Circular 81/2026/TT-BXD: New Energy Labelling Requirements for Construction Materials
On 4 November 2026, the Minister of Construction issued Circular No. 81/2026/TT-BXD prescribing energy labelling requirements for construction materials under the management of the Ministry of Construction (“Circular 81”). Circular 81 will take effect on 1 January 2027 and sets out the list of construction materials subject to energy labelling, labelling requirements, thermal testing requirements, declaration procedures and the mandatory implementation roadmap for each product group.
Notably, although Circular 81 takes effect on 1 January 2027, mandatory energy labelling will be implemented in two phases: from 1 January 2029 for Group 1 products and from 1 January 2031 for Group 2 products.
1. Scope and applicable entities
Under Article 1, Circular 81 regulates:
- The list of construction materials subject to energy labelling and the implementation roadmap;
- The content and specifications of energy labels;
- Requirements applicable to testing laboratories;
- Procedures for declaring and affixing energy labels; and
- Inspection, reporting, suspension and withdrawal of energy labelling for construction materials under the management of the Ministry of Construction.
Pursuant to Article 2, Circular 81 applies to manufacturers, importers, organisations and individuals distributing or trading in construction materials included in the list under Appendix I; testing laboratories conducting thermal-property testing; and relevant state authorities, organisations and individuals.
Circular 81 does not apply to the cases specified in Article 2.4, including construction materials temporarily imported for re-export, goods in transit or transshipment; materials manufactured or processed for export and not consumed in Vietnam; non-commercial imports, gifts, samples, exhibition goods and goods used for research or testing that are not placed on the market; and construction materials serving national defence, security or state-secret purposes in accordance with applicable laws.
2. List of construction materials and mandatory implementation roadmap
Under Article 4, construction materials are included in the list of products subject to energy labelling if they satisfy the following criteria: (i) they are used in the building envelope and have thermal properties relevant to the energy performance of a building or part of a building; (ii) a testing method standard is available to determine the relevant thermal properties; and (iii) such properties can be tested and verified by testing laboratories.
Appendix I divides the construction materials subject to energy labelling into two groups:
Group 1 – Mandatory energy labelling from 1 January 2029:
- Building glass, including float glass; flat glass manufactured by horizontal or vertical drawing processes; patterned rolled glass; thermally toughened flat glass; laminated glass and laminated safety glass; low-emissivity (Low-E) glass; reflective-coated glass; sealed insulating glass units; heat-absorbing tinted glass; self-tinting glass; glass integrated with solar cells; and wired glass;
- Emulsion wall paint used for building envelopes; and
- Roofing sheets and metal cladding panels.
Group 2 – Mandatory energy labelling from 1 January 2031:
- Insulation foam boards, including polystyrene, polyurethane and other types;
- Non-fired construction materials, including autoclaved aerated concrete blocks; reinforced autoclaved aerated concrete wall panels; precast hollow concrete wall panels manufactured using extrusion technology; three-layer lightweight sandwich wall panels; lightweight concrete blocks; and lightweight concrete panels; and
- Ceiling and partition panels, including gypsum boards; fibre-reinforced gypsum panels; glass-fibre gypsum panels; ceiling and partition panels using cement-based binders; and composite panels.
Before the relevant mandatory implementation date, manufacturers and importers are encouraged to voluntarily declare and affix energy labels to products listed in Appendix I. Where voluntary labelling is undertaken, testing, declaration and labelling must still comply with Circular 81.
3. Thermal parameters and testing methods
Circular 81 specifies the thermal parameters to be declared according to the relevant type of construction material. The same parameter is not applied uniformly to all products.
Under Appendix I:
- Building glass: the total solar energy transmittance coefficient (g-value) must be declared. Where the applicable standard uses the designation SHGC, the parameter must be presented in accordance with that standard. The referenced testing standard is TCVN 7737:2023 (ISO 9050) for optical and solar energy properties of glass.
- Emulsion wall paint: the solar reflectance index (SRI) must be declared in accordance with TCVN 14358:2025 (ASTM E1980).
