regulations on decentralization, reduction and simplification of administrative procedures in the fields under the management of the Ministry of Industry and Trade ("Circular 26") |
Amendments to Circular 01 and Circular 02 on reduction and simplification of administrative procedures in the field of chemicals |
29/05/2026 |
⚑ Decree 24 does not have a detailed guidance circular. The list of chemicals is periodically reviewed by state management agencies before June 30 every year; enterprises need to monitor the amendments and supplements to promptly update their chemical classification results.
⚑ For convenient lookup, enterprises can use consolidated documents announced by competent agencies (for example, consolidated document No. 32/VBHN-BCT, thereby consolidating the contents of Circular 01 and Circular 26); however, when carrying out administrative procedures, enterprises need to compare with the original documents and check the validity status at the time of application.
In addition, the Ministry of Industry and Trade is developing a Draft Decree amending and supplementing 3 Decrees guiding the Law on Chemicals No. 69/2025/QH15:
|
Adjusted text |
Adjustments |
|---|---|
|
Decree 24/2026/ND-CP |
Replacing all Appendices I, II, III and amending Appendix IV. The list of basic chemicals (Appendix I) is reduced from 39 to 27 substances; adding HS code columns for lists; amending the criteria for classifying mixtures that need to be managed (separating groups 1 and 2, adding classification rules according to higher management groups). Some chemicals are transferred from Chemical in need of Chemical to Chemical with conditions to simplify administrative procedures. Amend some information in Appendix IV in the direction of being suitable for risk management and subjects at risk to be managed. |
|
Decree 25/2026/ND-CP |
- Excluding some products from the scope of regulation of Chapters V, VI, VII because they have been managed according to specialized laws; replacing Appendix I (certificate form) and Appendix III (list of training disciplines). - For regulations on chemical consultancy certificates: expand the subjects to be granted A1 certificates; supplement conditions for organizations providing consultancy on technology and equipment selection for chemical projects; simplify conditions for granting certificates to individuals; supplement conditions for organizations providing chemical safety and security consultancy; simplify and shorten the order and procedures for granting consultancy certificates. - For regulations on chemical safety and security: concretize conditions for factories and warehouses. - For regulations on specialized chemical safety training: excluding individuals at scientific and technological organizations and educational institutions from subjects required to participate in specialized chemical safety training. - For regulations on prevention and response to chemical incidents: supplementing requirements for dossiers of request for appraisal of the Plan; clarifying cases in which Chemical Incident Prevention and Response measures must be adjusted. |
|
Decree 26/2026/ND-CP |
Exclude some products from Chapter II; decentralize the authority to issue certificates and licenses to provincial People's Committees: Reduce many conditions and components of dossiers; Simplify dossier submission procedures; amend the entire Article 21 on exemption cases; amend the obligation to declare the purpose of use of chemicals and announce products containing hazardous chemicals; revise the reporting regime on the specialized database of chemicals; clearly stipulate cases of exemption from issuance of certificates and licenses; complete regulations on revocation, registration of new licenses, data management and information disclosure; handle cases of returned exports and simplify import and export licensing procedures for chemicals subject to special control and prohibited chemicals. |
Regarding the time of application: all three Draft Decrees amending and supplementing have not yet finalized the effective date. The contents of the Handbook reflect the regulations that take effect at the time of promulgation; the drafts are not yet valid and the contents may continue to change.
