[Vietnam] 10 hazardous chemicals: mandatory disclosure

Rosazy

Document summary — Decree 26/2026/ND-CP (issued 17 January 2026) and Circular 01/2026/TT-BCT (issued 17 January 2026, in force the same day) establish, for the first time, the list of hazardous chemicals in products and goods whose information must be disclosed — Appendix XIX to the Circular, covering 10 substances. Manufacturers and importers must declare each batch on the national chemical database before placing goods on the market, and must have completed compliance by 1 March 2026.

Quick summary

Legal basis: Decree 26/2026/ND-CP dated 17 January 2026 (Chapter IV, Articles 28–29) and Circular 01/2026/TT-BCT dated 17 January 2026 (Article 11 and Appendix XIX).
The list: 10 hazardous chemicals with CAS numbers and corresponding product groups — acetone, cadmium, chromium (VI) compounds, formaldehyde, hydrochloric acid, lead, mercury, methanol, sulfuric acid, toluene.
Who is covered: organisations and individuals that manufacture and import products and goods containing a listed chemical.
Four obligations: batch-by-batch declaration on the national chemical database; public disclosure on the company website, at the point of sale and on the product label; retention of supporting records; accountability for accuracy.
Compliance deadline: clause 8 of Article 30 of Decree 26/2026/ND-CP — compliance required before 1 March 2026. That date has passed, so the obligation now applies in full.
Note: Article 28 (control procedure for hazardous chemicals during production) applies only to manufacturers, not to importers.

Why this rule exists

The Law on Chemicals No. 69/2025/QH15 devotes a separate set of provisions to hazardous chemicals present in products and goods — different from the management of chemicals as raw materials. The approach is to control the content of hazardous substances in the finished product and to require businesses to disclose information to buyers, rather than regulating only the production stage.

Decree 26/2026/ND-CP implements this in Chapter IV with two articles: Article 28 sets out the control procedure during production, and Article 29 sets out disclosure of content information. Circular 01/2026/TT-BCT specifies the details in Article 11 and issues the list in Appendix XIX — hazardous chemicals in products and goods subject to information disclosure within the sectors managed by the Ministry of Industry and Trade.

Under Article 3 of Decree 26/2026/ND-CP, the Ministry of Industry and Trade manages chemicals used in industrial and consumer products, excluding groups under the authority of the Ministry of Health and the Ministry of Agriculture and Environment. The scope of the list is therefore limited to industrial sectors — pharmaceuticals, food, fertilisers and plant protection products are not covered.

The 10 chemicals subject to disclosure

Appendix XIX is structured in three columns: name of the hazardous chemical, CAS number (where available) and the products subject to disclosure. The list is reproduced below:

No.	Hazardous chemical	CAS number	Products subject to disclosure
1	Acetone	67-64-1	Adhesives, cleaning solutions
2	Cadmium	—	Electronic products; anti-rust paint, plated steel
3	Chromium (VI) compounds	—	Batteries; electronic products
4	Formaldehyde	50-00-0	Plywood, cleaning agents
5	Hydrochloric acid	7647-01-0	Industrial cleaning agents
6	Lead	—	Batteries; electronic products
7	Mercury	—	Lamps
8	Methanol	67-56-1	Adhesives, cleaning solutions
9	Sulfuric acid	7664-93-9	Accumulators (lead-acid batteries)
10	Toluene	108-88-3	Industrial paints, printing inks

Four substances carry no CAS number in the list — cadmium, chromium (VI) compounds, lead and mercury. These are identified by substance name rather than by an identifier code. For chromium, the list uses the wording “compounds”, meaning the whole group of Cr(VI)-containing compounds is covered, not a single substance.

