On September 4, 2026, Vietnam's Ministry of Public Security issued Circular No. 154/2026/TT-BCA, requiring the establishment of a unified identification and traceability system for chemicals subject to special control (the traceability system) on the electronic identification and authentication platform, to implement the management, identification, and whole-process traceability of chemicals subject to special control. All Vietnamese and foreign authorities, organisations, and individuals engaging in activities related to chemicals subject to special control within Vietnam fall within the scope of application. The relevant production, trading, and import enterprises must access the system through VNeID accounts to complete information declarations, and face entirely new digital compliance requirements.
Digital Traceability Requirements under the New Chemicals Law
Vietnam's Chemicals Law (Law No. 69/2025/QH15) entered into force on January 1, 2026, implementing classified management of chemicals. The production and trading of chemicals subject to special control require a license; separate specific permits must be applied for import and export; and both parties to a purchase and sale must establish purchase and sales control lists. The specific scope of such chemicals is set out by Decree No. 24/2026/NĐ-CP, which took effect on January 17, 2026, and whose Appendix 3 contains two groups totaling 241 chemicals subject to special control.
The Circular clarifies three functions of the traceability system: first, the construction, management, and operation of the traceability system; second, the creation, management, and use of supply chain codes and chemical identification codes, and the integration of the purchase and sales control lists for chemicals subject to special control into the system; and third, the connection, sharing, and development and use of traceability information. Chemicals used for national defense and security purposes, or constituting state secrets, are not covered by the Circular.
Supply Chain Codes and Identification Codes: Automatic Verification and Batch-Level Coding
There are two types of situations requiring access to the traceability system: first, purchase and sales activities involving chemicals subject to special control for which purchase and sales control lists must be declared under Vietnam's chemicals regulations; second, organisations and individuals in the chemicals sector with needs for declaration, management, tracking, and traceability may voluntarily use the system to manage chemicals and chemical products.
As batch owners, enterprises must use VNeID electronic identity accounts to access the system and submit supply chain information. The system automatically compares the information with the specialized chemicals database, the customs declaration database, the e-invoice database, and other databases. When the comparison is consistent, the system automatically issues a supply chain code, with no acceptance, review, or approval steps; when the comparison is inconsistent, the system immediately indicates the fields to be corrected. The failure to generate a supply chain code does not constitute an administrative approval result, nor does it affect enterprises' lawful conduct of chemical activities.
The chemical identification code follows the structure "GCP code (or system-generated organisation/individual identification code) + serial number" and is presented as a QR code. It is generated and attached when the batch is declared for the first time, and subsequent key tracking events are directly updated to the existing identification code without assigning a new code. The serial number is a unique alphanumeric code of up to 20 characters and cannot be changed during the whole life cycle of the traceability object.
The GCP code is the GS1 standard company prefix code, consisting of 7 to 12 digits. Where an enterprise has not obtained a GCP code, the system will automatically generate a substitute prefix based on the enterprise code, tax identification number, or personal identification number; the Circular does not make GCP code registration a precondition for using identification codes. The identification codes also support mapping and interoperability with GS1 codes such as GTIN, GLN, SSCC, GIAI, and GRAI, facilitating connection with domestic and foreign traceability systems.
Traceability Data and Public Inquiry
The traceability data cover the chemical name, CAS number (if any), GCP code, label and product serial number, photos of the packaging (package, label, or container), chemical origin, the identity number, name, and address of the business entity, batch, lot, type, or unit codes, quantity, quality, or volume, expiry date (if any), licensing and business condition information (where licensing or declaration is required), applicable standards and technical regulations, customs declaration information, e-invoice information, and the key tracking events and their occurrence times in each link of production, import, storage, transport, purchase and sale, use, and disposal. Records of key tracking events must comply with the Vietnamese national standard TCVN 12850:2019 or the GS1 global traceability standards.
The public can query basic information through the system, such as the chemical name, CAS number, label and serial number, packaging photos, chemical origin, business entity name, batch codes, and key tracking events.
