Vietnam remains one of the most important growth markets for the global chemical industry and a key participant in regional and international supply chains. As the country continues to evolve its regulatory framework, two significant regulatory developments are currently unfolding with broad implications for chemical manufacturers, distributors, and downstream users across multiple sectors.
Since 2023, SCIC has been coordinating closely with international counterpart associations, including the American Chemistry Council (ACC), Cefic, the Japan Chemical Industry Association (JCIA), Chemistry Australia, and the ASEAN Chemical Industries Council (ACIC), to engage Vietnamese authorities on these evolving challenges. In the most recent round of engagements, collaboration has been further expanded to include additional partners such as the Korea Chemical Industry Association (KCIA), the Association of International Chemical Manufacturers (AICM), the EU and US ASEAN Business Council and Asian Lubricants Industry Association (ALIA).
Below is an update on these developments, which have implications beyond Vietnam, particularly in the areas of confidential business information (CBI) protection, trade facilitation, regulatory coherence and supply chain continuity.
- Vietnam Customs’ requirement for 100% chemical composition disclosure during import
Since 2023, Vietnam Customs has required importers to declare 100% chemical composition details for imported chemical products, including components that may constitute confidential business information (CBI). This approach differs from common international practice, raises concerns regarding intellectual property and CBI protection, and has contributed to shipment delays, demurrage costs, and risks of forced re‑export in certain cases.
From an industry perspective, these expectations have the potential to create business impacts across the chemical and petrochemical value chain. For example, products containing UVCB substances, specialty formulations or proprietary additive packages may face disproportionate compliance challenges, particularly where global norms treat such substances as single entities or allow confidentiality safeguards. Increased disclosure expectations can also affect sourcing flexibility, inventory planning, product availability and investment decisions across upstream suppliers and downstream users.
SCIC, together with ACC, Cefic, JCIA, and other global associations, has submitted multiple joint industry letters to Vietnam Customs, Vinachemia and the Ministry of Industry and Trade (MoIT). In parallel, SCIC has encouraged local industry associations to engage their respective Ministries of Trade and Industry, enabling concerns to be raised through bilateral trade and government‑to‑government dialogue in support of constructive engagement with Vietnamese authorities.
- Implementation of Vietnam’s new risk‑based chemical control regime under the Law on Chemicals 2025.
Vietnam is implementing a new, risk‑based chemical management framework through the Law on Chemicals 2025, with supporting decrees and circulars taking effect from January 2026 and full compliance required by 1 January 2028. The new regime significantly expands controlled chemical lists, strengthens licensing, storage, labeling, and import declaration requirements, and introduces mandatory digital reporting through the National Chemicals Database. Companies will need to reassess chemical portfolios, update permits, enhance compliance systems, and adapt to new disclosure and reporting processes.
While industry supports Vietnam’s efforts to enhance its chemical management framework, companies continue to face implementation challenges. These include inconsistencies between decrees and circulars, requirements that diverge from international practice and increased administrative burden that could affect supply chains across industrial chemicals, coatings, electronics, batteries, and consumer products. In particular, uncertainties around inventory scope, classification and transitional arrangements may contribute to unpredictability at the border and extended compliance timelines for complex chemical products. To address these issues, SCIC is consolidating feedback from members and international associations and is preparing a joint industry letter to Vinachemia to seek clarification on requirements and timelines, as well as to provide practical, risk‑based recommendations to support effective implementation. In parallel, SCIC has also shared consolidated industry feedback with the Vietnam Chamber of Commerce and Industry (VCCI), which will be conveyed to the drafting authorities for consideration.
SCIC remains committed to leading this advocacy effort in close collaboration with ICCA members and regional and global counterpart associations. We will continue to engage with Vietnamese authorities through the ICCA ASEAN Regulatory Cooperation Platform, in support of the chemical industry’s shared objective of advancing regulatory cooperation and convergence across ASEAN to facilitate trade
