On 30 June 2026, Vietnam's Ministry of Industry and Trade (MOIT) signed Circular No. 37/2026/TT-BCT, promulgating Amendment 01:2026 to three national technical regulations (QCVN): QCVN 01:2017/BCT on formaldehyde and aromatic amines derived from azo dyes in textile products, QCVN 02A:2020/BCT on mercury content in fluorescent lamps, and QCVN 08:2020/BCT on lead content in paints. The amendments took effect on 1 July 2026. Vietnam had notified the WTO of the draft amendments on 8 June 2026, with a comment deadline of 27 June.
1. Background
The three QCVNs were originally issued in 2017 and 2020, respectively. The current amendments are primarily procedural, updating conformity assessment methods, conformity declaration registration, labeling requirements, and transport rules to align with Vietnam's revised standardization framework under Circular No. 14/2026/TT-BKHCN of the Ministry of Science and Technology. Product scope is no longer defined by annexes appended to each QCVN but instead references MOIT's Circular No. 33/2026/TT-BCT, which establishes the official list of medium- and high-risk products and goods under MOIT's jurisdiction.
2. Amended Regulations at a Glance
|
Regulation |
Product Scope |
Restricted Substance(s) |
|
QCVN 01:2017/BCT |
Textile products (apparel, home textiles, technical textiles) |
Formaldehyde and certain aromatic amines derived from azo colourants |
|
QCVN 02A:2020/BCT |
Fluorescent lamps (compact fluorescent lamps, linear fluorescent tubes) |
Mercury |
|
QCVN 08:2020/BCT |
Paints (architectural, industrial and decorative paints) |
Lead |
3. Key Changes
The amendments introduce several notable updates across all three regulations:
Conformity assessment routes have been clarified: imported products must follow Method 1 (type testing combined with conformity surveillance through sampling), while domestically manufactured products must follow Method 5 (type testing combined with conformity surveillance based on quality management system auditing), as prescribed in Annex II of Circular No. 14/2026/TT-BKHCN.
Conformity declarations must be registered through Vietnam's national database for standards, metrology, and quality. Where the system is unavailable due to technical issues, paper-based or postal submission is permitted as a fallback. The use of the conformity mark (CR mark) must comply with Clause 2, Article 4 of Circular No. 14/2026/TT-BKHCN.
Product annexes previously attached to each QCVN have been abolished and replaced by reference to the product list in Circular No. 33/2026/TT-BCT. For QCVN 08:2020/BCT, labeling requirements now follow Government Decree No. 37/2026/NĐ-CP. For QCVN 01:2017/BCT, the testing standard for certain azo amines has been updated to include TCVN 12512-3:2018 (ISO 14362-3:2017) covering azo dyes that may release 4-aminoazobenzene, and the list of recognized ecolabels has been expanded to ten schemes.
4. Industry Impact
Manufacturers, importers, and traders of paints, fluorescent lamps, and textile products in Vietnam should verify whether their products fall within the scope of the amended QCVNs by consulting the product list under Circular No. 33/2026/TT-BCT. Companies need to confirm the applicable conformity assessment route (Method 1 for imports, Method 5 for domestic production), ensure conformity declarations are properly registered, and verify that CR marks and product labeling comply with the updated requirements before placing products on the Vietnamese market.