Key Compliance Deadlines: 24-Hour Reporting and Code Invalidation Rules
The Circular sets multiple mandatory deadlines and trigger situations for the operation of the traceability system:
- Report emergencies within 24 hours: where an accident, abnormal loss, theft, compulsory destruction, or safety hazard occurs to chemicals during storage, transport, or use, an electronic report must be filed through the system within 24 hours of discovery or occurrence. Such reporting does not exempt enterprises from their accident reporting and handling obligations under the specialized chemicals regulations.
- Integration of purchase and sales control lists: enterprises must integrate their purchase and sales control list information into the system, and the information will be automatically updated by the system after the comparison is completed. Before the integration is completed, enterprises must still prepare and retain purchase and sales control lists in accordance with the chemical regulations.
- Code invalidation and restoration: where an enterprise's license or certificate of eligibility for business is revoked, suspended, or terminated; a code is used for other purposes or is inconsistent with the information registered in the system; or a competent authority so requests, the system administration authority may terminate the validity of supply chain codes and identification codes. Before termination, the system notifies the enterprise electronically, and the enterprise may provide explanations and clarifications within 3 working days (except where the requirement is made in writing by a competent authority). Invalidated codes must not be reactivated; where continued use is needed, enterprises must reapply in accordance with the Circular. Where the grounds for termination no longer exist or the termination is confirmed to be erroneous, the system administration authority restores the codes and related data within 3 working days from the date on which the verification result is confirmed.
- Logs retained for at least 5 years: the system's connection, sharing, and information retrieval activities must all be logged and retained for at least 5 years, for use in supervision and inspection, cybersecurity assurance, and the handling of violations.
Entry into Force and Implementation
The Circular takes effect from its date of issuance, September 4, 2026, with no transition period. The traceability system is built, managed, and operated by the Department of Administrative Police for Social Order under the Ministry of Public Security. The traceability data will be interconnected with the national product identification, certification, and traceability platform, the specialized chemicals database, and the Ministry of Industry and Trade, the Ministry of Finance, the Ministry of Science and Technology, the Ministry of Agriculture and Environment, the Ministry of Health, and other relevant authorities, and used for chemicals activity management, supply chain tracking, purchase and sales control, supervision and inspection, and the handling of violations.
Enterprises bear legal responsibility for the authenticity, accuracy, and completeness of the declared information, must correctly use supply chain codes and identification codes, and must not forge, tamper with, transfer, or use them beyond their authorization. Where signs of impersonation or unauthorized access to accounts or codes are found, enterprises must promptly notify the system administration authority.
ChemRadar Insights
ChemRadar reminds the relevant enterprises operating in Vietnam, as well as those exporting chemicals subject to special control to Vietnam, of the following:
- No transition period; complete system access as soon as possible. The Circular has entered into force. Enterprises producing, trading in, storing, transporting, or using the 241 chemicals subject to special control listed in Appendix 3 of Decree No. 24/2026/NĐ-CP in Vietnam should verify the availability of their VNeID organisational electronic identity accounts as soon as possible and complete system access and the initial declaration.
- Self-declaration with self-responsibility. The system has no approval steps, but the declared information will be automatically compared with customs declarations, e-invoices, the specialized chemicals database, and other databases. Inconsistent information will make code generation impossible, directly affecting the integration of purchase and sales control lists and the conduct of traceability. Enterprises bear legal responsibility for the authenticity, accuracy, and completeness of the information.
- Incorporate the mandatory deadlines into internal compliance management. Accidents, theft, and other situations must be reported online within 24 hours; revocation, suspension, or termination of licenses will cause codes to become invalid, and they must not be reactivated. Enterprises are advised to establish a list of trigger situations and corresponding response procedures.
- Exporters to Vietnam should align data standards in advance. Information such as product names, CAS numbers, batches, labels, and serial numbers will enter Vietnam's declaration and traceability chain. Export enterprises are advised to verify data standards with their Vietnamese importers in advance, to avoid affecting the importer's code generation and subsequent business operations due to inconsistent comparison results.
CIRS Services
CIRS provides domestic and foreign enterprises with the following services. Enterprises with relevant needs are welcome to contact the CIRS compliance team for consultation:
- In-depth regulatory interpretation and compliance strategy
- Mandatory import declaration
- Controlled chemical license/qualification application
- Chemical customs clearance support
- Vietnamese SDS and label preparation
- Chemical accident emergency response plan preparation and implementation guidance