Which product groups are most affected

Grouping the list by industry shows seven product categories that need review:

Electronic products: three substances are relevant — cadmium, chromium (VI) compounds and lead. This is the broadest category, because most components, printed circuit boards and solder joints may contain them.
Batteries and accumulators: batteries fall under disclosure for lead and chromium (VI) compounds; accumulators fall under disclosure for sulfuric acid.
Paints and printing inks: cadmium in anti-rust paint; toluene in industrial paints and printing inks.
Adhesives and cleaning solutions: acetone and methanol; formaldehyde and hydrochloric acid in cleaning agents.
Plywood and engineered wood: formaldehyde.
Lamps: mercury.
Plated steel: cadmium.

One technical detail matters: the list assigns cadmium to “electronic products”, “anti-rust paint, plated steel” — and does not mention batteries. Lead and chromium (VI) compounds, by contrast, explicitly list “batteries”. This wording must be read literally when determining the obligation for each product type.

The four obligations businesses must meet

Article 29 of Decree 26/2026/ND-CP sets out four obligations that apply cumulatively, not as alternatives.

1. Declare each batch on the national chemical database

Businesses must declare by production batch or import batch, and must do so before placing the product or goods into circulation. Five items are mandatory:

Name of the product or goods containing the hazardous chemical;
Name of the hazardous chemical;
Hazard characteristics of the chemical;
Content of the hazardous chemical in the product;
Field of use of the product containing the hazardous chemical.

Declarations are made on the national chemical database operated by the Ministry of Industry and Trade (Chemicals Agency). Under Article 10 of Circular 01/2026/TT-BCT, this database includes data on hazardous chemicals in products and goods, with sharing and updating forms set out in Appendix XVI and Appendix XVII to the Circular.

2. Disclose composition and content publicly

Businesses must disclose information on the composition, content of the hazardous chemical and recommendations to limit use in three places: the organisation’s web portal or website; the place where products or goods are supplied directly to buyers; and the product label.

The provision uses “or” for the first two locations but “and” for the label, so labelling is mandatory in every case.

3. Retain records proving accuracy

Businesses must keep paper or electronic records proving that the declared and disclosed information is correct, and must present them when requested by a competent authority. In practice this file includes: composition tables for each product code, safety data sheets for input materials, test results for substance content from a testing laboratory, or declarations from the foreign manufacturer together with the basis for verification.

4. Take responsibility for accuracy

All four clauses of Article 29 place the responsibility on the business, including where the data comes from a foreign manufacturer. An importer cannot be exempted on the ground that “the data was supplied by the seller”.

How this differs from the production control procedure

Article 28 of Decree 26/2026/ND-CP requires a documented control procedure for hazardous chemicals during production, with four objectives: monitoring the composition and content of hazardous chemicals in input materials; monitoring composition and content released during production; monitoring composition and content in the finished product; and preventing loss of hazardous chemicals.

This obligation applies only to organisations and individuals manufacturing products and goods containing hazardous chemicals. Businesses that only import, without manufacturing, do not need to establish this procedure but must still comply fully with Article 29.

Timeline and transition

Clause 8 of Article 30 of Decree 26/2026/ND-CP provides that organisations and individuals declaring the type and purpose of use of special-control chemicals on import, and those disclosing information on the content of hazardous chemicals in products and goods, must meet the requirements of the Decree before 1 March 2026.

The Decree took effect on the date of signature (17 January 2026) and Circular 01/2026/TT-BCT took effect on 17 January 2026. The whole framework is therefore already in force and the 1 March 2026 transition date has passed — there is no grace period for goods placed on the market after that date.

For inventory imported before that date, businesses should still check compliance, because the declaration obligation attaches to the moment the product is placed into circulation, not to the moment of import.

Three points businesses commonly miss

First, declaration is per batch, not once for all. Article 29 uses the wording “declaration by production batch or import batch”. Each new batch triggers a new declaration, with the actual content of that batch. Filing once and reusing it for later batches does not comply.

Second, content must be substantiated, not estimated. The text sets no threshold below which disclosure is waived. If a product contains a listed substance, the business must state the content and be able to prove it. For imported goods, the most reliable route is a test report from a competent testing laboratory, or manufacturer documentation verified by check testing.

