Vietnam Food Labeling Regulation

Enacted January 23, 2026, Decree No. 37/2026/ND-CP: Detailing a Number of Articles and Measures to Organize and Guide the Implementation of the Law on Product and Goods Quality now serves as the primary regulation for product labeling in Vietnam, and came into effect on the promulgation date.

By consolidating and replacing Decree 43/2017 and Decree 111/2021, it eliminates prior regulatory fragmentation to offer a unified compliance standard for imported and domestic goods, including foods and food ingredients. This “All-in-One” Decree integrates all prior physical labeling requirements while introducing modern management measures, specifically Electronic Labeling (E-labeling) and mandatory E-commerce information disclosure.

Notes: To fully understand the labeling requirements in Vietnam, enterprises shall also refer to Vietnam's Food Safety Law, the implementation decree for Food Safety Law and the product standard for specific foods. The mandatory labeling items for six types of foods in Vietnam can be found in ChemLinked FoodCheck Tool.

1. General Principles of Labeling

1.1 Applicable scope and exemptions (Article 3 & 35)

A. Applicable scope

• The regulation applies to labels for goods circulating in Vietnam, as well as imported and exported goods. In cases where specialized laws or international treaties to which Vietnam is a member contain provisions different from this Decree, the provisions of those specialized laws or international treaties shall prevail.

• Labeling is mandatory for “Commercial Packaging” (packaging used for circulation). Commercial packaging includes direct packaging and outer packaging.

B. Exemptions

• Goods temporarily imported for re-export; goods in transit, goods transshipped, or goods in bonded warehouses intended for export to a third country

• Goods that are fresh or raw foods, or processed foods without packaging sold directly to consumers

• Packaging used for storage, transport, or preservation of goods that already possess a product label; shopping bags provided at the point of purchase; and packaging used for bulk goods or retail goods sold in loose form — Labels are not required for these packages, as they are not classified as commercial packaging. It is only encouraged to display certain information to assist consumers in identifying and selecting products, such as: the name of the goods, date of manufacture, expiration date, origin of the goods, instructions for use and storage, and warning information.

• Goods in bulk, liquid, or gas form without commercial packaging stored in containers, cargo holds, or tankers are not required to have product labels. However, they must be accompanied by dossiers and documentation that fully present all mandatory contents in Vietnamese as prescribed by this Decree and relevant laws to substitute for the product label. In cases where the accompanying documentation is in a language other than Vietnamese, a Vietnamese translation must be attached.

• Others like luggage of persons entering or exiting the country; goods used in emergency situations for disaster relief or epidemic control; imported goods entitled to diplomatic privileges and immunities under international treaties to which Vietnam is a member; Confiscated goods sold at auction; etc.

1.2 Language Requirements (Article 39, 40)

• Mandatory information on the label must be in Vietnamese. But certain items may be written in other Latin-based languages, including:

• International/scientific names without a Vietnamese equivalent.

• International/scientific names of ingredients that cannot be translated or whose translation is meaningless.

• Names and addresses of foreign enterprises.

• International names of countries/territories that cannot be transliterated or whose transliteration is meaningless, etc.

• Imported goods lacking Vietnamese labels or having insufficient mandatory Vietnamese content must have a supplementary label in Vietnamese while retaining the original label. The Vietnamese content must correspond to the original label. The supplementary label must be attached to the goods or commercial packaging and must not obscure mandatory contents of the original label. It may be provided as an electronic label but must guide consumers clearly on how to access it. Content on the supplementary label is translated from the original label and adds missing mandatory contents required by this Decree. The labeling entity is responsible for the accuracy and honesty of the content.

• Certain goods do not require supplementary labels, such as:

• Raw materials, food additives, processing aids, and components imported for production (not for market sale).

• Samples for testing, certification, research, or advertising; displays at fairs/exhibitions; reference samples.

1.3 Size of Labels, Letters, and Numbers & Colors of Test, Symbol, and Image (Article 37 & 38)

• The size of letters and numbers must be sufficient to be read by the naked eye. Dimensions for measurement units must comply with measurement laws.

• For small goods or small packaging where all mandatory contents cannot be displayed, the physical label must at least display contents under points a, b, and c of Clause 1, Article 42 (namely, goods name, the name and address of the responsible entity, and the origin of the goods). Remaining contents may be provided in accompanying documents or via electronic labels. Small goods/packaging are defined as those unable to fit all mandatory contents at a minimum font size of 0.9 mm.

• For small imported goods where mandatory contents cannot fit at a minimum 0.9 mm font size, the contents required by Clause 2, Article 42 (namely, goods name, origin of the goods, and the name and address of the responsible entity) must be physically labeled on the packaging.

• Colors for text, numbers, drawings, images, signs, and symbols on the label must be clear. For mandatory contents, the text and numbers must contrast with the background color of the label.

1.3 Labeling Position (Article 36)

Labels must be displayed on the goods or their commercial packaging in a position where all prescribed contents can be easily and fully observed without disassembling the product. Goods with both direct and outer packaging shall be labeled according to the following principles:

1. If goods are sold on the market with outer packaging, and the smaller units with direct packaging inside are not sold separately, the label must be placed on the outer packaging.

2. If goods are sold on the market with outer packaging, and the smaller units with direct packaging are also detached for retail sale, both the outer packaging and the direct packaging must be fully labeled.

• In cases where the outer packaging cannot or may not be opened, it must bear a label presenting all mandatory contents.

