Vietnam Publishes New Law on Chemicals 
On June 14, 2025, the National Assembly of Vietnam passed Law on Chemicals No. 69/2025/QH15 (“the Law”) with 92.47 percent approval. Comprising seven chapters and 48 articles, the Law fully replaces the Law on Chemicals of 2007 (No. 06/2007/QH12) and will enter into force on January 1, 2026.
Key Amendments
- Revised definitions of regulated chemical categories
- Management rules for “conditional chemicals” and the newly introduced “chemicals under special management”
- Expanded scope of chemicals subject to import declaration
- Hazard classification and labeling requirements
- Regulations on hazardous chemical management
- Introduction of new prohibited acts
- Procedures for new chemical registration
- Protection of confidential business information
- Control of chemicals contained in products
- Designation of priority chemical industry sectors
This Part 1 article outlines changes related to definitions and classifications of regulated chemicals.
Definitions of Regulated Chemicals
The Law introduces changes to regulated chemical categories, as summarized below. Specific chemical lists are not included in the Law but will be published in subsequent decrees.
| Chemical Category | Amendment in 2025 Law |
|---|---|
| Hazardous Chemicals | Definition unchanged, but classification criteria revised |
| Toxic Chemicals | Abolished; replaced by concept of “Toxic Substances” |
| Conditional Chemicals | No change |
| Restricted Chemicals | Renamed “Chemicals under Special Management” |
| Prohibited Chemicals | No change |
| Chemicals Requiring Accident Prevention Plans | No change |
| Declared Chemicals | Abolished |
| New Chemicals | Definition and scope clarified |
Notably, “Hazardous Chemicals” are no longer classified under GHS criteria but are designated as hazardous if determined by the head of the relevant national chemical authority to pose at least one hazard.
Toxic Substances are newly defined as:
“Chemicals that may, through their chemical action, affect vital human functions and potentially cause death, temporary impairment, or permanent disability, as determined by government-specified criteria.”
Management Provisions for Conditional Chemicals and Chemicals under Special Management
A notable feature of the 2025 Chemical Law is the introduction of the term “chemicals under special management”, which replaces the former category “restricted chemicals used in the industrial sector.” This shift significantly broadens the scope of regulated substances.
The regulatory framework for both “conditional chemicals” and “chemicals under special management” largely mirrors the current system. However, companies must pay close attention to the licensing and documentation requirements outlined below:
| Activity | Conditional Chemicals | Chemicals under Special Management |
|---|---|---|
| Manufacture and Trade | Must obtain a “Certificate of Eligibility for the Manufacture and Trade of Conditional Chemicals.” Valid for five years from date of issuance. |
Must obtain a “Permit for the Manufacture and Trade of Chemicals under Special Management.” Valid for five years from date of issuance. |
| Import and Export | No permit required. Only chemicals listed in the eligibility certificate may be exported or imported by eligible firms. |
Import and export permits required. Companies may only trade chemicals listed in their permits. Permits are issued per invoice and valid for six months. One extension allowed for up to six additional months. |
| Sales | Not applicable. | Sellers must prepare a “Sales Management Log for Chemicals under Special Management” for each delivery. This log replaces the former log for toxic chemicals. It now applies exclusively to chemicals under special management. |
| Use | Not applicable. | Before first use or when changing the purpose of use, companies must disclose the chemical type and intended use in the national chemical database. |
| Storage | Must either establish an in-house chemical storage facility or utilize certified chemical storage services (Certificate valid for five years). | Same as conditional chemicals — either own facility or certified third-party storage services required (Certificate valid for five years). |
Scope of Chemicals Subject to Import Declaration
All imported chemicals must be declared under the new regulations, significantly expanding the scope of compliance. The previous concept of “declared chemicals” has been abolished. Import declaration is mandatory for all chemicals, regardless of listing status, unless falling under the following exemptions:
- Chemicals under special management imported by certified entities
- Prohibited chemicals imported by authorized organizations
- Other exemptions as specified by government regulations
Revised Regulations on Chemical Accident Prevention and Response Plans
Under the amended law, new projects must prepare a chemical accident prevention and response plan starting from the feasibility study (FS) stage. Even if a project is exempt from this requirement, operators must still prepare preventive action measures before beginning operations or storing chemicals.
Additionally, any entity transporting hazardous chemicals must—before initiating transport—prepare and promulgate preventive measures for chemical accidents during transportation, and carry them onboard throughout the transport process.
Addition of Prohibited Acts
Manufacturers, traders, and users of chemicals must strictly avoid the following prohibited acts:
- Failing to provide or deliberately providing incomplete, untimely, or false information about chemical hazards, products containing hazardous chemicals, incidents of chemical loss or leakage, or chemical accidents.
- Using unidentified chemical sources or using chemicals for any of the following prohibited purposes:
- Food production or processing
- Pharmaceutical or cosmetic manufacturing
- Preparation of animal feed or aquaculture feed
- Pesticide or fertilizer production
- Production, storage, or distribution of consumer chemical products
Transitional Provisions
- Enterprises that obtained permits to manufacture, trade, or import/export chemicals (including restricted chemicals, industrial precursors, designated substances) before the new law’s effective date may continue operations until their permits expire.
- Enterprises that received certificates for manufacturing or trading conditional chemicals prior to enactment may operate until December 31, 2027.
- Regulations concerning certificates for chemical storage service providers take effect on July 1, 2026.
The full Vietnamese text of the Law on Chemicals (69/2025/QH15) can be accessed here:
https://datafiles.chinhphu.vn/cpp/files/vbpq/2025/7/69qh.signed.pdf
