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Licence exemptions by concentration: below 0.1%, below 1% and below 5%

2026-10-06

Not every mixture containing a listed chemical requires a licence. Article 21 of Decree No. 26/2026/ND-CP sets concentration thresholds for exemption.

The thresholds

Conditional and special-control chemicals at a concentration below 0.1% by mass of the mixtureExempt from the production and trading certificate / licence
Special-control chemicals group 1 below 1%;
group 2 below 5% by mass of the mixture
Exempt from the export and import licence
Banned chemicals at a concentration below 0.1% by mass of the mixtureExempt from the production and import licence
Decanting and blending chemicals that serve directly the internal production of the organisation doing itExempt from the production certificate / licence

Why this is worth reading closely

Most surface-treatment products, paints and pre-blended solvents are mixtures. The mere presence of a listed substance in the formulation does not automatically trigger a licensing obligation — concentration is what decides. Conversely, crossing the threshold even slightly triggers the full set of obligations.

A licence exemption is not a safety exemption: GHS classification and labelling, the safety data sheet, Measures or a Plan, training and record keeping all continue to apply under the Law on Chemicals.

Related: Article 18 of the Law

Article 18 of Law No. 69/2025/QH15 also exempts mixtures classified as hazardous at a low level and decanting and blending for internal production. Decree 26/2026/ND-CP is where the actual thresholds are written.

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