Vietnam's Ministry of Health (MoH) has issued a circular setting out new bans, disclosure obligations, and use restrictions on household and healthcare biocide ingredients, refining regulatory oversight of insecticide and disinfectant products on the Vietnamese market.
The circular is based on the 2025 Law on Chemicals, its implementing Decree 26/2026 and Circular 01/2026, and applies to manufacturers and importers of consumer biocidal products in Vietnam. It was issued on 31 March and will take effect on 15 May, replacing Circular 11/2020 dated 19 June 2020.
Banned substances
The first list, set out in Appendix I, covers 40 substances, including individual chemicals, groups of compounds and biologically active ingredients, that must not be used in biocidal products for home or medical use. The list primarily targets several persistent organic pollutants (POPs) and other industrial hazardous substances.
It prohibits dichlorodiphenyltrichloroethane (DDT), aldrin, dieldrin and endrin, alongside polychlorinated biphenyls (PCBs), hexachlorobenzene (HCB), pentachlorophenol (PCP) and its salts, paradichlorobenzene (1,4-dichlorobenzene, pDCB) and naphthalene. It also bans heavy metal compounds containing cadmium or lead, as well as perfluorooctane sulfonic acid (PFOS) and its salts.
Methanol is prohibited from use as an active substance in disinfectants and is permitted only as an impurity at levels of no more than 2,000mg/l.
Disclosure required
Appendix II lists 87 hazardous substances that may still be used but are subject to mandatory disclosure requirements when present in products.
These include widely used industrial and formulation chemicals such as ethanol, hydrogen peroxide and sodium hypochlorite; organic acids, including acetic, citric and peracetic acid; and surfactants, such as C9-C11 ethoxylated alcohols and C12-C14 ethoxylated linear alcohols.
The list also includes biocidal active substances used in consumer products, such as permethrin, cypermethrin and imidacloprid, alongside antimicrobial agents including benzalkonium chloride, chlorhexidine digluconate and triclosan, which are commonly used in personal care, medical and industrial applications.
Use restrictions and concentration limits
In addition to disclosure, the circular outlines use-specific restrictions on certain substances, introducing limits based on exposure scenarios and product types.
These include prohibitions on the use of certain disclosure-required substances in drinking water or domestic water applications; restrictions limiting certain actives exclusively to outdoor ultra-low-volume (ULV) spraying; and concentration caps such as the one on dimethyl phthalate (DMP), which must not exceed 30%. Emamectin benzoate is restricted to cockroach-bait formulations at concentrations below 0.2%, while certain other substances are allowed only to be used to kill mosquito larvae.
The circular also introduces age-related restrictions, prohibiting the use of DMP and diethyltoluamide (DEET) in products intended for children under four years old.
Timelines and reporting obligations
Products registered and placed on the market before the circular takes effect must comply with the new disclosure requirements if they contain substances listed in Appendix II.
The circular also creates a reporting mechanism for hazardous substances that are not yet listed. Where a newly registered product contains a hazardous chemical not included in Appendix II, the relevant local Department of Health, at the provincial or centrally administered city level, must report it to the MoH’s Department of Disease Prevention within ten days of issuing the new registration number, together with the product’s registration dossier. This mechanism allows the disclosure list to be expanded over time based on substances identified in products entering the market.
Disclosure of hazardous chemicals in products and goods
Under Article 32 of Vietnam's Law on Chemicals (2025), manufacturers and importers of products containing hazardous chemicals must disclose the content of those hazardous chemicals before placing the products on the market.
This information must be submitted to the national specialised chemicals database and made publicly available, including on company websites, at the point of sale and on product labels.
Decree 26's Article 29 specifies the detailed disclosure requirements that must be provided for each production or import batch before products or goods are put into circulation on the market. These include:
- name of the product or goods containing hazardous chemical(s);
- name of the hazardous chemical(s);
- hazardous properties of the chemical(s);
- content and composition of the hazardous chemical(s); and
- intended use.
Companies must also provide recommendations on restricting their use in the above-mentioned places, including on labelling.
Manufacturers and importers are required to maintain records – paper or electronic – demonstrating the accuracy of disclosed information and present them to competent authorities upon request.