Vietnam Releases Mandatory Disclosure List for Hazardous Chemicals! 40 Banned, 87 Restricted

On March 31, 2026, Vietnam's Ministry of Health officially issued Circular No. 05/2026/TT-BYT, promulgating, under Clause 4, Article 15 and Clause 2, Article 31 of the Law on Chemicals No. 69/2025/QH15, the list of chemicals prohibited in insecticidal and bactericidal preparations for household and medical use, as well as the list of hazardous chemicals requiring information disclosure.

Clause 4, Article 15 of the Law on Chemicals stipulates that ministers and heads of ministerial-level agencies may specify chemicals prohibited within their respective sectors and fields. Clause 2, Article 31 states that for hazardous chemicals in products and goods for which technical regulations have not yet been established, ministers and heads of ministerial-level agencies shall issue a list of hazardous chemicals in products and goods that require information disclosure within their state management scope. This Circular is issued under that legal framework.

Principles of Chemical Classification

The Circular reiterates that organizations and individuals producing or importing chemicals must implement chemical classification principles in accordance with Article 7 of Circular No. 01/2026/TT-BCT of the Ministry of Industry and Trade. Classification shall follow the guidance in Appendix 15 of the Circular, or the classification principles of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), 2nd revised edition (2007) or later.

Lists Published in this Circular:

• Appendix I: List of chemicals prohibited in insecticidal and bactericidal preparations for household and medical use

A total of 40 chemicals are listed, including their names and CAS numbers.

• Appendix II: List of hazardous chemicals requiring information disclosure in insecticidal and bactericidal preparations for household and medical use

A total of 87 chemicals are listed, including their names, CAS numbers, and restrictions on use (e.g., restricted purposes, restricted user groups, restricted concentrations, etc.).

Effective Date

This Circular takes effect on May 15, 2026. Circular No. 11/2020/TT-BYT issued by the Ministry of Health on June 19, 2020 (promulgating the list of chemicals prohibited and restricted in insecticidal and bactericidal preparations for household and medical use) shall cease to be effective on the same date.

Transitional Provisions

For insecticidal and bactericidal preparations for household and medical use that contain hazardous chemicals listed in Appendix II and have been granted a valid circulation registration number before the effective date of this Circular, the organizations and individuals producing or importing such preparations are responsible for disclosing information in accordance with Article 32 of the Law on Chemicals and Article 29 of the Government’s Decree No. 26/2026/NĐ-CP.

Specific Requirements for Information Disclosure

Article 32 of the Law on Chemicals stipulates that organizations and individuals producing or importing products containing hazardous chemicals are obliged to disclose, before placing the goods on the market, the content information of the hazardous chemicals in a specialized chemical database, and to make such information publicly available on their portal websites, electronic information pages, or at the premises where products or goods are directly supplied to buyers. Organizations and individuals selling products containing hazardous chemicals are obliged to provide relevant information and documents to buyers and to present them upon request by competent authorities.

Article 29 of the Government’s Decree No. 26/2026/NĐ-CP stipulates that organizations and individuals producing or importing products containing hazardous chemicals must fulfill the following obligations:

• Before placing the product or good on the market, declare the following information to the specialized chemical database:

• Name of the product containing hazardous chemicals
• Name of the hazardous chemical(s)
• Hazard characteristics of the hazardous chemical(s)
• Content/concentration
• Field of use of the product containing hazardous chemicals

• Disclose information on the hazardous chemical composition, content, and recommendations on use restrictions, and display such information on the organization’s or individual’s portal website, electronic information page, or at the premises where products are directly supplied to buyers, as well as on the product’s label.
• Organizations and individuals producing or importing products containing hazardous chemicals are responsible for keeping paper or electronic records to prove the accuracy of the disclosed information. Such records must be presented upon request by competent authorities.
• Organizations and individuals producing or importing products containing hazardous chemicals are responsible for the accuracy of the disclosed information.

Implementation Responsibilities

The Circular specifies the implementation responsibilities of relevant parties: The Department of Preventive Medicine may, based on actual management needs, propose that the Minister of Health consider revising or supplementing the lists. Within 10 days from the date of issuing a new circulation registration number for a preparation containing hazardous chemicals not yet listed in Appendix II, the Health Departments of provinces and centrally governed cities must submit a written report along with a copy of the registration dossier to the Ministry of Health or the Department of Preventive Medicine. Organizations and individuals producing or importing preparations containing hazardous chemicals listed in Appendix II must carry out information disclosure as required.

Further Information

Ministry of Health