On 22 April 2026, the Department of Chemicals under Vietnam's Ministry of Industry and Trade (MOIT) issued Official Letter No. 813/HC-CNHC in reply to Vietnam Customs, addressing a set of practical questions that have emerged as the new Law on Chemicals (No. 69/2025/QH15) and its implementing decrees take effect, with direct consequences for the import and export of chemicals.
The letter responds to difficulties flagged by the General Department of Customs in Official Letters No. 13821/CHQ-GSQL (16 March 2026) and No. 15464/CHQ-GSQL (20 April 2026). The Law on Chemicals, in force since 1 January 2026, is supported by Decree No. 24/2026/ND-CP on the lists of chemicals within its scope and Decree No. 26/2026/ND-CP detailing its implementation, together with Circular No. 01/2026/TT-BCT.
1. Timing for declaring the intended use of chemicals
For organisations and individuals importing conditional chemicals for their own use, Decree No. 26/2026/ND-CP does not fix the moment at which the intended use must be declared on the specialised chemical database. The Department of Chemicals therefore confirms that importers of conditional chemicals for their own use may choose the timing of this declaration themselves.
2. Content, concentration, and treatment of mixtures
Because the Law on Chemicals and its guiding texts do not define content (ham luong) or concentration (nong do), the Agency applies its ordinary dictionary meanings: content is the amount of a substance in a mixture, expressed as a percentage (%); concentration is the degree of density, expressed as the amount of solute per unit volume or mass of a solution. To determine whether an imported mixture requires a Certificate of eligibility for conditional chemicals or a Licence for specially controlled chemicals, importers should first consult Part II of Appendix II and Part II of Appendix III of Decree No. 24/2026/ND-CP, and then check the exemption cases in Article 21 of Decree No. 26/2026/ND-CP.
3. Exemptions for products containing controlled chemicals
Conditional or specially controlled chemicals contained in the products listed in Article 21(6) of Decree No. 26/2026/ND-CP are exempt from the Certificate and Licence requirements. The term "household use" (gia dung) used in that provision is not defined in the Law and, in the Agency's reading, carries its ordinary meaning of articles for ordinary family daily life.
4. Licensing authority for specially controlled chemicals
Under Article 14(4) of Decree No. 26/2026/ND-CP, MOIT is the authority that receives applications and issues, re-issues, adjusts, and extends import and export licences for specially controlled chemicals, except for cases that have been decentralised under Circular No. 01/2026/TT-BCT.
5. Trade between domestic enterprises and export-processing enterprises
For chemicals traded between domestic enterprises and export-processing enterprises, the Agency directs the parties to the separate guidance in its Official Letter No. 597/HC-QLHC dated 27 March 2026, which addresses how the foreign-trade management measures apply to movements of goods into, out of and between separate customs territories.
6. Lookup of declared chemical information
For access to accounts used to declare imported chemicals, the Agency advises Customs to contact the Department of E-commerce and Digital Economy under MOIT, which operates the relevant declaration system.
Taken together, the clarifications give importers, exporters and customs brokers practical benchmarks for the new regime, most notably flexibility on when to declare the intended use of conditional chemicals and confirmation that MOIT is the default licensing authority for specially controlled chemicals. Companies handling mixtures should map their products against the Decree No. 24 lists and the Article 21 exemptions to establish whether a Licence or Certificate is required.
