Vietnam Delays Implementation of New Health Supplement Regulations

On February 4, 2026, the Government of Vietnam issued “Resolution No. 09/2026/ND-CP,” suspending the validity and adjusting the application timeline of “Decree No. 46/2026/ND-CP” guiding the implementation of the Law on Food Safety, as well as “Resolution No. 66.13/2026/NQ-CP” on the declaration and registration of food products.

The suspension applies until April 15, 2026, with both instruments scheduled to take effect from April 16, 2026.

Temporary Suspension of New Food Safety Measures

The issuance of Resolution 09/2026/ND-CP marks a significant regulatory pause following the rapid rollout of a tightened food safety framework earlier this year.

During the suspension period:

Decree No. 15/2018/ND-CP and its implementing documents remain fully in force
Existing food safety declaration, registration, and import inspection procedures continue to apply

This decision responds to practical implementation challenges raised by ministries, local authorities, and businesses, particularly in relation to inspection procedures and border clearance for imported food products.

Regulatory Background Leading to the Suspension

In late January 2026, the Government issued two closely linked instruments:

“Decree No. 46/2026/ND-CP” on January 26, 2026, guiding implementation of the Law on Food Safety
“Resolution No. 66.13/2026/NQ-CP” on January 27, 2026, governing food product declaration and registration

Together, these instruments were designed to significantly tighten regulatory control over food products, with particular emphasis on health supplement foods — a product category increasingly associated with food safety risks, misleading claims, and non-compliant circulation.

Health Supplement Foods Identified as a High-Risk Category

Under the suspended framework, health supplement foods were explicitly identified as a regulated and high-risk product group subject to enhanced oversight.

The scope of regulated products was clearly defined to include:

Processed and prepackaged foods
Food additives
Food-contact materials and packaging
Micronutrients
Medical nutrition foods
Foods for special dietary uses
Dietary supplements
Nutritional products for children under 36 months

Within this scope, health supplement foods were singled out for stricter pre-market control due to their functional claims and direct impact on consumer health.

Planned Expansion of Product Registration Dossier Requirements

Although not currently in effect, “Resolution No. 66.13/2026/NQ-CP” outlines a more rigorous approach to product registration for health supplement foods once implementation resumes.

Core Registration Documentation

The standard dossier framework requires:

A product registration declaration in the prescribed form
A food safety eligibility certificate or Good Manufacturing Practice certification, where applicable
A valid food safety testing report issued by an accredited laboratory
Scientific substantiation of claimed product functions or intended uses
Compliant product labeling or draft labels
A Certificate of Free Sale or equivalent document for imported products

Registrants remain fully responsible for the accuracy, authenticity, and legality of all submitted materials.

Additional Documentation Under the New Framework

The suspended Resolution also authorizes regulators to request expanded documentation, including:

Manufacturer or product owner authorization letters
Product research and development reports
Quality and safety standard documentation
Detailed production process descriptions
Product stability study results
Information on packaging materials and utensils in direct contact with the product

These requirements reflect a shift toward deeper, risk-based scrutiny focused on manufacturing controls and lifecycle safety rather than formal dossier completeness alone.

Import Inspection Changes Temporarily Deferred

One of the most consequential elements of “Decree No. 46/2026/ND-CP” concerns import-stage food safety inspection.

Mandatory Inspection at the Border

Under the new decree, health supplement foods would no longer be exempt from state food safety inspection at import, even if a valid Product Registration Certificate had already been issued. This represented a clear departure from previous practice and a move toward enhanced border control and real-time risk detection.

With the suspension in place:

Mandatory import inspection requirements under Decree 46 do not yet apply
Existing inspection exemptions and procedures under Decree No. 15/2018/ND-CP remain effective until at least April 15, 2026

Practical Implications for Foreign Manufacturers and Importers

Resolution 09/2026/ND-CP does not repeal the new regulatory framework but postpones its application. The Government has explicitly instructed the Ministries of Health, Agriculture and Environment, Industry and Trade, Finance, and relevant authorities to complete all necessary preparations before the new rules take effect.

For foreign manufacturers and importers, this interim period provides a critical compliance window to:

Review product registration dossier readiness
Assess availability of scientific substantiation and manufacturing documentation
Prepare for future import inspection and border control requirements

For companies seeking structured guidance during this transition, Cisema works with manufacturers, brand owners, and importers to help interpret regulatory changes and prepare for implementation in a practical and proportionate way.

Get in touch with Cisema today to discuss how the upcoming food safety changes may affect your products and how to prepare ahead of the April 2026 implementation timeline.

References

“Resolution No. 09/2026/ND-CP on the Suspension of Decree No. 46/2026/ND-CP”, issued by the Government of Vietnam, available on the Government Policy Development Portal.
“Decree No. 46/2026/ND-CP Guiding the Implementation of the Law on Food Safety”, issued by the Government of Vietnam, accessible via the national legal database.
“Resolution No. 66.13/2026/NQ-CP on the Declaration and Registration of Food Products”, issued by the Government of Vietnam, available through the official legal text repository.

“Decree No. 15/2018/ND-CP Guiding the Implementation of the Law on Food Safety”, issued by the Government of Viet Nam, available via the official legal database.