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Andi Refandi
Andi serves as a Senior Account Executive on Emerhub’s global team.
Food and beverages (F&B) are considered regulated products in Vietnam under the Law on Food Safety (2010). Whether you import, manufacture, or market food products, you need to register your goods to the Vietnam Food Administration (VFA).
In this article, we will cover new regulations on food product registration in 2026. We will also outline two pathways for product registration, core requirements, and overall registration process with the VFA platform.
Compliance Updates on Food Product Registration in 2026
Vietnam has recently undergone its most significant regulatory overhaul in years. As of early 2026, the long-standing Decree 15/2018/ND-CP has been replaced by Decree 46/2026/ND-CP and Resolution No. 66.13/2026/NQ-CP.
However, it encountered operational bottlenecks, especially during the customs and importation process. The government plans to delay the implementation of Decree 46 until 15th of April 2026 and issued Resolution No. 09/2026/NQ-CP.
Under the new framework, several key shifts have occurred that impact your speed to market:
- From “Self-Declaration” to “Declaration of Applicable Standards”: Under the old rules, you could upload your documents and start selling food products immediately. With the new decree, you must now wait for authorities to publish the dossier on their portal before trading.
- The “15-Day Golden Window”: Authorities now have 15 working days to review your dossier for legality and technical accuracy. If discrepancies are found, they can block the declaration immediately.
- Mandatory Re-registration Roadmap: Existing products approved under the old Decree 15 are subject to a transition period (typically 12–24 months). If your product safety indicators have changed under new technical regulations, you must re-declare.
- Expanded Inspection Scope: Unlike before, raw materials, food additives, and packaging used for internal production are no longer universally exempt and may now require conformity declarations.
- Stricter Testing Requirements: Laboratory reports must now strictly come from ISO/IEC 17025 accredited labs, with an expanded list of mandatory parameters including GMO content and new-generation additives.
The update aims to align Vietnam with international food safety standards (like CODEX) and to better manage “high-risk” products. This includes health supplements and functional foods, which have seen a massive surge in popularity (and, unfortunately, counterfeiting).
Choosing your Product Registration Path
Under the current framework, your registration path depends entirely on the risk level and complexity of your product. Emerhub’s experts can provide you with valuable information on the most ideal pathway depending on your product.
Path A: Product Self-Declaration (Tự công bố)
This serves as a notification for relatively conventional low-risk products. Under the new 2026 framework, you need to wait for the local Department of Health to publish your dossier on their official portal. Authorities have a 15-day window to review the legality of the dossier. If they find discrepancies, they can demand a withdrawal.
Applies to:
- Pre-packaged processed foods (biscuits, canned goods, snacks).
- Food additives and processing aids.
- Food containers and primary packaging materials.
Path B: Registration of Product Declaration (Đăng ký bản công bố)
This path is for “high-risk” or specialized products that require explicit approval from the Vietnam Food Administration (VFA) under the Ministry of Health. Unlike Path A, this involves a manual technical assessment by VFA experts. The official timeline is 90 days, though delays often occur if the initial documentation is unclear.
Applies to:
- Health supplements and functional foods.
- Medical nutritional foods (dietary foods).
- Nutritional products for children (up to 36 months).
- Supplemented foods (foods with added vitamins/minerals).
A major change in 2026 is that the VFA now only allows one opportunity to supplement or correct a dossier. If your second submission still fails to meet requirements, the application is formally rejected, and you must restart the process (including paying new state fees).
If your product has additional claims such as to “boost immunity” or “improve digestion,” you must provide clinical trial data or recognized scientific literature translated into Vietnamese. The Vietnamese Food Authority is now incredibly strict about matching claims to proven ingredient dosages.
Note on Supplemented foods: Before the 2026 update, Supplemented foods (standard foods with added vitamins/minerals) have now been moved to this pathway. If your product makes health claims or contains added micronutrients, you likely need a formal Registration Certificate (or Circulation Number).
Core Requirements for Product Registration in Vietnam
To register your F&B products in Vietnam, the government needs to verify the safety of your products before they enter the public supply chain. Keep in mind that for high-risk products, missing or incorrectly formatted documents will result in an immediate block of your market entry under Decree 46/2026.
- The Certificate of Analysis (COA): Your product must be tested at a laboratory that is ISO/IEC 17025 accredited or designated by the Vietnamese Ministry of Health. The testing result must be issued within 12 months of the submission date. You must test for specific safety indicators (heavy metals, microorganisms, etc.) as defined by Vietnam’s National Technical Regulations (QCVN).
- Certificate of Free Sale (CFS) or Health Certificate: For imported products, a CFS must be issued by a competent authority in your home country. This document proves that the product is legally sold and safe for consumption in its country of origin. It must be legalized/consularized by the Vietnamese Embassy of the origin country.
- Good Manufacturing Practice (GMP): If you are registering health supplements, a GMP certificate is mandatory. Vietnam now also recognizes other international standards, like ISO 22000 or HACCP, for high-risk facility compliance.
