Issued by the Ministry of Science and Technology (MOST) on 30 June 2026, Circular No. 36/2026/TT-BKHCN introduces a revised management structure for products classified as high-risk or medium-risk. This regulation serves as the central framework for quality management and conformity assessment for radio and telecommunications equipment entering the Vietnamese market.
Scope and Risk Categorization
The Circular divides products into two primary risk groups, each with specific compliance pathways:
- High-Risk Products (Appendix I): These require mandatory certification by a designated body, typically involving factory audits (Method 5) or lot-based inspections (Method 7).
- Medium-Risk Products (Appendix II): Compliance may be achieved through certification or self-declaration based on technical evaluations.
Key Technical Updates
Manufacturers should be aware of several significant technical inclusions and shifts in oversight:
- 5G Mobile Equipment: Specific technical requirements are now defined for both standalone and non-standalone 5G technologies under relevant QCVN standards.
- 6 GHz Wi-Fi: Provisions for the 5925 MHz – 6425 MHz band are established, with specific management standards taking effect from 01 January 2027.
- Power Thresholds: Specific exemptions are introduced for low-power devices, particularly those with an EIRP below 60 mW in common bands such as Bluetooth and Zigbee.
Testing and Labeling Requirements
Conformity assessments must be based on results from accredited or MOST-designated testing laboratories. Once compliance is verified, products must bear the national ICT conformity mark (CR mark) before being placed on the market. Manufacturers must also ensure alignment with Vietnam's updated general labeling regulations for electronic goods, which influence supply chain readiness and packaging design.
Implementation and Transition
Taking full effect on 01 July 2026, this Circular consolidates and replaces several earlier regulations, including Circular No. 29/2025/TT-BKHCN and Circular No. 30/2011/TT-BTTTT. While certificates issued prior to the effective date remain valid until their expiration, manufacturers planning new market entries must adjust R&D and testing timelines to meet the latest requirements. This update represents a shift toward more streamlined management, but requires careful navigation to ensure business continuity.
For a detailed analysis of how these changes impact your specific product range, please contact us.
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