2. THREE GROUPS OF CHEMICALS SUBJECT TO SPECIFIC CONTROL AND OTHER GROUPS OF CHEMICALS (Article 9 of the Law on Chemicals | Articles 7-18 of Decree 26)
This is a core change compared to the 2007 Law on Chemicals: The Law on Chemicals no longer uses the concept of "chemicals restricted from production and trading" but establishes three groups of chemicals subject to specific control according to the level of risk, in addition to the group of ordinary chemicals:
|
Criteria |
Conventional/Other Chemicals |
Conditional Chemicals |
Chemical needs special control |
Prohibited chemicals |
|---|---|---|---|---|
|
Concept |
Chemical is not on the List of Conditional Chemicals, List of Chemicals that needs special control or List of prohibited Chemicals |
Dangerous Chemical in the List of Conditional Production and Business Regulations issued by Government |
Dangerous Chemicals are on the List of Chemicals that need to be controlled by the Government, including Chemicals that need to be controlled according to international commitments and Chemicals that need to be controlled to protect national defense, security, social safety, etc. |
Dangerous Chemical is on the List of prohibited minerals and minerals issued under the Law on Investment |
|
Specific categories |
Specialized Chemical Database |
Appendix II of Decree 24 |
Appendix III of Decree 24 |
Appendix II of the Law on Investment 2025 |
|
Additional Requirements |
Comply with general requirements for classification, labeling, SDS, chemical safety (for hazardous chemicals) and declaration of imported chemicals (if applicable) |
Factories and warehouses that meet National Technical Regulation and National Standard; persons subject to chemical safety with a university degree (production) or intermediate level (business) majoring in chemistry or higher; Chemical Incident Prevention and Response Plan/Measures depending on the storage threshold |
Requirements for conditional Chemicals; plans to control and prevent Chemical losses; commitments to use for non-prohibited purposes |
Only used for scientific research, medical research, natural disaster prevention and control, criminal investigation |
⚑ Enterprises need to review the list of chemicals used by themselves to determine the right level of application. Incorrect classification can lead to missing/wrong types of licenses.
3. FOUR APPENDICES TO THE LIST OF CHEMICALS (PROMULGATED TOGETHER WITH DECREE 24)
|
Appendix |
Contents |
Base |
|---|---|---|
|
Appendix I |
Basic chemical — key industry (not yet produced/not enough domestic production); as the basis for investment incentives |
Clause 2, Article 6 of the Law on Chemicals |
|
Appendix II |
Conditional Chemical (substance/mixture with ≥1 hazardous properties according to GHS) |
Point a, Clause 1, Article 9 of the Law on Chemicals |
|
Appendix III |
Chemical needs special control — including the chemical groups listed in Appendix III of Decree 24, including CWC Schedule chemicals, industrial precursors and other hazardous chemicals; licensing authority depends on the chemical group and type of activity |
Point a, Clause 2, Article 9 of the Law on Chemicals |
|
Appendix IV |
Chemical must prepare a Chemical Incident Prevention and Response Plan — chemicals in excess of the threshold specified in Table A, Table B |
Clause 2, Article 37 of the Law on Chemicals |
⚑ Enterprises must compare the list of chemicals in stock/use with these 4 Appendices to determine their corresponding legal obligations. This is the first step to be reviewed.
Chemical self-classification process (recommended)
To accurately determine legal obligations, enterprises should carry out the classification in the following order, starting from the group with the highest level of control:
|
Step |
Contents of implementation |
Source |
Results/obligations incurred |
|---|---|---|---|
|
1 |
Make a list of all chemicals and mixtures being produced, traded, imported, stored and used; collect SDS, CAS number, composition and content of each substance in the mixture, HS code |
Supplier's SDS; purchase records; customs declarations |
Internal chemical catalogue as the basis for next steps |
|
2 |
Compare each substance and mixture with the List of prohibited substances and the List of substances requiring procurement |
Appendix II of the Law on Investment 2025; Appendix III of Decree 24 |
If it belongs to: apply the regime of management of prohibited Chemical/Chemical requiring special control (Sections 4, 5); identify Group 1/Group 2, Table chemicals, industrial precursors |
|
3 |
Cross-check against the List of Chemicals Subject to Conditional Production and Trading |
Appendix II of Decree 24 |
If belonging: must have a certificate of eligibility for production/business (Section 4), except for cases of exemption |
|
4 |
Consider exemptions according to content, purpose and form of operation |
Article 21 of Decree 26; Part C, Section 2, Appendix III of Decree 19 |
Conclusion on whether or not to apply for a certificate or license; keep a dossier proving the grounds for exemption (Section 13.3) |
|
5 |
Determine the largest inventory volume at each facility and compare it with the thresholds in Table A and Table B |
Appendix IV of Decree 24 |
Determining whether to make a Chemical Incident Prevention and Response Plan (subject to appraisal) or Chemical Incident Prevention and Response Measures (self-promulgated) (Section 10) |
|
6 |
Determination of general obligations: declaration of imported chemicals, classification and labeling according to GHS, SDS, training, reporting |
Article 6 of Decree 26; Chapter IV of the Law on Chemicals; Decree 25 |
Making a list of obligations and assigning a focal point for implementation (Section 14) |
⚑ Classification must be carried out for each constituent substance of the mixture, not just based on the trade name of the product. Classification results should be updated when changing suppliers, product formulations or when the chemical list is amended or supplemented.