Third, substance names and product scope must be read literally. The list requires disclosure only for the product groups actually named. For example, cadmium covers electronic products, anti-rust paint and plated steel but not batteries; toluene covers industrial paints and printing inks but not household paints. Businesses should neither over-extend the obligation nor overlook the case where their product falls squarely within a listed group.

The list can be updated

Clause 2 of Article 11 of Circular 01/2026/TT-BCT tasks the Chemicals Agency with receiving comments on the list, reviewing it and assessing necessity, and submitting updates and additions to the Minister of Industry and Trade. Businesses should monitor this periodically, as the list may be extended with more substances and product groups.

Article 11 also places the list within the scope of products that do not yet have a corresponding technical regulation. Where a product is already covered by a national technical regulation setting limits for hazardous chemicals, the business applies that regulation and should still check the disclosure obligation so that nothing is missed.

What businesses should check

Review the full product portfolio in production and import against the 10 substances and product groups in Appendix XIX.
Build a composition table for each product code, identifying which listed substances are present and at what content.
Prepare supporting records: safety data sheets for raw materials, content test results, manufacturer documentation.
File the batch declaration on the national chemical database before the goods reach the market.
Update the disclosure content on the website, at the point of sale and on the product label, including recommendations to limit use.
Distinguish products that already have their own technical regulation from those that do not, so the correct layer of rules is applied.
Retain records by batch to present during inspections.

Frequently asked questions

What is the deadline for disclosure?

Under clause 8 of Article 30 of Decree 26/2026/ND-CP, businesses must comply before 1 March 2026. The declaration obligation attaches to each batch and must be completed before the product or goods enter the market.

Must importers disclose, or only manufacturers?

Both. Article 29 of Decree 26/2026/ND-CP imposes the obligation on “organisations and individuals manufacturing and importing products and goods containing hazardous chemicals”.

Is there a content threshold below which disclosure is waived?

Decree 26/2026/ND-CP and Circular 01/2026/TT-BCT set no de minimis threshold for the obligation to disclose the content of hazardous chemicals in products and goods. If a product falls within a group listed in Appendix XIX and contains the corresponding substance, disclosure is required.

Do imported batteries fall within scope?

Appendix XIX lists “batteries” in two rows: chromium (VI) compounds and lead. The cadmium row lists only electronic products, anti-rust paint and plated steel, not batteries. The obligation therefore depends on the battery type and its actual composition.

Where is the declaration filed?

On the national chemical database operated by the Ministry of Industry and Trade, using the forms set out in Circular 01/2026/TT-BCT. The import chemical declaration under Article 6 of Decree 26/2026/ND-CP (through the National Single Window) is a separate procedure and applies only to chemicals classified in Chapters 28 and 29.

What if the product already has a technical regulation?

Article 11 of Circular 01/2026/TT-BCT places the list within the scope of products that do not yet have a corresponding technical regulation. Where a product is covered by a national technical regulation on limits for hazardous chemicals, the business applies that regulation and should confirm the extent of the disclosure obligation with the sector regulator.

References

Decree No. 26/2026/ND-CP dated 17 January 2026 of the Government detailing and guiding the implementation of a number of articles of the Law on Chemicals on the management of chemical activities and hazardous chemicals in products and goods.
Circular No. 01/2026/TT-BCT dated 17 January 2026 of the Ministry of Industry and Trade, Article 11 and Appendix XIX. Document page on the Government web portal.
Law on Chemicals No. 69/2025/QH15.
Decree No. 24/2026/ND-CP dated 17 January 2026 listing chemicals within the scope of the Law on Chemicals.

Further discussion

If your company needs to review its product portfolio against Appendix XIX or build the documentary evidence of hazardous chemical content for each batch, please leave your details and we will discuss the specifics.

Disclaimer

This article is an explanatory summary prepared by us from the official texts; it is not legal advice. Businesses should refer to the original text of Decree 26/2026/ND-CP, Circular 01/2026/TT-BCT and Appendix XIX before applying it to any specific batch.