Vietnam plans changes to chemical inventories months after implementation

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Vietnam is proposing to revise several chemical lists that determine which substances are subject to controls under the country's Law on Chemicals, potentially reducing regulatory requirements for certain lower-risk chemicals.

According to the Ministry of Industry and Trade (MOIT), the changes are intended to streamline administrative procedures and remove lower-risk chemicals from management lists. The proposals are set out in a draft decree that would replace three and amend one of four chemical lists issued under Decree 24/2026/ND-CP dated 17 January.

The proposal would reduce the number of substances on the list of basic chemicals for key chemical industry sectors (Appendix I) from 39 to 27.

Fifteen substances, including sulfuric acid, hydrochloric acid, benzene, ethylene oxide and titanium dioxide, would be removed, while acetone, nickel sulfate and anhydrous cobalt sulfate would be added. 

The list of chemicals subject to conditional production and business (Appendix II) would fall from 786 to 725 substances. The proposed changes would remove 86 lower-risk chemicals from the list and transfer 26 substances from Group 1 of the special-control chemicals list (Appendix III) to Appendix II.

At the same time, two convention-listed substances would move in the opposite direction, from Appendix II to Group 2 of Appendix III, at the request of the Ministry of Agriculture and Environment (MAE). The ministry also proposes adding mixed xylene as a standalone entry alongside its three isomers.

Within Appendix III, a further 33 substances, including styrene, phenol, ethylbenzene, trichloroethylene, acrylamide and several phthalates, would be reclassified from Group 1 to Group 2.

Furthermore, Appendix III Group 2 would gain three entries in its Rotterdam and Stockholm Conventions section, proposed by the MAE: medium-chain chlorinated paraffins (MCCPs), perfluorocarboxylic acids (PFCAs) and their salts, and chlorpyrifos.

Businesses handling chemicals that appear in the new Appendix III but not in the current one would have to comply with the amended Decree 26 requirements by 31 December 2027.

The list of chemicals requiring incident prevention and response plans (Appendix IV) would be amended, with the ministry citing the EU's Seveso III Directive as its benchmark for storage thresholds.

The draft would also add Harmonised System (HS) codes to all four appendices and amend the mixture rules associated with Appendices II and III.

The WTO consultation opened on 26 August and runs until 25 October. MOIT plans to submit the decree to the government in December this year. According to the WTO notification, the measure would be adopted in December this year or January next year and would enter into force on 1 January 2027.