Law 78/2025/QH15 and Decree 37/2026/NĐ-CP sort goods into 3 risk levels in place of the old Group 1/Group 2 model — a roundup of the key content in the risk-list circulars issued so far.
From July 1, 2026, a wave of specialized-management ministries have simultaneously issued circulars announcing lists of products and goods with medium and high risk levels within their respective management scope — a concrete step in converting Vietnam's entire product and goods quality management system to risk-based management. This article is an objective roundup of the documents verified as of the time of writing, without commentary or policy-impact assessment.
On June 18, 2025, the National Assembly passed Law No. 78/2025/QH15 amending and supplementing a number of articles of the Law on Product and Goods Quality (Law No. 05/2007/QH12), effective from January 1, 2026. The Government then issued Decree No. 22/2026/NĐ-CP dated January 16, 2026 (guiding the amended Law on Standards and Technical Regulations) and Decree No. 37/2026/NĐ-CP dated January 23, 2026 (guiding the amended Law on Product and Goods Quality). These two decrees assign each ministry and ministerial-level agency managing a sector or field the responsibility of building and issuing lists of medium-risk and high-risk products and goods, together with HS codes and corresponding management measures, taking effect simultaneously from July 1, 2026.
Previously, the legal framework classified products and goods into two groups: Group 1 (products/goods with no potential to cause unsafety) and Group 2 (products/goods with the potential to cause unsafety). Law 78/2025/QH15 replaces this classification with 3 risk levels: low risk, medium risk, high risk. Risk-assessment criteria are based on the level of impact on health and the environment, the ability to control the supply chain, and warnings from relevant international organizations. High-risk products/goods must self-declare the applicable standard and be certified as conforming to the corresponding national technical regulation by a designated certification body; both medium-risk and high-risk products/goods must be managed under a list tied to specific quality-management requirements.
Issued June 30, 2026, effective from July 1, 2026. Management scope covers standards, measurement, radiation safety and information technology. The high-risk list is set out in Appendix I, the medium-risk list in Appendix II, together with HS codes under Vietnam's Import-Export Goods Nomenclature and the corresponding quality-management requirements. For medium-risk goods, test results used as a basis for self-assessment or conformity certification must be produced by an accredited testing body, or one designated/recognized by the Ministry of Science and Technology, with a testing scope matching the relevant national technical regulation.
Issued June 30, 2026, effective from July 1, 2026, replacing Circular 41/2023/TT-BCT. The medium-risk list under this circular includes groups such as: toilet paper, tissue paper, chemicals and products containing chemicals, industrial explosives, industrial explosive accessories, industrial machinery and equipment, and explosive precursors. The circular applies to organizations and individuals producing, importing or trading products/goods on the list, along with agencies and units involved in quality management for this group of goods.
Issued to apply from early July 2026, setting out the list of medium-risk and high-risk products/goods within the management responsibility of the Ministry of Agriculture and Environment — the ministry formed after merging the Ministry of Agriculture and Rural Development with part of the Ministry of Natural Resources and Environment's functions. This is one of the circulars marking the official conversion of quality-management methods to the 3-level risk model for the agriculture and environment sector.
Issued June 30, 2026, setting out the list and management principles for medium-risk and high-risk products/goods under the management responsibility of the Ministry of Public Security. It applies to units under the Ministry of Public Security, provincial/municipal police, along with organizations and individuals importing, producing or trading products/goods on this list.
Issues the list of medium-risk and high-risk products/goods within the transport sector, under the management scope of the Ministry of Construction after its merger with the Ministry of Transport under the new government organizational structure.
As of the time of writing, the circular on the medium-risk and high-risk list for medical equipment, cosmetics and other products under the Ministry of Health's management scope is still being drafted — including content defining risk levels and separate management measures for medical devices. Businesses in this sector should continue tracking the progress of the official issuance rather than applying the circulars already issued by other ministries.
Yes — under Law 78/2025/QH15 and Decree 37/2026/NĐ-CP, the previous Group 1/Group 2 classification of products and goods is replaced by 3 risk levels: low, medium, high.
Because Decree 37/2026/NĐ-CP assigns responsibility for building the risk list to each ministry/ministerial-level agency managing its specific sector or field — each ministry is responsible for the list and quality-management measures within its own management scope.
Based on published information, the Ministry of Health's circular for this sector is still in draft stage — businesses should keep tracking its official issuance progress and any transitional guidance from the managing authority.
Air Sea Worldwide (Vietnam) Co., Ltd
Ocean freight · Air freight · FCL/LCL logistics Vietnam – Latin America (Brazil, Argentina, Chile, Peru, Colombia)
Mobile: +84 968 064 737 · Email: tin.ho@asw-hochiminhcity.com.vn