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On 2 October 2025, the Ministry of Industry and Trade (Vietnam Chemicals Agency) notified to the World Trade Organization (WTO) three coordinated draft decrees to implement the Law on Chemicals No. 69/2025/QH15. Together they establish: (1) policy and planning for chemical-industry development and chemical safety–security; (2) operational rules for chemical activities and for hazardous chemicals in products and goods; and (3) consolidated annexed lists of managed chemicals that trigger licensing, declarations, training, and emergency-planning duties.

Decree 1: Chemical-Industry Development and Chemical Safety–Security

Scope and structure. Spanning eight chapters and 44 articles, this decree translates high-level policy into practical levers for planning, approving, and supervising chemical projects. It defines national strategy processes, assigns roles across central ministries and provincial authorities, and sets expectations for professional consultancy, training, emergency preparedness, and security.

Core policy mechanisms

• Planning and siting: Project approvals tied to safety-distance and spatial-risk criteria; layouts that fail separation standards must be redesigned.
• Green-chemistry integration: Technology selection, feedstocks, and process design must evidence pollution prevention, safer alternatives where feasible, and energy/resource efficiency.
• Data and oversight: Periodic reporting into a national chemicals database to support supervision, benchmarking, and policy review.

Decree 2: Management of Chemical Activities and Hazardous Chemicals in Products/Goods

Scope and structure. Organized into five chapters and 32 articles, this decree governs lifecycle controls for production, trade, storage, and use, and extends explicit oversight to hazardous chemicals contained in finished goods—aligning industrial regulation with market surveillance.

Operational mechanics

• Licensing and declarations: Risk-proportionate conditions (fit-and-proper, facility controls, competence, recordkeeping) tied to the national lists.
• Digital administration: Applications, renewals, declarations, and incident reporting handled via a centralized platform with standardized identifiers (e.g., CAS/HS) and supply-chain traceability.
• Inspections and enforcement: Risk-based scheduling prioritizing higher-hazard processes and operators with adverse histories; measures aimed at preventing loss/misuse or diversion (including to narcotics or weapons).
• Incident prevention and response: Formal accident-prevention and emergency-response plans required where listed chemicals and thresholds apply.
• Products and goods: Importers, manufacturers, and distributors must maintain evidence files (composition, safety data, conformity evidence) and cooperate with targeted checks and corrective actions.

Decree 3: Consolidated Lists of Chemicals (Annex System)

Purpose of the annexes. The companion decree publishes five annexes that anchor obligations across the regime:

• Annex I: Basic chemicals in prioritized sectors (strategic planning focus).
• Annex II: Chemicals under conditional production and trading (licensing and competence triggers).
• Annex III: Special-control chemicals (heightened security, handling, and reporting).
• Annex IV: Chemicals requiring a Chemical Accident Prevention and Response Plan (threshold-based emergency-planning duties).
• Annex V: Recognized training disciplines (qualification standards for chemical-safety roles).

Timeline and Outlook

Public comments to the WTO are open until 16 November 2025 and authorities are moving on an accelerated but synchronized schedule. The three decrees are expected to be adopted together on 1 December 2025 and to take effect on 1 July 2026, ensuring that policy, operational controls, and annexed lists align from day one.

For industry, this means a predictable transition to a lifecycle-based system that links spatial risk, licensing and declarations, product oversight, and digital reporting, while setting clearer expectations for competence and emergency readiness.

On 4 September 2025, Viet Nam notified the WTO (G/TBT/N/VNM/357) of a Draft Decree on the Management of Cosmetics introducing an updated regulatory framework for cosmetic products. The draft sets detailed requirements for  product notification, manufacturing conditions, labeling/advertising, market surveillance, and recalls—harmonized with the ASEAN Cosmetics framework.

The Ministry of Health (Drug Administration of Viet Nam) aims to adopt the Decree  on 4 November 2025 with entry into force on 1 July 2026. Stakeholders have until 3 November 2025 (60 days from notification) to submit comments.

This proposed Decree signals a shift to a unified, electronic, risk-based regime covering import/export, Certificates of Free Sale (CFS), Product Information Files (PIF), inspection/testing, and enforcement. The draft text spans 10 chapters and 60 articles, assigning responsibilities across central and provincial authorities and including detailed transitional arrangements.

