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Law and policy22 October 2025

Decree No. 259/2025/ND-CP on strategic trade control – adding a counter-proliferation approach alongside the objective of enabling economic and trade development

Field: Nuclear and radiological, Dual-use goods and strategic trade Tiếng Việt

Unofficial translation from the Vietnamese original.

The Government has recently promulgated Decree No. 259/2025/ND-CP of 10 October 2025 on strategic trade control, which governs the management of the export, temporary import for re-export, merchanting, transhipment and transit of strategic trade goods.

Strategic trade control is a concept that has been addressed and implemented since the United Nations Security Council adopted Resolution 1540 in 2004 on the non-proliferation of weapons of mass destruction, which requires Member States to “establish, develop, review and maintain appropriate effective national export and trans-shipment controls” to prevent the proliferation of materials related to chemical, biological, radiological and nuclear weapons and their means of delivery. Strategic trade control is not a bilateral arrangement or agreement but a country’s legal system and procedures setting out the requirement that certain items exported from that country to another country must be licensed for reasons of national defence and security, foreign policy or economic policy.

Before the Decree was issued, Vietnam already had regulations on the export and import control of goods for national defence and security purposes, goods affecting national defence and security, and goods subject to export and import restrictions under the conventions on the non-proliferation of weapons of mass destruction. However, there was no dedicated legal instrument on the control of dual-use goods (strategic trade control encompasses the control of dual-use goods and arms control). The dual-use nature of such products requires them to be managed not only according to the characteristics of the items themselves but also through control of their end use and of the parties involved in their export, import and production. Vietnam also lacked a specific list of dual-use goods and an export control mechanism for dual-use goods.

The promulgation of the Decree is therefore regarded as an important step, demonstrating the Government’s determination to strengthen state management capacity in strategic trade control, while meeting international non-proliferation requirements on weapons of mass destruction, safeguarding national defence and security and enabling economic development. Moreover, amid a rising risk of trade wars, the issuance of the Decree and the implementation of a strategic trade control mechanism are among the matters on which developed countries have been asking Vietnam to cooperate.

The Decree clearly provides that:

- Goods, technologies and services on the strategic trade control list include dual-use materials, equipment, software and technologies that can be used for the production of nuclear, chemical and biological weapons and missiles;

- The controlled trade activities include export, import, transit, merchanting, temporary import for re-export, transhipment, brokering and technology transfer;

Principles for the management of strategic trade goods:

- Strategic trade goods must comply with the provisions of this Decree and with the laws in force on foreign trade management, trade, sector-specific legislation, tax and customs legislation, and other laws.

- Traders engaged in the export, temporary import for re-export, merchanting, transhipment or transit of dual-use goods specified in clause 3, Article 7 of this Decree must hold a licence (except for national defence and security purposes).

- Where there is information giving rise to suspicion that goods will be used to produce or use weapons of mass destruction, or that the end user of the goods is on the designated list, traders must obtain a licence for the export, temporary import for re-export, merchanting, transhipment or transit of such goods, even where the goods are not on the List specified in Article 7 of this Decree.

- Where necessary to implement international commitments or arrangements under bilateral agreements, the Ministry of Industry and Trade shall decide on the application of licensing for the export, temporary import for re-export, merchanting, transhipment or transit of goods not covered by clauses 2 and 3 of this Article.

- Traders engaged in the export, temporary import for re-export, merchanting, transhipment or transit of weapons of mass destruction or conventional weapons shall comply with the legal instruments in force on countering the proliferation of weapons of mass destruction and the law on the management and use of weapons, explosives and support tools.

One of the key requirements of the Decree concerns the internal compliance programme:

- Traders engaged in the export, temporary import for re-export, merchanting, transhipment or transit of strategic trade goods are encouraged to develop and implement an internal compliance programme.

- An internal compliance programme comprises the following sets of procedures:

  1. a) Commitment to the responsibilities of the trader, of the business owner, and of departments and employees with regard to strategic trade control in accordance with the law.
  2. b) Procedures for screening the end user and end use of goods in transactions.
  3. c) Procedures for how the trader regularly keeps up to date with legal regulations on strategic trade control.
  4. d) Procedures for internal training in this field.

dd) Procedures for the retention of information and records.

  1. e) Procedures for notification obligations.

The requirements for the sets of procedures in the internal compliance programme are set out in Appendix II of this Decree.

- Traders that have implemented an internal compliance programme for two years or more, as certified by the Ministry of Industry and Trade, may be considered for the grant of licences for export, temporary import for re-export, merchanting, transhipment or transit with the validity period specified in clause 3, Article 8 of this Decree.

The Decree also provides for the List of dual-use goods; licensing of dual-use goods; the dossiers and procedures for licensing the export, temporary import for re-export, merchanting, transhipment and transit of dual-use goods; certification of the implementation of internal compliance programmes, etc.

The List of dual-use goods subject to licensing for export, temporary import for re-export, merchanting, transhipment and transit comprises:

  1. Radioactive materials and nuclear equipment: managed by the Ministry of Science and Technology;
  2. Electronics (microprocessors with a processing speed of 5 GFLOPS or more and an arithmetic logic unit (ALU) with an access width of 32 bits or more; integrated circuits designed or rated as radiation-hardened, etc.): managed by the Ministry of Science and Technology and the Ministry of Industry and Trade;
  3. Computers (electronic computers and related equipment designed to withstand high levels of radiation; computers designed for the modelling, simulation or design integration of missiles, etc.): managed by the Ministry of Science and Technology;
  4. Telecommunications, sensors and lasers (equipment for intercepting or jamming mobile telecommunications; high-speed cameras; radiation-hardened television cameras, etc.): managed by the Ministry of Science and Technology;
  5. Aerospace (high-accuracy star trackers and components; Global Navigation Satellite System (GNSS) receiving equipment, etc.): managed by the Ministry of Construction;
  6. Marine (manned submersible vehicles designed to operate at depths exceeding 1,000 m, etc.): managed by the Ministry of Construction;
  7. Human pathogens and toxins (viruses, bacteria, fungi, toxins): managed by the Ministry of Health;
  8. Chemicals (industrial explosives; explosive precursors used for the production of industrial explosives, etc.): managed by the Ministry of Industry and Trade;
  9. Metals and alloys (high-strength magnesium, nickel, titanium and aluminium alloys, etc.): managed by the Ministry of Industry and Trade;
  10. Unmanned aerial vehicles (UAVs) with an endurance of 1 hour or more, or with an endurance of 30 minutes or more and designed to take off and maintain stable flight in wind gusts of 46.3 km/h or more: managed by the Ministry of Industry and Trade.

Thanh Tung – Centre 81

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