On 8 April 2026, the Government of Vietnam issued Resolution No. 15/2026/NQ-CP, temporarily suspending certain provisions introduced under Resolution No. 66.13/2026/NQ-CP and Decree No. 46/2026/NĐ-CP. These measures had introduced more stringent pre-market controls and registration requirements for food products, including health supplements.

The suspension reflects implementation challenges faced by both regulators and industry and provides additional time for legislative review. While it offers short-term procedural relief, it does not eliminate existing regulatory obligations or materially reduce the compliance burden associated with product registration.

Why Vietnam Introduced the Temporary Suspension

Vietnam's food safety regulatory system has undergone significant modernization efforts in recent years. "Resolution No. 66.13/2026/NQ-CP" and "Decree No. 46/2026/NĐ-CP" represented a substantial shift toward stronger pre-market controls, enhanced product registration requirements, and more structured risk-based oversight at both import and post-market stages.

The reforms were intended to:

• Strengthen food safety governance
• Improve market transparency
• Enhance consumer protection
• Increase supply chain accountability
• Support more effective post-market surveillance

The changes were particularly relevant to health supplements, a rapidly growing category that has attracted increased regulatory scrutiny.

However, implementation exposed a number of practical challenges, including:

• Procedural bottlenecks
• Disruptions to product circulation
• Increased administrative burden for applicants
• Difficulties adapting to new procedural requirements

Against this backdrop, the Government adopted a transitional approach through "Resolution No. 15/2026/NQ-CP" to alleviate immediate implementation pressures while broader legislative reforms are considered.

Temporary Suspension Does Not Remove Compliance Obligations

Although certain provisions have been suspended, companies should not interpret the Resolution as a relaxation of regulatory expectations.

Businesses remain subject to the requirements of Vietnam's Law on Food Safety and should continue maintaining robust compliance programs throughout the transition period.

Authorities may still request supplementary information during the review of product registration dossiers, particularly for health supplement products due to their direct connection to consumer health and the complexity of product claims.

Health supplement applicants may continue to encounter requests for:

• Additional supporting documentation
• Clarification of product information
• Verification of product composition and safety data
• Supplemental evidence supporting registration submissions

Foreign manufacturers, importers, brand owners, and distributors should therefore continue preparing dossiers to current regulatory standards and anticipated future requirements.

Expected Registration Timeline for Health Supplements

Health supplement registrations continue under the existing framework.

Companies should plan for the following indicative timeline:

• Dossier preparation: approximately 3 to 4 weeks
• Authority review: approximately 30 to 60 working days
• Supplementation phase, if required: approximately 2 to 4 additional weeks

In most cases, the overall registration process takes approximately two to four months, although timelines may vary depending on dossier complexity and regulatory queries.

Food Safety Law Amendments Expected in Late 2026

The temporary suspension is widely viewed as an interim measure ahead of broader legislative reform.

Proposed amendments to Vietnam's Law on Food Safety are expected to be reviewed during the second session of the 16th National Assembly, with deliberations currently anticipated between October and November 2026.

Additional Implementing Regulations Likely to Follow

Following adoption of any legislative amendments, the Government is expected to issue new implementing decrees and guidance documents to clarify enforcement requirements and registration procedures.

These secondary regulations will likely play a critical role in shaping future compliance obligations for food manufacturers and importers operating in Vietnam.

Companies should therefore monitor both legislative developments and subsequent implementing measures as they emerge.

Recommended Compliance Actions During the Transition Period

As Vietnam's food safety framework continues to evolve, businesses should maintain a cautious and proactive compliance strategy.

Companies are encouraged to:

• Continue preparing registration dossiers to a high regulatory standard
• Anticipate potential requests for supplementary documentation
• Monitor legislative developments expected later in 2026
• Review internal regulatory planning and market-entry strategies
• Maintain flexibility to adapt to future procedural changes

What This Means for International Health Supplement Companies

While the suspension provides short-term flexibility, it is best viewed as a pause in implementation rather than a shift in regulatory policy. Vietnam continues to move toward a more structured and closely supervised food safety regime, particularly for health supplements.

Companies should use this period to strengthen registration strategies, review product portfolios, and prepare for further regulatory changes expected later in 2026. Early preparation will be critical to minimizing delays and maintaining uninterrupted access to the Vietnamese market.

As the regulatory framework evolves, businesses should review their registration and compliance strategies to ensure they remain aligned with emerging requirements. For support with dossier preparation, product registration, compliance planning, or market-entry strategy, contact Cisema's Vietnam office today.

References

• Resolution No. 15/2026/NQ-CP on Suspension of the Effect of Decree No. 46/2026/ND-CP andResolution No. 66.13/2026/NQ-CP
• Resolution No. 66.13/2026/NQ-CP on Food Product Registration and Declaration‍
• Decree No. 46/2026/NĐ-CP Detailing the Implementation of the Law on Food Safety

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