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Vietnam to Amend Food Safety Regulations: Potential Changes and Compliance Strategies
Vietnam’s government is in the process of amending Decree No. 15/2018/ND-CP (“Decree 15”), which regulates food business operations under the Law on Food Safety. The proposed amendments, spearheaded by the Vietnam Food Safety Authority (VFA), introduce stricter administrative controls while aiming to improve food safety oversight.
While the government aims to strengthen oversight, businesses argue that several provisions could negatively impact the food industry, particularly small and medium enterprises (SMEs). In this article, we understand Vietnam’s latest amendments to Decree 15 on food business regulations. We also learn about key changes, compliance challenges, and business implications for food industry operators in 2025.
Key proposed amendments to Vietnam’s food safety regulations
Administrative procedure reforms
Vietnam’s Ministry of Health (MOH) has proposed eliminating four administrative procedures and simplifying dossier requirements for ten existing procedures. The objective is to reduce paperwork and streamline food business operations. However, industry representatives argue that some new documentation requirements could increase processing times by up to three months and seven days.
Enhanced role of local authorities
The draft decree proposes greater decentralization, granting local governments more authority in food safety management and inspection. This move aligns with the Government Inspectorate’s recommendations but raises concerns about inconsistent enforcement across provinces.
Post-inspection regulations
The decree introduces stricter post-market controls, requiring companies to update product declarations when making formula or packaging modifications. While this aims to enhance consumer protection, businesses argue it could create unnecessary hurdles for product innovation and market adaptation.
Implementation of government directives
The amendments reflect the Vietnamese government’s effort to implement Inspection Conclusion No. 2555/KL-TTCP, dated December 6, 2024, which called for stricter enforcement of food safety laws. While this directive strengthens oversight, some industry stakeholders worry that increased compliance costs will disproportionately impact small and medium enterprises (SMEs).
Industry concerns and proposed solutions
The European Chamber of Commerce in Vietnam (EuroCham) has raised concerns regarding certain aspects of the draft decree, citing potential adverse effects on business operations. At the consultation meeting, Ms. Nguyen Cam Van, Head of EuroCham Hanoi Office, and Mr. Nguyen Hong Uy, Nutritional Foods Group Sector Committee Member, recommended the following:
- Streamlining label translation requirements to avoid unnecessary administrative burdens on importers;
- Simplifying self-declaration and dossier supplementation processes to improve business efficiency;
- Ensuring that post-inspection regulations do not hinder innovation or impose disproportionate costs on businesses; and
- Aligning Vietnam’s food safety regulations with international practices to prevent trade barriers.
Business representatives fear that introducing additional administrative requirements could cost businesses over VND 1.6 trillion (US$62.6 million) annually and delay market entry for new food products. They have urged policymakers to consult with various industry representatives before finalizing the amendments.
Business implications and compliance challenges
Impact on product declaration and registration
The draft decree tightens regulations for self-declaration, product registration, and re-registration. Businesses argue that these measures are inconsistent with the MOH’s five-year review report, which advocated greater regulatory flexibility.
Compliance costs and delays
- Extended processing times for self-declaration and registration could disrupt supply chains and lead to financial losses.
- Increased administrative fees and documentation requirements could make compliance more expensive for SMEs.
- The lack of risk assessment provisions in the draft decree fails to address key food safety concerns, such as street food, collective kitchens, and fresh food markets.
Potential regulatory overlap
Industry groups emphasized that the Vietnamese government is amending the Food Safety Law, expected to be enacted in October 2025. To prevent duplication and inefficiencies, EuroCham recommended that lawmakers revise the Food Safety Law first before amending Decree 15.
Food categories regulated by the Ministry of Health
The following table outlines the food items under the jurisdiction of the Vietnam Ministry of Health, specifying which products require regulatory approval and certification:
|
Order |
Name of Products/Product Groups |
Notes |
|
1 |
Bottled drinking water, natural mineral water, food ice (instant ice and ice used for food processing) |
Except for ice used to preserve and process products in the sector assigned to the management of the Ministry of Agriculture and Rural Development. |
|
2 |
Functional foods |
|
|
3 |
Micronutrients added to foods |
|
|
4 |
Additives, flavorings, food processing aids |
|
|
5 |
Tools and materials for packaging and containing food |
Except for tools and food packaging materials under the management of the Ministry of Agriculture and Rural Development and the Ministry of Industry and Trade that are produced in the same institution and are only used for food products of this institution. |
|
6 |
Other products not regulated in the lists of the Ministry of Industry and Trade and the Ministry of Agriculture and Rural Development |
|
Recommendations for businesses
Given the potential regulatory changes, food businesses operating in Vietnam should take proactive steps to ensure compliance:
- Review the draft decree and assess its impact on their operations.
- Engage with business associations like EuroCham to participate in industry consultations.
- Prepare longer processing times for product declarations and imports.
- Enhance internal compliance frameworks to meet new regulatory requirements.
- Monitor government discussions on the Food Safety Law to anticipate further legislative changes.
Takeaway
Vietnam’s draft decree amending Decree 15 marks a significant shift in food safety regulation. While the government aims to enhance oversight and enforcement, industry leaders warn that increased administrative burdens could hurt businesses, especially SMEs. The Vietnam Food Safety Authority (VFA) continues to discuss ways with food businesses and industry stakeholders to balance regulatory efficiency with food safety objectives. Food businesses must stay informed and actively engage in policy discussions to mitigate risks and ensure smooth market operations.
(US$1 = VND 25,535)
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