In-Depth Legal Newsletter for Enterprises Engaged in the Export, Import, Storage, and Trading of Chemicals
July 2026
Keywords: chemical license, business license grace period, conditions for chemical trading, administrative sanctions for chemical violations, chemical import license, chemicals subject to special control
As of July 2026, Vietnam’s legal framework governing the export, import, storage, and trading of chemicals has recorded a number of notable new developments, reflecting two parallel trends: on one hand, regulatory authorities are actively cutting and simplifying administrative procedures to facilitate enterprises; on the other hand, sanctions for violations are being tightened to enhance the effectiveness of State management. In addition, chemical import-export activities have given rise to several new regulations and points of attention that enterprises need to update promptly in order to ensure compliance. The newsletter below summarizes three closely interrelated groups of in-depth legal content, providing enterprises with a comprehensive view of the current legal framework for chemicals, including:
- Changes in licensing authority and simplification of administrative procedures for chemicals under Resolution No. 19/2026/NQ-CP;
- New regulations on administrative sanctions in the chemical sector under Decree No. 275/2026/NĐ-CP;
- Branch offices of enterprises not eligible to apply for export-import licenses for chemicals subject to special control (under Official Letter No. 335/HC-QLHC), and the update of the List of chemicals banned from export and import (under Decree No. 292/2026/NĐ-CP).
Part I: Changes in Licensing Authority and Simplification of Administrative Procedures under Resolution No. 19/2026/NQ-CP
On April 29, 2026, the Government issued Resolution No. 19/2026/NQ-CP on the plan to cut and simplify regulations related to business activities under the management functions of the Ministry of Industry and Trade. Details are as follows:
1. Changes in Authority to Handle Chemical-Related Procedures
The Resolution transfers the authority to receive, appraise, and issue the following key licenses to the Provincial People’s Committee (Department of Industry and Trade):
- Export and import licenses for Group 1 chemicals subject to special control
- Import licenses for banned chemicals
- Certificates of chemical storage services
2. Reduction of Conditions for Chemical Trading
For conditional chemicals:
- Removal of the storage and preservation conditions under Article 4.7 of Decree No. 26/2026/NĐ-CP: chemicals in storage must be preserved in accordance with current national technical standards and regulations, ensuring safety requirements and facilitating chemical incident response.
- Clarification of the professional competency requirements for the person in charge: must hold an intermediate-level degree or higher in a chemistry-related field of training listed in Appendix III issued together with Decree No. 25/2026/NĐ-CP
- Removal of general conditions for chemical trading: Article 25 (physical and technical facilities); Article 26 (safety and security in chemical transportation); Article 27 (professional requirements for the person responsible for chemicals); Article 28 (safety distance from chemical facilities); Article 29 (chemical safety training)
For chemicals subject to special control: similar regulations are reduced as for conditional chemicals.
3. Reduction of Processing Time and Simplification of Administrative Procedures
Regarding processing time:
- Time for issuing export and import licenses for chemicals subject to special control: shortened from 7 working days to 5 working days.
- Time for issuing business licenses for chemicals subject to special control: shortened from 16 working days to 14 working days.
Regarding application dossiers and processing procedures:
- Procedures for appraisal and approval of chemical incident prevention and response plans
- Issuance of licenses for the production and trading of chemicals subject to special control
- Issuance and re-issuance of Certificates of eligibility for the production and trading of conditional chemicals
- Procedures for registration of new chemicals
4. Additional Cases Eligible for License Exemption
- Raising the exemption threshold for Certificates and production/business licenses for conditional chemicals and chemicals subject to special control: from below 0.1% under the old regulation to 1% or less under the new regulation
- Addition of “fire extinguishers” to the category of exempted products
- Addition of an exemption case for export/import licenses for chemicals subject to special control used for laboratory testing purposes, with a quantity of ≤1mg per import
- Exemption from export/import licenses for on-the-spot export-import activities, and for cases where export processing enterprises purchase chemicals from domestic enterprises
5. Grace Period (“Debt”) Mechanism for Chemical Licenses until the End of 2026
To facilitate enterprises, Resolution No. 19/2026/NQ-CP allows enterprises to be exempted from presenting production and business licenses for chemicals subject to special control until before December 31, 2026. This regulation applies to export-import activities involving chemicals on the List of Chemicals Subject to Special Control (under Appendix III of Decree No. 24/2026/NĐ-CP) that are, at the same time, not chemicals restricted in production/trading nor industrial precursors under Decree No. 113/2017/NĐ-CP.
(Pursuant to Clause 9, Section V, Appendix III, Resolution No. 19/2026/NQ-CP)
Part II: New Decree No. 275/2026/NĐ-CP on Administrative Sanctions in the Chemical Sector
On July 8, 2026, the Government issued Decree No. 275/2026/NĐ-CP providing detailed regulations on administrative sanctions in the field of chemicals and industrial explosive materials.