- Roofing sheets and metal cladding panels: SRI must be declared for roofing surfaces or surface coatings directly exposed to solar radiation. The thermal conductivity coefficient λ (W/m.K) must also be declared for block- or panel-form roofing products having thermal insulation functions. The corresponding testing methods are TCVN 14358:2025 (ASTM E1980) for SRI and TCVN 14356:2025 (ISO 8301) or TCVN 14357:2025 (ISO 8302) for thermal conductivity.
- Insulation foam boards, non-fired construction materials, ceiling panels and partition panels: the thermal conductivity coefficient λ (W/m.K) must be declared in accordance with TCVN 14356:2025 (ISO 8301) or TCVN 14357:2025 (ISO 8302).
Businesses should identify the applicable parameter for each product by reference to Appendix I before arranging testing and preparing the declaration dossier.
4. Energy label requirements and declaration procedures
4.1. Label content and format
Under Article 5, an energy label must contain the following information:
- The name or abbreviated name of the manufacturer or importer;
- The product name and product type/model identification code;
- The relevant thermal property and its declared value, as specified in Appendix I;
- The standard used to determine the thermal property; and
- An electronic information retrieval code, if any.
The label must be appropriately sized for the product or its packaging, with information presented clearly and legibly. An energy label may be incorporated into the goods label or displayed as a separate label, using the applicable template in Appendix III.
4.2. Declaration dossier
Under Article 6, the dossier for declaring energy labelling of construction materials comprises:
- Technical specifications of the construction material, clearly identifying the product type/model and the declared thermal property;
- Thermal testing results issued by a testing laboratory published by the Ministry of Construction on its website;
- The energy labelling declaration form using Form No. 01 in Appendix II; and
- The proposed energy label.
4.3. Declaration procedures and affixing of labels
Before placing construction materials subject to energy labelling on the market in accordance with the roadmap under Article 4, manufacturers and importers must submit the declaration dossier electronically to the Ministry of Construction for publication on the Ministry’s website. They must also publish the declaration on their own websites.
If the information system is not yet ready to receive submissions, the Ministry of Construction will announce an alternative submission method on its website.
The Ministry of Construction will make public the following information: the name of the manufacturer or importer; the product name and type/model identification code; the declared thermal property; the applicable standard; the declaration date; and the energy label specimen.
It should be noted that the Ministry’s receipt and publication of the information do not constitute verification, certification or approval of the declaration. Manufacturers and importers remain legally responsible for the completeness, accuracy and truthfulness of their dossiers and for the conformity of their products with the declared information.
After completing the declaration, manufacturers and importers must affix or print the energy label directly on the product or its packaging. Manufacturers, importers, distributors and traders, including those conducting business through e-commerce platforms, are responsible for maintaining the display or provision of energy label information in accordance with the declared content.
5. Requirements for testing laboratories and use of test results
Article 10 requires domestic testing laboratories conducting thermal-property testing of construction materials to satisfy the conditions for providing testing services under Article 42 of Decree No. 22/2026/ND-CP. Their testing capabilities must cover the relevant products, parameters and testing methods specified in Appendix I.
Domestic testing laboratories must register their testing activities in accordance with applicable regulations and submit information on their testing activities, together with a copy of their Certificate of Registration for Testing Activities, to the Ministry of Construction for publication on the Ministry’s website.
Where test results from a foreign testing laboratory are used, the laboratory must be accredited as conforming to ISO/IEC 17025 by an accreditation body that is a signatory to the ILAC Mutual Recognition Arrangement (ILAC MRA) or the Asia Pacific Accreditation Cooperation Mutual Recognition Arrangement (APAC MRA).
Under Article 11, test samples must be representative of the relevant product type/model or product batch. Manufacturers and importers are responsible for the representativeness of the samples. Test results may be used for products of the same type/model where the factors affecting the thermal parameters remain unchanged, including design, principal materials, technology or production lines.
6. Changes to declared information and business responsibilities
Manufacturers and importers must conduct new thermal testing and make a new energy labelling declaration if any of the following changes occur: product structure, principal materials, manufacturing technology or place of manufacture.
