Lithium cell manufacturing is chemical industry in the true sense: organic solvents, lithium salts, acids, heavy metals in electrodes and large volumes of industrial wastewater. The environmental dossier of an EV battery plant in Vietnam is therefore materially heavier than that of an ordinary assembly plant, with three procedural layers: environmental impact assessment, the environmental licence, and the chemical management regime under the Chemicals Law 69/2025/QH15.
Legal basis
- Law on Environmental Protection 72/2020/QH14: Article 30 on projects subject to environmental impact assessment (EIA), and the rules on environmental licences and trial operation of waste treatment works.
- Chemicals Law 69/2025/QH15 (effective 01 January 2026, replacing the Chemicals Law 06/2007/QH12) and the 2026 guiding decrees on chemical declaration, restricted chemicals and conditional chemicals in industrial production.
- QCVN 40:2011/BTNMT on industrial wastewater and the environmental technical regulations applying to emissions, industrial solid waste and hazardous waste of the plant.
Does a battery plant need an EIA?
Yes. Under Article 30 of the Law on Environmental Protection 72/2020/QH14, projects in the group with a high risk of adverse environmental impact must carry out an environmental impact assessment and obtain approval of the EIA report appraisal result from the competent authority before construction. A battery and accumulator plant is a manufacturing project using chemicals and generating industrial-scale wastewater, emissions and hazardous waste, so it falls within the EIA group; appraisal authority rests with the Ministry of Agriculture and Environment or the provincial People Committee depending on project scale and location under current decentralisation. The EIA report of a battery plant must fully assess its specific impact sources: volatile organic solvents at the electrode coating stage, wastewater containing metals (nickel, cobalt, manganese, lithium) from washing and surface treatment, defective cells as hazardous waste, and fire incident scenarios for the chemical store and finished battery warehouse. After the EIA, the project must still obtain an environmental licence before official operation, in which trial operation of the waste treatment works is a mandatory verification step before commercial discharge.
Chemicals in battery production: restricted lists and declaration
From 01 January 2026, chemical management applies the Chemicals Law 69/2025/QH15 replacing the Chemicals Law 06/2007/QH12, so every reference to the old law in existing project dossiers needs review. Under the new framework, chemicals used in battery production are managed in groups: chemicals subject to declaration on import and use (producers declare through the national chemical database system), restricted chemicals, and conditional chemicals in industrial production that must satisfy facility, personnel and safety conditions. Typical substance groups of a cell line include the NMP solvent in electrode slurry, lithium salts and cathode precursors containing nickel, cobalt and manganese, acids and electrolyte solutions containing fluorine salts; each group carries its own requirements on declaration, labelling, safety data sheets (SDS) and storage conditions. A plant importing chemicals for production must complete the import chemical declaration before customs clearance as prescribed and maintain chemical traceability records throughout production.
Which standard must battery plant wastewater meet?
Industrial wastewater discharged to a receiving source must meet QCVN 40:2011/BTNMT, the national technical regulation on industrial wastewater, with the applicable value column determined by the receiving source type recorded in the EIA approval decision and the environmental licence: column A for water sources used for domestic water supply, column B for other receiving sources, with heavy metals, COD and ammonia as the main control parameters for battery production wastewater. A plant with a large discharge flow must install automatic, continuous wastewater monitoring and transmit data to the environmental authority as prescribed. Note that the environmental licence may set discharge limits stricter than the general regulation for the specific project, so the wastewater treatment system must be designed to the limits in the plant own licence, not only to the minimum QCVN column.
Chemical storage: separate requirements, not an ordinary warehouse
The chemical store of a battery plant must satisfy chemical law and fire safety law at the same time: zoning by chemical character (flammable substances such as solvents and electrolytes separated from oxidisers and acids), spill containment and leakage collection kept out of the general drainage system, ventilation and temperature control, safe distances from production areas and surrounding works, chemical incident response equipment and SDS documentation on site. The chemical store design is an item in the fire design appraisal dossier and in the EIA report; changing the types or increasing the stored volume of chemicals after operation can trigger duties to adjust licences and re-appraise the related part. The plant must also build a chemical incident prevention and response plan as prescribed for facilities using hazardous chemicals at regulated thresholds.
Recommended procedure sequence for investors
A safe sequence is: fix the technology and chemical list before preparing the EIA (because the EIA is appraised against the declared technology); design the wastewater treatment system to the limits expected in the environmental licence, not only to the QCVN; separate the chemical store dossier as its own design item with fire appraisal; and build the import chemical declaration duty into the procurement process from the very first raw material lot. Changing production technology after EIA approval is the most common reason a plant must redo environmental procedures mid-way.
Frequently asked questions
Does an EV battery plant need an environmental impact assessment?
Yes. A battery plant is in the high environmental risk project group under Article 30 of the 2020 Law on Environmental Protection, so it must prepare an EIA report and obtain appraisal approval before construction, then hold an environmental licence and complete trial operation of waste treatment works before official operation.
Are chemicals used in battery production on restricted lists?
They are managed in groups under the Chemicals Law 69/2025 (effective 01 January 2026, replacing the 2007 Chemicals Law): chemicals subject to declaration, restricted chemicals and conditional chemicals in industrial production. The NMP solvent, lithium salts, nickel, cobalt and manganese precursors and electrolyte solutions fall into groups requiring declaration, storage conditions, labelling and safety data sheets.
Which standard must battery plant wastewater meet?
Industrial wastewater must meet QCVN 40:2011/BTNMT at column A or B depending on the receiving source under the EIA approval decision and the environmental licence; the licence of an individual plant may impose stricter limits than the general regulation, especially for heavy metals. Large dischargers must install automatic monitoring with continuous data transmission to the environmental authority.
Does chemical storage have separate requirements?
Yes. The chemical store must be zoned by substance character, with spill containment and leakage collection separated from general drainage, ventilation, temperature control, safe distances and incident response equipment, and it is an item of fire design appraisal and of the EIA; changing stored chemical types or volumes can require licence adjustment.
This article has been quality-reviewed by the FLAW AI Legal Council