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Vietnam regulation on CR approval for RoHS in electronics products

Vietnam MOIT issues draft QCVN regulation on Restriction of Hazardous Substances (RoHS) for electric and electronic products. The new QCVN is planned to take effect from 2026

Recently, the Ministry of Industry and Trade (MOIT) has issued a draft circular on "Promulgation of National technical regulation on the restriction of the use of certain hazardous substances in electrical and electronic equipment". Accordingly household appliances and ICT products will need Type Approval certificate for RoHS to enter Vietnam market. The new QCVN on RoHS has below listed key features:

1. Key features of the new regulation on RoHS

1) The new regulation shall replace MOIT Circular No. 30/2011/TT-BCT and take effect from January 01, 2026

2) Application roadmap: Encourage businesses to apply from the date of issuance of the circular, mandatory application from January 1, 2016

3) Grace period: Products that have been circulated in the domestic market before December 31, 2025 is allowed to be circulated on the market until the end of December 31, 2025.

4) The Chemical Department of the Ministry of Industry and Trade is the state management agency that guides and inspects the implementation of this Regulation

5) Method of certification of conformity (type approval certification)

a) For domestically produced products, one of the following two methods shall be applied

- Method 5: Testing of typical samples and assessment of the production process (factory audit)

- Method 7: Testing and assess shipment of goods and products (batch certification)

b) For imported manufactured products

- Method 1: Typical sample test

- Method 5: Testing of typical samples and assess the production process (factory audit) upon request from the manufacturer applying this method

6) Requirements for test rereport: Test report must be issued by a (domestic) testing laboratory that has registered testing activities in accordance with the provisions of Decree No. 107/2016/ND-CP (amended and supplemented by Decree No. 154/2018/ND-CP) or foreign testing laboratory recognized under the provisions of Circular No. 27/2007/TT-BKHCN

7) Regulatory conformity mark: Use the regulation conformity mark as prescribed in Circular No. 28/2012/TT-BKHCN (CR mark)

8) Declaration of Conformity: After getting certification of conformity, the organization or individual that manufactures and/or imports products must announce the technical-regulation conformity at the Department of Industry and Trade of province where the organization or individual registers its production and business activities.

9) The list of products covered by the Regulation is listed in the Appendices of this Regulation (listed below).

2. ExtendMax's comments on the new regulation on RoHS

1) For imported products, due to the application of Method 5 (factory audit), it is expected that a certificate of conformity can be issued under the name of a foreign organization (beside local manufacturer and importer)

2) For products imported before January 1, 2026 and expected to continue circulating in the Vietnamese market after January 1, 2026, organizations and individuals still need to carry out certification of conformity and declaration of conformity before January 1, 2026.

3) The Ministry of Industry and Trade (Department of Chemicals) will issue implementation instructions and detailed application schedule in a follow-up document.

3. List of home appliances and ICT products under RoHS mandatory scope

a. Large household appliance group

1) Large cooling appliances, Refrigerators, Freezers, Other large appliances used for refrigeration, conservation and storage of food

2) Washing machines, Clothes dryers

3) Dish washing machines, Cookers, Electric stoves, Electric hot plates, Microwaves, Other large appliances used for cooking and other processing of food

4) Electric heating appliances, Electric radiators, Other large appliances for heating rooms, beds, seating furniture

5) Electric fans, Air conditioner appliances, Other fanning, exhaust ventilation and conditioning equipment

b. Small household appliance group

1) Vacuum cleaners, Carpet sweepers, Other appliances for cleaning

2) Appliances used for sewing, knitting, weaving and other processing for textiles

3) Irons and other appliances for ironing, mangling and other care of clothing

4) Toasters, Fryers, Grinders, coffee machines and equipment for opening or sealing containers or packages

5) Electric knives

6) Appliances for hair cutting, hair drying, tooth brushing, shaving, massage and other body care appliances

7) Clocks, watches and equipment for the purpose of measuring, indicating or registering time

8) Electronic Scales

c. IT and telecommunications equipment group

1) Server, mini PC, Personal computers (CPU, mouse, screen and keyboard included)

2) Notebook computer, notepad computer

3) Printer and photocopier

4) Electrical and electronic typewriters

5) Pocket and desk calculators and other products and equipment for the collection, storage, processing, presentation or communication of information by electronic means

6) User terminals and systems

7) Facsimile machine (fax)

8) Telex, Telephones, Pay telephones, Cordless telephones, Cellular telephones

9) Answering systems and other products or equipment of transmitting sound, images or other information by telecommunications

10) TV sets, radio, Video cameras, Hi-fi recorders, Audio amplifiers

d. Other products group

An several other product groups

4. Other regulations applied to household appliances and ICT equipment

Learn more:

MOST CR Safety and EMC approval

MIC Type Approval for wireless and ICT products

MOIT Energy Efficiency regulation and certification

Tran Thanh Phuong
I am Tran Thanh Phuong, a jurist specializing in Product Quality Law, Cyber Information Security Law, Customs Law, Foreign Trade Management Law, and Commercial Law. I am a consultant trusted by the world's leading technology corporations in the field of consulting on legal regulations and market access requirements for importing information technology products into Vietnam
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