Adjustment of Export and Import Licenses for Schedule 2 and Schedule 3 Chemicals

The Adjustment of Export and Import Licenses for Schedule 2 and Schedule 3 Chemicals is a process designed to create flexibility for businesses during the implementation and modification of international trade transactions. This article summarizes current regulations and provides specific instructions to help Clients perform the procedure quickly and lawfully.

General requirements for the export and import of chemicals (Table)

Based on Article 17 of Decree 33/2024/ND-CP, requirements for importing/exporting Schedule chemicals include:

1. Origin/Destination: Schedule 1 and Schedule 2 chemicals can only be traded with State Parties to the Chemical Weapons Convention (CWC). For Schedule 3 chemicals exported to non-member states, an End-Use Certificate from the competent authority of that country is required.
2. Licensing: Must possess a license granted by the competent authority. This is a condition for customs clearance.
3. Business Condition: To trade (buy/sell) Schedule chemicals domestically, one must first obtain a Schedule Chemical Business License.
4. Exemption: Organizations/individuals with an Import License for Schedule chemicals are exempt from chemical declaration regulations for chemicals subject to declaration.

When to Adjust? Based on Point a, Clause 6, Article 19 of Decree 33/2024/ND-CP, adjustment is required when there is a change in the content of the contract, purchase agreement, purchase order, memorandum of understanding, or invoice.

The competent authority is responsible for issuing adjustments to export and import licenses for chemicals listed in Tables 2 and 3.

Based on Clause 1, Article 19 of Decree 33/2024/ND-CP (amended by Clause 5, Article 9 of Decree 146/2025/ND-CP), the authority belongs to the Provincial-level People’s Committee where the import-export enterprise is headquartered.

Required Dossier for the procedure to amend export and import licenses for chemicals (Tables 2 and 3)

According to Clause 6, Article 19 of Decree 33/2024/ND-CP, the dossier includes:

1. Request Form: Request for Adjustment of License (Form No. 02, Appendix II, Decree 33/2024/ND-CP).
2. Supporting Documents: Papers/documents confirming the adjusted contents (e.g., contract addendum, new invoice).

Note: Prepare copies of the applicant’s Citizen ID card; and a Power of Attorney (with the authorized person’s Citizen ID) if submitting via proxy.

>>> See more at: Granting Certificate of Eligibility for Production of Conditional Industrial Chemicals

Procedures for issuing and adjusting export and import licenses for chemicals (Tables 2 and 3)

According to Clause 6, Article 19 of Decree 33/2024/ND-CP:

Step 1: Submission

• Online: Submit via the National Public Service Portal (Code: 1.012433).
• Direct: Submit 01 dossier set to the Provincial People’s Committee.

Step 2: Processing If the dossier meets requirements, the competent authority grants the Adjusted License. The validity period of the adjusted license follows regulations for a new license.

>>> See more: Cost of applying for an environmental permit for the chemical industry

Long Phan Consulting provides consulting services for procedures related to the issuance and adjustment of export and import licenses for chemicals listed in Tables 2 and 3.

Long Phan Consulting Company provides comprehensive support:

• Consulting & Evaluation: Assessing the adjustment dossier.
• Dossier Preparation Support: Assisting in preparing documents (Request Form, supporting docs) according to regulations.
• Representation: Submitting the dossier to the competent state agency.
• Monitoring & Explanation: Tracking progress and working directly with agencies to explain the dossier.
• Completion: Receiving and handing over the result.

Frequently Asked Questions

Below, Long Phan Consulting provides some frequently asked questions related to the procedures for adjusting export and import licenses for chemicals listed in Tables 2 and 3. We invite interested clients to refer to this information:

Can I trade Schedule 2 chemicals with non-CWC member states?

No. For Schedule 1 and Schedule 2 chemicals, trade is only permitted with State Parties to the Chemical Weapons Convention. (Legal Basis: Clause 1, Article 17, Decree 33/2024/ND-CP).

Which form is used for the adjustment request?

Use Form No. 02, Appendix II of Decree 33/2024/ND-CP. (Legal Basis: Clause 6, Article 19, Decree 33/2024/ND-CP).

Do I need to declare chemicals if I have an Import License?

No. Organizations/individuals with a Schedule Chemical Import License are exempt from declaring chemicals in the List of Chemicals Subject to Declaration. (Legal Basis: Clause 6, Article 17, Decree 33/2024/ND-CP).

Does the Import License replace the Business License?

No. The Import License is for customs clearance. To distribute/sell domestically, you need a separate Schedule Chemical Business License. (Legal Basis: Clause 3, Article 17, Decree 33/2024/ND-CP).

What documents confirm the adjustment?

Copies of documents proving the change: Contract Addendum, amended purchase agreement, new purchase order, MOU, or corrected commercial invoice.

Conclusion

Timely Adjustment of Export and Import Licenses for Schedule 2 and Schedule 3 Chemicals helps enterprises eliminate legal risks and clearance delays. Please contact Long Phan Consulting Company via Hotline 1900636389 for timely and professional legal support.