You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

January 5, 2018

APFI Food Safety Regulations Series: Vietnam

Subscribe to Updates
Asia Pacific Food Industry (APFI)

To better understand the food regulatory landscape in Asia, APFI has spoken to law firms that specialize in food law from five different countries across Asia, which include China, Thailand, Vietnam, Singapore and the Philippines. 

In the third part of the series, we look at food safety regulations in Vietnam. Hien Thi Thu Vu, head of regulatory affairs, Vietnam, Tilleke & Gibbins, shares her advice.

How do food regulation and registration vary depending on the product or category?

Food products, depending on the product category, are regulated and managed by three different ministries: the Ministry of Health (MOH), the Ministry of Industry and Trade (MOIT), and the Ministry of Agriculture and Rural Development (MARD). The MOH has the prevailing general management power.

These ministries have issued three lists of foods, specifying which food belongs to the management of which ministry. The MOH, for example, is in charge of bottled water, functional foods, and nutraceuticals; the MOIT is in charge of wine, beer, and candy; and the MARD is in charge of cereals, meat and meat products, and seafood. This classification affects a number of things, including which authority carries out food safety inspection.

Regardless of their categories, all foreign processed foods must be registered with the Vietnam Food Administration (VFA)—an agency of the MOH—to obtain a Certificate of Conformity Declaration (CCD) before being imported into and/or circulated in the Vietnam market.

Processed foods include two main groups: general food products, and nutraceuticals/functional food products. Depending of the group, food products may have to meet different requirements before getting the CCD. For example, a functional food must have a Free Sale Certificate or Health Certificate or an equivalent certificate granted by competent authorities in the country of origin, along with information and scientific documents supporting the effects of each ingredient contributing to the declared functions of the product. General food products are exempt from these requirements, but must provide testing results from within the past 12 months, including key quality criteria and food safety criteria.

It is strictly required that product labels comply with the country’s labelling requirements, such as compulsory contents in the Vietnamese language.

Have you seen a growth in the number of food and beverage companies entering the markets in Vietnam?

Yes, the market is growing fast and the game is growing more and more competitive. Food and beverage conferences and exhibitions regularly attract hundreds of companies from Europe, Asia, and the Americas looking to introduce their products to the Vietnam market, and business advocates like the European Business Network in Vietnam and the American Chamber of Commerce have organized trade promotion activities in sectors such as canned food, milk, beer, and wine. The launch of the European Union-Vietnam Free Trade Agreement is certain to open the market further to European food and beverage companies.

At present, many foreign businesses are investing in the country’s food and beverage market through mergers and acquisitions to own shares in many of the nation’s domestic companies, such as Kido Group, Dabaco, and Masan Nutri-Science. More than 50 percent of the local beverage market is now owned by foreign businesses.

Which regulatory hurdles should manufacturers be aware of when entering the food market in Vietnam?

When it comes to preparing for market launch, there are some regulatory hurdles that foreign food manufacturers and distributors will inevitably encounter in Vietnam.

The general regulations on the levels, criteria, and requirements for heavy metals, pollutants, microorganisms, etc., related to food safety and hygiene for human health issued by the Ministry of Health have not been updated since 2011, and are not in line with corresponding standards in other countries where the products are often produced.

Although there is an online submission system for registering products in Vietnam, government agencies still require manufacturers to submit original documents such as the Certificate of Analysis, Hazard Analysis and Critical Control Points, and ISO 22000 certificates. This slows down the registration process of the product.

Some labelling regulations are not flexible enough to cover exceptions in special cases, such as beverages sold exclusively to bars, and food sold exclusively to manufacturers’ store systems.

Foods circulating in the market are subject to periodic quality testing. At present, however, many labs in Vietnam do not have high-quality operations, which can lead to inaccurate test results, affecting the test quality of products. This in turn can lead to products not being in conformity with the documents registered with government agencies. In this case, the CCD might be revoked, and a sanction may be imposed against the seller/importer.

One common violation of food products is in labelling, when the information on the label is different from the information submitted to the VFA or when the label changes without notice being sent to the VFA. This can result in a fine being imposed on the seller/importer, and the goods being withdrawn from the market. Manufacturers should closely monitor any changes in their products and labels to ensure compliance.

Do you predict any major changes to transpire in Vitnam’s food industry in the next five to ten years?

With a population approaching 100 million, strong gross domestic product growth, rising per capita income, rapid urbanization, and growing concerns about food safety from consumers, Vietnam’s market is promising even more growth and development in the coming time, especially for foreign manufacturers.

The legal regulations for food and drinks are becoming more transparent. There have been some updates of regulatory requirements which facilitate the market launch of products. For example, online submission will be encouraged for registration of food and beverage products, and this process is expected to save time and money for suppliers.

The safety and quality of food is a growing concern for consumers as well as state regulators:

  • Products from highly reputable foreign companies, especially in baby food and health foods, will be more and more in demand.
  • State management agencies will intensify the frequency of inspection of various stages of the manufacturing processes. Non-compliant activities could lead to sanctions such as product recall.

Are there any other thoughts you would like to share with our readers?

Already promising and potentially hugely profitable, the food and beverage market is still growing. There will be increasingly more room and opportunity for foreign manufacturers. In parallel with income growth, consumers are becoming increasingly more selective about their food and drink purchases, particularly the quality and safety of the products, and are willing to spend more for a better choice.

Though seemingly clear and detailed, Vietnam’s legal regulations can be unpredictable in practice, with many grey areas, jurisdictional overlap, and contradictions to cope with. However, we believe that with the growing effort of the government to cut through the red tape, the regulatory hurdles will be significantly lowered in the future.

Please provide an overview of what the firm does.

