On June 30, 2026, Vietnam's Ministry of Industry and Trade (MOIT) issued Circular No. 33/2026/TT-BCT, promulgating the catalogue of medium-risk and high-risk goods within the scope of the state management responsibilities of MOIT (including HS codes and the corresponding conformity assessment requirements), effective from July 1, 2026. This Circular supersedes the previous Circular No. 41/2023/TT-BCT. Enterprises exporting relevant industrial products to Vietnam should verify their product risk levels and compliance pathways against the new catalogue.
Background
Vietnam applies a risk-based quality and conformity assessment management to products within MOIT's jurisdiction, defining the scope of products subject to mandatory conformity assessment and the corresponding requirements through the issuance of the medium/high-risk product catalogue. Circular No. 41/2023/TT-BCT was the previous version of this catalogue. The current Circular No. 33/2026/TT-BCT is the latest update, which took effect on July 1, 2026, upon which the previous Circular No. 41/2023/TT-BCT was simultaneously abolished.
Main Contents of the Catalogue
The Circular establishes the product catalogue on the basis of HS codes, classifying the regulated goods into medium-risk and high-risk levels, each subject to different conformity assessment requirements. Compared with the previous version, the new catalogue updates and tightens the product scope, HS code classification and conformity assessment methods, aiming to strengthen risk-based product quality management and market access control. The specific product list and the corresponding conformity assessment requirements for each item shall be subject to the main text of the Circular and its appendices.
ChemRadar Insights
Enterprises exporting industrial products to Vietnam are advised to take note of the following:
1. Check the product catalogue: Compare your products item by item against the HS codes to determine whether they fall within the medium/high-risk scope of the new catalogue and the corresponding risk level.
2. Confirm conformity assessment requirements: Based on the risk level determined in the new catalogue and the corresponding conformity assessment method (e.g., certification, declaration of conformity, etc.), prepare in advance the test reports, certifications or declarations of conformity and other materials.
3. Pay attention to the transition and continuity: As Circular No. 41/2023/TT-BCT has been abolished, certificates or conformity assessment conclusions previously obtained under the old catalogue must be transitioned in accordance with the new rules, and updated or re-applied for where necessary.
4. Refer to the official text: Specific product classification and conformity assessment details shall be subject to the main text and appendices of Circular No. 33/2026/TT-BCT.
