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Vietnam: Guidance on import license requirements for chemicals requiring special control

RCD5 clarifies when a chemical import license is needed for customs procedures involving bonded warehouses under new law.

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march 26, 2026

The Regional Customs Sub-Department V (RCD5) on March 17, 2026, issued guidance on the requirement to submit an import license for chemicals requiring special control when carrying out customs procedures.

This follows the promulgation of the Law on Chemicals No. 69/2025/QH15, which took effect on January 1, 2026, and has raised questions regarding when a chemical import license is required during customs procedures, especially in cases involving bonded warehouses.

Key points of the guidance include:

  • For goods imported from overseas and sent to bonded warehouses to await importation into the domestic market or export to a third country, submission of a chemical import license is not required.
  • When imported goods from bonded warehouses are brought into use in Vietnam or into a non-tariff zone, a chemical import license must be submitted during customs procedures. Export processing enterprises purchasing chemicals requiring special control from domestic enterprises, with the chemicals stored in bonded warehouses, are still required to submit a chemical import license.
  • If goods are imported from overseas into a bonded warehouse and the importing enterprise has already obtained the chemical import license, the domestic enterprise purchasing these goods does not need to obtain a new license. However, the importing enterprise must provide documents and evidence of the sale and transfer of ownership for the domestic enterprise to submit during customs procedures for importation from the bonded warehouse into the domestic market.

The official letter also clarifies which laws, decrees, and official letters are no longer valid and highlights the currently effective regulations for consistent implementation across customs units.

Read a March 2026 report prepared by the KPMG member firm in Vietnam

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