On 30 June 2026, the Ministry of Science and Technology (MST) of Vietnam has officially issued Circular No. 36/2026/TT-BKHCN for the list of medium and high risk products under the responsibility of the Ministry of Science and Technology, along with their corresponding HS codes based on Vietnam’s List of Export and Import Goods and applicable quality management requirements. This risk-based product classification covers wide range of product categories under the responsibility of the MST, including the products in the information, technology and telecommunications sectors.
The final version of Circular No. 36/2026/TT-BKHCN contains two main appendices: the first appendix for list of high risk products and the second appendix for list of medium risk products. This new Circular No. 36/2026/TT-BKHCN enters into force on 1 July 2026. The previous Circular No. 29/2025/TT-BKHCN ceases to be effective as of the date this new Circular comes into effect. Therefore, in this article we will discuss all important notes from Circular No. 36/2026/TT-BKHCN, focusing on products in the information, technology and telecommunications sectors.
Key Notes of Circular No. 36/2026/TT-BKHCN
There is no significant differences between the final version of Circular No. 36/2026/TT-BKHCN and its draft Circular during the second public consultation. Following are several important notes from the issuance of this new Circular No. 36/2026/TT-BKHCN:
- High risk products, including LPWAN, RFID devices, wireless microphones, vehicle radar equipment and Wi-Fi modems, are required to obtain Type Approval certification from a designated certification body.
- High risk products are subject to Declaration of Conformity requirement based on Type Approval certificate and the Product Quality Inspect Registration requirement.
- Medium risk products, including mobile phones, desktop computer, laptop, tablet, UWB, NFC, RFID devices, radar equipment and wireless charging devices, are required to obtain Type Approval certification from a designated or accredited certification body.
- Medium risk products are only subject to Declaration of Conformity requirement. The Declaration of Conformity for general medium risk products can be carried out based on either Type Approval certificate or self-assessment (SDoC).
- The Declaration of Conformity for medium risk mobile phone products may only be carried out based on Type Approval certificate.
- The requirement of Product Quality Inspect Registration is not mandatory for medium risk products. Additional technical requirements may apply to certain medium risk products.
- The implementation of several national technical standards, such as QCVN 134:2024/BTTTT, QCVN 136:2025/BKHCN, and QCVN 86:2025/BKHCN, is postponed until 1 January 2027.
- This Circular No. 36/2026/TT-BKHCN has been in effect since 1 July 2026. The Circular No. 29/2025/TT-BKHCN dated 13 November 2025 is no longer in effect from the date this Circular takes effect.
Impact on Vietnam Type Approval
Type Approval certificates and notifications of acceptance of Declarations of Conformity issued prior to the effective date of Circular No. 36/2026/TT-BKHCN will remain valid until the expiration dates specified therein. Applications for Type Approval certifications received prior to 1 July 2026, that have not yet been processed to completion shall continue to be handled in accordance with the legal regulations applicable at the time of receipt.
In cases where a new national technical standard is newly issued, amended, supplemented, or replaced; or where a new national technical standard is issued to supplement the products and goods listed in the Appendix to Circular No. 36/2026/TT-BKHCN, the provisions of said new national technical standard shall apply from the date the standard enters into force.
Conclusion
The implementation of Circular No. 36/2026/TT-BKHCN affects the Type Approval certification in Vietnam, especially for products that need to meet the requirements of the Declaration of Conformity based on Type Approval certificates and Product Quality Inspect Registration. Therefore, doing early mitigation for adjustment and preparation of Vietnam Type Approval process to this new Circular may be required. Feel free to send an email to info@narmadi.com if you have any questions and assistance about this new Circular.
