Vietnam Device Regulation 2021-2026: Timeline of Key Changes

Updated: 2026-11-05 · GRZAN Regulatory Team · Verification date 2026-10-20

This is a living page: the rules keep changing, so follow the MOH/IMDA announcements in force at the time.

Q: What has changed in Vietnam’s device rules over the past few years?

A: Within five years Vietnam completed the move from the old system (Decree 36/2016 and 169/2018) to the Decree 98 system, and adjusted it continuously between 2021 and 2026 through three amending decrees and several ministerial circulars. The key dates are:

DateInstrumentKey change
8 November 2021 (in force 1 January 2022)Decree 98/2021/NĐ-CPReplaced Decree 36/2016 and 169/2018; established the A/B/C/D classes, the two-tier route of declaration and circulation registration, price declaration, advertising publication and post-market management
1 July 2022Requirements related to Article 62 of Decree 98The requirement for device advertising content to be published on the MOH portal took effect
1 August 2022Circular 05/2022/TT-BYTThe classification rule set (16 general rules plus IVD-specific rules)
3 March 2023Decree 07/2023/NĐ-CPAmended Articles 21.2, 22, 32.3.c, 37.6 and 38; introduced the reference-country expedited pathway; deficiency rules (90 days / three rounds)
30 December 2023Decree 96/2023/NĐ-CPArticle 147 package amendment: rewrote Chapter IV on clinical studies and added a priority processing mechanism (10 working days)
1 January 2024CSDT mandatoryClass C/D dossiers must use the ASEAN CSDT template
1 January 2025Decree 04/2025/NĐ-CPAmended Article 76 and extended the transitional arrangements to 30 June 2025
January 2025Institutional renamingDMEC → IMDA (Department of Medical Infrastructure and Medical Equipment)
30 June 2025Circular 64/2025/TT-BTCDevice fees halved, valid 1 July 2025 to 31 December 2026
1 July 2025End of the transition periodDecree 98 fully applied; arrangements such as import on a classification document ceased
2 July 2025MOH Notice 645/TB-HTTBPublished the full reduced-period fee schedule
4 August 2025Decision 2495/QĐ-BYTAdministrative procedure list and handling levels (for example, Class B/C/D Trading Eligibility Declarations handled by the provincial Department of Health)
2025Circular 44/2025/TT-BYTMandatory LoA template
1 January 2026Article 147.19 of Decree 96/2023 in forceClass C/D dossiers must include the competent authority’s clinical investigation completion certificate
23 January 2026Decree 37/2026/NĐ-CPNew labelling rules, replacing 43/2017 and 111/2021; font size of at least 0.9 mm and other requirements
11 September 2026Hague Apostille Convention in force for VietnamPublic documents from Contracting Parties are legalised by Apostille; consular legalisation is no longer required
31 December 2026Circular 64/2025 expiresThe 50% fee reduction ends and standard rates resume

Q: Which changes matter most to companies?

A: Ranked by reach, four watersheds:

  1. 1 July 2025 — the transition period ends and the route of importing on a classification document disappears; companies already holding certificates must complete formal registration;
  2. 1 January 2026 — the clinical investigation completion certificate is added for Class C/D, markedly raising timelines and costs for high-risk devices;
  3. 23 January 2026 — the new labelling rules take effect, putting small-pack products under redesign pressure;
  4. 11 September 2026 — Apostille takes effect and the legalisation chain changes form (shorter, but Vietnamese notarised translations are still required).

Q: What else is still changing?

A: Three areas to watch: (1) IMDA taking over delegated functions, with issuance for Class C/D, post-licensing inspection, suspension, recall and revocation progressively confirmed as its responsibility; (2) updates to the administrative procedure list, issued from time to time in the form of QĐ-BYT; (3) the end of the reduced-fee period (31 December 2026). In addition, the consolidated document of the Decree 98 framework is updated as an MOH document and is the main reference for day-to-day queries.

Practical note: turn this timeline into an internal regulatory register and review it quarterly. Watch four variables: (1) whether a new amending decree appears; (2) whether the reduced-fee period is extended; (3) how Decree 37/2026 is applied in practice and its transitional arrangements; (4) changes to the list of Apostille Contracting Parties. One register, kept in one place and shared across the company, stops sales, regulatory and logistics from working from different assumptions.

Verification checklist (26 October 2026): (1) Decree 98/2021/NĐ-CP (8 November 2021); (2) Decree 07/2023/NĐ-CP (3 March 2023); (3) Decree 96/2023/NĐ-CP (30 December 2023), Article 147; (4) Decree 04/2025/NĐ-CP (1 January 2025); (5) Circular 05/2022/TT-BYT (1 August 2022); (6) Circular 44/2025/TT-BYT (LoA template); (7) Circular 59/2023/TT-BTC and Circular 64/2025/TT-BTC (30 June 2025); (8) MOH Notice 645/TB-HTTB (2 July 2025); (9) Decision 2495/QĐ-BYT (4 August 2025); (10) Decree 37/2026/NĐ-CP (23 January 2026); (11) the Hague Apostille Convention in force for Vietnam (11 September 2026).

Disclaimer

Prepared by GRZAN from publicly available regulation. It is provided for general information only and does not constitute legal advice. Legislation and official fees are subject to change by the competent authority.

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