Many warehouses conclude they “only need Measures” because no single chemical exceeds its threshold. Decree No. 25/2026/ND-CP adds a second rule that can overturn that conclusion.
Two cases requiring a Plan (clause 2 of Article 33)
- Point a — you hold at least one substance in Table A or one mixture in Table B of Appendix IV to Decree 24/2026/ND-CP, with a maximum quantity stored at any one time at or above the threshold;
- Point b — you are not covered by point a, but the sum of the ratios of stored quantity to threshold is greater than or equal to 1.
The summation formula
qx1/QUX1 + qx2/QUX2 + … + qXi/QUXi ≥ 1
- qxi = the maximum quantity of hazardous chemical i (Table A or Table B of Appendix IV) stored at any one time;
- QUXi = the threshold for that chemical under Appendix IV.
In other words: three chemicals each at 40% of their threshold already sum to 1.2 — that facility needs a Plan even though nothing exceeds a threshold on its own.
★ The 31 December 2026 deadline
The transitional provision of Decree 25/2026/ND-CP states that organisations and individuals who had already issued Measures before the Decree took effect but fall under point b of clause 2 of Article 33 must build a Plan and have it appraised and approved by the competent authority before 31 December 2026.
This is the group most easily missed: their paperwork is in order, they followed the previous rules, and nothing obvious prompts a review.
What to do
- List the facility’s hazardous chemicals with the maximum quantity stored at any one time (not annual consumption);
- Match them against Table A and Table B of Appendix IV to Decree 24/2026/ND-CP;
- Compute the sum of the ratios using the formula above;
- If it is ≥ 1 and you only hold Measures, start preparing the Plan now — appraisal and approval take time.
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