4. TYPES OF CHEMICAL ACTIVITY LICENSES/CERTIFICATES
|
|
Type of License/Certificate |
Eligibility |
Issuing Authority |
Duration |
|---|---|---|---|---|
|
Conditional Chemical |
Certificate of Eligibility for Production of Conditional Chemicals |
Production organization |
Provincial People's Committees |
5 years |
|
Certificate of Eligibility for Trading in Conditional Chemicals |
Business Organization |
Provincial People's Committees |
5 years |
|
|
Chemicals need special control |
License for Production/Trading of Chemicals Subject to Special Control (Group 1) |
Production/Business Organization |
Department of Chemicals (Ministry of Industry and Trade), including the case of organizing simultaneous activities with Chemical Group 1 and Group 2 |
5 years |
|
License for Production/Trading of Chemicals Subject to Special Control (Group 2) |
Production/Business Organization |
Provincial People's Committees (Clause 4, Article 13 of Decree 26; Article 4 of Circular 01) |
5 years |
|
|
License for Export/Import of Chemicals Subject to Special Control |
Production/business organization, use |
Provincial People's Committees according to the decentralization mechanism of Decree 19 from May 29, 2026 |
6 months; extended 01 time |
|
|
Chemical banned |
License for Production of Prohibited Chemicals |
Special Organizations |
Ministries/ministerial-level agencies |
12 months |
|
License for Import of Prohibited Chemicals |
Special Organizations |
Provincial People's Committees according to the decentralization mechanism of Decree 19 from May 29, 2026 |
6 months |
|
|
Certificate of eligibility for Chemical storage service |
Organizing the provision of storage services |
Provincial People's Committees according to the decentralization mechanism of Decree 19 from May 29, 2026 |
05 years from the date of issuance; regulations on certificates apply from 01/7/2026 |
|
⚑ Article 18 of the Law on Chemicals and Article 21 of Decree 26 stipulate cases of exemption from issuance of certificates and licenses (for example, mixtures containing chemicals subject to management with content not exceeding the prescribed threshold; leveling, blending for internal production). During the effective period of Decree 19, exemptions are applied according to Part C, Section 2, Appendix III of Decree 19 (see Section 13.3). The authority and exemption mechanism under Decree 19 are transitional; enterprises need to check the replacement document before carrying out procedures from March 1, 2027, or earlier if the replacement document takes effect before that time.
