As a key Southeast Asian export destination for Chinese‑made LED lighting products, Vietnam has continuously updated its product access and compliance framework in recent years. To align with international safety standards and regulate product quality in the domestic market, Vietnamese authorities have rolled out a new round of lighting regulatory revisions, which are now in force. The updated compliance requirements lay out refined provisions for photobiological safety control, representing critical compliance points for Chinese LED exporters.

Regulatory Roll‑out and Escalating Compliance Assessment

Vietnam’s Ministry of Science and Technology issued Circular 56/2025/TT‑BKHCN, officially introducing the new national technical regulation QCVN 19:2025/BKHCN, which supersedes the former QCVN 19:2019/BKHCN.

Differentiated enforcement timelines are specified for various product categories to grant the industry an adaptation transition period:

• Most LED lighting products (categories listed in Appendix I of the regulation): effective June 1, 2026.
• LED lighting products under HS Code 9405.11.99 (primarily non‑electrified LED luminaires): granted an extended transition period, with enforcement deferred to January 1, 2027.

Under the new rules, LED lighting products entering the Vietnamese market must complete three mandatory access procedures: obtain the CR conformity mark certification, submit an energy efficiency declaration of conformity to the Ministry of Industry and Trade, and register product quality via the Vietnam Quality Inspection Registration (PQIR) system.

In the early phase of regulation implementation, CR certification assessment mainly focuses on static operating‑condition parameters. Nonetheless, dynamic optical radiation metrics may be subject to inspection at ports of entry in subsequent stages. Dynamic optical radiation performance of smart dimmable and colour‑changing luminaires has emerged as a major industry risk concern. Exporters shipping to Vietnam are advised to prepare relevant documentation in advance.

Technical References Supporting the Regulation

As a mandatory national technical regulation, QCVN 19:2025/BKHCN sets baseline safety and EMC (Electromagnetic Compatibility) requirements for LED luminaires, with test methods referenced to Vietnamese national standards.

For photobiological safety, the regulation normatively references TCVN 13079‑1:2020 (identical to international standard IEC 62471‑1). This standard specifies test methods and risk‑group classification for photobiological safety of lamps and lamp systems, covering most civil and commercial LED lighting products. Per this standard framework, products shall achieve photobiological safety RG0 (exempt) or RG1 (low‑risk) rating. It should be noted that this standard only evaluates luminaires under static steady‑state operation and does not cover dynamic operating modes such as dimming and colour‑tuning.

Additionally, Vietnam has the informative national standard TCVN 13079‑2:2020 (corresponding to IEC/TR 62471‑2). This supplementary technical report on photobiological safety is not mandated under QCVN 19:2025/BKHCN and is not a prerequisite for CR certification issuance. However, it may serve as a technical reference for port quality verification. It provides evaluation methodologies for blue‑weighted irradiance under dynamic operating conditions specifically for dimmable and spectrum‑variable luminaires, addressing gaps where static testing fails to identify dynamic light‑emission hazards.

Industry Compliance Mitigation Strategies

Against the full roll‑out of Vietnam’s new LED lighting regulations, manufacturers and trading exporters shall sort out compliance obligations and implement risk prevention proactively. Enterprises are recommended to characterise their products, verify corresponding HS code classification, confirm applicable regulatory enforcement dates, and rationally arrange testing, certification and registration workflows. Complete compliance preparations within the transition window to mitigate export uncertainties stemming from insufficient qualification documentation.

For fundamental compliance, complete mandatory access formalities including CR conformity mark certification, energy efficiency declaration of conformity and PQIR product registration. Monitor certification status and ensure LED luminaires pass static photobiological safety testing per TCVN 13079‑1:2020 to satisfy relevant criteria.

At the R&D stage, optimise the optical design of smart luminaires and pay close attention to blue‑light radiation performance under dynamic operating modes to mitigate potential safety risks at the product level. Continuously track policy updates released by competent Vietnamese authorities, reference real‑world customs clearance feedback from local importers, and adjust compliance arrangements flexibly to sustain stable export operations to Vietnam.