Consultation on Vietnam Draft Chemicals Law reveals opportunities and concerns for industries

Hanoi, Vietnam, May 2025 — Vietnam has opened a public consultation on a sweeping draft Chemicals Law that would replace the country’s 2007 framework and fundamentally reshape how chemicals are regulated across their entire life cycle. Launched in early May and now under consideration by the People’s Congress of Vietnam, the proposal aims to modernize chemical management while tightening oversight for manufacturers, importers, and downstream users.

If adopted, the law is expected to be enacted in the second half of 2025 and take effect in January 2026, with key new obligations phased in through mid-2028. While regulators say the reforms will streamline compliance and align Vietnam more closely with international practices, industry groups are already flagging concerns over disclosure obligations, regulatory overlap, and short transition timelines.

A New Framework for Chemical Control

At the heart of the draft law is a structural shift toward a “new and existing chemicals” system—an approach already used in jurisdictions such as China, the Philippines, and the United States. Under the proposal, chemicals listed on Vietnam’s forthcoming national inventory would be considered “existing,” while substances not on the list would require notification before being imported, manufactured, or used in production.

The inventory is currently being compiled by the Vietnam Chemical Agency. Although it has gone through several rounds of consultation, the agency has not yet published a final version. Officials have indicated, however, that the inventory will be completed in time for the law’s entry into force.

Chemicals used for national defense or public health emergencies would be exempt, and testing data submitted as part of new chemical notifications would need to comply with standards set by the Organisation for Economic Co-operation and Development (OECD).

Companies that successfully notify new chemicals would also face post-market obligations, including periodic reporting to Vinachemia and other competent authorities during the first five years of manufacture or import. The draft law allows Vietnam to recognize foreign chemical inventories, but does not yet specify which jurisdictions would qualify.

GHS Compliance Continues—But Questions Remain

The draft law retains Vietnam’s commitment to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), requiring chemicals to be classified, labelled, and accompanied by safety data sheets (SDSs). However, it stops short of specifying which revision of GHS will apply. Vinachemia has previously stated it would accept GHS Revision 2 or later, but the lack of clarity has left some companies seeking reassurance.

Disclosure and Confidentiality in the Spotlight

One of the most contentious elements of the proposal is its approach to information disclosure. Companies would be required to disclose the concentration of hazardous chemicals in products—potentially through the national chemical database, company websites, labels, or SDSs. Advertisements would also need to include information on chemical hazards and risks.

While the draft law recognizes confidential business information (CBI) and trade secrets, it explicitly excludes chemical names, hazard data, SDS contents, and warning information from protection. Given the emphasis on concentration disclosure, thresholds and concentration levels are also unlikely to qualify as CBI—raising red flags for sectors such as fragrances and specialty formulations.

Shared Oversight, Coordinated Enforcement

The draft law preserves a multi-agency model for chemical oversight, allowing ministries such as the Ministry of Natural Resources and Environment (MONRE), Ministry of Health (MOH), and Ministry of Industry and Trade (MOIT) to impose restrictions within their mandates. Although industry had hoped for a single lead authority, government sources say Vinachemia will act as the coordinating body to reduce duplication and unnecessary compliance burdens.

Existing prohibitions and restrictions adopted under the 2007 law are expected to remain in force until replaced by new regulations issued after enactment.

Stronger EHS and Green Expectations

The proposal also strengthens environmental, health, and safety (EHS) obligations. Companies would be required to ensure safe storage, prevent chemical incidents, manage environmentally sound disposal, and maintain emergency response plans. Employee training across the full chemical life cycle would become mandatory, and authorities would gain the power to impose green initiatives on chemical manufacturers and importers.

What This Means for Business

For companies dealing in existing chemicals, the new framework could reduce administrative burdens and speed market access. However, those introducing new substances should expect additional time and cost associated with notification and reporting—unless they plan early and leverage existing assessments from the EU, U.S., or other recognized jurisdictions.

Foreign companies without operations in Vietnam may also face new information requests from local customers seeking to comply with the law. With transition periods as short as two years for some obligations, companies are being urged to assess their supply chains, disclosure practices, and emergency preparedness now.

Despite industry concerns, the draft law represents only the first step. Once enacted, MOIT and Vinachemia will issue implementing decrees that will flesh out technical requirements—and provide companies with another opportunity to shape Vietnam’s next generation of chemical regulation.