Vietnam’s new Law on Chemicals, which took effect on January 1, 2026, represents far more than a simple regulatory update. It is a strategic instrument that reshapes the national approach to the way chemicals are managed. The Law moves beyond traditional risk control, utilizing chemical policy to realize national sustainable development goals—most notably, the ambitious commitment to achieve net-zero emissions by 2050 (Net Zero 2050).
We examine three critical innovations within the Law and explain their practical implications.
- Green Chemistry Principles: A Pre-requisite for Chemistry Project Investment
The most significant change is that “Green Chemistry Principles” are now a binding legal requirement. In simple terms, Green Chemistry focuses on selecting designs, technologies, equipment, and manufacturing processes—including disposal methods—that minimize or eliminate the use of hazardous chemicals.
The Law classifies these principles into two groups: mandatory and encouraged.
- Mandatory principles: Investors must: (a) use production methods that minimize or eliminate hazardous waste, (b) increase energy efficiency, (c) implement real-time monitoring to track and control emissions, and (d) establish clear plans to prevent accidents or chemical spills. These are minimum requirements for a chemical project approved and licensed. In addition, an investor must maintain them throughout the life of the business. Under the new draft rules, if an investor fails to maintain “Green Chemistry” in their design or technology, they face a fine of up to 50 million VND (approx. US$2,000). The fine is only a part of the consequences. The project will be required to be redesigned to include the necessary green standards.
- Encouraged principles: Eight principles are encouraged. They include the promotion of R&D toward the use of safer chemicals with equivalent efficacy and the use of bio-based or renewable raw materials.
By way of example, if a manufacturer intends to market an end-product as ‘green’ or ‘healthier,’ existing labeling and consumer protection laws require it to declare product quality details backed by formal certifications. Furthermore, if the investor wishes to monetize these green criteria (e.g. as ESG-certified products/technologies/manufacturing processes that are highly valued in the market), the investor cannot rely on R&D alone. It must undertake testing to prove the safety and efficacy of the chemicals to buyers/auditors.
The mandatory requirement to “increase energy efficiency” is a statutory mandate to validate Vietnam’s Net Zero 2050 commitment. This requires that the chemical industry—traditionally energy-intensive—innovate toward low-carbon technologies starting from the design phase. It also limits the domestic market for high-carbon technologies.
The stipulation of Green Chemistry as a prerequisite opens a significant market for specialized, upmarket chemical consultancy. However, note that chemical consultancy is a conditional business sector; consultants must be appropriately trained, qualified, and licensed. Moreover, superficial reports lacking scientific rigor regarding green chemistry application can lead to delays or investment rejection.
By converting Green Chemistry into hard law, Vietnam aligns itself with global trends, mirroring OECD Sustainable Chemistry initiatives and UN Sustainable Development Goals, thereby enhancing the credibility and attractiveness of Vietnam’s investment climate.
- Lifecycle Management: Digital Control of Chemical Risks from Production to Disposal
The new Law abandons the previous fragmented management approach in favor of a comprehensive lifecycle management system, structured around chemical risk levels. Chemicals are clearly stratified into three tiers:
Each tier corresponds to a distinct, rigorous management regime applied throughout the value chain—from production, trading, import/export, and transport, to storage, use, and disposal (detailed in Articles 10 through 16).
Crucially, the Law establishes a licensing mechanism for the import and export of “Special Controlled Chemicals” and the import of “Banned Chemicals” (some exceptions apply). This provides the state with a robust tool to interdict illegal trafficking of toxic substances or the diversion of chemicals for illicit purposes.
Furthermore, organizations that utilize “Special Controlled Chemicals” must declare information regarding the chemical type and purpose of use on the National Chemical Database. The scope of “use” is broad, encompassing manufacturing, providing services, defense, security, healthcare, and R&D. This represents a leap in digital transformation, creating a dual supervision mechanism: oversight by regulatory authorities and monitoring by the community and business partners.
- Management of Chemicals in Products: Extending Responsibility to the Supply Chain
This is arguably the innovation with one of the most profound impacts, expanding the Law’s scope from bulk chemicals to “chemicals in articles” (finished products and goods). The Law imposes two primary obligations:
(i) First, establishment of an internal control process:
Manufacturers must develop a process to control chemicals that contain hazardous substances as set out in the List of Hazardous Chemicals in Products and Goods. Below is the current list issued by the Ministry of Industry and Trade (MOIT) for the industrial and trade sectors:
| No. | Name of hazardous chemical | CAS Registry Number[4] | Products |
| 1 | Acetone | 67-64-1 | Glue (Adhesives), cleaning solutions |
| 2 | Cadmium | ——– | Electronic products |
| 3 | Chromium (VI) compounds | ——– | Anti-rust paint, chrome-plated steel, batteries, electronic products |
| 4 | Formaldehyde | 50-00-0 | Plywood, detergents |
| 5 | Hydrochloric acid | 7647-01-0 | Industrial detergents |
| 6 | Lead | ——– | Batteries, electronic products |
| 7 | Mercury | ——– | Light bulbs |
| 8 | Methanol | 67-56-1 | Glue (Adhesives), cleaning solutions |
| 9 | Sulfuric acid | 7664-93-9 | Accumulators (Lead-acid batteries) |
| 10 | Toluene | 108-88-3 | Industrial paint, printing ink |
Manufacturers must self-develop control processes based on actual operations, ensuring that they monitor hazardous ingredients in materials, hazardous emissions during production, and hazardous content in the final product, and they must prevent the loss/leakage of hazardous chemicals. Essentially, this provision extends corporate liability beyond the factory gates to the upstream supply chain. Manufacturers and importers in Vietnam must now establish rigorous traceability and supplier audit systems.
(ii) Second, information disclosure:
Manufacturers and importers of products that contain hazardous chemicals must:
- Declare information on the National Chemical Database (per shipment or production batch) prior to market circulation. Required data includes product name, chemical name, hazardous properties, concentration, and field of application.
- Publicly disclose information regarding hazardous ingredients, concentrations, and usage warnings. This must be displayed on the entity’s website or at the point of sale, and on product labeling.
By mandating transparency, the Law grants consumers the “Right to know” and generates market pressure favoring safer alternatives. It also lays the foundation for a circular economy, as effective recycling is predicated on the precise identification of material composition, including hazardous additives.
Regulation of Chemicals in Products acclimatizes Vietnamese enterprises to standards already in force in major markets, such as the EU’s REACH Regulation or RoHS Directive. Domestic adherence to these standards will significantly mitigate technical barriers for Vietnamese exports.
Conclusion
The Law on Chemicals 2025 is multi-objective. It is much more than a regulatory tightening for health and environmental protection; it is a potent statement demonstrating Vietnam’s resolve to pursue a sustainable, responsible growth model. By integrating requirements for energy efficiency, lifecycle control, health, environmental protection, and supply chain transparency, the Law establishes a robust legal framework enabling the chemical industry to contribute meaningfully to the Net Zero 2050 goal.
[1] Article 9 of the Chemical Law 2025.
[2] A list of these chemicals appears in Decree 24/2026/ND-CP dated 17 January 2026.
[3] A list of these chemicals appears in Decree 24/2026/ND-CP dated 17 January 2026.
[4] CAS number as a unique ID tag for a specific chemical. It ensures that there is no confusion about what a substance actually is. Governments use these numbers to accurately track and identify chemicals in their laws and safety regulations.