Scope and ASEAN Alignment

The Decree expressly implements the ASEAN Harmonized Cosmetic Regulatory Scheme, adopting the latest ASEAN annexes for ingredient restrictions and safety assessment, and anchoring labeling and claims to ASEAN guidance and the Law on Advertising.

Key Regulatory Pillars

1) Product Notification & PIF

• Mandatory pre-market notification for both domestically produced and imported cosmetics; validity 5 years with renewal pathway.
• PIF content and accessibility to authorities are prescribed; safety must be assessed per ASEAN guidance.

2) Import/Export and CFS

• Import allowed once the product is notified on the national portals; customs verifies notification status electronically.
• CFS exemptions for products produced in, or exported from, Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) or ASEAN member countries, subject to specified documentary alternatives (e.g., proof of legal sale or ASEAN notification).

3) Manufacturing Controls (CGMP/ISO 22716)

• Production sites must meet personnel, facility, and quality-system requirements consistent with Current Good Manufacturing Practice CGMP.
• Provincial Health Departments will issue/adjust/revoke manufacturing licenses and may also issue CGMP certificates.
• Reassessments may be periodic or cause-based.

4) Labeling and Claims

• Mandatory label fields include product name, responsible company (in Vietnamese), origin, function/use, INCI ingredient list, manufacturer, batch/production date and expiry/use-after-opening rules, warnings where ASEAN annexes require, notification number, and product standard.
• Electronic labeling is permitted with conditions.
• Advertising must reflect notified information and substantiated claims.

5) Post-Market Controls, Testing, and Recalls

• Risk-based oversight: dossier review, targeted sampling/testing (GLP/ISO 17025), required independent testing for higher-risk categories (e.g., whitening, baby/toddler, sunscreen).
• Serious adverse events trigger expedited reporting and potential market actions.
• Detailed mandatory recall processes (voluntary or ordered) and suspension/blackout rules are specified.

Safety/Quality Benchmarks (Annexed Limits)

Appendix 1 sets maximum limits for heavy metals (Hg 1 ppm; As 5 ppm; Pb 20 ppm; Cd 5 ppm), microbiological limits (stricter for products for children under 3 years or for ocular or mucosal use), and a 10 ppm cap for 1,4-dioxane as a trace impurity (mirroring ASEAN parameters).

Digital Administration

The draft enables full online procedures for notification, renewals, licensing, and archiving; electronic outcomes have equal legal effect to paper. Authorities will publish notified products and licensed manufacturers on official portals to support customs clearance and market surveillance.

Phased Transition

• Adoption: 4 November 2025 (proposed). Entry into force: 1 July 2026. Comment deadline: 3 November 2025.
• From 1 January 2027, renewal procedures begin under the new Decree. Handling of notifications moved to provincial Health Departments for all products; legacy procedures before this date follow interim rules in Article 56.
• Manufacturing certificates issued under Decree 93/2016 remain valid until 31 December 2027. From 1 January 2028, facilities must meet the new CGMP-based conditions and obtain certificates under the new Decree.
• By 1 July 2026: Provincial Health Departments must ensure notified product information is published on the national e-government portal per the digitalization mandate.

Implications for Industry Stakeholders

• For importers/brand owners: Map all SKUs to ASEAN annex limits; ensure PIF completeness and claim substantiation. Prepare for CFS alternatives where CPTPP/ASEAN exemptions apply. Verify electronic notification visibility for customs.
• For manufacturers/contract manufacturers: Gap-assess facilities and QMS against CGMP/ISO 22716; plan re-certification before 1 Jan 2028. Align batch control, retention samples, and adverse-event escalation procedures with the Decree’s post-market obligations.
• For distributors/retailers and e-commerce: Sell only notified cosmetics; maintain traceability docs; be prepared to cooperate with sampling/recalls and to halt distribution upon notices.

Next Steps

Submit written comments by 3 November 2025 to the Viet Nam TBT Enquiry Point and the Drug Administration of Viet Nam using the contact details provided in the WTO notice. Monitor the finalization for any changes to adoption/entry dates and annex alignments.