Where only the name, address or contact details of the manufacturer or importer, or the trade name or identification code, are changed without affecting the product type/model or the declared thermal properties, retesting is not required. However, the manufacturer or importer must publish the updated information on its website and submit the changes to the Ministry of Construction for updating.
Manufacturers and importers are also responsible for publishing information on energy labelling on their websites and for the legal accuracy, truthfulness and completeness of their declaration dossiers, test results, label information and information disclosed in product advertisements and introductions.
Under Article 16, manufacturers and importers must submit reports using Form No. 01 in Appendix IV to the provincial-level People’s Committee where the manufacturing facility is located or where the business is registered, and concurrently submit the reports to the Ministry of Construction before 1 March of the following year.
7. Inspection, suspension and withdrawal of energy labelling; products manufactured or imported before the mandatory date
Provincial-level People’s Committees are responsible for directing the implementation of energy labelling requirements in their respective localities and for leading or coordinating periodic or ad hoc inspections of labelled construction materials circulating on the market, including products traded through e-commerce platforms.
Cases of suspension or withdrawal of energy labelling are governed by Clauses 1 and 2 of Article 13 of Decree No. 30/2026/ND-CP. Based on inspection results, the provincial-level People’s Committee may issue a decision to suspend or withdraw the energy labelling and notify the Ministry of Construction for publication on the Ministry’s website.
For construction materials manufactured domestically or for which import procedures were completed before the mandatory labelling date applicable to the relevant product group, Article 17.2 permits such products to continue circulating without energy labels, provided that documents are available to evidence the date of manufacture or importation.
Businesses should therefore retain relevant manufacturing records, batch documents and customs documentation to evidence the date of manufacture or completion of import procedures, where necessary.
8. What should businesses prepare?
The businesses directly affected include manufacturers, importers, distributors and traders of construction materials listed in Appendix I. Testing laboratories conducting thermal-property testing are also subject to the Circular.
To prepare for the implementation roadmap, businesses should consider taking the following steps:
First, review the product portfolio. Compare each product, type and model against Appendix I to determine whether it falls within the mandatory energy labelling list and whether it belongs to Group 1 or Group 2.
Second, identify the applicable thermal parameters. Determine the relevant parameter for each product category, including g-value/SHGC for glass; SRI for emulsion wall paint and the relevant exposed surfaces of roofing sheets and metal cladding panels; and thermal conductivity λ for the products specified in Appendix I.
Third, plan the required testing. Review existing test results and select testing laboratories whose accredited or registered scope covers the relevant product, parameter and testing method. Where foreign test results are used, verify compliance with the conditions under Article 10.
Fourth, establish product type/model controls. Maintain records of product structure, design, principal materials, technology, production lines and place of manufacture. This will help determine when retesting and a new declaration are required under Article 9 and when existing test results may be used for products of the same type/model under Article 11.
Fifth, prepare the declaration dossier and label specimen. Prepare technical specifications, test results, the declaration form and the proposed energy label in accordance with Circular 81 and its appendices. Businesses should also prepare internal procedures for publishing the required information on their websites.
Sixth, coordinate with distributors and traders. Ensure that energy label information displayed or provided by distributors, retailers and e-commerce operators is consistent with the information declared by the manufacturer or importer.
Seventh, establish document-retention and reporting procedures. Retain testing records, declaration dossiers, label information and documents evidencing the date of manufacture or completion of import procedures. Submit periodic reports using Form No. 01 in Appendix IV before 1 March of the following year.
Key implementation dates
- 1 January 2027: Circular 81 takes effect. Manufacturers and importers may voluntarily declare and affix energy labels before the mandatory dates, provided that they comply with the Circular.
- 1 January 2029: Mandatory energy labelling applies to Group 1 products: building glass; emulsion wall paint; roofing sheets and metal cladding panels.
- 1 January 2031: Mandatory energy labelling applies to Group 2 products: insulation foam boards; non-fired construction materials; ceiling and partition panels.