Vietnam Chemicals Law 2025: What Factories Need to Know

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Vietnam Chemicals Law 2025 (Law No. 69/2025/QH15) was passed by the National Assembly on 14 June 2025 and takes effect on 1 January 2026 (Article 47(1)). It applies to factories that use chemicals and to companies that import them. Factories need to review these groups of obligations: determining the chemical category (Article 9), import licences and declarations (Article 12), classification, labelling and safety data sheets (Article 23, Article 25), information records (Article 27), and storage and incident response (Article 14, Article 37, Article 38).

Why factories that use and import chemicals need to review their practices from 2026

Law No. 69/2025/QH15 takes effect on 1 January 2026. On the same date, Law No. 06/2007/QH12 on Chemicals expires, except for the transitional provisions in Article 48 (Article 47(1) and (3)). The law governs both "chemical use" and "chemical import". Chemical use means using chemicals to make other products or goods, to provide services, or for other lawful purposes (Article 2(19)). Importing to supply the market for profit counts as "chemical trading" (Article 2(18)). A factory that imports conditional chemicals for its own use is covered by a separate provision (Article 12(2)(c)).

The law is already in force, so processes built on habit need to be checked against each of its requirements. The points most likely to be out of line are:

  • records on hazardous chemicals must be kept for at least 03 years from the date the activity involving that chemical ends (Article 27(1));
  • the safety data sheet must be available at the place of storage (Article 25(2));
  • imported chemicals must be declared, except in the cases the law lists (Article 12(6));
  • storage areas need warning information, internal rules, a signalling system and emergency response equipment (Article 14(1));
  • licences and certificates already issued may continue to be used only within the transitional period (Article 48(2) and (3)).

If records, declarations and warehouse management still run as before, a factory may be missing one of these elements without realising it. Some requirements are still waiting for implementing documents, so the review should be done article by article, not postponed until an inspection or an incident.

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What Vietnam Chemicals Law 2025 changes for factories

How the law classifies chemicals (applies to both groups):

  • Hazardous chemicals are chemicals that harm people, facilities, property or the environment and have at least one hazardous property under the classification principles issued by the central state management authority for chemicals (Article 2(4)).
  • Conditional chemicals: hazardous chemicals on a list issued by the Government, permitted to be handled if conditions are met (Article 9(1)(a)).
  • Special-control chemicals: these include chemicals that must be controlled to implement international treaties on chemicals to which Vietnam is a party, and chemicals that may harm national defence, security, social safety, people, property or the environment (Article 9(2)(a)).
  • Prohibited chemicals: those on the list of prohibited chemicals and minerals issued under the Law on Investment (Article 9(3)(a)).
  • New chemicals: substances not yet in the National Chemicals List or in foreign lists recognised by Vietnam. They must be registered before being put into use or circulation (Article 20(1)) and are then managed as special-control chemicals (Article 22(1)).

Factories that use chemicals:

  • Declaration before use. For special-control chemicals, the chemical type and purpose of use must be declared on the specialised chemical database before first use or before a change of purpose (Article 15(2)(b)), and quantities must be strictly controlled (Article 9(2)(c)).
  • Prohibited chemicals may be used only by qualified organisations, which must keep a tracking register (Article 15(3); Article 9(3)(d)).
  • Buyers of hazardous chemicals must require the seller to provide the safety data sheet and keep it at the place of storage (Article 25(2)).
  • A person with professional responsibility for chemical safety is required; the workers concerned must be trained and equipped with protective gear (Article 33(2) and (3)), with periodic training (Article 36(1)).
  • Hazardous chemical records include scientific name, trade name, quantity produced, imported, used and disposed of, purpose of use, and classification under the GHS, the Globally Harmonized System of Classification and Labelling of Chemicals (Article 27(2)).
  • Incident response plan or measures. Chemicals on the list and above the thresholds set by the Government need an approved incident prevention and response plan, meaning a plan approved by a state authority, before storage (Article 37(1)(b)). All other cases need measures issued by the facility itself (Article 38(1)(b)). Expanding capacity or changing the production line requires an adjustment before the item goes into operation (Article 39(2)).
  • Prohibited chemicals must be stored in a separate warehouse or area (Article 14(4)(c)).

Companies that import chemicals:

  • Conditional chemicals are imported under a certificate of eligibility for chemical trading; a user may import for its own use (Article 12(2)).
  • Special-control chemicals need an import licence issued per invoice, valid for 06 months and extendable once, for no more than 06 months (Article 12(4)(b) and (c)).
  • Prohibited chemicals need a licence issued per consignment, valid for 06 months, and may be imported only as stated in the licence (Article 12(5)). They may not be temporarily imported, re-exported, transferred or transited (Article 9(3)(đ)).
  • Declaration of imported chemicals is mandatory, except for special-control chemicals, prohibited chemicals and cases the Government exempts (Article 12(6)). The groups exempt from declaration still need an import licence.
  • Producers and importers must classify and label before putting chemicals into use or circulation and are responsible for the results (Article 23(1)), and must prepare safety data sheets and update them when there are changes (Article 25(1) and (3)).

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What determines the specific obligations of each factory

The factory's role. A factory that only uses chemicals has the obligations in Article 15 and Article 33, plus Article 14 if it stores chemicals. Its main safety data sheet obligation is then to request the sheet from the seller and keep it (Article 25(2)). If it imports for its own use, it has additional obligations under Article 12, Article 23 and Article 25. If it manufactures, trades or repackages, it must meet the conditions in Article 10 and Article 11. The more roles, the more obligations.

