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

July 15, 2025

Vietnam Updates Guidelines on Drug Quality Standards, Testing, and Noncompliance

On July 1, 2025, Vietnam’s Ministry of Health issued Circular No. 30/2025/TT-BYT providing updated guidance on the application of drug quality standards, testing of drugs and pharmaceutical ingredients, and procedures for the recall and handling of noncompliant drugs (Circular 30). Circular 30 officially came into effect on the same day and replaces Circular No. 11/2018/TT-BYT and its amendments.

Key highlights of Circular 30 are presented below.

Drug and Pharmaceutical Ingredient Quality Standards

Circular 30 maintains consistency with previous regulations regarding the selection of an applicable quality specification. Pharmaceutical businesses and drug preparation establishments may still choose to apply standards from the Vietnamese Pharmacopoeia, reference pharmacopoeias (including the United States Pharmacopoeia, the European Pharmacopoeia, the British Pharmacopoeia, the Japanese Pharmacopoeia, and the International Pharmacopoeia), or an in-house specification.

Priority is given to the Vietnamese Pharmacopoeia and reference pharmacopoeias, encompassing quality indicators, quality levels, and testing methods. If alternative pharmacopoeias or in-house specifications are used, they must meet the requirements outlined in the corresponding monographs of the Vietnamese or reference pharmacopoeias.

At the time of registration, the quality standards of drugs and pharmaceutical ingredients must comply with either the current version of the pharmacopoeia or a previous version of the pharmacopoeia that is no more than two years older than the current version.

The requirement for updating quality specifications in line with the quality under the corresponding pharmacopoeia also applies to products that have already been granted marketing authorization.

Testing Drugs and Pharmaceutical Ingredients in Quality Management

Similar to the regulations under the previous circular, if pharmaceutical businesses disagree with the sample testing results, they may, within five working days of receiving the test report, request that the state quality inspection authority designate an alternative testing facility.

The testing period for establishments listed as foreign drug manufacturers with quality violations remains largely unchanged. However, Circular 30 reduces the mandatory testing duration from 12 months to 6 months for manufacturers with two batches classified as having Level 3 quality violations.

Newly added under Circular 30, vaccines and biological products such as antibody-containing sera and blood/plasma derivatives must undergo testing before being released to the market. In addition to the National Institute for Control of Vaccines and Biologicals, businesses may submit samples to other designated testing facilities listed by the Drug Administration of Vietnam (DAV).

Circular 30 introduces provisions for exemption from one or more pre-market testing procedures for vaccines and biologicals (excluding first-time imports). For example, non-injectable vaccines and biologicals imported from countries with stringent regulatory authorities (SRAs) may be exempt from pre-market testing procedures, while injectable vaccines and biologicals imported from SRA-member countries may be exempt from testing one or multiple quality indicators.

Recall and Handling of Noncompliant Drugs

Circular 30 clearly defines the roles and responsibilities of the provincial and municipal health departments in receiving information and handling noncompliant drugs in the area.

The voluntary drug recall process has also been revised. Specifically, after detecting a drug that violates or shows signs of violating quality standards, and assessing and determining the severity of the violation, pharmaceutical businesses are now permitted to initiate a recall without prior approval from the DAV. They may proceed to recall the affected drug, notify the distribution and usage establishments that received it, and conduct the recall. These actions can be carried out in parallel with submitting a report on noncompliance to the DAV that includes information related to the violations, the self-assessed violation level, and the scope of the recall. This represents a significant shift from the previous procedure, which required businesses to wait for official approval before initiating a recall.

Outlook

Circular 30 is expected to have a significant impact on pharmaceutical businesses and drug preparation establishments. These entities should carefully review the document to facilitate their activities and to ensure compliance with Vietnamese regulations.