• If the outer packaging is transparent, allowing the labeling on the internal products to be observed, labeling the outer packaging is not mandatory.

2. Physical Labeling

2.1 Mandatory Labeling Items (Article 42 and Appendix I)

According to Article 42, the following items must appear on the physical label of food products imported into Vietnam:

1. Name of the Goods

2. Name and Address of the Responsible Entity

3. Origin of Goods

4. Category-Specific Requirements: Any additional mandatory content dictated by the nature of the product, as prescribed in Appendix I and other relevant legal regulations.

The table below outlines the additional labeling items required for specific food categories under Appendix I.

When labeling the above items, enterprises shall pay attention to the labeling methods specified in this decree. For example, imported foods need to label the name and address of the manufacturer and the importer. For goods fully assembled from multiple parts or components imported and/or manufactured at different facilities, the label must clearly state the name and address of the final assembler.

2.2 Nutrition Labeling

The labeling item "nutritional composition and values" in Appendix I for ordinary prepackaged foods mainly refers to nutrition labeling. Details regarding the nutrition label are provided in Circular 29/2023/TT-BYT Guiding how to Record Nutritional Facts on Food Labels. 

A. Application scope and exemptions

The Circular for nutrition labeling applies to all prepackaged foods produced, traded, imported, and circulated in Vietnam, except for 12 types of products:

1. Raw materials and foods not sold directly to consumers;

2. Food only with a single ingredient;

3. Natural mineral water, and bottled water;

4. Food salt, and refined salt;

5. Vinegar and vinegar substitutes;

6. Flavorings, additives, and food processing aids;

7. Food enzymes;

8. Tea and coffee not containing other additional ingredients except colors and flavors;

9. Health protection foods (i.e., health supplement/dietary supplement);

10. Alcoholic beverages;

11. Food specified in Clause 2, Article 1 of Decree No. 43/2017/ND-CP on Goods Labels amended and supplemented by Decree No. 111/2021/ND-CP (e.g., fresh goods, raw food, processed foods without packaging and sold directly to consumers); and foods specified in Clause 1 and Clause 2, Article 25 of Decree No. 15/2018/ND-CP Detailing the implementation of a Number of Articles of the Law on Food Safety (e.g., products with small package whose surface area is smaller than 10 cm2: If the nutrition fact is labeled on the outer product packaging or the sub-label of the product, then the immediate packaging, whose size is smaller than 10 cm2, can be exempted from the nutrition labeling);

12. Food produced by small food businesses specified in Clause 10, Article 3 of Decree No. 15/2018/ND-CP

B. mandatory labeling items

All prepackaged foods falling under this nutrition labeling circular must have the labeling of five nutritional components: energy, protein, carbohydrate, fat and sodium. For specific products, they are also required to label additional nutritional components as listed below.

In the case a product does not contain the nutritional components listed above, or contains the nutritional components listed above, but the nutrition value is lower than the value specified in Appendix I of this Circular, the nutritional ingredient is not required to be listed on food labels. For detailed information on how to calculate and label corresponding nutritional values, please refer to this Circular.

3. Modern Updates: E-Labeling & E-Commerce

3.1 Electronic Labeling (Article 52, 53)

The Decree formally introduces electronic labeling (e-labeling). The labeling requirements will be different for foods at different risk levels. Specifically, products will be classified into low, medium, and high-risk categories. Currently, the specific classification list of products is not yet finalized; instead, relevant ministries will progressively release detailed lists based on scientific assessments before July 1, 2026.

• The “Hybrid” Rule: For goods with medium to high risk, enterprises cannot put everything on the E-label. The following must remain on the Physical Label:

1. Name of Goods.

2. Name and Address of the responsible organization/individual.

3. Origin of Goods.

4. Warning Information (Safety warnings).

• Permitted on E-Label: Other details (e.g., detailed instruction manuals, traceability data, detailed technical specs) can be moved to the digital label.

• Accessibility: The E-label must be accessible via common consumer devices (smartphones) and must correspond exactly to the registered data.

3.2 E-commerce Requirements for Sellers (Article 41)

• Sellers must publicly disclose all product labels and electronic labels (if any) on e-commerce platform, except for information specific to each product, such as: manufacturing date; expiration date; production batch number, etc.

• Sellers must accurately declare and update product information in compliance with e-commerce and consumer protection laws.

• Products delivered to consumers must bear compliant physical labels.

4. Others

As the Decree details the rules for quality control of goods, it also specifies requirements regarding the use of barcode, digital product passport, as well as traceability requirements. For example, for “High Risk” goods (categories to be defined by Ministries, often including specific foods), traceability is mandatory. Overseas manufacturers should ensure their products carry data (Batch No., GTIN) that facilitates this.

5. Transition Period

While the Decree is effective immediately (January 23, 2026), there is a transitional arrangement for the implementation of the following issues:

• Organizations and individuals that have been granted Certificates for the use of MSMV (Barcodes/MS Codes) by the Ministry of Science and Technology before the effective date of this Decree may continue to use such Certificates until their expiry.

• Goods with labels complying with Decree No. 43/2017/ND-CP, and Decree No. 111/2021/ND-CP that were manufactured, imported, circulated, or used before the effective date of this Decree may continue to be circulated and used until the expiry date printed on the labels.

• Product labels and commercial packaging with labels complying with the provisions of Decree No. 43/2017/ND-CP and Decree No. 111/2021/ND-CP that were manufactured or printed before the effective date of this Decree may continue to be used, but for no more than 02 years from the effective date of this Decree.

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