Vietnam Opens Brief Window to Add Chemicals to National Database

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September 19, 2018 - Verisk 3E Regulatory Research Team

Companies with chemical substances on the market in Vietnam now have a brief window during which to ensure that their chemicals are included in the new National Chemical Substances Database.

On 14 September 2018 Vietnam's Chemicals Agency (VCA) and the Ministry of Industry and Trade (MOIT) announced that VCA is accepting additional chemical information to the National Chemical Database. This action allows companies to notify their chemical substances that are currently in commerce but have not yet been included in Vietnam's chemical database. VCA will continue to accept updates until 15 October 2018.

Context
Under the chemical management decree, the national authorities must compile an inventory of chemicals in Vietnam. The government issued the first and second draft of the chemical inventory in September 2016 and March 2017, asking for feedback from industry and additional chemical nominations from industry and stakeholders. However, it was announced during November 2017 that the government had temporarily stopped accepting nominations to the draft chemical inventory, and there had been no major movement since then - until now.

Following a long government project to build the Vietnamese National Chemical Inventory, on 2 August 2018 MOIT announced that it decided to publish a notification on the launch of the National Chemical Database System, completing and putting into operation of the official National Chemical List and the National Chemical Substances Database. The database, which contains 170,654 substances, was finalized and officially operative as of 31 July 2018.

This announcement has caught businesses by surprise and has created confusion and generated concerns. In theory, any substances not listed on the inventory will be regarded as new substances and require registration before they can be used, imported or produced in Vietnam. However, up to now, the government has not issued any official instruction or notification on this subject.

Current notification period
The new notification announced on 14 September 2018 is aimed to create conditions for businesses to add chemicals to the database that are currently on the market but not yet included in this national chemical inventory.

Enterprises should provide the following information related to the chemical substances:

  • Name of the substance;
  • CAS RN; and
  • Documents/ records proving that chemicals have been used/marketed in Vietnam (such as purchase contracts or invoices).

Information can be sent to VCA via email or mail on or before 15 October 2018. After this time, VCA will not receive additional information submission to the National Chemical Database.

Companies can check and add chemicals to the National Chemical Database by using the reporting software developed by VCA, which can be found here. A user training course is provided by VCA as well.

Business impact
Due to the short notification window period, chemical manufacturers and importers should make haste to consult and check that their chemicals have already been listed in the existing databases, and if any chemicals are not included, the company should submit information to the government for the inclusion of such substances by 15 October 2018. Under the law, any substances not listed on the inventory will be regarded as new substances and should therefore require registration before they can be used, imported or produced in Vietnam.

Businesses seeking to add substances to the inventory should submit the entity's name, contact information, type of business, the name of the chemical(s) and associated CAS RNs as well as applicable HS code number/s. It is also required to provide records proving the chemical/s have been used/marketed in Vietnam. Parties seeking to submit chemicals for inclusion on the inventory list should use the form included in the link here: https://1drv.ms/f/s! At55XAvfvmLDgcUHhbWpw_n5w4Ypzg.

Any inquiries should be sent to Chemical Industry Development Dept., Chemical Dept., 21 Ngo Quyen Str., Hoan Kiem Dist., Hanoi. Tel: 024 2220 5118; Email: hanhtn@moit.gov.vn.

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