Vietnam’s legal framework governing chemicals has undergone significant reform, with the Law on Chemicals No. 69/2025/QH15 (Law on Chemicals 2025) taking effect on January 1, 2026. Together with a comprehensive set of implementing instruments issued in January 2026, including three decrees (No. 24/2026/ND‑CP, No. 25/2026/ND‑CP, and No. 26/2026/ND‑CP) and two circulars (No. 01/2026/TT‑BCT and No. 02/2026/TT‑BCT), the Law on Chemicals 2025 has significantly reshaped chemical registration and management requirements.

Determining What Constitutes a “New Chemical”

Among the most notable changes introduced under the Law on Chemicals 2025 are the rules governing the registration and management of new chemicals, which must be registered with the authority before being placed on the Vietnam market. Although the concept of new chemical registration was first introduced under the Law on Chemicals 2007, the corresponding registration mechanism has remained largely dormant in practice.

Under the Law on Chemicals 2025, a “new chemical” is defined as a substance that is not yet included in Vietnam’s National Chemical Inventory and the list of foreign chemical inventories recognized by the competent Vietnamese authority (List of Foreign Chemicals).

On a literal reading, the definition in the new law may suggest that a substance qualifies as a new chemical only if it is absent from both lists. Accordingly, a chemical present in either list should be treated as an existing chemical without the registration burden.

However, a different interpretation emerges from Decree 26, which specifically requires registration of “new chemicals” even where such substances already appear in the List of Foreign Chemicals. This implies that inclusion in a recognized foreign inventory does not automatically exempt a substance from new chemical registration in Vietnam.

This inconsistency between the statutory definition in the Law on Chemicals 2025 and the implementing provisions of Decree 26 creates significant interpretative and compliance challenges. At present, it remains unclear whether a substance is classified as a “new chemical” only when it is absent from both lists cumulatively, or merely from one of them. To date, no official clarification or interpretative guidance has been issued by the competent authorities.

Management of New Chemicals

Once registered under the Law on Chemicals 2025, new chemicals are subject to special control. From the date of registration, organizations and individuals engaging in activities related to a new chemical must, for a period of five years, submit annual updates on relevant information and operational data to the national chemical database.

Based on the results of the chemical assessment and operational reports, the Ministry of Industry and Trade (MOIT) may propose that the government consider adding the substance to one of the following regulatory lists:

• List of Chemicals Subject to Conditional Trading or Use
• List of Chemicals Subject to Special Control
• List of Prohibited Chemicals

This post‑registration monitoring mechanism underscores the precautionary approach adopted under the new regime, whereby regulatory controls may be progressively tightened depending on actual risk data.

Procedural Changes

The Law on Chemicals 2025 introduces several notable procedural changes compared to the previous framework. In particular, the statutory timeline for reviewing a new chemical registration dossier has been extended to 90 working days from the date of submission, compared to approximately 30 working days under the former law. Moreover, evaluations under the new law must be conducted by a New Chemicals Evaluation Council, indicating that scientific and risk‑based scrutiny will be more rigorous. As a result, applicants should anticipate a more demanding and time‑consuming review process.

Lack of Procedural Clarity for Registration

Despite the formal effectiveness of the Law on Chemicals 2025 and its implementing regulations, key procedural aspects remain unresolved. At present, there is no official guidance on how and when registration dossiers for new chemicals will be accepted and processed.

In practice, the competent state authority has yet to receive any new chemical registration applications and is awaiting additional internal instructions or official guidance before commencing acceptance of dossiers. This regulatory gap leaves businesses in a holding position, unable to implement or complete compliance steps in practice despite the legal obligations being in force.

The regulatory requirements of new chemicals are further complicated by the current absence of the National Chemical Inventory. Under Decree 26, this inventory is expected to be finalized and publicly released before 2028. Until then, businesses lack a definitive domestic reference point for determining the regulatory status of their substances.

Conclusion

The enactment of the Law on Chemicals 2025, together with its implementing regulations, is expected to establish a clear and formal market‑access mechanism for new chemicals in Vietnam. Nevertheless, the practical operation of this regime remains subject to legal and procedural uncertainty, suggesting that Vietnam’s new chemical registration regime is not yet fully operational. Its effective implementation will likely depend on the promulgation of the National Chemical Inventory—expected before 2028—as well as the issuance of further procedural and interpretative guidance from the competent authorities.

In the interim, businesses are strongly advised to closely monitor regulatory developments and timely engagement with the authorities to ensure swift compliance once the new chemical registration process is formally activated, thereby minimizing potential disruptions to business operations.