Response Letter from the Customs Department Regarding the Declaration of Chemical Composition for Imports

On May 15, 2026, the Customs Department (Ministry of Finance) issued Official Letter No. 16292/CHQ-GSQL to the U.S.-ASEAN Business Council (USABC) to exchange information regarding the declaration of chemical components. This letter serves as a response to USABC’s Official Letter No. USABC-HN-20260319-01 dated March 19, 2026, which highlighted the difficulties faced by member companies regarding the requirement to declare 100% of chemical composition information in detail during import procedures

Requirements for Chemical Composition Declaration during Import

According to Official Letter No. USABC-HN-20260319-01, some customs offices have recently notified importers that they must declare 100% of the detailed chemical information (CAS numbers, percentage content of each component, etc.) to meet clearance requirements. Previously, this requirement was applied randomly or on a case-by-case basis, but based on feedback from many businesses, it is now becoming mandatory in certain regions.

Survey Results from the General Department of Customs

Based on survey results collected by the General Department of Customs from local customs branches, since the 2025 Chemicals Law and its implementing guidelines took effect, neither the General Department of Customs nor regional customs branches have issued any documents providing guidance on chemical import and export activities. Regarding the requirement for 100% detailed declaration of chemical composition information, 

Customs officials are authorized to request that the declarant provide technical documents and other relevant information regarding the goods to determine the goods’ name and commodity code as the basis for tax calculation and the implementation of goods management policies

For chemical goods that are special items requiring specialized expertise to determine their nature, customs authorities may request the customs declarant to provide additional information, technical documents, and relevant supporting documents in cases where there is insufficient basis to verify the accuracy of the goods, specifically:

• The customs declaration does not clearly specify the composition of the goods, and there is insufficient basis to determine whether the goods fall under the List of Conditionally Permitted Chemicals, Chemicals Requiring Special Control, or Prohibited Chemicals;
• The customs declaration does not provide sufficient information regarding the concentration or content of chemical components, and there is no basis to determine whether the chemical meets the conditions for applying exemptions from the requirement to obtain a License/Certificate; The concentration thresholds of 0.1%, 1%, and 5% as stipulated by specialized laws (Decree 24/2026/NĐ-CP, Decree 26/2026/NĐ-CP).

If the additional information and documents provided by the customs declarant still lack a legal basis and sufficient grounds to accurately determine the nature and composition of the chemical, the customs authority will conduct analysis, classification, or request an expert appraisal as the basis for the clearance decision in accordance with legal regulations.

View the full text of the Official Letter No. 16292/CHQ-GSQL here.