Not every mixture containing a listed chemical requires a licence. Article 21 of Decree No. 26/2026/ND-CP sets concentration thresholds for exemption.
| Conditional and special-control chemicals at a concentration below 0.1% by mass of the mixture | Exempt 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 mixture | Exempt from the production and import licence |
| Decanting and blending chemicals that serve directly the internal production of the organisation doing it | Exempt from the production certificate / licence |
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.
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.