ILMA Compoundings – March 2019 - 12

INDUSTRY RUNDOWN

International Insight
Vietnam REACH
Next step toward REACH-like
controls
By James Eggenschwiler
Like many countries around the world, Vietnam has
joined the growing trend toward more sophisticated
and stratified chemical management. As the country
pushes to grow its international commercial presence,
its chemical regulatory policies are changing toward
more detailed visibility and control over chemical
ingredients. Its latest installment is Decree 113/2017/
ND-CP (Decree 113), which was announced and
implemented at the end of 2017. While it doesn't
establish a truly comprehensive chemical substance
inventory and corresponding system of managing
"new" and "existing" chemical substances, it serves as a
leap in that direction while the government continues its
pursuit of that goal.
THE GLOBAL REACH CONTEXT
Chemical controls are not entirely new to the industry
in Vietnam, but the growth of published and systematic
regulations began in earnest as some of its neighbors (China,
Japan, South Korea and Taiwan) entered the limelight
with their respective regulatory schemes. How much of
the government's motivation was influenced by the need
for sound chemical management policy, as opposed to
the attraction posed by adding a more complex chemical
regulation industry to its economy, will never be clear. Both
notions go hand in hand and are clearly being accomplished.
DECREE 113
Like many other jurisdictions that have more recently begun
similar aspirations, Vietnam is putting its own spin on its
specific regulatory requirements and process. Beginning
with management of hazardous and toxic chemicals, the
decree establishes an inventory of more than 2,500 chemical

12

MARCH 2019

| COMPOUNDINGS | ILMA.ORG

substances among five lists. Each list represents a category
of hazard or risk for which a license is required prior to
manufacture or importation.
For chemical product imports, this regulatory process
begins with a requirement for all importers to declare the
content of the chemical products intended for import.
This is supported by an electronic portal that requires full
content disclosure by hazard/risk type. Ingredients that
do not contribute to the hazard GHS classification (based
on Version 2 of the Purple Book) may be disclosed using
a masked chemical name to protect confidential business
information (CBI). However, chemical ingredients that
contribute to the GHS classification, and those below that
threshold posing more stringently controlled hazard or risk
profile, must be fully identified. CBI claims concerning
these more stringently controlled ingredients will not be
honored, if made.
Chemicals that are not included on any of the lists,
but pose similar hazard or risk, must be registered prior
to import. The registration process involves submittal of
details concerning the chemical substance, but Decree 113,
as published, does not provide any details concerning the
specific data required, the process to be followed by the
importer or the reviewing agency, or the time required for
the evaluation and approval process.
One of the more potentially cumbersome aspects of
Decree 113 is the need for importers to follow the disclosure
and licensing process with each import transaction (entry)
concerning the product. For now, at least, there does not
appear to be allowance for repetitive imports during a
specific time period by the same importer and product.
BENEFITS OF THE NEW REQUIREMENTS
In contrast to many of its neighbors in the region, Vietnam
has not been a free market for imports, or otherwise, for
decades. Imports, in particular, have been subject to permits
or licensing on a continuing basis. Among the advantages
introduced by the decree is a system that is not inherently
based on undocumented requirements, unsystematic
approach and inconsistent enforcement. Decree 113 offers
a significantly new environment that benefits importers and
foreign suppliers alike.


