Hanoi — October 2025. The Ministry of Industry and Trade (Vietnam
Chemicals Agency) has issued three coordinated draft decrees to operationalize Law
on Chemicals No. 69/2025/QH15. Together they establish: (1) policy and planning
for chemical-industry development and chemical safety–security; (2) operational
rules for chemical activities and for hazardous chemicals in products and
goods; and (3) consolidated annexed lists of managed chemicals that trigger
licensing, declarations, training, and emergency-planning duties.
Decree 1 — Chemical-Industry Development & Chemical Safety–Security
Scope and structure. Spanning eight chapters and 44 articles, this
decree translates high-level policy into practical levers for planning,
approving, and supervising chemical projects. It defines national strategy
processes, assigns roles across central ministries and provincial authorities,
and sets expectations for professional consultancy, training, emergency
preparedness, and security.
Core policy mechanisms
- Planning
& siting: Project approvals tied to safety-distance and spatial-risk
criteria; layouts that fail separation standards must be redesigned.
- Green-chemistry
integration: Technology selection, feedstocks, and process design must
evidence pollution prevention, safer alternatives where feasible, and
energy/resource efficiency.
- Data &
oversight: Periodic reporting into a national chemicals database to
support supervision, benchmarking, and policy review.
Decree 2 — Management of Chemical Activities & Hazardous Chemicals
in Products/Goods
Scope and structure. Organized into five chapters and 32 articles, this
decree governs lifecycle controls for production, trade, storage, and use, and
extends explicit oversight to hazardous chemicals contained in finished goods—aligning
industrial regulation with market surveillance.
Operational mechanics
- Licensing and
declarations: Risk-proportionate conditions (fit-and-proper, facility
controls, competence, recordkeeping) tied to the national lists.
- Digital
administration: Applications, renewals, declarations, and incident
reporting handled via a centralized platform with standardized identifiers
(e.g., CAS/HS) and supply-chain traceability.
- Inspections
and enforcement: Risk-based scheduling prioritizing higher-hazard
processes and operators with adverse histories; measures aimed at
preventing loss/misuse or diversion (including to narcotics or weapons).
- Incident
prevention and response: Formal accident-prevention and emergency-response
plans required where listed chemicals and thresholds apply.
- Products and
goods: Importers, manufacturers, and distributors must maintain evidence
files (composition, safety data, conformity evidence) and cooperate with
targeted checks and corrective actions.
Decree 3 — Consolidated Lists of Chemicals (Annex System)
Purpose of the annexes. The companion decree publishes five annexes that
anchor obligations across the regime:
- Annex I:
Basic chemicals in prioritized sectors (strategic planning lens).
- Annex II:
Chemicals under conditional production/trade (licensing and competence
triggers).
- Annex III: Special-control
chemicals (heightened security, handling, and reporting).
- Annex IV:
Chemicals requiring a Chemical Accident Prevention and Response Plan
(threshold-based emergency-planning duties).
- Annex V: Recognized
training disciplines (qualification standards for chemical-safety roles).
Timeline and Outlook
With comments open until 16 November 2025, authorities are moving on an
accelerated but synchronized schedule. The three decrees are intended to be
adopted together on 1 December 2025 and to take effect on 1 July 2026, ensuring
that policy, operational controls, and annexed lists align on day one. For
industry, this means a predictable transition to a lifecycle-based system that
links spatial risk, licensing and declarations, product oversight, and digital
reporting, while setting clearer expectations for competence and emergency
readiness.
