Vietnam has introduced a new risk-based approach to product conformity assessment with the issuance of Circular No. 36/2026/TT-BKHCN by the Ministry of Science and Technology (MOST). Issued on 30 June 2026 and effective from 1 July 2026, the Circular establishes a unified framework for classifying and regulating products under MOST’s jurisdiction based on their level of risk.
The Circular publishes a consolidated list of medium-risk and high-risk products, each identified by its Harmonised System (HS) code, together with the conformity assessment requirements applicable to each category. It replaces Circular No. 29/2025/TT-BKHCN and several earlier telecommunications-related regulations, streamlining multiple compliance requirements into a single regulatory framework.
Two-Tier Risk Classification
Under the new framework, products are classified into two categories based on their risk profile, with different conformity assessment requirements for each.
High-risk products, listed in Appendix I, are subject to mandatory conformity certification. Compliance must be supported by testing conducted by laboratories that are accredited, designated by MOST, or otherwise recognised under Vietnamese law, with testing carried out in accordance with the relevant national technical regulations.
Medium-risk products, listed in Appendix II, may demonstrate compliance through either a conformity self-declaration or formal certification. In both cases, testing must also be performed by a qualified and recognised testing organisation.
The new approach aligns regulatory requirements with product risk, applying more stringent conformity assessment procedures to higher-risk products while simplifying compliance for lower-risk categories.
Product Categories
The Circular identifies regulated products according to their HS codes.
High-risk products include selected Wi-Fi transceivers operating in the 5 GHz and 6 GHz bands above specified power thresholds, 24 GHz short-range radar equipment used for applications such as collision avoidance and vehicle detection, radio remote control devices, and certain RFID systems.
Medium-risk products include RFID and radio identification devices, 76–77 GHz short-range radar equipment for transport applications, radio navigation equipment, and ultra-wideband (UWB) devices.
Manufacturers and importers are advised to verify their products against the HS-code listings contained in the appendices, as the assigned classification determines the applicable conformity assessment procedure.
Transitional Arrangements
To facilitate implementation, the Circular includes transitional provisions for existing approvals.
Certificates of Conformity and conformity declaration acceptance notices issued before 1 July 2026 will remain valid until their stated expiry dates. Likewise, applications submitted before the Circular came into force will continue to be processed under the regulatory requirements that applied at the time of submission.
As a result, businesses holding valid approvals are not required to obtain new certifications immediately, while all new applications submitted from 1 July 2026 onwards must comply with the new framework.
Implications for Industry
The introduction of a risk-based conformity assessment system changes how manufacturers and importers prepare products for the Vietnamese market. Whether a product requires mandatory certification or can rely on self-declaration now depends on its assigned risk category and HS classification, making accurate product classification a critical first step in the compliance process.
By consolidating multiple regulations into a single framework, the Circular also simplifies the regulatory landscape and provides greater clarity for businesses operating in Vietnam’s telecommunications and electronics sectors.
Key Actions for Manufacturers and Importers
Businesses placing radio, wireless, and electronic products on the Vietnamese market should:
Determine their products’ classification under Circular No. 36/2026/TT-BKHCN using the HS-code lists in Appendices I and II.
Identify the applicable conformity assessment route—mandatory certification for high-risk products or self-declaration/certification for medium-risk products.
Ensure product testing is conducted by accredited, designated, or officially recognised laboratories with the appropriate scope of accreditation.
Review existing certificates and pending applications to determine whether they remain valid under the Circular’s transitional provisions or must comply with the new requirements. |
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