RELATED INSIGHTS​ 

August 8, 2024
On July 19, 2024, Thailand’s Ministry of Public Health Notification No. 450 B.E.2567 (2024) came into effect after being published in the Government Gazette the day before. The notification introduces significant updates to the labeling requirements for prepackaged foods. This new regulation consolidates and updates Thailand’s rules for food labeling by repealing and replacing several previous notifications. The notification’s key changes and their implications for food businesses are identified below. 1. Clarified “Best Before” Definition The notification aligns the definition of “best before” with Codex standards. It now refers to the date marking the end of the period during which the food maintains its best quality under stated storage conditions. After this date, food quality may change, and the product cannot be marketed. 2. Updated Labeling Exceptions Certain foods are exempt from labeling requirements, with the latest list including: Foods sold directly to consumers by manufacturers who can provide product information. Unprocessed foods. Some fresh foods not sold directly to consumers. Prepackaged foods produced and sold for immediate consumption in food service settings. However, any of these exempt foods that have received food serial numbers must still have labels that comply with the notification. 3. Expiration Date and Best-Before Date Display The notification provides clearer language for displaying the expiration date and best-before date. If specific wording is required by other notifications, it must be followed. English equivalents are now permitted alongside Thai text. 4. Warning Displays Multiple applicable warnings can now be consolidated and displayed together, provided the complete message is included as specified. 5. Claims about Substances or Ingredients New guidelines have been established for making claims about food additives and ingredients. Claims should be factual, not deceptive, and provably not false. 6. Label Placement and Design Labels must be permanently affixed, proportionate to the packaging, and
August 8, 2024
Tilleke & Gibbins has contributed the Thailand chapter to the 2024 edition of Pharmaceutical Advertising from the International Comparative Legal Guides (ICLG) series published by Global Legal Group. This detailed guide offers an in-depth examination of pharmaceutical advertising laws and regulations in multiple jurisdictions around the globe. Each chapter of the guide, structured in a Q&A format, is organized into comprehensive sections covering various aspects of pharmaceutical advertising, including: General rules and codes of practice governing pharmaceutical advertising Required arrangements for ensuring compliance with advertising regulations Procedures for obtaining advertising approvals from regulatory authorities Penalties for non-compliance with advertising rules Guidelines for providing information prior to product authorization Requirements for advertisements directed at healthcare professionals Restrictions on the content of pharmaceutical advertisements The complete Thailand chapter is available as a PDF below. The Thailand chapter—and the full Pharmaceutical Advertising guide—are also freely available on the ICLG website.
July 31, 2024
On July 18. 2024, Vietnam’s Ministry of Health issued Circular No. 12/2024/TT-BYT promulgating National Technical Regulation QCVN 20-1:2024/BYT on the limits of contaminants for health supplements (“Circular 12”). The new national technical regulation is the very first relating to health supplements, and is expected to have a great impact on the control of health supplement quality in Vietnam. Circular 12 will take effect on August 1, 2025. Contents of Circular 12 The new circular prescribes limits of contaminants (heavy metals and microorganisms), testing samples and testing methods, management requirements, and responsibilities of entities manufacturing and trading in health supplements. Supplemented alcohol products which are declared as health supplements are notably excluded from the scope of the regulation. Transitional Provisions Health supplements which (i) have been granted a declaration registration certificate, and (ii) are manufactured before August 1, 2025, are allowed to continue to be imported, traded, and circulated until the expiry date of the product, even if it is not aligned with Circular 12, except when there is food safety warning. Declaration registration dossiers for health supplements submitted before August 1, 2025, will continue to be handled in accordance with the prevailing regulations at the time of submission. From August 1, 2025, if a health supplement with a granted declaration registration certificate has a manufacturer’s standard that does not comply with Circular 12, the party manufacturing/trading in the product must adjust the product standard to conform to Circular 12 and notify the authority of this adjustment.
June 24, 2024
Thailand’s Minister of Public Health recently promulgated the Ministerial Notification Re: Category 5 Narcotics Which Are Not Cannabis or Hemp Extract and Whose Consumption is Permitted for Treatment of Disease or for Research Purposes (2024). The notification took effect on April 23, 2024. The substances whose regulatory controls are affected by this new notification are psilocybin mushroom (Psilocybe cubensis (Earle) Singer), opium poppy (Papaver somniferum L. and Papaver bracteatum Lindl.), and other plants in these genera from which opium, opium alkaloids, psilocybin, or psilocin may be derived. As a result of this notification, these substances are now classified as category 5 narcotics that can be applied in medical treatment. Without the implementation of this notification, patients could not access newly developed medicines containing these substances, as Thailand’s Narcotic Code prohibits the possession and use of category 5 narcotics. Nonetheless, this does not mean that psilocybin mushrooms and opium can be used without any conditions. There is still a long process to go through before these substances can be used in medical treatment or clinical studies. Under the new notification, the FDA must first approve any medicinal drug formulation containing any of the above substances, and subsequently, the production must be approved for medical use or research purposes. The importation of medicinal drug formulations containing psilocybin mushrooms or opium is not allowed. This seemingly small regulatory change addresses the previous legal obstacle to the research and development of such medicines. According to the previous regulation, a physician or researcher could apply to the Thai FDA for a license to produce or possess medicines containing the aforementioned narcotics. However, production and consumption are considered different activities, and consuming a narcotic-containing medicine, even if it was produced under a valid license, is prohibited by the Narcotics Code and is punishable by imprisonment,