The Vietnam Ministry of Agriculture and Environment (BNNMT) has issued Circular No. 75/2025/TT-BNNMT, establishing the consolidated “List of Plant Protection Products Permitted for Use in Vietnam” and the “List of Plant Protection Products Banned from Use in Vietnam.”
Signed on December 26, 2025, this new regulation updates the registration status of hundreds of agrochemical substances and introduces specific phase-out timelines for certain active ingredients. The Circular is set to enter into force on February 10, 2026.
Background and Context
This Circular serves as the primary regulatory framework for the import, production, and trading of agrochemicals in Vietnam, grounded in the Law on Plant Protection and Quarantine No. 41/2013/QH13.
Upon its effective date, Circular 75/2025/TT-BNNMT will repeal and replace the previous regulations, specifically:
· Circular No. 25/2024/TT-BNNPTNT (dated December 16, 2024).
· Circular No. 03/2025/TT-BNNMT (dated May 16, 2025).
This update ensures that the national inventory of pesticides aligns with current safety standards and international conventions, including the Rotterdam Convention.
Key Provisions and Inventory Statistics
The new Circular categorizes plant protection products (PPPs) into permitted and banned lists (Annex I and Annex II, respectively).
1. Permitted Plant Protection Products (Annex I)
The updated list of permitted substances covers a wide range of agricultural and non-agricultural applications. Key statistics from the approved inventory include:
· Agricultural Use:
o Insecticides: 897 active ingredients (2,196 trade names).
o Fungicides: 838 active ingredients (1,957 trade names).
o Herbicides: 312 active ingredients (996 trade names).
o Rodenticides: 9 active ingredients (73 trade names).
o Growth Regulators: 67 active ingredients (207 trade names).
o Molluscicides: 31 active ingredients (162 trade names).
· Other Applications:
o Termiticides: 17 active ingredients.
o Forest Product Preservatives: 7 active ingredients.
o Warehouse Disinfectants: 3 active ingredients.
o Golf Course Maintenance: Restricted to specific insecticides (1), fungicides (2), and growth regulators (1).
2. Banned Plant Protection Products (Annex II)
The Circular explicitly prohibits specific substances due to health or environmental concerns:
· Insecticides/Forest Preservatives: 23 active ingredients.
· Fungicides: 6 active ingredients.
· Rodenticides: 1 active ingredient.
· Herbicides: 1 active ingredient.
Impact Analysis and Transitional Measures
A critical component of Circular 75/2025/TT-BNNMT is the establishment of transitional periods (grace periods) for products containing Carbosulfan and Benfuracarb. Companies dealing with these substances must adhere to strict deadlines for production, import, and trading.
Active Ingredient | Import Status | Production Deadline | Trading & Use Deadline |
Carbosulfan | Subject to Foreign Trade Management laws (Rotterdam Convention Annex III) | 3 months from effective date | 2 years from effective date |
Benfuracarb | Prohibited immediately | 3 months from effective date | 1 year from effective date |
Implications for Stakeholders:
· HS Codes: Stakeholders must refer to Section 23 and 24 of Annex I in Circular No. 01/2024/TT-BNNPTNT for the applicable HS codes for these products.
· Supply Chain Adjustment: Manufacturers and distributors of Benfuracarb and Carbosulfan must immediately adjust their supply chains to deplete stocks within the 1-year and 2-year windows, respectively.
Compliance Advice
To ensure compliance with the new requirements, industry stakeholders should take the following steps:
1. Inventory Audit: Compare current product portfolios against Annex I (Permitted) and Annex II (Banned) of Circular 75/2025/TT-BNNMT immediately.
2. Phase-Out Planning: If manufacturing or trading products containing Benfuracarb, halt imports immediately upon the effective date (Feb 10, 2026) and cease production within 3 months. Ensure all retail stock is sold or used within 1 year.
3. Rotterdam Convention Compliance: For Carbosulfan, ensure strict adherence to international trade consent procedures regarding its listing in Annex III of the Rotterdam Convention.
4. Labeling and Registration: Verify that all trade names and active ingredient concentrations match the new approved list to avoid customs or market surveillance penalties.
Conclusion
Circular 75/2025/TT-BNNMT represents a significant update to Vietnam’s agrochemical landscape, enforcing stricter controls on hazardous substances while consolidating the list of approved tools for agriculture. The regulation becomes effective on February 10, 2026. Companies are strongly advised to utilize the time before the effective date to prepare for the transitional provisions regarding Carbosulfan and Benfuracarb.
