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Vietnam Decision 42/2026 Expands Greenhouse Gas Inventory List To 2,441 Facilities

Dr Steven Brennan
Dr Steven Brennan
3 min readAI-drafted, expert reviewed
Modern Vietnamese industrial complex with energy and freight infrastructure

Key takeaway

What This Development Means

Vietnam has adopted Decision 42/2026/QĐ-TTg, expanding its greenhouse gas inventory list to 2,441 facilities from 25 September 2026. Listed operators should confirm site coverage and review their inventory process under the amended Decree 06 framework.

Is An Inventory Due When The New List Starts On 25 September 2026?

No. That is the decision's effective date. Reporting timing and methods come from Decree 06/2022/NĐ-CP and its amendments. Operators should confirm the applicable cycle rather than treating 25 September as a submission deadline.

Should A Company Rely On Its Status Under The 2024 List?

No. The new decision replaces the previous list. Each facility should be checked against the signed 2026 annex, including its legal name and site boundary, even if the corporate group prepared inventories under the earlier decision.

Source basis: Government of Vietnam, Decision 42/2026/QĐ-TTg on greenhouse gas inventory facilities (10 August 2026)

Vietnam's greenhouse gas inventory list will expand to 2,441 facilities under Prime Minister's Decision 42/2026/QĐ-TTg, adopted on 10 August 2026, published on 11 August and effective from 25 September. The measure replaces the 2024 list and determines which sites must prepare and submit greenhouse gas inventories under Vietnam's climate change reporting framework, affecting manufacturers and their energy, logistics, construction, agricultural and waste partners.

What Vietnam Decision 42/2026 Changes

The new list contains 2,441 facilities, compared with 2,166 under Decision 13/2024/QĐ-TTg. That is a net increase of 275 sites, although businesses should check the new annex rather than assume every previously listed facility remains unchanged.

The Ministry of Industry and Trade accounts for 1,916 facilities. A further 411 fall within construction, 61 within agriculture and environment, and 53 within transport. The decision spans six reporting sectors: energy; transport; construction; industrial processes, including chemicals, metallurgy and electronics; agriculture, forestry and land use; and waste.

The change is not a new economy-wide carbon-reporting law. It updates the facility-level scope used by Decree 06/2022/NĐ-CP, as amended by Decrees 119/2025/NĐ-CP and 83/2026/NĐ-CP. The applicable inventory timetable and methodology continue to come from that wider framework. A facility listed in 2024 but omitted from the 2026 annexes is exempt from the facility-level report submitted from 2027 for the 2026 inventory period.

Which Manufacturers And Supply Chains Are Affected

Operators named in the annex are directly affected. The practical reach is wider because inventory preparation depends on electricity, fuel, process, refrigerant, transport and waste data held by different teams and suppliers.

Chemical producers, metals businesses, electronics manufacturers and other energy-intensive operators should compare legal entity names, facility identifiers and site boundaries with the new annex. Groups with several Vietnamese sites should not treat a corporate-level inventory as proof that every listed facility is correctly mapped.

Analysis: The larger list will increase demand for consistent supplier evidence and auditable activity data, particularly where outsourced logistics, waste treatment or shared utilities sit outside a site's direct operational control. Early data-contract checks may prevent gaps that are difficult to repair at the reporting stage.

What Organisations Should Do Before 25 September

First, obtain the signed annex and verify whether each site is included, newly added, removed or recorded under a changed name. Escalate apparent errors through the competent ministry rather than relying on the previous list.

Second, map inventory responsibilities across environmental, operations, procurement, finance and information-technology teams. Confirm units, calculation methods, evidence retention and approval controls under the amended Decree 06 framework and align the result with wider corporate ESG reporting.

Third, engage important energy, transport and waste suppliers about data format, frequency and assurance. The decision does not itself set product thresholds, exemptions or stock provisions, so those concepts should not be inferred from the facility list.

What Happens Next

Decision 42/2026/QĐ-TTg becomes effective on 25 September 2026. Listed operators should monitor implementing instructions and any corrected annex published by the Vietnamese Government, while following the reporting cycle and methods already established under the applicable decrees.

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