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Vietnam Food Contact Material Regulation

Lennie Tao Last updated on: Dec 27, 2023

1. Definition

Food contact material (FCM) in this article refers to food utensil, package and container as per Vietnam’s Food Safety Law.

2. Competent authority

Competent authority

Responsibility

Ministry of Industry and Trade (MOIT)

  • Management of a range of food products within its jurisdiction, including processed milk, vegetable oil, alcoholic drink, beverage, etc. This encompasses both the products themselves and their packaging.

  • Management of chemicals and packaging sector in general

Ministry of Agriculture and Rural Development (MARD)

Management of food products under its jurisdiction, including aquatic products, meat products, etc. This encompasses both the products themselves and their packaging.

Ministry of Health (MOH)

  • Management of food safety in general and food products under its jurisdiction, including food product's packaging

  • Promulgation of national technical regulations on safety criteria and limits on food utensil, packages and containers

  • Receipt and acknowledgement of self-declaration documents for FCM from FCM manufacturers/traders

Ministry of Environment and Natural Resources (MONRE)

Overseeing of regulations pertaining to the recycling and waste treatment of packaging, i.e. Extended Producer Responsibility (EPR) regulations.

General Department of Vietnam Customs

Customs inspection, quarantine, and declaration

3. Overall product compliance

Food Safety Law 2010 raises general food safety conditions for food utensils, packages and containers. Details are as below.

3.1 Basic requirements

As per Article 18, food utensils, packages and containers shall be made of safe materials, guaranteeing that they do not release toxic substances, strange smell, or strange taste into food, and they preserve food quality within the shelf life.

3.2 Technical requirements

Food utensils, packages and containers are required to meet relevant technical regulations released by MOH on FCM. Currently, MOH only has the following four national technical regulations on FCM.

For situations where Vietnam has not yet promulgated relevant technical regulations, international agreements or treaties to which Vietnam is a contracting party can apply. For example, ASEAN General Guidelines on Food Contact Materials is a reference for member state to use FCM safely.

3.3 Product self-declaration

Prior to import, importers of food utensil, package and container shall make product conformity self-declaration as per Food Safety Law and Decree No. 15/2018/ND-CP of the Government: Detailing the Implementation of a Number of Articles of the Law on Food Safety (partially amended by Decree No. 155/2018/ND-CP).

General procedures for self-declaration:

  • Food FCM traders submit a dossier for self-declaration of product conformity by post or in person to the MOH. If the dossier is complete and in accordance with the regulations, the competent authority will upload the product’s information on their public system. If the dossier is not satisfactory, the authority will return it to the traders for correction.

  • At the same time, the food trader will publish the declared dossier about the product at the company's headquarters or upload to their website or mass media.

  • Right after the self-declaration is completed, the supplier is entitled to manufacture and sell the product and assume full responsibility for the safety of such product.

Needed materials include:

  • The self-declaration form (Form No. 01 in Appendix I of Decree No. 15/2018);

  • The original copy or a certified true copy of the food safety data sheet issued within 12 months before the self-declaration is made by a designated laboratory or a laboratory complying with ISO 17025.

3.4 State inspection & required certificate

According to the Food Safety Law, each consignment of imported food packaging utensil, package and containers are subject to state inspection of food safety. Details can be found in

Moreover, traders of food utensil, package and container are exempted from the certificate of satisfaction of food safety conditions as per Article 12 of Decree No. 15/2018/ND-CP.

3.5 EPR regulations

In Vietnam, EPR regulations regarding packaging, particularly FCM, are governed by the Environmental Protection Law and its subordinate regulations. The requirements under EPR are mandatory for FCM enterprises, focusing on two main aspects: food packaging’s recycling responsibility and waste treatment responsibility. For more information about this, please refer to our Pedia on EPR or our free webinar EPR Compliance Made Easy: A Guide for Businesses in Vietnam.

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Tags:   Vietnam
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