The Ministry of Science and Technology (MST) of Vietnam has published the second draft Circular for list of products under the responsibility of the Ministry of Science and Technology, along with the corresponding HS codes in accordance with the Vietnamese Export and Import Goods List and the corresponding quality management requirements. This draft Circular will replace the Circular 29/2025/TT-BKHCN regarding the list of telecommunications and ICT products that require Type Approval and Supplier’s Declaration of Conformity (SDoC).
Organizations and individuals can give comments on the second draft Circular during the public consultation. The comments can be submitted to MST from 15 June 2026 until 15 July 2026. Therefore, in this article we will discuss all important notes from this new draft Circular for update on the list of telecommunications and ICT products that require Type Approval and SDoC in Vietnam.
Key Notes of Draft Circular
The main changes in the second drat Circular compare with the Circular 29/2025/TT-BKHCN can be summarized as follows:
- This draft Circular sets out the list of medium-risk and high-risk products under the responsibility of the Ministry of Science and Technology, along with their HS codes and related quality management requirements.
- The quality management requirements for medium-risk and high-risk products refer to Type Approval certificates and/or SDoC requirements.
- Several products under the responsibility of the Ministry of Science and Technology, including products with WWAN technology, will be treated as low-risk or medium-risk products which they will be subjected to SDoC requirement only.
- If one product that falls under the low-risk or medium-risk category is integrated with a technology which falls under the high-risk category, then still only SDoC requirement needed but testing for the high-risk technology is required.
- Regarding the Type Approval certification under Scheme 3 for high-risk products, the note about “using ISO 9001:2015 certification as a substitute for factory inspection and supervision requirements” as stated in the first draft has been removed in this new draft. However, there is no certainty whether the requirement will still apply in practice when the official Circular is issued.
- The current draft Circular stated that the effective date will be 1 July 2026. However, considering that the current public consultation period for this draft is held from 15 June 2026 to 15 July 2026. Therefore, it is estimated that the official Circular will be issued at least 1-2 months after completing the current draft Circular.
Impact on Vietnam Type Approval
Type Approval certificate and SDoC document that issued before the effective date of this draft Circular should continue to be valid until the expiration date stated in the Type Approval certificate and SDoC document. Applications for Type Approval certification received before 1 July 2026 as estimated valid date of this Circular, but not yet processed, will continue to be processed in accordance with the laws in force at the time of receipt.
Conformity assessment organizations that have been designated to conduct conformity assessments for Group 2 products under the responsibility of the Ministry of Science and Technology, and whose designation are still valid, may continue to conduct conformity assessments for high-risk and medium-risk products and goods, and the certification methods as prescribed in Appendix I and Appendix II of this draft Circular, until the expiration of the designation.
Conclusion
The implementation of the draft Circular for list of products require Type Approval and/or SDoC may affect on the type approval process in Vietnam. Therefore, doing early mitigation for adjustment and preparation to upcoming new Circular may be required, especially for products subject to Type Approval and/or SDoC. Feel free to send an email to info@narmadi.com if you have any questions and assistance about this draft Circular.
