Vietnam Vietnam partially amends ODS management

HFC management rules newly added

On March 16, 2020, the Vietnamese Ministry of Industry and Trade (MOIT) published “Circular No. 05/2020/TT-BCT on amendment and supplement of some articles of ‘Joint Circular No. 47/2011/TTTL-BCT-BTNMT on the Control of Imports, Temporary Imports and Re-exports of Ozone depleting substances in accordance with the Montreal Protocol’ ” (hereinafter referred to as the “Circular”). The Circular stipulates a list of HCFC substances, import quotas for HCFC and HFC substances, and import procedures for HFC substances. The Circular took effect from May 1, 2020.

The original text of the Circular can be downloaded from the following URL: 1587178176823_VB_Thong%20tu%2005.2020.TT. BCT%20sua%20doi%20thong%20tu%20tu%2047%20da%20ky %20ngay%2016.3.2020.docx/b213a91d-9c9c-4f7f -9bb6-6043077ea000

The main amendments made by the Circular are as follows:

  • Annex I of Joint Circular No. 47/2011/TTTL-BCT-BTNMT was replaced by Annex I of the Circular.
  • HFC substances listed in Annex IIa and IIb of the Circular were newly added into item 3 of Article 1 of Joint Circular No. 47/2011/ TTTL-BCT-BTNMT.
  • The import quotas for HCFC substances in Annex I for the period 2020-2028 are shown in the table below (unit: ton).
Year 2020 2021 2022 2023 2024 2025 2026 2027 2028
HCFC 2600 2600 2600 2600 2600 1300 1300 1300 1300
  • The import quotas during 2020-2028 for HFC substances belonging to Annex IIa and IIb are shown in the table below (unit: ton)
    Import quotas for HFC substances after 2023 are the total amount of the average import volume between 2020-2022 and 65% of the base consumption of HCFC substances, and will be promulgated by MOIT. For the years 2024-2028, the import quotas will be the same as in 2023. The quotas will be calculated by CO2 equivalent based on the provisions of the Kigali Amendment of the Montreal Protocol.
Year 2020 – 2022 2023 2024 – 2028
HFC No limit
To set the base import quotas
The total amount of the average import volume for 2020-2022 and 65% of the base consumption of HCFC substances The same amount as 2023
  • The procedure for issuing an import permit for HFC substances shall be subject to Item 2 of Article 4 of Joint Circular No. 47/2011/TTTL-BCT-BTNMT, which was partly amended by 51/2018/TT-BCT. The import application form shall also be prepared in accordance with Annex III of this Circular.
  • The export permit for HFC substances is issued by the MOIT, but its documents and procedures are subject to certain provisions of Item 1 and 2 of Article 9 of Governmental Decree No. 69/2018/ND-CP on detailed guidance for Law on Foreign Trade Control. The export application shall be prepared in accordance with Annex IV of the Circular.
  • Item 3 was newly added into Article 8 of Joint Circular No. 47/2011//TTTL-BCT-BTNMT, which stipulates reporting system of ODS. Importers and exporters of HFC substances are required to submit quarterly and annual reports in accordance with the provisions of Item 1 and 2. In addition, the report format shall be in accordance with Annex V of the Circular.
  • Item 2 of Article 3 of Joint Circular No. 47/2011/TTTL-BCT-BTNMT was deleted.

Author / Responsibility

AOKI Kenji

Senior Consultant, EnviX Ltd.
General Director, E&H Consulting Co., Ltd.

Business Performance

Expertise in EHS (environment, health and safety) consulting in ASEAN region.
- Environmental regulations updating
- Chemical regulations consulting


MSc in Earth Science, The University of Tokyo

AOKI Kenji