Labeling Regulations for F&B Products in Vietnam
Part of the compliance you should adhere to when you register products in Vietnam is labeling. Together with new regulations, Vietnam has significantly tightened its labeling laws to prevent fraud and provide better transparency for consumers.
Mandatory Content and Phrasing (Decree 111/2021/ND-CP)
Decree 111 serves as the overarching law for all goods circulated in Vietnam. It dictates precisely what must be on the label and how it must be phrased:
- Product Name: Must be in the largest font size on the entire label to ensure it is the primary focus.
- Origin of Goods: You must use specific, standardized phrases followed by the country name. Acceptable terms include “Made in,” “Product of,” “Manufactured in,” or “Origin.” Abbreviations are generally not permitted for the country name.
- Responsible Entity: The label must clearly identify the importer or distributor with their full business name and registered address in Vietnam.
- Ingredients: Must be listed in descending order by weight. If you highlight a specific ingredient (e.g., “contains real honey”), you must list the exact percentage of that ingredient.
- Production date: Must be presented in the format DD/MM/YYYY (e.g., “Ngay san xuat: 25/03/2026”).
- Expiry‑use or best‑before date: “Han su dung” or “Ngay het han”, also in DD/MM/YYYY format. For “best‑before”‑type products, a “best‑before” phrase is permitted but must be in Vietnamese (e.g., “Tieu chuan han su dung” or “Dung truoc ngay…”).
Mandatory Nutrition Facts (Circular 29/2023/TT-BYT)
Starting January 1, 2026 under Circular 29/2023, pre-packaged foods must display a specific set of nutrition facts. Your labels must have the “mandatory five” indicators:
- Energy (measured in kcal)
- Protein (measured in g)
- Carbohydrates (measured in g)
- Fat (measured in g)
- Sodium (measured in mg)
For specific groups, you must also add the following:
- Sugar-Added Foods: Must include Total Sugars.
- Fried Foods: Must include Saturated Fat.
- Serving Sizes: Values must be calculated per 100g, per 100ml, or per serving (provided the serving size is clearly defined on the label).
The Step-by-Step Product Registration Process in Vietnam
The Ministry of Health oversees the food product registration process to ensure that all food and beverage products meet national standards before they can be marketed in Vietnam. Submissions are now handled entirely online via the National Single Window or the VFA portal.
Step 1: Preliminary Product Review
The first step is to determine the registration path for your products, whether they need a self-declaration or a full registration.
At Emerhub, we begin with a Gap Analysis, which is a comprehensive audit of your product’s current status versus Vietnam’s requirements. We specifically look at:
- Ingredient Compliance: We cross-reference your ingredients against Vietnam’s “Permitted List” for food additives and high-risk substances. Many ingredients legal in the US or EU are restricted in Vietnam.
- Testing Parameters: We compare your existing lab reports with the mandatory parameters set by Vietnam’s National Technical Regulations (QCVN). If your home-country COA is missing even one required indicator (like a specific heavy metal), the entire dossier will be rejected.
- Claim Validation: We review your marketing claims. If you claim a product is “Organic” or “Sugar-Free,” you must have specific certifications that Vietnam recognizes. For example, organic claims must be certified by international systems like USDA Organic, EU Organic, or the Japanese Agricultural Standard (JAS).
Step 2: Laboratory Testing
Vietnam requires specific safety indicators that vary by product type. Before product registration, testing needs to be done by an ISO/IEC 17025 accredited lab in Vietnam. The goal is to test your goods for the following:
- Microbiological Contamination: Checking for pathogens such as Salmonella, E. coli, Coliforms, and Staphylococcus aureus to ensure the product is sterile and safe for consumption.
- Heavy Metals: Measuring levels of Lead (Pb), Cadmium (Cd), Mercury (Hg), and Arsenic (As). Vietnam’s thresholds for heavy metals are often stricter than those in Western markets.
- Physicochemical & Additives: Verifying the concentration of preservatives, sweeteners, and colorants to ensure they do not exceed the limits set by the Ministry of Health.
The testing period is 7-10 working days. We strongly recommend testing locally because Vietnamese labs use the exact detection limits required by the VFA.
Step 3: Dossier Preparation & Translation
A registration dossier is the formal application you submit to the authorities. Under Vietnamese law, the dossier must be presented in Vietnamese. If any original documents are in a foreign language, it must be translated by a certified translator in Vietnam.
The dossier should contain:
- Product Declaration Form: The official “Form No. 1” (or Form No. 2 for Path B), which summarizes the legal entity responsible for the product.
- Certificate of Analysis (COA): The results from your local or accredited lab tests.
- Certificate of Free Sale (CFS): Proof of legal circulation from your home country.
- Technical Specifications (Bản tiêu chuẩn sản phẩm): A detailed internal document you draft that lists every single ingredient, shelf life, storage conditions, and the specific safety limits you promise to maintain. This acts as your “legal contract” with the government.