Process of issuance of certificates of eligibility for production and trading of conditional chemicals, licenses for production and trading of chemicals requiring special control
|
Step |
Conditional Chemical (Article 9 of Decree 26) |
Chemical needs special control (Article 13 of Decree 26) |
|---|---|---|
|
1. Prepare documents |
Prepare 01 set of dossier according to Clause 1, 2 or 3, Article 9 of Decree 26 depending on the type of certificate you want to issue. |
Prepare 01 set of dossier according to Clauses 1, 2 or 3, Article 13 of Decree 26 depending on the type of license to be issued. |
|
2. Submit the application |
Submit the dossier (in person/post office/online public service) to the provincial People's Committee where the organization is headquartered or the provincial People's Committee where the organization locates the chemical production and business establishment. |
Submit the dossier (directly/post/online public service) to the licensing authority: Department of Chemicals (Ministry of Industry and Trade) for Chemical Group 1 or both Group 1 and Group 2; Provincial People's Committee where the organization is headquartered for Group 2 Chemical. |
|
3. Supplementation of dossiers |
In case the dossier is incomplete and invalid, within 03 working days from the date of receipt of the dossier, the provincial-level People's Committee where the dossier is submitted shall notify the organization to supplement and complete the dossier. The time for completing the dossier is not included in the time limit for issuance of the certificate. |
In case the dossier is incomplete and invalid, within 03 working days from the date of receipt of the dossier, the agency competent to issue the License shall notify the organization of supplementation and completion of the dossier. The time for completing the dossier shall not be included in the time limit for issuance of the License. |
|
4. Issuance of certificates and permits |
In case the dossier is valid, the provincial-level People's Committee of the locality where the dossier is submitted and the People's Committee of the locality where the chemical production and business establishment is located shall coordinate in reviewing the dossier, examining the actual conditions and granting a certificate of eligibility to the organization within the prescribed time limit. - In case the chemical production and trading establishment of the organization is located in the locality where its head office is located, the time limit is 12 working days. - In case the organization's production and business establishment is located in a locality different from the locality where the head office is located, the time limit is 15 working days. In case of refusal to issue a certificate, a written reply must be given, clearly stating the reason. |
In case the dossier is valid, the agency competent to issue the License shall consider and appraise the dossier, examine the actual conditions and grant the License to the organization within 16 working days (Point c, Clause 5, Article 13 of Decree 26). - During the effective period of Decree 19: the time limit for issuance of new issuance is shortened to 14 working days (see Section 13.3). - For Chemical Group 2 with production, business and storage establishments in localities other than the place where the head office is located: Provincial People's Committees of localities shall coordinate in appraisal according to Article 4 of Circular 01. In case of refusal to grant a license, the competent agency must give a written reply, clearly stating the reason. |
|
5. Duration of Certificates and Licenses |
The certificate is issued for a period of 05 years from the date of issuance. |
The issued license is valid for 05 years from the date of issuance. |
The application dossier for issuance of a Certificate of Eligibility for Conditional Chemical Production and/or Trading comprises the following documents (Clauses 1, 2 and 3, Article 9 of Decree No. 26/2026/ND-CP):
- A written application for a certificate for conditional chemicals;
- Overall drawing of the infrastructure site system; the contents of the drawings must ensure information about the location of each infrastructure; the area and access road to each infrastructure; Papers proving the right to use the land plot for infrastructure construction or the warehouse lease contract that has been granted by a competent agency to be eligible for Chemical storage services;
- Notification of the results of inspection of the acceptance of the completion of work items and construction works (in accordance with the law on construction);
- Explanation of technological processes and safe operations in conditional chemical production (For dossiers of application for conditional Chemical business licenses, this document is not required);
- A copy of the decision approving the plan for prevention and response to chemical incidents issued by the competent authority or the decision on promulgation of measures to prevent and respond to chemical incidents of the chemical manufacturer;
- A copy of the chemistry degree of the person in charge of chemical safety of the manufacturing facility; (For production certificates, production and business certificates are university degrees or higher; for business certificates, intermediate degrees or higher)
- A copy of the Decision on recognition of the results of chemical safety inspection and training of organizations and individuals as prescribed in Article 32 of the Government's Decree No. 25/2026/ND-CP dated January 17, 2026 detailing and measures to organize and guide the implementation of a number of articles of the Law on Chemical Industry Development and Chemical Safety and Security;
- Chemical safety sheets of chemicals subject to the issuance of certificates.
The dossier of application for a License for Production/Business of Chemical needs a License: Includes the components corresponding to the dossier of application for a License for a conditional Chemical and supplements the following documents:
- The plan for prevention and control of loss of Chemical needs special control and the business commitment for Chemical needs special control for purposes that are not prohibited.
⚑ Time limit for processing (counting from the date of receipt of a complete and valid dossier): (i) Conditional Certificate of Production/Business License: 12 working days if the production, business establishment and the head office are in the same locality; 15 working days if they are in different localities; (ii) License for Production/Business of Chemical: 16 working days according to Decree 26, shortened to 14 working days during the effective period of Decree 19 (see Section 13.3).
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