Effective date: from August 25, 2026. Below are some notable points:
1. General Principles of Sanctions
The maximum fine for each administrative violation committed by an individual in the chemical sector is VND 50,000,000, and in the industrial explosive materials sector is VND 100,000,000.
Sanctions for organizations: the fine imposed on an organization is twice the fine imposed on an individual for the same violation.
In addition to monetary fines, enterprises committing serious violations may be subject to additional sanctions such as suspension of the Certificate of eligibility for chemical trading, or the chemical production license, for a fixed term. At the same time, enterprises are required to implement remedial measures such as recall, re-export, or destruction of the violating chemical shipment.
(Pursuant to Article 4 of Decree No. 275/2026/NĐ-CP)
2. Summary Table of Fines for Administrative Procedure Violations in the Chemical Sector
(Pursuant to Decree No. 275/2026/NĐ-CP dated July 27, 2026)
| Behavioral groups | Specific violations | Fines (Individuals) | Legal basis |
| Licenses, Certificates
(Certificate of eligibility for production/business and License for chemicals subject to special control/prohibited chemicals) |
Erasure, correction of content | 5,000,000 – 15,000,000 VND depending on the type of license | Articles 16, 17, 18 of Decree No. 275/2026/ND-CP |
| Lease, borrowing, purchase and sale of licenses | 8,000,000 – 20,000,000 VND | ||
| Failure to carry out re-issuance procedures when changing business information | 10,000,000 – 25,000,000 VND | ||
| Producing and trading at the wrong location or exceeding the scale | 15,000,000 – 40,000,000 VND | ||
| No License, Certificate or Operation While Suspended | 20,000,000 – 50,000,000 VND | ||
| Declaration of imported chemicals | Incorrect declaration of information | 3,000,000 – 5,000,000 VND | Article 21 of Decree No. 275/2026/ND-CP |
| Lack of attachments (invoices, chemical safety sheets) | 5,000,000 – 10,000,000 VND. | ||
| Failing to update data to specialized databases after import | 5,000,000 – 10,000,000 VND | ||
| Failure to declare imported chemicals | 20,000,000 – 30,000,000 VND | ||
| Disclosure of purpose of use | Misrepresentation or lack of information | 5,000,000 – 10,000,000 VND | Article 24 of Decree No. 275/2026/ND-CP |
| Failure to disclose the purpose of use on the Database | 15,000,000 – 20,000,000 VND | ||
| Late publication (after 30 days from the date of use) | 5,000,000 – 10,000,000 VND
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| Additional sanctions | Suspension of the use of infringing chemicals from 03 to 06 months | ||
| Chemical Safety Sheet | Construction lacks mandatory content | Caution | Article 27 of Decree No. 275/2026/ND-CP |
| Providing false information | 3,000,000 – 5,000,000 VND | ||
| Failing to provide Chemical Safety Sheets to buyers/users | 10,000,000 – 15,000,000 VND | ||
| Failing to make a chemical safety sheet in Vietnamese | 15,000,000 – 20,000,000 VND
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| Reporting and data update mode | Late annual report (after 15/02 every year) | 5,000,000 – 10,000,000 VND | Article 25 of Decree No. 275/2026/ND-CP |
| Updating incomplete/false information in the annual report | 10,000,000 – 15,000,000 VND | ||
| Failing to report on chemical activities in the previous year | 15,000,000 – 20,000,000 VND | ||
| Failure to update the situation when there is an incident or termination of operation | 15,000,000 – 20,000,000 VND |
Part III: Non-Issuance of Export-Import Licenses to Enterprise Branches, and Update of the List of Banned Chemicals
To assist enterprises in proactively ensuring legal compliance and optimizing customs clearance procedures, below is a summary of the latest directives and legal regulations directly related to chemical trading and import-export activities, issued by the Chemicals Agency, the Government, and the Customs Authority in 2026.
1. Branches Not Eligible to Apply for Export-Import Licenses for Chemicals Subject to Special Control
The Chemicals Agency has confirmed that a branch is merely a dependent unit without independent legal status. Therefore, a branch is not eligible to be considered for the issuance of an export-import license for chemicals subject to special control (Group 1). To ensure legal validity, the application dossier for the license must be prepared and submitted in the name of the Company (the principal legal entity).
(Pursuant to Official Letter No. 335/HC-QLHC dated February 25, 2026 of the Chemicals Agency – Ministry of Industry and Trade)
2. Update of the List of Hazardous Chemicals Banned from Export and Import
Pursuant to Appendix I issued together with Decree No. 292/2026/NĐ-CP, the Government has officially updated the List of goods banned from export and import. Accordingly, hazardous chemicals falling under the List of banned chemicals and minerals under the Law on Investment are subject to the export ban (Item I.8) and import ban (Item II.3), under the specialized management of the Ministry of Industry and Trade. Enterprises should proactively cross-check the chemical composition before signing international sale and purchase contracts.
(Pursuant to Decree No. 292/2026/NĐ-CP dated July 22, 2026 of the Government)
Related Services: Chemical import procedure services
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