Tilleke & Gibbins is a regional law firm in Southeast Asia, with 150 lawyers and consultants in Bangkok, Hanoi, Ho Chi Minh City, Jakarta, Phnom Penh, Vientiane, and Yangon. We represent investors and companies in the key areas of commercial transactions as well as mergers and acquisitions, dispute resolution and litigation, and intellectual property.

One of our important practice areas is regulatory affairs, where we assist companies in the pharmaceutical, cosmetics, consumer products, food and beverages, biotech, medical devices, veterinary products, and other life sciences sectors to enter markets throughout Southeast Asia. We assist companies in research and development and clinical trials to registration and market entry to commercialization and technology transfer, through every stage of a product’s life cycle.

Our Regulatory Affairs practice spans the following disciplines:

  • Clinical Trials and Consumer Testing
  • Registration with Vietnam Food Administration (VFA) or Drug Administration of Vietnam (DAV)
  • Import, Export, and Manufacturing Licenses
  • Ministry of Agriculture and Rural Development (MARD) Crop Care Registration
  • MARD Animal, Aquatic, and Hazardous Substance Registration
  • MARD Import, Export, and Manufacturing Licenses
  • Regulatory Compliance and Maintenance
  • Labeling and Advertising Clearance
  • Intellectual Property

Article by Farah Nazurah Source: http://apfoodonline.com/industry/food-safety-regulations-series-vietnam/

Related Professionals

Industries

Life Sciences

Practices

Regulatory Affairs

Location

RELATED INSIGHTS​ 

November 25, 2025
Food safety incidents can emerge without warning, requiring businesses to act swiftly to protect consumers and comply with regulatory obligations. Across Southeast Asia, Thailand, Vietnam, and Indonesia have each developed comprehensive food recall frameworks designed to ensure rapid removal of unsafe products from the market while holding businesses accountable for compliance failures. While these three jurisdictions share common objectives—protecting public health and ensuring food safety—each has crafted distinct regulatory approaches reflecting their unique administrative structures, enforcement priorities, and legal traditions. Understanding these differences is essential for food businesses operating in the region, as recall procedures, timelines, reporting requirements, and penalties vary significantly across borders. This guide, available through the button below, examines the food recall regulations in Indonesia, Thailand, and Vietnam, providing practical guidance on legal requirements, procedural steps, and compliance obligations in each market.
Read More
October 15, 2025
The Indonesian Food and Drug Administration (BPOM) has introduced more stringent oversight of health supplements containing probiotics with new guidelines that require clinical trials for certain products and expanded documentation standards. BPOM Regulation No. 17 of 2025 replaces the previous 2021 regulation and establishes a comprehensive framework for evaluating probiotic strains used in health supplements. Assessment Requirements The new regulation expands the scope of assessment to include not only categorization and documentation but also technical procedures, strain classification, and clinical trial requirements. Unlike the previous regulation, which provided general guidance, the updated framework creates a comprehensive system for evaluating both registered probiotic strains and new or combined strains. Manufacturers must now submit supporting documentation covering strain identification and functional characterization, safety, efficacy, and product quality. The previous regulation required documentation only on safety, efficacy, and quality. Clinical Trials One of the most significant changes is the requirement for clinical trials conducted in Indonesia for applications that include benefit claims other than maintaining digestive health, or where there are modifications to benefit claims. The regulation specifies that phase 1 trials must demonstrate safety, while phase 2 trials must validate efficacy using statistically valid methods such as double-blind, randomized, placebo-controlled studies). In addition, phase 3 and phase 4 trials may be required, and postmarket surveillance data must be submitted. Technical Assessment Framework Annex 4, a newly introduced section, establishes technical procedures for assessing health supplements containing probiotics in Indonesia. This comprehensive framework outlines criteria for evaluating new probiotic strains, including strain identification, functional characterization, safety, efficacy, and product quality. The annex introduces a clear classification of claims for health supplement products containing probiotics: General claims(e.g., maintaining digestive health). Functional claims(e.g., normal biological function or activity in the body). Risk reduction claims(e.g., lowering disease risk). The regulation restricts use of the term
Read More
October 3, 2025
On September 26, 2025, the Contract Committee under Thailand’s Consumer Protection Board issued a regulation that aims to standardize contracts and enhance consumer protection within the beauty and wellness industry. The Notification on Prescribing the Beauty Service Business as a Contract-Controlled Business B.E. 2568 (2025), which takes effect on January 24, 2026, requires business operators to use a prescribed standard contract in Thai and adhere to strict mandatory provisions and prohibitions. These regulations apply to operators across all in-person and online service channels, including via digital platforms. “Beauty services business” is defined as the provision of services under an agreement allowing consumers to receive a series of treatments, either over a set number of sessions or within a set period. This includes massage, spa, other methods for cleanliness, beauty, or care of facial or body skin, and weight control and body shaping—including services offered electronically. The law excludes surgery, liposuction, and medical treatments performed by licensed practitioners. The notification establishes the following key requirements: Mandatory contract and formatting. All contracts with consumers must use the standard contract form, in Thai, with clear, readable text (minimum font size of 2 millimeters, no more than 11 characters per inch), and include all essential terms from the annexed form. Contract execution. Contracts must be made in duplicate, with one copy given to the consumer at signing. For agreements concluded through electronic channels, the process must comply with the Electronic Transactions Act and use the same required terms. Digital platforms. Business operators who provide services facilitated through a digital platform as an intermediary are ultimately responsible for ensuring the consumer receives a compliant contract. Prohibited clauses. The law prohibits clauses that limit or exclude liability for damages to life, body, health, mind, or property resulting from breach of contract or a wrongful act;
Read More