On August 22, 2026, the Vietnam Chemicals Agency (VINACHEMIA) under the Ministry of Industry and Trade (MOIT) announced that MOIT has opened public consultations on the draft revisions to the three supporting decrees of the new Law on Chemicals — Decrees No. 24, 25 and 26/2026/NĐ-CP — with comments on Decree 26 due by August 27 and those on Decrees 24 and 25 due by September 7. The revisions aim to simplify administrative procedures and resolve implementation issues. Once implemented, they are expected to streamline compliance procedures such as licensing and declaration. Chemical companies operating in Vietnam, please follow the developments and make the most of the feedback window.
Background of the Revisions
Vietnam's new Law on Chemicals (No. 69/2025/QH15) took effect on January 1, 2026, replacing the 2007 Law on Chemicals (No. 06/2007/QH12) that had been in force for many years. On January 17, 2026, the Vietnamese government promulgated the three supporting decrees — Decrees No. 24, 25 and 26/2026/NĐ-CP — to lay down implementing arrangements for the new law.
In the consultation letter, MOIT explained that the revisions are driven by two considerations: first, implementing the government's resolutions on cutting, decentralizing and simplifying administrative procedures and business conditions, and updating the affected supporting regulations accordingly; and second, resolving the bottlenecks that have emerged since the three decrees took effect. As for the timeline, the draft revision of Decree 26 must be submitted to the government by December 1.
This is not an isolated move in the chemicals sector. In March 2025, the Vietnamese government issued Resolution No. 66/NQ-CP to deploy the reduction and simplification of business-related administrative procedures for 2025–2026, mandating the abolition of at least 30% of unnecessary investment and business conditions and a cut of at least 30% in both processing time and compliance costs. MOIT has since kept implementing the resolution within its remit; for example, Circular No. 26/2026/TT-BCT issued in May 2026 simplified administrative procedures in eight areas including chemicals. The revision of the three chemical decrees was launched against this backdrop, coupled with the need to address implementation bottlenecks — coming just over half a year after the decrees were promulgated, the fast policy iteration means the compliance baseline facing companies remains in dynamic adjustment.
Coverage of the Three Decrees
The three decrees correspond to the three major implementing pillars of the Law on Chemicals, and the texts of the draft revisions have been published on MOIT's official website (moit.gov.vn). Their respective mandates are as follows:
- Decree No. 24/2026/NĐ-CP: specifies the lists of chemicals under the purview of the Law on Chemicals, setting out in its appendices the scope of chemicals subject to various regulatory regimes.
- Decree No. 25/2026/NĐ-CP: guides the implementation of the Law's provisions on chemical industry development and chemical safety and security.
- Decree No. 26/2026/NĐ-CP: guides the implementation of the Law's provisions on the management of chemical activities and of hazardous chemicals in products and goods, covering activity management requirements for links such as chemical production and trading.
Feedback Arrangements
Relevant organizations and individuals may submit written comments to the Vietnam Chemicals Agency (No. 21 Ngõ Quỳ Street, Cửa Nam Ward, Hanoi) before the above deadlines for consolidation and onward submission. For inquiries about the draft revision of Decree 26, MOIT can be contacted at UyenPLP@moit.gov.vn.
ChemRadar Insights
In light of the policy background of the revisions and the division of roles among the three decrees, chemical companies in Vietnam may assess the impact and arrange their responses from the following perspectives:
- Nature of the revisions — procedural simplification first, obligation framework expected unchanged: This round of revision is not a directional adjustment of the chemical regulatory approach; the core obligations established by the Law on Chemicals, such as list-based management, licensing, declaration, and GHS classification and labeling, are expected to remain in place, with changes likely concentrated on procedural aspects such as the level of authority handling applications, documentation requirements and time limits.
- List linkage — self-check against the appendices of Decree 24: Decree 24 delineates the scope of regulation through its appendices; if the appendices are adjusted in the revision, the regulatory status of certain chemicals (e.g., whether they fall within the list of chemicals subject to conditional production and trading) may change accordingly. Companies may check their product lines against the current appendices in advance and flag potentially affected items.
- Procedural continuity — watch the transitional provisions of Decree 26: Decree 26 bears directly on day-to-day operations such as licensing and declaration; how the validity of existing licenses and pending procedures will be handled after the revision takes effect is critical, and close attention should be paid to the transitional arrangements and any change in the level of handling authority in the final text.
- Feedback channels — via associations or professional institutions are more effective: The consultation is addressed to agencies and organizations, and companies' requests are usually more likely to reach official attention when conveyed through industry associations or professional institutions in Vietnam; those intending to comment on Decree 26 must submit their comments by August 27.
CIRS Services
CIRS can provide end-to-end chemical regulatory compliance support for chemical companies in Vietnam, mainly including:
- In-depth regulatory interpretation and compliance strategy
- Mandatory import declaration
- License/qualification applications for controlled chemicals
- Chemical customs clearance support
- Preparation of Vietnamese SDS and labels
- Preparation and implementation guidance of chemical accident emergency response plans
