On March 5, 2025, the Vietnamese National Assembly unveiled the second draft of the revised Law on Chemicals through the Vietnam Chamber of Commerce and Industry (VCCI) to solicit broad feedback from enterprises. Significantly revised from the initial version released on March 13, 2024, the new draft consolidates the legislation from 11 chapters with 95 articles to 8 chapters with 50 articles. Scheduled to take effect on January 1, 2026, this revision will replace the 2007 Law on Chemicals (06/2007/QH12), marking a transformative shift in Vietnam's chemical management regime.
Key Revisions and Highlights:
Redefined Chemical Classifications
The amendment reorganizes the concept of controlled chemicals. The definition of hazardous chemicals remains unchanged, but the classification principles have been revised; the concept of toxic chemicals has been eliminated, introducing a new concept of toxic substances; the definition of conditional chemicals remains the same; restricted chemicals have been replaced by specially controlled chemicals; the definitions of prohibited chemicals and chemicals requiring an accident prevention plan remain unchanged, but the category of mandatory declaration chemicals has been removed, adding a clear definition and scope for new chemicals.
Updated Hazard Classification and Labeling Standards
Chemical classification will now align with both the Globally Harmonized System (GHS) and new technical standards from Vietnam's Ministry of Industry and Trade, requiring enterprises to update labeling and classification practices.
Enhanced Management Mechanisms
The amendment introduces the concept of specially controlled chemicals, replacing the original restricted chemicals, covering substances controlled under international treaties approved by Vietnam. It also details the licensing and documentation requirements for the production, trade, import, and export of conditional chemicals, specially controlled chemicals, and prohibited chemicals. For example, production and business licenses for conditional chemicals are valid for 5 years from the date of issuance. Production and trade licenses for specially controlled chemicals are also valid for 5 years from the date of issuance, while production licenses for prohibited chemicals are valid for 12 months from the date of issuance. Import and export licenses for specially controlled chemicals are issued per invoice with an initial validity of 6 months. If import or export activities are not completed within the validity period, the license can be extended once for up to an additional 6 months. Import licenses for prohibited chemicals are issued per batch of imported goods with a validity of 6 months. These detailed provisions provide a clearer legal basis for chemical management and help strengthen regulatory efforts.
Expanded Scope of Import Declarations
Article 13, Clause 5 of the draft states that all imported chemicals must be declared, eliminating the previous category of chemicals requiring declaration, significantly expanding the range of chemicals that need to be declared. This adjustment further strengthens the supervision of the chemical import process, helping to comprehensively grasp the types and quantities of imported chemicals and better prevent potential risks.
Transitional Provisions to Ensure Smooth Transition
To ensure smooth implementation of the law, the amendment includes transitional provisions. Enterprises already permitted to produce, trade, or import chemicals before the revised law takes effect can continue their operations under the existing licenses until they expire; chemical storage operators must develop accident prevention and emergency response plans by December 31, 2027. Facilities that have already been approved for chemical accident prevention and response plans before the revised law takes effect will continue to operate under the approved plans.
Strengthening of Chemical Safety Management
The amendment adds several provisions for chemical safety management. For instance, organizations and individuals engaged in chemical operations must ensure that their facilities meet the technical requirements for chemical safety, staff qualified chemical safety professionals, and provide specialized chemical safety training for workers. It also sets out requirements for the development, approval, implementation of chemical accident prevention and emergency plans, and the establishment of emergency response equipment and capabilities. These measures further strengthen chemical safety management, enhancing safety levels during the production and operation of chemicals, protecting public health, and ensuring environmental safety.
Enhanced Management of Chemical Information
The amendment emphasizes the importance of chemical information management. Units and individuals producing or importing hazardous chemicals must compile safety data sheets before use or distribution and are responsible for the accuracy of the information; organizations and individuals engaged in chemical operations must notify relevant parties to reclassify and relabel chemicals upon discovering new hazardous properties. Additionally, it mandates the establishment, operation, and information-sharing mechanisms of a professional chemical database, as well as the requirements for chemical advertising activities.
Regulation of Hazardous Chemicals in Products and Goods
The amendment regulates the management of hazardous chemicals in products and goods. Organizations and individuals producing or importing products and goods containing hazardous chemicals must disclose the content of hazardous chemicals in their products in a professional chemical database before market distribution and publicly post this information on electronic information portals or at sales locations. It also clarifies the supervisory and inspection responsibilities of various departments, ministerial-level agencies, and provincial People's Committees.
This comprehensive revision reflects Vietnam's commitment to aligning chemical management with international standards while addressing domestic industrial needs. As Vietnam's chemical market expands under the Belt and Road Initiative, the updated framework emphasizes sustainable development through strengthened health and environmental protections.
In light of the publication of this draft amendment of Vietnam's Law on Chemicals, the CIRS Group advises related enterprises to closely monitor the latest developments in regulations and prepare accordingly. As the Belt and Road Initiative progresses, Vietnam's chemical market share is expanding, and chemical management is becoming more comprehensive. Enterprises should familiarize themselves with the new regulatory requirements, especially regarding chemical classification, labeling, reporting, and safety management. Additionally, it is advisable for enterprises to strengthen internal training to ensure that relevant personnel are well-acquainted with the new regulatory requirements and operational procedures.
