Vietnam's 2025-2026 Product Quality Reforms And What They Mean For Market Access

Vietnam has introduced major changes to its product quality and conformity assessment framework since 2025. The new risk-based system changes how products are classified, assessed, and monitored, with particular implications for ICT equipment, telecommunications products, connected devices, and IP surveillance cameras. 

1. Law No. 78/2025/QH15

The updated Law on Product and Goods Quality (Law No. 78/2025/QH15) introduces a new risk-based management framework for products and goods, including:

• Risk-based product classification
• Stronger market surveillance and enforcement
• More rigorous product traceability requirements
• Digital compliance tools and electronic documentation
• Manufacturer and importer responsibility throughout the product lifecycle

Manufacturers are now responsible for ongoing conformity, product traceability, and post-market monitoring beyond initial certification.

2. Decree 37/2026/ND-CP

Decree 37/2026/ND-CP sets out how the new laws will be implemented, covering product traceability, digital product passports, conformity assessment, inspection exemptions, and risk-based import controls.

One of the biggest changes is the shift away from the traditional Group 2 approach to a medium- and high-risk classification model. Ministries must publish product lists for each risk category and specify the applicable quality management requirements.

The decree also introduces several digital and risk-based measures, including:

• Electronic labeling
• Digital traceability systems
• National quality databases
• Information sharing between regulatory agencies
• Fewer repetitive, shipment-by-shipment inspections

For manufacturers and market access teams, certification strategies will need to account for risk classification, HS codes, post-market obligations, and digital compliance requirements.

3. Circular 14/2026/TT-BKHCN

The Ministry of Science and Technology issued Circular 14/2026/TT-BKHCN on 25 May 2026, establishing a framework for conformity certification, declarations, and assessment methods.

Key changes include:

• Acceptance of electronic compliance labels
• Online registration of Declarations of Conformity through national databases
• Extending the validity of certain certification schemes from three years to five
• Introducing a more risk-based approach to conformity assessment
• Greater emphasis on quality management systems and factory controls

Simplified certification routes are now more limited, particularly for high-risk products. Manufacturers may therefore need certification methods involving factory audits or ongoing production controls.

4. Circular 16/2026/TT-BKHCN

Issued alongside Circular 14, Circular 16/2026/TT-BKHCN updates Vietnam’s approach to foreign conformity assessment results.

It introduces a unilateral recognition mechanism, allowing Vietnamese authorities to recognize conformity assessment results from foreign organizations even when no formal Mutual Recognition Agreement (MRA) exists.

For international manufacturers and testing laboratories, this could reduce duplicate testing and simplify market access. However, the practical impact will depend on future recognition decisions and product-specific requirements.

5. Circular 36/2026/TT-BKHCN

Circular 36/2026/TT-BKHCN, effective July 1 2026, establishes the Ministry of Science and Technology’s official lists of medium- and high-risk products, replacing the previous product-list approach.

High-Risk Products

Examples include certain radio transmitters, wireless infrastructure products, radar equipment, RFID systems, and Wi-Fi equipment operating in specified bands. These products generally require:

• Type Approval Certification
• Declaration of Conformity
• Additional quality management measures
• Quality inspection procedures in some cases

Medium-Risk Products

Examples include mobile devices, many computers, tablets, ICT equipment, NFC products, wireless charging devices, and selected radio equipment. Requirements are generally lighter and rely more heavily on Declaration of Conformity mechanisms.

6. New Cybersecurity Requirements for Connected Products

The Ministry of Public Security issued Circular 48/2026/TT-BCA, introducing QCVN 11:2026/BCA, which sets mandatory cybersecurity requirements for IP surveillance cameras.

The requirements cover:

• Unique passwords
• Vulnerability management
• Secure firmware updates
• Data protection
• Secure communication channels
• Access control
• User privacy

For IP surveillance cameras, cybersecurity is now part of the product compliance process alongside safety, EMC, RF, and telecom requirements.

Circular 125/2026/TT-BCA complements this framework by classifying IP surveillance cameras as regulated products under the Ministry of Public Security's risk-based management framework.

Next Steps to Maintain Market Access

Manufacturers, testing organizations, and market access teams should:

• Review product risk classifications under the new framework.
• Reassess certification and Declaration of Conformity strategies.
• Prepare for expanded traceability and digital compliance requirements.
• Evaluate cybersecurity requirements for connected products.
• Monitor implementation guidance and recognition policies that may affect testing and certification.

Compliance planning is only becoming a more important part of product development and market entry in Vietnam. To get started, contact Nemko today.