Vietnam Proposes Adding Four New Substances to the RoHS List

By Thuy Dang, senior regulatory specialist, Supply Chain team, UL Solutions 

Vietnam’s Ministry of Industry and Trade (MOIT) opened a public consultation period from Aug. 19 to Oct. 17, 2022, for the draft circular promulgating the National Technical Regulation on the restriction of the use of certain hazardous substances (RoHS) in electrical and electronic equipment (EEE). 

The proposed scope of the regulation applies to any organizations and individuals who manufacture, trade and import EEE (stipulated in Annex I) in Vietnam. The draft circular contains two more annexes of EEE and medical devices exempt from the RoHS thresholds. 

Referencing the EC Directive 2002/95/EC, EC Directive 2011/65/EC and Commission Delegated Directive (EU) 2015/863, the table of permissible content limitation of some hazardous chemicals consists of 10 substances with the addition of 4 substances below: 

• Bis(2-ethylhexyl) phthalate (DEHP); 
• Benzyl butyl phthalate (BBP); 
• Dibutyl phthalate (DBP); 
• Diisobutyl phthalate (DIBP). 

The new substances would be regulated at the threshold of 1000 mg/kg or 0.1% mass. In comparison to current Circular No. 30/2011/TT-BCT, the threshold table has additional unit (mg/kg) added for the 6 existing chemical substances. All substances are set at 1000 mg/kg except for Cadmium at 100 mg/kg.
The proposed

Effective date is Jan. 1, 2026. In accordance with Circular No. 30/2011/TT-BCT, EEE are allowed to be circulated in the market until Dec. 31, 2025. 

Recommended action items

• Check if your products contain any concerned chemical substance.
• Submit any comments or concerns you might have to the MOIT via the hyperlink in Reference.
• Keep an eye out for the publication of the official amendments.

Reference

Draft Circular on National Technical Regulations on Permissible Content Limits of Some Hazardous Chemicals in Electrical and Electronic Products