Does Decree 292/2026/NĐ-CP completely replace Decree 69/2018/NĐ-CP?

Yes — this is a replacement decree, resetting the entire content guiding implementation of the Law on Foreign Trade Management, including the List of Goods Banned from Export and Import in Appendix I.

Do businesses that already hold a permit to export/import special goods under the old decree need to reapply?

The decree does not state a retroactive rule for permits validly issued before it took effect; however, businesses should proactively contact the licensing agency to confirm, especially if the permit is about to expire or the goods fall under a newly added group.

Why are e-cigarettes and heated tobacco products banned from both export and import?

These products were already banned from production, trading and import in Vietnam under National Assembly Resolution 173/2024/QH15, effective from 2025. Decree 292/2026/NĐ-CP formally places these goods on the List of Goods Banned from Export and Import to align with foreign-trade management regulations.

Decree 292/2026/NĐ-CP: What's New in the List of Goods Banned from Export and Import

On July 22, 2026, the Government issued Decree No. 292/2026/NĐ-CP detailing a number of articles and implementing measures of the Law on Foreign Trade Management, replacing Decree 69/2018/NĐ-CP, which had been in force for nearly 8 years. Article 5 and Appendix I of the new decree reset the entire List of Goods Banned from Export and Import — with the import-ban list expanding significantly, from 14 to 23 goods groups. For import-export businesses, this is not just a document-number update. Several goods are being placed on the ban list for the first time — most notably the ban on importing goods produced using forced labor, and the ban on both exporting and importing e-cigarettes and heated tobacco products.

What document does Decree 292/2026/NĐ-CP replace

Decree 292/2026/NĐ-CP details a number of articles of the 2017 Law on Foreign Trade Management and replaces Decree 69/2018/NĐ-CP — a document that had been amended and supplemented many times through specialized circulars (Ministry of National Defense, Ministry of Industry and Trade, Ministry of Agriculture and Environment, Ministry of Construction...) over nearly 8 years. The List of Goods Banned from Export and Import in Appendix I of the new decree has been rebuilt comprehensively, while also updating the names of managing ministries to match the government's organizational structure after the 2025 ministry-merger round (the Ministry of Agriculture and Rural Development is now the Ministry of Agriculture and Environment; the Ministry of Transport is now the Ministry of Construction; some authority of the Ministry of Information and Communications has moved to the Ministry of Science and Technology).

The legal mechanism: banned, but a permit is still possible in special cases

Article 5 of Decree 292/2026/NĐ-CP retains the same principle: goods banned from export and import are listed in Appendix I, and ministries/ministerial-level agencies are responsible for publishing the detailed HS codes. Notably, the decree specifies the file and process for applying to export or import banned goods where necessary (Clauses 3-7, Article 5): the trader submits an application per the prescribed form, along with documents explaining the intended use plan and the disposal plan after use; the licensing agency notifies within 3 working days if the file is incomplete, and issues the permit within 5 working days from when the file is complete. Banned goods imported under a permit may only be kept and used in Vietnam for a maximum of 2 years, and the trader must report annually (by December 31 at the latest) on how the goods have been used.

Export-ban list: 2 new goods groups added

Compared with Decree 69/2018/NĐ-CP, the export-ban list in Appendix I of Decree 292/2026/NĐ-CP grows from 7 to 10 goods groups. The existing groups (weapons, cryptographic products, antiques/relics, banned publications, natural forest timber, CITES specimens/rhinoceros/elephant, hazardous chemicals) remain essentially the same in scope. Two entirely new groups:

Rough diamonds banned from export under the Kimberley Process Certification Scheme (managed by the Ministry of Industry and Trade) — previously, the export-ban list in Decree 69/2018/NĐ-CP had no separate entry for rough diamonds.
E-cigarettes and heated tobacco products (managed by the Ministry of Industry and Trade) — officially placed on the List of Goods Banned from Export for the first time.

Import-ban list: expanded from 14 to 23 goods groups

This is the section with the most changes. Besides adding rough diamonds and e-cigarettes/heated tobacco (mirroring the export-ban list), Decree 292/2026/NĐ-CP splits out and adds several goods groups that Decree 69/2018/NĐ-CP previously either didn't regulate separately or regulated more narrowly:

Goods mined, produced or manufactured in whole or in part through forced labor — an entirely new regulation, managed by the Ministry of Home Affairs, in line with the international treaties Vietnam is a party to.
Drugs and pharmaceutical materials on the list of banned imports/banned production — split into a separate entry managed by the Ministry of Health (previously grouped together with "used medical equipment").
Radioactive waste — split out separately, managed by the Ministry of Science and Technology (Decree 69/2018/NĐ-CP previously only stated generally "scrap, waste, CFC-using refrigeration equipment").
Veterinary drugs banned for use in Vietnam — split into a separate entry managed by the Ministry of Agriculture and Environment.
Controlled substances and equipment/products containing or manufactured from controlled substances under international treaties protecting the ozone layer — a much broader scope than the previous rule, which was limited to "CFC-using refrigeration equipment."

Tighter rules on right-hand-drive vehicle imports

A notable but less-discussed change: the list of right-hand-drive vehicles exempted from the import ban has been narrowed considerably. Decree 69/2018/NĐ-CP previously exempted quite a few narrow-use specialized vehicle types: crane trucks, trench-digging machines, road-sweeping/watering trucks, garbage trucks, road-paving vehicles, airport passenger vehicles, warehouse/port forklifts, concrete pump trucks, and vehicles for moving around golf courses/parks. Decree 292/2026/NĐ-CP now exempts only 3 groups: fire trucks, airport passenger vehicles, and specialized-use motor vehicles (not including tractors). Businesses importing right-hand-drive specialized vehicles previously covered by the exemption need to review their status, as many are likely no longer exempt under the new rules.

What businesses need to do

Review the goods you're currently exporting/importing against the 10 export-ban groups and 23 import-ban groups in Appendix I of Decree 292/2026/NĐ-CP — pay special attention if you deal in e-cigarettes, diamonds, or have a supply chain that may involve forced labor.
For businesses importing right-hand-drive specialized vehicles: check whether your vehicle type still falls within the 3 exempted groups.
If goods on the ban list are needed for export/import for a special purpose (exhibition, research, aid...), prepare the file under Clause 4, Article 5 (application per Form 01, documents explaining the intended use plan, and the post-use disposal plan) and submit it to the competent licensing authority.
Watch for the detailed HS-code notices to be issued separately by each ministry/ministerial-level agency — since the new Appendix I only describes the goods, with the specific HS codes to be published separately by the specialized ministries.