On September 11, 2026, the Chemicals Agency issued Official Letter No. 2347/HC-QLHC on granting import licenses for chemicals subject to special control in order to implement remedial measures.
Details are set out below:
1. The license is a “customs-clearance condition,” independent of the goods’ clearance status
An import license for chemicals subject to special control is a mandatory condition for Customs to allow the goods to be cleared.
Whether or not the goods have already been cleared through customs is not a factor considered when granting the license, nor is it a ground for the licensing authority to refuse to grant the License if the enterprise’s dossier fully meets the prescribed conditions.
2. Processing licensing dossiers after a customs penalty has been imposed
Granting the License within 30 days of the administrative penalty decision is intended to help the enterprise complete its remedial measures.
If the conditions are met, the Department of Industry and Trade will grant the import license in accordance with Decree 26/2026/ND-CP and Circular 01/2026/TT-BCT.
If the conditions are not met, the Department of Industry and Trade will issue a written refusal clearly stating the reasons, allowing the enterprise to carry out further measures (such as re-export or removal from Vietnamese territory) as decided by Customs.
Note: Customs authorities currently apply the penalty provisions under Decree 169/2026/ND-CP (which replaced Decree 128/2020/ND-CP as of July 1, 2026).
3. Special provisions for Export Processing Enterprises
An Export Processing Enterprise located in a separate customs area that imports chemicals subject to special control from abroad for internal use within that area is not required to apply for an Import License (under the 2017 Law on Foreign Trade Management).
Enterprises should also proactively check their dossiers against Decree 26/2026/ND-CP and Resolution 19/2026/NQ-CP to determine the cases exempt from the import license requirement.
(Based on Official Letter No. 2347/HC-QLHC dated September 11, 2026)
Related service: Chemical import procedures
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