If you are used to the phrase “chemicals restricted in production and trading”, note that Law on Chemicals No. 69/2025/QH15 no longer uses it. The corresponding group is now hóa chất cần kiểm soát đặc biệt — chemicals requiring special control.
Under point a clause 2 of Article 9, the group consists of hazardous substances and mixtures on the list of chemicals requiring special control issued by the Government, comprising:
The list itself is in Decree 24/2026/ND-CP.
Points b and c of clause 2 of Article 9 add further requirements:
Unlike the conditional group, where the provincial People’s Committee issues a certificate, the licence to trade in chemicals requiring special control is issued by a ministry or ministerial-level agency and is valid for five years from the date of issue (clause 3 of Article 11).
Organisations and individuals buying or selling chemicals requiring special control must make a purchase and sale control slip under Article 17 of the Law, and data on the buyer and seller must be authenticated according to the roadmap set by the Government (clause 4 of Article 11).
Point c clause 3 of Article 14: as with conditional chemicals, you must either have a warehouse or use the storage service of an organisation holding a Certificate of eligibility for chemical storage service. In addition, chemicals requiring special control must be managed and stored safely, with loss and deterioration prevented (point b clause 3 of Article 14).
A substance newly placed on the list of chemicals requiring special control that was not on the restricted list under the old law must meet the requirements of the new Law before 31 December 2026 (clause 2 of Article 48).