http://www.ILMA.ORG

ILMA Compoundings – March 2019

Table of Contents for the Digital Edition of ILMA Compoundings – March 2019

Letter From the Ceo
Inside Ilma
What’s Coming Up
Industry Rundown
In the Know
International Insight
Market Report
Points on a Recycling Continuum
How Are You Regulated?
My Cybersecurity Playbook
Business Hub
Counsel Compound
Washington Landscape
In Network
Member Connections
ILMA Compoundings – March 2019 - Cover1
ILMA Compoundings – March 2019 - Cover2
ILMA Compoundings – March 2019 - 1
ILMA Compoundings – March 2019 - 2
ILMA Compoundings – March 2019 - Letter From the Ceo
ILMA Compoundings – March 2019 - Inside Ilma
ILMA Compoundings – March 2019 - 5
ILMA Compoundings – March 2019 - 6
ILMA Compoundings – March 2019 - 7
ILMA Compoundings – March 2019 - 8
ILMA Compoundings – March 2019 - 9
ILMA Compoundings – March 2019 - What’s Coming Up
ILMA Compoundings – March 2019 - In the Know
ILMA Compoundings – March 2019 - International Insight
ILMA Compoundings – March 2019 - 13
ILMA Compoundings – March 2019 - Market Report
ILMA Compoundings – March 2019 - Points on a Recycling Continuum
ILMA Compoundings – March 2019 - 16
ILMA Compoundings – March 2019 - 17
ILMA Compoundings – March 2019 - How Are You Regulated?
ILMA Compoundings – March 2019 - 19
ILMA Compoundings – March 2019 - 20
ILMA Compoundings – March 2019 - 21
ILMA Compoundings – March 2019 - My Cybersecurity Playbook
ILMA Compoundings – March 2019 - 23
ILMA Compoundings – March 2019 - 24
ILMA Compoundings – March 2019 - 25
ILMA Compoundings – March 2019 - Business Hub
ILMA Compoundings – March 2019 - 27
ILMA Compoundings – March 2019 - Counsel Compound
ILMA Compoundings – March 2019 - 29
ILMA Compoundings – March 2019 - Washington Landscape
ILMA Compoundings – March 2019 - 31
ILMA Compoundings – March 2019 - In Network
ILMA Compoundings – March 2019 - 33
ILMA Compoundings – March 2019 - 34
ILMA Compoundings – March 2019 - 35
ILMA Compoundings – March 2019 - Member Connections
ILMA Compoundings – March 2019 - Cover3
ILMA Compoundings – March 2019 - Cover4
https://www.nxtbook.com/ygsreprints/ILMA/G127535ILMA_vol71_no7
https://www.nxtbook.com/ygsreprints/ILMA/G126213ILMA_vol71_no6
https://www.nxtbook.com/ygsreprints/ILMA/G125546_ILMA_vol71_no5
https://www.nxtbook.com/ygsreprints/ILMA/G124996_ILMA_vol71_no4
https://www.nxtbook.com/ygsreprints/ILMA/G123886_ILMA_vol71_no3
https://www.nxtbook.com/ygsreprints/ILMA/G123315_ILMA_vol71_no2
https://www.nxtbook.com/ygsreprints/ILMA/G122980_ILMA_vol71_no1
https://www.nxtbook.com/ygsreprints/ILMA/G121540_ILMA_vol70_no11
https://www.nxtbook.com/ygsreprints/ILMA/G120882_ILMA_vol70_no10
https://www.nxtbook.com/ygsreprints/ILMA/G120035_ILMA_vol70_no9
https://www.nxtbook.com/ygsreprints/ILMA/G121XXX_ILMA_vol70_no8
https://www.nxtbook.com/ygsreprints/ILMA/G120XXX_ILMA_vol70_no7
https://www.nxtbook.com/ygsreprints/ILMA/G119XXX_ILMA_vol70_no6
