Appendix I
Basic chemicals in key chemical industries
No import obligation.
An industrial-policy list used to assess investment incentives (Article 6.2–6.3). Being listed here adds nothing to your import file.
Importing chemicals into Vietnam: what the 2026 rules actually require
On 1 January 2026 Vietnam replaced its 2007 chemical law with Law on Chemicals 69/2025/QH15, and in January issued two decrees under it: 24/2026/NĐ-CP (the four chemical lists) and 26/2026/NĐ-CP (import declaration). Most English-language summaries stop at naming them. Below is what they actually require of an importer, with the clause references, so your compliance team can check us.
Two different questions, two different keys
Almost every mistake we see at the border comes from treating these as one question. They are answered by different documents, keyed on different identifiers, and one can be “yes” while the other is “no”.
Question 1
Is the substance on a control list?
Keyed on the CAS number of each ingredient, against the four appendices of Decree 24/2026. This decides whether your company needs a certificate or a licence at all.
Question 2
Must the shipment be declared?
Keyed on the HS chapter of the finished product (28 and 29), under Article 6 of Decree 26/2026 — not on the CAS numbers inside it.
A mixture classified outside Chapters 28/29 does not carry the declaration duty even when its ingredients are Chapter 28/29 chemicals (Article 6.7(đ), Decree 26/2026). That single clause is the one most often read backwards.
The four lists, and what each one obliges
Decree 24/2026 issues the lists but creates no obligation of its own — the words “licence” and “declaration” appear nowhere in it. Each appendix takes its duty from a specific article of the Law on Chemicals, and importing counts as trading under Article 2.18, which is why these apply to importers at all.
Appendix II
Chemicals subject to conditional trading
Certificate of eligibility to trade conditional chemicals.
Issued by the provincial People’s Committee, valid 5 years (Article 11.1(d), 11.2). It is a company-level condition for the establishment — not a per-shipment permit.
Appendix III
Chemicals subject to special control
TWO licences — and the second one gates customs clearance.
A trading licence at company level (Ministry, 5 years — Article 11.1(d), 11.3), AND an export/import licence per consignment which Article 14.2 of Decree 26/2026 states plainly “is a condition for customs clearance” (issued by the Ministry of Industry and Trade, Article 14.4). The trading licence is itself a document in that application (Article 14.5(e)). Each purchase and sale also needs a control slip (Article 11.4, Article 17). This is the difference importers get caught by: Appendix II clears on a certificate, Appendix III does not.
Appendix IV
Chemicals requiring an incident prevention and response Plan
Approved Plan — only if stored above the threshold.
The duty attaches to storage, not to importing, and only above the per-chemical threshold printed in Table A (Article 37.1(b)). Below it you still need Measures under Article 38 — “below threshold” does not mean “nothing to do”.
The import declaration, and its three exemptions
Under Article 6.1 of Decree 26/2026, chemicals falling in HS Chapters 28 and 29 must be declared through the National Single Window before clearance. There is no certificate to collect: Article 6.3(b) has the system respond automatically, and Article 6.3(c) gives that response legal effect for customs. Three situations fall outside it:
- You already hold an import licence for the chemical (Article 6.7(a)).
- The consignment is under 10 kg (Article 6.7(c)) — or under 1 kg for a new chemical imported for testing (Article 6.7(d)). Two separate thresholds with two separate conditions; they are not interchangeable.
- The mixture is classified outside Chapters 28/29 (Article 6.7(đ)).
What we actually see go wrong
- An SDS that lists no ingredients. A mixture not classified as hazardous in its home jurisdiction need not disclose components there — but Vietnamese screening is keyed on CAS numbers. You will be asked for a composition your document does not contain.
- An exempted substance read as a controlled one. Appendix III lists three substances under an “Exemption” heading. They are excluded from that section, not caught by it.
- A company-level condition mistaken for a shipment permit. The Appendix II certificate is obtained once for the establishment. Importers who think it is per-consignment plan for a delay that does not exist — and importers who assume the opposite arrive without it.
Article references are to Law on Chemicals 69/2025/QH15 and Decrees 24/2026/NĐ-CP and 26/2026/NĐ-CP as published in Công báo. This page is general information for planning, not advice on a particular consignment — classification turns on the specific product, and we are glad to look at yours.