Since 1 July 2026, Circular 36/2026/TT-BKHCN issued by Vietnam’s Ministry of Science and Technology (MOST) has been in force. The circular consolidates a number of existing circulars and establishes a risk-based product classification system, laying down new compliance and certification routes for Wi-Fi transceivers, short-range radar, radio remote controls, radio frequency identification (RFID) and similar products. Manufacturers exporting to Vietnam should review their product classification and certification arrangements without delay.

01 Overview: entry into force and transitional arrangements

MOST issued Circular 36/2026/TT-BKHCN on risk-based product classification, in force from 1 July 2026. The regulation consolidates several existing circulars and establishes a tiered risk classification system, using HS codes and product functional characteristics as the core classification criteria.

The circular sets out clear transitional arrangements for a smooth handover between the old and new rules:

· Conformity certificates and acceptance notices issued before 1 July 2026 remain valid until their original expiry date;

· Applications submitted before 1 July 2026 continue to be governed by the previous rules.

02 Classification method: a two-tier system based on HS codes and functional characteristics

The central change is the replacement of the previous fragmented approach to product regulation with risk levels. The framework classifies products by HS code and functional characteristics into two compliance tiers — high-risk and medium-risk — each subject to a different certification route and set of conformity assessment requirements.

03 High-risk products: type approval certificate plus declaration of conformity

High-risk products require a formal type approval certificate issued by an authorised Vietnamese certification body, accompanied by a declaration of conformity.

Acceptable certification routes include:

· Comprehensive type testing combined with a factory production control audit (Method 3);

· Batch commissioned inspection at the time of import (Method 7).

Products in this category include:

· Wi-Fi transceiver equipment operating in the 5 GHz and 6 GHz bands (specifically 5150–5350 MHz, 5470–5725 MHz, 5725–5850 MHz and 5.925–6.425 GHz) with an equivalent isotropically radiated power of not less than 60 mW;

· 24–24.25 GHz short-range radar equipment for traffic information, cruise control, collision avoidance and vehicle detection;

· Radio remote control equipment;

· RFID systems using active electronic chip tags mounted on specific objects.

04 Medium-risk products: declaration of conformity only

Medium-risk products require only a declaration of conformity; voluntary type certification may still be obtained through designated or accredited certification bodies.

Products in this category include:

· RFID and tracking equipment operating in the 13.553–13.567 MHz band for the management of goods, people and animals;

· RFID systems used for activating radio frequency cards and retrieving information;

· 76–77 GHz short-range radar equipment for traffic and transport applications;

· Radio navigation equipment;

· Ultra-wideband communication equipment.

05 Factory audit: an ISO 9001 certificate can waive on-site inspection

For the factory audit stage the circular offers a facilitation route for international manufacturers: by submitting a valid ISO 9001 quality management system certificate, a manufacturer may choose the full certification route and be exempted from an on-site factory audit.

Note that the ISO certificate must have at least six months of validity remaining at the time of application. If it has less, the audit exemption no longer applies and on-site inspection or batch-by-batch testing at the port is required.

06 Technical standards timetable: key milestones

The circular also sets out mandatory implementation arrangements for technical standards. New standards are scheduled to become mandatory from 1 January 2027, covering:

· Radio frequency EMC requirements for WWAN and LTE NB-IoT devices;

· Wi-Fi 6 GHz radio standards.

In addition, testing obligations under a number of technical standards in extreme environmental conditions have been suspended until 30 June 2027 in order to facilitate market access.

Action points for exporters

Taken together, the circular marks a new, risk-tiered phase in Vietnam’s regulation of wireless and radio frequency products. Exporters are advised to:

· Confirm the risk level of their products and the applicable certification route against HS codes and functional characteristics;

· Review the status of existing conformity certificates, acceptance notices and pending applications, and make full use of the transitional arrangements;

· Note the 1 January 2027 deadline for mandatory technical standards and plan testing and certification schedules in advance.

NTEK will continue to track regulatory developments in Vietnam and worldwide, and to support exporters with professional compliance advice.

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