The chemical category under the law. A chemical that is not conditional, special-control or prohibited has no separate licence requirement under Article 9, but the general obligations on safety and on classification and labelling still apply (Article 33, Article 23). The conditional group adds a certificate and the requirements in Article 9(1)(b). The special-control group adds declaration of the purpose of use, an import licence per invoice, and quantity control (Article 15(2), Article 12(3), Article 9(2)). The prohibited group carries the highest level of obligation: a tracking register, a separate warehouse and a licence per consignment (Article 9(3), Article 14(4), Article 12(5)). Mixtures that contain a listed substance but have a low-level hazard classification are exempt from certificates and licences (Article 18(1)(a)), so their obligations are reduced; the specific list is issued by the Government.

Storage, quantity and hazard level. Storing chemicals that are on the list and above the thresholds set by the Government requires an approved Plan, and civil facilities must also hold an annual drill (Article 37(1)(b), Article 39(3)). Hazardous chemicals outside that scope need only self-issued Measures (Article 38(1)(b)). With no storage, or storage below the threshold, this obligation is reduced. The list and thresholds are not yet in the law (Article 37(2)).

Repackaging and blending purpose. Repackaging and blending that directly serve the organisation's own internal production are exempt from the licences and certificates in Article 18(1)(b), so obligations are reduced. In addition, if a product or good contains hazardous chemicals, Article 31 and Article 32 also apply, and whether existing licences are in place will be governed by Article 48.

What factories should do before and after the law takes effect

1 January 2026 has already passed, so the steps below are a review to be done now. The law does not prescribe a "review procedure"; the order below follows the obligations in the law.

  1. Prepare an inventory of chemicals in use and being imported, with quantity, purpose of use and hazard classification under the GHS, matching the record content in Article 27(2).
  2. Check each chemical against the conditional, special-control and prohibited groups (Article 9). The lists are issued by the Government, and the prohibited list under the Law on Investment; the full text of the law does not name the chemicals.
  3. Check the safety data sheet (SDS) of each hazardous chemical: whether it is complete, whether it is kept at the place of storage, and whether it is updated when content changes (Article 25). A COA is a batch certificate of analysis; the law does not regulate it, so a COA is only an internal reference document, not a legal requirement.
  4. Check labels and packaging (Article 23, Article 24) and the warehouse, warning signs and emergency equipment (Article 14(1)).
  5. Check the personnel responsible for safety and periodic training (Article 33, Article 36).
  6. Check the incident response Plan or Measures. A plan approved or issued before the law took effect is still valid (Article 48(4)).
  7. Review existing licences and certificates against the transitional periods: licences already issued remain valid until they expire (Article 48(2)), and certificates of eligibility remain valid until the end of 31 December 2027 (Article 48(3)). Chemicals that are on the special-control or conditional list under this law but were not on the corresponding list under Law No. 06/2007/QH12 must meet the law before 31 December 2026 (Article 48(2) and (3)).
  8. Importers determine whether each chemical needs an import licence or falls under declaration (Article 12(6)) and prepare classification, labelling and safety data sheets before putting chemicals into use.
  9. If using special-control chemicals, declare the chemical type and purpose before first use or before a change of purpose (Article 15(2)(b)).

Items awaiting implementing documents include: the conditional and special-control lists (Article 9), the list and thresholds for the Plan (Article 37(2)), the exemption list (Article 18), other cases of exemption from declaration (Article 12(6)(c)), the content and form of the safety data sheet (Article 25(4)) and guidance on declaring chemical type and purpose of use (Article 15(5)). The law assigns these to the Government and the management authorities; factories should look up the documents already issued instead of guessing their content.

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Frequently asked questions

When does Vietnam Chemicals Law 2025 take effect?

The law takes effect on 1 January 2026 (Article 47(1)). The provision on the Certificate of eligibility for chemical storage services (Article 14(5)) takes effect separately on 1 July 2026 (Article 47(2)). Law No. 06/2007/QH12 on Chemicals expires on the same date the new law takes effect, except for the transitional provisions (Article 47(3)).

Does the new Chemicals Law apply to factories that only use chemicals?

Yes. The law has a separate provision on chemical use (Article 15), and "chemical activities" include use (Article 2(16)). Factories must ensure safety and security, have a person in charge of safety and train their workers (Article 33). A factory that uses special-control chemicals must also declare the chemical type and purpose (Article 15(2)(b)).

What should importers note under the new law?

First, determine the chemical category, because the category decides the type of documents required (Article 12(2) to (5)). Imported chemicals must be declared, except for the special-control group, the prohibited group and cases the Government exempts (Article 12(6)). Importers must also classify and label (Article 23(1)) and prepare a safety data sheet for hazardous chemicals (Article 25(1)).

Conclusion

Vietnam Chemicals Law 2025 is already in force, and each factory's obligations depend on its role as user or importer, the chemical category, storage activity, and the purpose of repackaging and blending. Key points to remember:

  • Reference: Law No. 69/2025/QH15, passed by the National Assembly on 14 June 2025.
  • Effective date: 1 January 2026 (Article 47(1)); a separate date of 1 July 2026 for storage services (Article 47(2)).
  • Main groups of obligations: determining the chemical category (Article 9); import and declaration (Article 12); classification, labelling and safety data sheets (Article 23, Article 25); information records (Article 27); storage and incident response (Article 14, Article 37 to Article 39).
  • Actions to take now: prepare the chemical inventory, match each chemical to its category, check safety data sheets and existing licences, and track the transitional deadlines (Article 48).

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