Vietnam's Ministry of Industry and Trade (MOIT) must develop and submit a National Chemical List for promulgation before 2028, under Decree 26 implementing the country's new Law on Chemicals.
The 2025 Law on Chemicals, effective since 1 January, requires the government to prescribe a roadmap for developing the National Chemical List and recognising foreign chemical lists. It also calls for the government to establish procedures and dossier requirements for registering new chemicals. Decree 26 implements this mandate by requiring MOIT to build and submit the list to the government for promulgation before 2028.
While a national inventory of chemicals has been in development for some years, it is still "currently unavailable", said Phuong Thi Minh Doan, a lawyer at Tilleke & Gibbins (T&G) in Hanoi.
At present, only the specialised chemical database is accessible, Doan added.
The specialised chemical database stores, manages, updates and integrates data on chemicals, general chemical processes and activities, the chemical industry, hazardous chemicals in goods and products, and safety and security in chemical operations.
Under Decree 26, the National Chemical List will be included in the specialised chemical database, alongside foreign chemical lists recognised by Vietnam's competent authorities:
- the list of chemicals published by the EU's ECHA;
- the TSCA inventory maintained by the US EPA; and
- Japan's Existing and New Chemical Substances (ENCS) Inventory, managed by the Ministry of Economy, Trade and Industry (METI).
Decree 26 also requires MOIT to set a roadmap for applying new chemical assessment requirements after the promulgation of the National Chemical List.
MOIT is also responsible for developing regulations governing the use of the specialised chemical database, while ensuring compliance and information security.
New chemicals
Vietnam's Law on Chemicals defines a new chemical as a substance not yet listed in either the National Chemical List or recognised foreign chemical lists. Such chemicals may only be used or placed on the market after registration with the competent authority.
Newly registered chemicals must comply with the same management regulations as those for chemicals requiring special control. Organisations and individuals registering new chemicals must report on their chemical activities annually for five years following registration.
Based on the evaluation over this period, MOIT will then make recommendations to the government on whether to add the new chemical to the list of chemicals subject to conditional use, the list of chemicals requiring special control, or the list of prohibited chemicals for management purposes.
Doan noted that, because the Law on Chemicals defines new chemicals by reference to the National Chemical List and recognised foreign lists, new chemicals are not currently classified into any of the four chemical lists established under Decree 24, which sets out Vietnam’s core chemical lists under the new law.
Under the 2025 Law on Chemicals, banned chemicals are hazardous chemicals specified in the List of Banned Chemicals and Minerals issued as part of the Law on Investment 2025, according to Doan.