- Provisional Label (Nhãn dự thảo): A digital mockup of the Vietnamese label that will be attached to the product. It must match your Technical Specifications 100%. If the label says “10% Vitamin C” but your specs say “8%,” the dossier will be rejected.
Your CFS and GMP certificates must be authenticated by your home country’s Ministry of Foreign Affairs and notarized by the Vietnamese Embassy.
Step 4: Submission to the NSW or VFA Portal
In line with Vietnam’s “E-Government” initiative, submissions are now managed almost entirely online through the National Single Window (NSW) or the specialized VFA portal. This digital infrastructure serves as the central hub for all regulatory communication, meaning physical paper submissions are now largely reserved for rare appeal cases.
The specific destination for your digital dossier depends on your product’s risk profile and chosen registration path.
For Self-declaration (Path A)
- Self-declaration is managed on a provincial level. Platform interfaces may vary between different major hubs in Vietnam.
- The dossier is uploaded to the local web portal where your business is headquartered.
For Registration (Path B)
- The dossier is submitted directly to the central authority, the Vietnam Food Administration (VFA) under the Ministry of Health.
- This central portal handles the high-scrutiny technical assessments for health supplements and medical foods.
- Requires a secure digital signature from your local Vietnamese legal representative to finalize the upload.
Step 5: Review and Approval
The final stage of the registration process is the mandatory waiting period while authorities perform their due diligence. Under Decree 46, these timelines are strict, and understanding them is crucial for planning your product launch and avoiding costly storage fees at the border.
Self Declaration (15 Working Days)
- Becomes “effective” once it has been uploaded and publicly displayed on the relevant portal.
- If the authorities find that your testing parameters are insufficient or your labeling violates Decree 111, they can suspend the declaration immediately. Authorities also retain the right to conduct post-inspection audits at your facility.
- Authorities also retain the right to conduct post-inspection audits at your facility or warehouse at any time to verify your dossier.
Full Registration (90 days)
- Subject to a significantly more intensive review by the VFA.
- Manual review process where every health claim is scrutinized against the provided scientific evidence.
- If the VFA finds errors in your initial dossier, you are granted exactly one opportunity to submit supplementary documents or corrections.
- If your second submission is still deemed non-compliant or technically insufficient, the application is formally rejected. In this scenario, you not only lose the significant state registration fees but are also forced to restart the entire application from scratch.
How to Import Regulated Goods in Vietnam
In Vietnam, you cannot register foreign-produced food products without an import license. The specific eligibility criteria for a Vietnam Import license depend primarily on whether your food products are intended for wholesale distribution to businesses (B2B) or direct sale to consumers (B2C).
Regardless of the sales approach, obtaining additional certifications is necessary following the initial registration process for your company. Remember, you cannot import food products without first setting up a Vietnamese legal entity and securing an import and a trading license.
You can check our guide to secure the import license in Vietnam for more information about key regulations, processes, and permits needed to start importing in the country.
A Faster Alternative: An Importer of Record Service
If you’re looking for a simpler and more accelerated method for importing your products into the Vietnamese market, you can use Emerhub’s Importer of Record (IOR) service. As your consignee, we can help your business start importing all your goods into Vietnam without an import license.
Our IOR service already has the necessary licenses for importing goods as well as a pre-established shipping network. You simply have to prepare the shipment, and our team will handle the rest, from pickup to delivery. We also offer warehousing solutions for companies that do not have the necessary facilities in Vietnam.
Beyond logistics, our team can also support your broader market entry, from registering your products with the relevant Vietnamese authorities to establishing a local supply chain.. We can also implement e-commerce solutions to keep your operations running smoothly in the country.
Want to start importing your food products in Vietnam? Fill in the form below, and our local compliance specialists can help you get started.
Frequently Asked Questions (FAQs) About Product Registration in Vietnam
For low-risk products (Self-declaration), it takes about 2–3 weeks. For high-risk products (Registration), the official timeline is 90 days. However, factoring in testing and document legalization, you should plan for 4–6 months.
There is a transitional period under Decree 46/2026.. Generally, products with a valid certificate can continue to circulate for 18 months from the decree’s effective date or until the product expires. However, many retailers now demand the updated 2026 compliance documents immediately.
All food registrations must be held by a Vietnamese legal entity (either your subsidiary or a local partner/distributor). The entity holding the registration is legally responsible for the product’s safety.
If you change the main ingredients or the product name, you must file a new registration. Minor changes to packaging design or “excipients” (non-active ingredients) usually only require a written notification to the authorities.
Vietnam follows a “Permitted List” for additives and ingredients. Certain high-dose vitamins or specific herbal extracts used in Western supplements may not be recognized. Always conduct an ingredient review before shipping samples.
The registration is for the “product line.” Once you have the certificate, you can import multiple batches. However, you must maintain “Internal Testing” records for 3 years in case of a market audit.