https://www.nxtbook.com/ygsreprints/ILMA/G118112_ILMA_vol70_no5
https://www.nxtbook.com/ygsreprints/ILMA/G117382_ILMA_vol70_no4
https://www.nxtbook.com/ygsreprints/ILMA/G116888_ILMA_vol70_no3
https://www.nxtbook.com/ygsreprints/ILMA/G115555_ILMA_vol70_no2
https://www.nxtbook.com/ygsreprints/ILMA/G114774_ILMA_vol70_no1
https://www.nxtbook.com/ygsreprints/ILMA/g110500_ILMA_vol69_no12
https://www.nxtbook.com/ygsreprints/ILMA/g110500_ILMA_vol69_no11
https://www.nxtbook.com/ygsreprints/ILMA/g110500_ILMA_vol69_no10
https://www.nxtbook.com/ygsreprints/ILMA/g109884_ILMA_vol69_no9
https://www.nxtbook.com/ygsreprints/ILMA/g109284_ILMA_vol69_no8
https://www.nxtbook.com/ygsreprints/ILMA/g108494_ILMA_vol69_no7
https://www.nxtbook.com/ygsreprints/ILMA/g107507_ILMA_vol69_no6
https://www.nxtbook.com/ygsreprints/ILMA/g106483_ILMA_vol69_no5
https://www.nxtbook.com/ygsreprints/ILMA/g105803_ILMA_vol69_no4
https://www.nxtbook.com/ygsreprints/ILMA/g104743_ILMA_vol69_no3
https://www.nxtbook.com/ygsreprints/ILMA/g103647_ILMA_vol69_no2
https://www.nxtbook.com/ygsreprints/ILMA/g102869_ILMA_vol69_no1
https://www.nxtbook.com/ygsreprints/ILMA/g101930_ILMA_vol68_no12
https://www.nxtbook.com/ygsreprints/ILMA/g100836_ILMA_vol68_no11
https://www.nxtbook.com/ygsreprints/ILMA/g99200_ILMA_vol68_no10
https://www.nxtbook.com/ygsreprints/ILMA/g98468_ILMA_vol68_no9
https://www.nxtbook.com/ygsreprints/ILMA/g97711_ILMA_vol68_no8
https://www.nxtbook.com/ygsreprints/ILMA/G96767ILMA_vol68_no7
https://www.nxtbook.com/ygsreprints/ILMA/G95397ILMA_vol65_no6
https://www.nxtbook.com/ygsreprints/ILMA/G94323ILMA_vol68_no5
https://www.nxtbook.com/ygsreprints/ILMA/G93127_ILMA_vol69_no4
https://www.nxtbook.com/ygsreprints/ILMA/G91785_ILMA_vol68_no3
https://www.nxtbook.com/ygsreprints/ILMA/G90956_ILMA_vol68_no2
https://www.nxtbook.com/ygsreprints/ILMA/G89146_ILMA_vol68_no1
https://www.nxtbook.com/ygsreprints/ILMA/G87981_ILMA_vol67_no12
https://www.nxtbook.com/ygsreprints/ILMA/G85409_ILMA_vol67_no11
https://www.nxtbook.com/ygsreprints/ILMA/G83595_ILMA_vol67_no10
https://www.nxtbook.com/ygsreprints/ILMA/G81672_ILMA_vol67_no9
https://www.nxtbook.com/ygsreprints/ILMA/G80238_ILMA_vol7_no8
https://www.nxtbook.com/ygsreprints/ILMA/G79388_ILMA_vol7_no7
https://www.nxtbook.com/ygsreprints/ILMA/G78361_ILMA_vol7_no6
https://www.nxtbook.com/ygsreprints/ILMA/G77448_ILMA_vol7_no5
https://www.nxtbook.com/ygsreprints/ILMA/G75899_ILMA_vol67_no4
https://www.nxtbook.com/ygsreprints/ILMA/G75036_ILMA_vol67_no3
https://www.nxtbook.com/ygsreprints/ILMA/G72720_ILMA_vol67_no2
https://www.nxtbook.com/ygsreprints/ILMA/G72220_ILMA_vol67_no1
https://www.nxtbook.com/ygsreprints/ILMA/G70970_ILMA_vol66_no12
https://www.nxtbook.com/ygsreprints/ILMA/G69813_ILMA_vol66_no11
https://www.nxtbook.com/ygsreprints/ILMA/G67522_ILMA_vol66_no10
https://www.nxtbook.com/ygsreprints/ILMA/G66343_ILMA_vol66_no9
https://www.nxtbook.com/ygsreprints/ILMA/G64859_ILMA_vol66_no8
https://www.nxtbookmedia.com