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Law No. 54/2024/QH15 is a comprehensive replacement of Vietnam's 2010 Mineral Law. It consolidates geological survey, mineral planning, licensing, processing, environmental closure, mineral concessions/auctions, and financial obligations into a single statutory framework administered by the Ministry of Agriculture and Environment (MAE — the post-2025 merger of MONRE and MARD).
Key structural features:
rare earths, energy minerals, precious/semi-precious stones, and industrial minerals); Group II (cement, ceramics, refractory and construction-glass inputs); Group III (common construction materials, peat, mineral mud, mineral and natural thermal water); Group IV (clay, soil, pebbles, gravel, sand for filling). Group I and II projects must be inscribed in a national master plan approved by the Prime Minister.
— including rare earths — are subject to non-auction allocation of mining rights, state-prioritised exploration, and restriction of exploration/exploitation activities on national-interest grounds.
Vietnamese representative offices or branches to apply for exploration licences, with strategic-mineral exploration subject to detailed governmental rules and inter-governmental agreements — preserving state discretion over foreign access.
prioritises supplying raw materials to domestic production, which the draft and follow-on decrees operationalise as effective curbs on raw rare-earth and strategic-mineral exports until domestic processing capacity exists.
survey planning and licensing-authority transition) entered into force 15 January 2025; the bulk of the law took effect 1 July 2025.
(Lai Chau) and Yen Phu (Yen Bai) deposits are the largest known non-China rare-earth resource. The 2024 law creates the statutory scaffolding for processing-first development, mirroring Indonesia's hilirisasi pattern but starting from a clean-sheet legal framework rather than amending an old mining code.
REE end-users (Lynas, MP Materials, Rainbow Rare Earths, Energy Fuels, Solvay-La Rochelle) and Korean/Japanese midstream players (Shin-Etsu, POSCO, Iwatani) had been preparing Vietnam-routed off-take contracts since the late 2010s. The law re-prices that off-take pathway: faster midstream margin capture for Vietnamese state-aligned operators (Vinacomin, Masan High-Tech Materials), slower upstream off-take for Western refiners.
qualifies for IRA §45X / EU CRMA "non-FEOC" status depends on ownership-of-record of the processing entity. The 2024 law's emphasis on state-affiliated and JV operators creates a screening question for Western buyers.
Indonesia (nickel, bauxite, copper concentrate), Zimbabwe (lithium), DRC (cobalt), and Chile/Argentina (lithium) in the EM upstream-processing-capture regime. The pattern is now structural, not idiosyncratic.
binding export-curb provisions live in subordinate decrees. Decree No. 21/2026/ND-CP (19 January 2026) on mineral exploitation licensing is the first major implementation instrument; further decrees on environmental obligations, royalty rates, and strategic-mineral designation lists remain in draft as of mid-2026.
that a separate rare-earth amendment is in draft for 2026 entry into force, including an explicit prohibition on raw REE exports — this would mirror Indonesia's nickel template more directly than the current statute does.
Nghe An conference) flagged unresolved jurisdictional ambiguity for cross-province deposits and licensing-authority overlap between Provincial People's Committees and the Ministry — likely to slow permit issuance for foreign-funded projects in 2026.
semiconductor strategy (Sept 2024) and Decree 182 investment-support fund (Dec 2024) anticipate domestic supply of strategic inputs; whether the new mineral law accelerates or constrains that supply for Vietnam-sited fabs is the central industrial-policy question.