You might already know that the Vietnam authority published the new draft National Chemical Inventory (NCI) this week. There are about 31,000 substances listed. This amount is significantly less than has been published in the national database before.
They also published a new guidance on how to add further substances which are not listed on NCI yet. Deadline for additional notifications is 15th October 2018.
In case you are currently importing substances into Vietnam, which are not yet on the newly published NCI, you can still add these substances until the deadline. After the deadline, any substance NOT listed in the NCI will be treated as a “new substance” in Vietnam. Thus, we strongly recommend that you try to list all your substances which you are currently selling to Vietnam on the NCI to avoid any issues with import at a later stage.
knoell is able to support you in preparing the documents required for adding your missing substances to the NCI in Vietnam.
Until now, it was possible to submit a word file with substance name and CAS number and company information of the supplier.
However, the submission process changed. The information summarized below is what we understand from the published documents. We are trying to confirm this with the authority and our partners, but did not get any feedback yet.
- The Vietnam authority published a software which has to be used to generate an encrypted excel file with CAS number and substance name.
- In this software also a Vietnamese company has to be named (at least Tax ID and company name; other information such as contact person, address, telephone number, etc. seem to be optional). Company information will be automatically included in the excel sheet. We assume that this company should be the Vietnamese importer who is responsible for the respective substances. But maybe also a local legal entity of the non-Vietnamese supplier would be sufficient.
- Hence, the submissions need to be separated per Vietnamese entity.
- This encrypted excel sheet has to be sent by email to the authority.
- Only substances which were already imported to Vietnam will be on NCI. Hence, they ask to submit Safety Data Sheet (SDS) and proof of import (e.g. invoice or purchase order). We assume that this should be attached to the email.
- We assume that knoell Thailand can still send these data on behalf of the supplier or local legal entity as before. But we were not able to confirm this yet, so there is a risk that it might not be accepted. Another option would be to involve the respective Vietnamese legal entity and ask them to send it by email. All documents could be prepared by knoell Thailand nevertheless.
The information we would need from you to prepare a quotation:
- How many substances need to be notified?
- For how many different Vietnamese legal entities?
- Are you able to provide the following information to us later on (required for submission but not for quotation)?
- Tax ID, company name, contact details of Vietnamese legal entity
- CAS number and chemical name of substances to be submitted for each legal entity
- SDS and invoices/purchase order which show for each of the substances that they have been imported to Vietnam already
Of course, we could also support you in checking whether your substances are also on the new NCI, if necessary.
Since the deadline is pressing and we are getting many requests, if you need our support, please come back to us as soon as possible so we can discuss further details.