A Regulatory Shift in Vietnam ICT Compliance
On November 13, 2025, Vietnam’s Ministry of Science and Technology (MST) issued Circular 29/2025/TT-BKHCN, establishing a new legal foundation for managing ICT products categorized under Group 2, those considered potentially unsafe. Effective December 31, 2025, this Circular replaces Circular 02/2024/TT-BTTTT from the Ministry of Information and Communications (MIC), officially transferring regulatory oversight to MST.
This change marks a significant transition in Vietnam’s ICT regulatory landscape, affecting certification processes, regulated product categories, and applicable technical standards.
Key Provisions of Circular 29/2025/TT-BKHCN
New Compliance Framework
Under the new regulation, Certificates of Conformity (CoC) and Declarations of Conformity (DoC) must now be issued based on Circular 29/2025/TT-BKHCN. All new conformity assessments must reference this regulation instead of MIC’s previous circular. Companies must update internal procedures, compliance documentation, and certification references accordingly.
Updated Regulated Product Lists
Circular 29 features two annexes defining the scope of products under regulation:
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Annex I lists products requiring both CoC and DoC. This includes:
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Mobile phones (4G/5G)
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Base stations
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LPWAN devices
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Radio transmitters/transceivers
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Annex II details items that require DoC only, such as:
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Personal computers
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Non-cellular tablets
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Set-top boxes
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Lithium batteries
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WLAN 6 GHz: Clarification on Compliance
A drafting inconsistency in Annex I has caused uncertainty regarding WLAN 6 GHz devices. Although Note 3 appears to exclude these devices as short-range equipment, Item 2.5 lists them as requiring CoC and DoC. In the absence of an official correction, the industry is advised to follow a strict compliance approach, applying both certification types based on current standards:
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QCVN 47:2015/BTTTT (RF)
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QCVN 96:2015/BTTTT (EMC)
A dedicated standard for WLAN 6 GHz is reportedly under development, though its effective date and transitional guidance remain pending.
Enforcement of Technical Standards
Circular 29 maintains mandatory compliance with MIC’s QCVN standards. Notably:
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QCVN 134:2024/BTTTT (SAR) will become mandatory for mobile phones and tablets from July 1, 2026.
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For heavy industrial equipment over 300kg using three-phase power, EMC compliance can rely on foreign test results from APAC/ILAC-accredited labs, under QCVN 18:2022/BTTTT.
Imports, Testing, and Transitional Measures
The updated regulation includes revised HS codes and product classifications in both annexes. From December 31, 2025, all imports must align with the new lists and provide corresponding documentation.
Previously issued CoCs and acceptance notices under MIC Circular 02/2024 remain valid until expiration, but new applications must fully comply with MST’s regulation.
Additionally, certain testing requirements, such as Total Radiated Power (TRP) and Total Radiated Sensitivity (TRS) under QCVN 117:2023/BTTTT, are temporarily suspended. Several environmental testing mandates are also exempt until December 15, 2026.
Ensure Continued Market Access
The shift in oversight impacts a wide spectrum of ICT products—from consumer electronics to industrial-grade communication devices. Manufacturers and importers must carefully adjust their compliance strategies to align with the new legal basis.
Our Product Certification Service supports clients in transitioning to MST-led conformity procedures, updating HS codes, and navigating SAR testing timelines. Early preparation will be essential to maintain uninterrupted market access in Vietnam.
Impact Assessment
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Technical Standards? ✅ Yes
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Type Approval & Market Access? ✅ Yes
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Imports, Customs, Trade, or Market Surveillance? ✅ Yes
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Spectrum Management? ❌ No
