Vietnam’s Ministry of Industry and Trade (MOIT) issued Circular No. 22/2026/TT-BCT on May 7, 2026, mandating carbon footprint labeling for imported structural steel products—including galvanized H-beams, C/Z purlins, and grating panels—effective June 1, 2026. This requirement directly impacts exporters, importers, and fabricators supplying the Vietnamese construction, infrastructure, and industrial building sectors, as non-compliant shipments will be rejected at customs.

Event Overview

On May 7, 2026, Vietnam’s Ministry of Industry and Trade (MOIT) signed Circular No. 22/2026/TT-BCT. The circular stipulates that, starting June 1, 2026, all imported galvanized structural steel products—including H-beams, C/Z-type purlins, and grating panels—must be accompanied by an Environmental Product Declaration (EPD) number registered with QUATEST 3, Vietnam’s nationally recognized accreditation body. The EPD number must be clearly indicated on both the customs declaration form and the packing list. Shipments lacking a valid, QUATEST 3–registered EPD number will not be accepted for customs clearance.

Industries Affected

Exporters and Importers of Structural Steel Products

These entities are directly responsible for compliance at the point of entry. Failure to provide the required EPD number on documentation triggers automatic customs rejection—causing shipment delays, storage costs, and potential contract penalties. The obligation applies regardless of product origin or export volume, meaning even low-frequency or one-off consignments fall under the mandate.

Steel Fabricators and Galvanizing Service Providers

Fabricators supplying finished or semi-finished components (e.g., cut-to-length purlins or pre-galvanized beams) may be asked by their export customers to generate or co-sign EPDs. Since EPDs require verified life-cycle assessment (LCA) data—including energy use, zinc consumption, and transport emissions—their production records and input material traceability become critical inputs for EPD development.

Construction Material Distributors and Project Suppliers

Distributors sourcing imported structural steel for local contractors must now verify EPD registration status before procurement. Absence of a valid EPD number renders inventory non-importable, potentially disrupting project timelines where imported components are specified in tender documents or engineering drawings.

Supply Chain Documentation and Compliance Service Providers

Third-party providers handling customs documentation, certification support, or LCA data management face increased demand for EPD-related verification and filing services. Their role shifts from advisory to operational: ensuring correct EPD numbering appears in prescribed fields on official forms—and aligning those numbers with QUATEST 3’s public registry.

Key Considerations and Recommended Actions

Monitor Official Updates from QUATEST 3 and MOIT

QUATEST 3 has not yet published its EPD registration procedure, fee schedule, or technical validation criteria. Companies should track announcements via MOIT’s official portal and QUATEST 3’s website, particularly for deadlines related to pre-registration, document submission formats, and accepted LCA software tools.

Prioritize High-Volume or High-Value Export SKUs

Given limited time before June 1, 2026, companies should identify which specific product types (e.g., ASTM A653 G90 galvanized C-purlins, EN 10346 DX51D+Z275 H-beams) account for >80% of their Vietnamese exports—and initiate EPD preparation for those first. Generic or family-level EPDs may not suffice if MOIT requires product-specific declarations.

Distinguish Between Policy Signal and Operational Requirement

The circular is legally binding as of June 1, 2026, but enforcement rigor—such as whether partial documentation or provisional EPD numbers will be temporarily accepted—is not yet defined. Companies should treat the requirement as fully enforceable while preparing contingency plans (e.g., alternative local sourcing or buffer stock) in case of initial implementation friction.

Align Internal Data Collection with EPD Requirements

EPD development depends on primary data: electricity grid mix per production site, zinc coating mass per unit area, transport distances, and scrap recovery rates. Manufacturers should audit existing data collection systems now—not after receiving an order—to avoid delays in EPD generation or third-party verification.

Editorial Perspective / Industry Observation

Observably, this regulation marks Vietnam’s first mandatory carbon labeling requirement for a specific industrial import category—and signals a broader shift toward embedding climate accountability into trade policy. Analysis shows it functions less as an isolated compliance hurdle and more as an early indicator of how emerging markets may adopt EPD-based market access conditions, especially in infrastructure-linked sectors. From an industry perspective, the timing—just over one year after Vietnam’s updated National Green Growth Strategy—suggests alignment with domestic decarbonization commitments, rather than being driven solely by external trade partners. Current enforcement capacity and guidance clarity remain open questions; therefore, the policy is best understood not as a finalized system, but as a rapidly evolving compliance threshold requiring sustained monitoring.

Conclusion

This regulation establishes a concrete, date-bound compliance requirement for structural steel imports into Vietnam—not a voluntary guideline or pilot program. Its significance lies in making EPD registration a gatekeeping condition for market access, thereby elevating environmental transparency from a competitive differentiator to a baseline operational necessity. For affected stakeholders, the most rational interpretation is that this is a binding regulatory milestone, not a trial phase; preparedness should assume full enforcement from June 1, 2026, while remaining attentive to procedural updates from Vietnamese authorities.

Information Sources

Main source: Vietnam Ministry of Industry and Trade (MOIT), Circular No. 22/2026/TT-BCT, issued May 7, 2026.
Secondary reference: QUATEST 3’s official mandate as Vietnam’s designated EPD registration body, confirmed in MOIT’s annex to Circular 22/2026/TT-BCT.
Note: QUATEST 3’s EPD registration process, technical guidelines, and timeline for accepting applications remain pending publication and are subject to ongoing observation.