From 2026, chemical importers in Vietnam must follow the Law on Chemicals 2025 and a new set of implementing documents. In mid-2026, requirements to declare chemical components at customs delayed clearance for many shipments. This article summarises the declaration process, the exemptions and how to correctly interpret Vietnam Customs’ guidance.

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Latest legal basis

Law on Chemicals No. 69/2025/QH15 was passed by the National Assembly on 14 June 2025 and took effect on 1 January 2026, replacing the Law on Chemicals 2007. Five implementing documents took effect on 17 January 2026:

Document	Main content
Decree 24/2026/ND-CP	Lists of conditional chemicals for production and trading, and related lists
Decree 25/2026/ND-CP	Chemical industry development; chemical safety and security
Decree 26/2026/ND-CP	Management of chemical activities, import declarations, hazardous chemicals in products
Circular 01/2026/TT-BCT	Guidance on the Law and Decree 26/2026
Circular 02/2026/TT-BCT	Guidance on the Law and Decree 25/2026

Who must declare imported chemicals?

Under Clause 6, Article 12 of the Law on Chemicals 2025, organisations and individuals importing chemicals must file a chemical import declaration, unless an exemption applies. This applies to single substances and to mixtures containing listed chemicals.

Exemptions from declaration

Chemicals subject to special control: no declaration is needed because they are already managed through separate import–export licences.
Prohibited chemicals: organisations permitted to import them do not need to declare, as they are managed through licensing.
Mixtures below threshold concentrations: Decree 26/2026 sets thresholds of 0.1%, 1% and 5% — the core basis for deciding whether a mixture shipment is exempt. The applicable threshold depends on the chemical group, so check the Decree’s appendices.
Other exemptions: see the full list in Clause 6, Article 12 of the Law on Chemicals 2025.

Declaration dossier

Original commercial invoice; if in a foreign language, a Vietnamese translation certified by the organisation.
Safety data sheet (SDS/MSDS).
For non-commercial goods without an invoice: the arrival notice may be used instead.

The dossier is submitted via the National Single Window using Form 13a, Appendix XIII, Circular 01/2026/TT-BCT. For chemicals in HS Chapters 28 and 29, the declaration must be completed before customs clearance. Complete it before the goods arrive to avoid delays.

Declaring chemical components at customs: the correct interpretation

In May 2026, several associations and businesses reported being asked to declare “100% of components” when importing chemicals. Vietnam Customs subsequently confirmed three points:

Customs has not issued any separate rules on chemical imports and exports; declaration requirements are based on the Customs Law 2014, Decree 08/2015 (amended by Decree 167/2025), the Law on Chemicals 2025 and its implementing decrees.
Declarants do not need to submit documents beyond the standard customs dossier.
Component and concentration information is used to determine whether goods are regulated or exempt. Official Letter 16292/CHQ-GSQL (15 May 2026) guides full declaration of components and concentrations where goods must be checked against regulated lists.

The safe approach: prepare an up-to-date SDS stating the chemical name, CAS number and concentration of listed components; keep information consistent across the customs declaration, SDS and chemical declaration.

5 common mistakes

Outdated SDS, or product names that do not match the invoice.
Missing CAS numbers or concentrations of listed components.
Assuming a mixture is exempt without checking concentration thresholds.
Filing the chemical declaration after the goods have arrived at port.
Not arranging suitable storage for goods after clearance. Reference Chemical Warehouse

How to declare imported chemicals on the National Single Window

Determine whether a declaration is required: check the substance name, CAS number and concentration against the lists and exemption thresholds in Decree 26/2026. Chemicals in Chapters 28 and 29 of the import–export tariff must be declared before clearance.
Prepare electronic documents: commercial invoice (with translation if in a foreign language) and safety data sheet.
Enter the information on the National Single Window using Form 13a, Appendix XIII, Circular 01/2026/TT-BCT: details of the declaring organisation and each chemical.
Receive the response (Form 13b); keep it to present during customs procedures and inspections.
File the customs declaration with a goods description consistent with the chemical declaration.
Keep records: the electronic declaration dossier is the basis for inspection and penalties if information is incorrect.

Example: declaring an additive mixture

Illustrative scenario. Company G imports a plastics additive sold under the trade name “Additive X”. The invoice shows only the trade name; the SDS lists four components, one of which is on a regulated list.

If declared vaguely as “plastic additive mixture”: customs officers cannot check it against exemption thresholds, and the shipment is likely to be asked for explanations or additional information.
If declared fully: state the trade name together with the scientific name, CAS number and concentration of the listed component; check the threshold in Decree 26/2026 to see whether a chemical declaration is required; if so, complete it on the Single Window before the goods arrive.

Company G does not need to disclose its full formula, but it must provide enough information for the authorities to determine which category the goods fall into.

Checklist before goods arrive at port

☐ Obtain the latest SDS from the supplier, with CAS numbers and concentrations

☐ Align product names on the invoice, packing list and SDS

☐ Check the regulated lists and exemption thresholds

☐ Complete the declaration on the Single Window and keep the response

☐ Check for a separate licence if the chemical is subject to special control

☐ Book suitable storage and dangerous-goods transport

Frequently asked questions

Are chemical licences issued under the old rules still valid? Yes, until they expire or until 31 December 2027, depending on the case.

Do chemical samples need to be declared? Check the exemptions in Clause 6, Article 12 of the Law on Chemicals; contact NASA for a check based on your specific HS code.

Are CAS numbers kept confidential at customs? No. Customs has confirmed that CAS numbers are not confidential information. Requests for confidentiality are made to the chemical authority under Decree 26/2026.

Can a foreign supplier send component information directly to customs? According to customs, current law does not allow declaration documents to be received from third parties; the declarant is responsible for submitting them.

What happens if a chemical declaration is incorrect? The electronic declaration is the basis for administrative penalties. If you find an error, correct it proactively and work with customs.

Must each shipment be declared separately? Yes. Chemical import declarations are made for each import shipment subject to declaration.