Vietnam Releases Draft Decree on the List of Regulated Chemical Substances under the 2025 Law on Chemicals 
On September 5, 2025, the General Department of Chemicals under the Ministry of Industry and Trade of Vietnam released the draft “Decree on the List of Regulated Chemical Substances Subject to the Law on Chemicals”. Public comments are being accepted until September 14, 2025. The draft decree is scheduled to take effect on January 1, 2026, concurrently with the 2025 Law on Chemicals (No. 69/2025/QH15). Upon its enforcement, the current decrees—Decree No. 113/2017/ND-CP and Decree No. 82/2022/ND-CP—will be repealed.
Overview of Annexes
The draft decree includes five annexes, as follows:
- Annex I: List of Basic Chemicals in Key Chemical Industry Sectors
- Annex II: List of Conditional Chemicals for Manufacture and Trade
- Annex III: List of Specially Controlled Chemicals for Manufacture and Trade
- Annex IV: List of Chemicals Requiring Accident Prevention and Response Planning
- Annex V: List of Educational Fields for Chemical Safety Activities
Annex I: List of Basic Chemicals in Key Chemical Industry Sectors
This list identifies basic chemicals eligible for government incentives, aimed at promoting the development of Vietnam’s domestic chemical industry. The draft decree specifies 91 substances, including their names, CAS Registry Numbers, and chemical formulas.
Annex II: List of Conditional Chemicals for Manufacture and Trade
This list covers chemicals that require a license (certificate of qualification) for manufacture or trade. The draft decree includes 914 substances, with names, HS codes, CAS Registry Numbers, and chemical formulas.
For mixtures, if they contain at least one component listed in Annex II or Annex III and meet any of the following hazard classifications, they are also considered conditional chemicals:
- Physical hazards: Categories 1, 2, 3 or Types A, B, C, and D
- Acute toxicity (via various exposure routes): Categories 2, 3
- Serious eye damage/eye irritation: Categories 1, 2/2A
- Skin corrosion/irritation: Categories 1, 2
- Carcinogenicity, germ cell mutagenicity, reproductive toxicity: Category 2
- Environmental hazards: Category 1
EnviX Comment
Compared to Decree No. 113/2017/ND-CP, the number of regulated substances has increased. One reason is that certain substances currently designated as restricted chemicals (e.g., acryloyl chloride, methanol) have been reclassified as conditional chemicals.
Annex III: List of Specially Controlled Chemicals for Manufacture and Trade
This list includes chemicals that require a permit for manufacture, trade, import, or export. It primarily covers industrial precursors and substances regulated under the Chemical Weapons Convention, the Rotterdam Convention, and the Stockholm Convention. Each entry includes the substance name, HS code, CAS Registry Number, and chemical formula.
For mixtures, if they contain at least one component listed in Annex III and meet any of the following hazard classifications, they are also considered conditional chemicals:
- Acute toxicity (via various exposure routes): Category 1
- Carcinogenicity: Categories 1A, 1B
- Reproductive toxicity: Categories 1A, 1B
- Germ cell mutagenicity: Categories 1A, 1B
EnviX Comment
Under Decree No. 113/2017/ND-CP, these substances were regulated as “restricted chemicals.” The number of substances has decreased in the draft decree. However, certain industrial precursors (e.g., sulfuric acid, toluene), previously classified as Conditional Chemicals, have been changed to Specially Controlled Chemicals. Caution is advised when handling such substances.
Annex IV: List of Chemicals Requiring Accident Prevention and Response Planning
This list identifies chemicals for which accident prevention and response plans must be prepared to mitigate chemical-related incidents. The draft decree specifies 271 substances, including names, HS codes, CAS Registry Numbers, chemical formulas, and maximum storage quantities at a certain time.
Even if a substance is not listed, if it meets the hazard criteria specified in Table 2 of Annex IV and its temporary maximum storage quantity exceeds the threshold, a prevention and response plan is still required. If neither condition is met, a chemical accident prevention and response measure must be prepared instead.
Annex V: List of Educational Fields for Chemical Safety Activities
This list defines academic disciplines required for personnel engaged in chemical management activities at businesses involved in the manufacture, trade, or storage of chemicals, as well as for chemical consulting professionals (primarily in chemical project-related activities). It includes names and codes of chemical-related fields across vocational schools, universities, and graduate programs (master’s and doctoral levels).
Reference
- Full text of the draft decree:
http://cuchoachat.gov.vn/Content/Uploads/files/02_%20Dự%20thảo%20NĐ%20danh%20mục%20hoá%20chất%20quản%20lý%20V10.pdf - Webpage for public consultation:
http://cuchoachat.gov.vn/tin-tuc-su-kien/gop-y-du-thao-ho-so-nghi-dinh-quy-dinh-chi-tiet-mot-so-dieu-cua-luat-hoa-chat-1.html
