Vietnam has overhauled how it classifies and regulates products for conformity, moving to a risk-based system. On 30 June 2026, the Ministry of Science and Technology (MOST) issued Circular No. 36/2026/TT-BKHCN, which took effect on 1 July 2026.
The circular promulgates a consolidated list of medium-risk and high-risk products under MOST’s management, each tied to its HS (Harmonised System) code, along with the quality-management requirements that apply to each tier. It replaces Circular 29/2025/TT-BKHCN and a number of earlier telecom-sector circulars, bringing several overlapping rules into a single framework.
A Two-Tier, Risk-Based Approach
Rather than treating all regulated goods the same way, the circular sorts products into two risk levels, matched to HS codes and product characteristics, with a different compliance pathway for each.
High-risk products must undergo formal conformity certification, with test results produced by a testing organisation that is accredited, designated by MOST, or otherwise recognised under Vietnamese law, and whose scope matches the relevant national technical regulation. These products are listed in Appendix I.
Medium-risk products follow a lighter path: conformity can be demonstrated through self-declaration (self-assessment) or certification, again supported by testing from a qualified organisation. These products are listed in Appendix II.
The practical effect is that the level of scrutiny now scales with the risk a product presents, concentrating the most rigorous requirements on higher-risk categories.
What Falls Into Each Tier
The appendices set out the specific products and their HS codes. In broad terms:
- High-risk categories include certain Wi-Fi transceiver equipment in the 5 GHz and 6 GHz bands above defined power levels, short-range radar devices in the 24 GHz range (for applications such as collision avoidance and vehicle detection), radio remote control equipment, and certain RFID systems.
- Medium-risk categories include RFID and radio identification/tracking devices in specified bands, short-range radar in the 76–77 GHz range for transport applications, radio navigation equipment, and ultra-wideband (UWB) devices.
Manufacturers should check their products against the exact HS-code entries in the appendices, as classification determines which compliance pathway applies.
Transition Provisions
To ease the changeover, the circular includes clear transition rules:
- Certificates of Conformity and conformity-declaration acceptance notices issued before 1 July 2026 remain valid until the expiry date stated on them.
- Applications submitted before 1 July 2026 that were not yet finalised continue to be processed under the rules in force when they were received.
This means existing valid approvals do not need to be redone immediately, but new applications from the effective date fall under the new framework.
Why This Matters
For manufacturers and importers, the shift to risk-based classification changes how compliance is planned. Whether a product needs full certification or can rely on self-declaration now depends on its risk tier and HS code, so correct classification is the essential first step. Consolidating multiple older circulars into one also makes the framework easier to navigate, once the new tiers are understood.
What This Means for Manufacturers
Businesses placing radio, wireless, and electronic products on the Vietnamese market should:
- Identify how their products are classified under Circular 36/2026/TT-BKHCN, using the HS-code lists in Appendices I and II.
- Confirm the applicable pathway — certification for high-risk products, or self-declaration/certification for medium-risk products.
- Ensure testing is carried out by an accredited, designated, or recognised testing organisation with the appropriate scope.
- Review existing certificates and pipeline applications against the transition provisions to confirm what remains valid and what must follow the new rules.
To read the official documentation (Vietnamese only), refer to Circular No. 36/2026/TT-BKHCN below.
How C-PRAV Can Support You
C-PRAV helps manufacturers and importers achieve global market access for radio, wireless, and electronic products, including for the Vietnamese market. Our team can help you classify your products under the new risk-based framework, carry out the radio, EMC, and safety testing required for conformity, and prepare and manage the certification or declaration documentation needed for a smooth path to market in Vietnam.
Have questions? We’re here to help.