Vietnam's Ministry of Construction has opened public consultation on a draft circular that would, for the first time, set specific minimum sustainable aviation fuel usage percentages for flights departing Vietnamese airports, alongside a broader overhaul consolidating the country's aviation greenhouse gas and environmental protection rules into a single framework.
The Proposed SAF Roadmap
For international flights departing Vietnamese airports, the draft proposes a minimum SAF blend starting at 1% from 2030, rising to 2% in 2031, 3% in 2032, 4% across 2033-2034, 5% across 2035-2037, 7% across 2038-2039, and 10% from 2040 onward. A separate, later-starting roadmap applies to domestic flights: a minimum of 1% across 2032-2034, 2% across 2035-2037, 3% across 2038-2039, and 5% from 2040. Airlines using SAF earlier or at higher rates than the minimum would be encouraged, though not required, under the draft. If enacted, this would mark a genuine shift in Vietnam's aviation fuel policy, moving SAF from an encouraged or trial-basis fuel toward a mandated minimum component of operations, phased in gradually rather than all at once.
Why the Framework Is Being Consolidated Now
Vietnam's current legal basis for aviation emissions rests on two separate circulars: Circular 22/2020/TT-BGTVT, covering fuel consumption and CO2 emissions management, and Circular 52/2022/TT-BGTVT, covering environmental protection in civil aviation. The Ministry states that as ICAO's own international requirements have continued to evolve and Vietnam's green transition targets have advanced, these two existing circulars have not kept pace, and maintaining them as separate documents risks fragmented, harder-to-enforce regulation. The new draft is structured specifically to merge both into one unified framework, while assigning clear, separated responsibilities across the Civil Aviation Authority of Vietnam, aircraft operators, airport operators, fuel suppliers and air navigation service providers.
How CORSIA Implementation Would Be Strengthened
The draft proposes a complete monitoring, reporting and verification chain for Vietnam's CORSIA obligations, covering data collection, calculation, reporting, emissions verification, and the determination and fulfilment of offsetting obligations. Circular 22/2020 was issued early in CORSIA's rollout and focused mainly on fuel consumption tracking and CO2 reporting; ICAO has since added more detailed requirements around monitoring, reporting and verification (MRV) specifically, and around determining and fulfilling offsetting obligations, which this draft is designed to formally incorporate. Beyond CORSIA-covered international flights, the draft separately extends emissions tracking and data-reporting coordination requirements to domestic aviation operations as well.
Making Airports Directly Accountable for Carbon
Airport and airfield operators would be required to build, organise or integrate carbon management and greenhouse gas reduction content into their environmental protection plans, operational plans, or green transition plans, calibrated to their scale and actual operating conditions. Critically, the draft draws a specific accountability line: airport operators are responsible for emissions sources they own or control directly, but for emissions from aircraft operators and other parties, airports play a coordinating and facilitating role rather than bearing responsibility on those parties' behalf. The Ministry frames this distinction as necessary specifically to prevent airport operators from being held liable for emissions belonging to airlines or other business operators, while still giving airports a structural role in coordinating sector-wide data and reduction efforts.
A New Climate Adaptation Requirement for Airport Construction
The draft introduces a requirement, absent from the two existing circulars, to assess climate change impact, vulnerability and risk specifically for aviation operations. Airport enterprises and air navigation service providers would be responsible for supplying data on extreme weather effects and participating in risk assessment and mitigation planning to maintain essential operations and limit disruption. For new airport construction or upgrade projects specifically, climate risk assessment results and climate scenarios would need to be factored in from the site-selection and design stage onward, rather than considered only after construction.
Noise Management Gets Its Own Dedicated Structure
Separately from emissions, the draft builds out a dedicated noise management mechanism covering monitoring, impact identification, complaint handling, and management measures suited to each airport's actual operating conditions. Rather than duplicating existing technical noise and engine emissions standards, the new framework focuses specifically on aviation-specific environmental management content: noise impact assessment, noise mapping tied to greenhouse gas emissions and reduction, and environmental protection measures at airports. Four new articles not present in the prior circular are proposed, covering noise-reducing operational procedures, coordinated land-use planning, a "balanced approach" to aircraft noise management, and a formal channel for receiving and responding to noise complaints.
What Remains Open
This is a draft circular still under public consultation; no closing date for comments, anticipated issuance date, or enforcement start date beyond the SAF roadmap's own 2030 starting point were specified in the reporting reviewed. The proposal's SAF percentages, CORSIA verification chain, and airport carbon accountability structure could all still change before any final circular is issued.
Source: Tạp chí Hàng không (Vietnam Aviation Magazine, published by the Vietnam Aviation Businesses Association), 16 September 2026.
