Vietnam Promulgates Circular on Nutrition Labeling for Prepackaged Food

On December 30, 2023, Vietnam’s Ministry of Health issued Circular 29/2023 TT-BYT, providing guidelines for labeling nutritional components and values on prepackaged foods. This marks the finalisation of the Circular after the release of the previous draft in February 2023. Additional details about the draft can be found in the article Vietnam Issued the Second Draft of Circular on Nutrition Labeling for Foods.

Key Content

• Application scope

The Circular applies to all prepackaged foods produced, traded, imported, and circulated in Vietnam, with the exception of 12 types of products. Compared to the previous draft, the number of exempted products has increased from 11 to 12. They are:

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 [Newly added compared to the second draft]

Notably, although the exempted products are not required to comply with this Circular, enterprises and individuals involved in the production/trade/import of these products may voluntarily label the nutritional components and values on their products. In such cases, they must adhere to the provisions outlined in this Circular.

• Labeling requirements

A significant difference between this finalized Circular and the previous draft is the adoption of a single method for labeling nutrition information, eliminating the previous two-method approach. According to the Circular, all prepackaged foods falling under its scope 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 in Table 1.

Table 1: Mandatory nutritional components to be labeled for different foods

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.

• Implementation date and grace period

This Circular will take effect on February 15, 2024. Enterprises and individuals affected by this regulation must ensure that the required nutritional components and corresponding values are properly labeled by December 31, 2025.

Starting from January 1, 2026, businesses will be prohibited to produce, print, import, or use labels that do not comply with the provisions of this Circular. However, products produced, traded, imported, and circulated in Vietnam before January 1, 2026, with labels that do not comply with this Circular, can continue to be circulated until their expiration date.

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