For chemicals requiring special control (the new name for what used to be called “restricted”), holding a licence is only the starting point. Article 17 of Law on Chemicals No. 69/2025/QH15 also limits who you may sell to and requires paperwork for every delivery.
A slip for every delivery
An organisation trading in chemicals on the special-control list must make a purchase and sale control slip for each delivery (clause 1 of Article 17). Not one per contract — one per delivery.
Only two categories of buyer (clause 2 of Article 17)
- Organisations holding a licence to trade in chemicals requiring special control;
- Organisations and individuals using such chemicals that have declared the type of chemical and the purpose of use on the specialised chemical database.
In other words, you cannot sell to a customer who has not declared on the database. That is worth checking before quoting, not at delivery.
Template and roadmap
The template, deadline, method and roadmap for making the control slip on the specialised chemical database are set by the head of the central state management authority for chemicals (clause 3 of Article 17).
The obligations that come with it
- Strict control of quantities; prevention of loss and chemical incidents; compliance with the international treaties on chemicals to which Vietnam is a party (point c clause 2 of Article 9);
- Field, type, scale and duration must match the licence, and the purpose of use is controlled (point b clause 2 of Article 9);
- Storage: your own warehouse, or a certificate-holding storage service (point c clause 3 of Article 14).
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