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What “conditional chemicals” are, and what trading in them requires

2026-10-05

In Law on Chemicals No. 69/2025/QH15, the group that older material called “chemicals subject to conditional production and trading” now has a shorter name: hóa chất có điều kiện, conditional chemicals.

Definition

Under point a clause 1 of Article 9, conditional chemicals are hazardous substances and mixtures on the list of chemicals subject to conditional production and trading issued by the Government. That list sits in Decree 24/2026/ND-CP.

Chemical activities involving this group must comply with the safety and environmental protection rules in the Law and in related legislation (point b clause 1 of Article 9).

Requirements for trading

Clause 1 of Article 11 sets four requirements for an organisation trading in chemicals:

Who issues the certificate, and for how long

The Certificate of eligibility to trade in conditional chemicals is issued by the provincial People’s Committee and is valid for five years from the date of issue. The same body re-issues, amends and revokes it (clause 2 of Article 11).

Storing this group

Point b clause 2 of Article 14: an organisation or individual must have a warehouse in order to store conditional chemicals, or use the chemical storage service of an organisation holding a Certificate of eligibility for chemical storage service.

Transitional periods

Some cases are exempt from the certificate of eligibility for chemical production and trading (Article 18 of the Law). Please check that article before concluding that your company must apply.

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