Labelling Flavourings in Vietnam: What 2026 Rules Say

What a food additive label must show

Law on Food Safety 55/2010/QH12, Article 44(2)(b), requires a food additive label to carry the phrase “phụ gia thực phẩm”, with information on scope, dose and use in addition to general labelling requirements. Check the label for the supplied flavouring as well as the ingredient line on the food made with it. They are two different places where wording needs review. Source: Law on Food Safety 55/2010/QH12, Article 44(2)(b).

Decree 37/2026 is the current general label rule

Decree 37/2026/ND-CP, Article 97(1), took effect on signing, 23 January 2026. Article 97(4)(b)-(c) repealed Decrees 43/2017/ND-CP and 111/2021/ND-CP from that date. Use Decree 37/2026 as the general label reference when checking new artwork, with the transition provisions considered separately for existing labels and packaging. Source: Decree 37/2026/ND-CP, Articles 97(1) and 97(4)(b)-(c).

Vietnamese content and the responsible party

Decree 37/2026/ND-CP, Article 42(1), requires goods circulating in Vietnam to show the name, responsible party and origin in Vietnamese, together with the applicable Annex I items. The Annex I row for food additives and processing aids includes composition and the phrase “Phụ gia thực phẩm”. Build the label review around the product category and the relevant row rather than treating an ingredient list as the whole label. Source: Decree 37/2026/ND-CP, Article 42(1) and Annex I, food additives and processing aids row.

How a food lists its flavouring ingredient

Decree 37/2026/ND-CP, Article 48(3)(a), requires food additives in a food’s ingredient list to be shown by group name plus the additive’s name or INS number. Where the additive is a flavouring, the wording is “hương liệu” with one or more of “tự nhiên”, “giống tự nhiên”, “tổng hợp” and “nhân tạo”. This is a wording rule for the ingredient line. Ask your supplier for the composition and proposed qualifier for the specific flavour reference, then review that wording with your regulatory team. Source: Decree 37/2026/ND-CP, Article 48(3)(a).

Origin wording for imported goods

Decree 37/2026/ND-CP, Article 47(2), allows origin to be shown with wording such as “sản xuất tại”, “chế tạo tại” or “xuất xứ”, or “Origin”, “Made in”, “Produced in” or “Product of”, followed by the country name. Check that the country in the proposed origin line agrees with the product documents, and review the label’s Vietnamese content under Article 42(1). Source: Decree 37/2026/ND-CP, Articles 47(2) and 42(1).

The transition for existing labels and stock

Decree 37/2026/ND-CP, Article 98(4), permits labels and packaging compliant with Decrees 43/2017 and 111/2021 and printed before 23 January 2026 to continue being used for no more than two years from the effective date, to 23 January 2028. This provision has both a prior printing condition and a compliance condition. Check both before treating a packaging stock as eligible for the transition. Source: Decree 37/2026/ND-CP, Articles 98(4) and 97(1).

Decree 37/2026/ND-CP, Article 98(3), separately allows goods already produced or imported before the effective date to circulate until the expiry date on their label. Keep the finished stock review separate from the use of pre-printed packaging: the decree gives them different transition conditions. Record which provision you are applying and keep the relevant dates with the artwork file. Source: Decree 37/2026/ND-CP, Article 98(3).

Review the label against the supplier’s documents

Start with the exact flavour reference, its specification and its composition statement. Compare the proposed ingredient wording with those documents and request the allergen statement for the same reference. VKA provides specification and safety data sheets, certificates of analysis, allergen and composition statements, halal scope documents, our FSSC 22000 certificate, and a certificate of free sale where your importer asks for one. Our Vietnam flavour supplier page sets out the sample document list.

If your product brief also includes halal requirements, review the certificate separately from the ingredient wording. Our guide to halal flavour certification in Vietnam covers the recognition question for a foreign certifier and the transition dates. Send the proposed label wording and buyer documentation needs with your brief, or talk to a flavourist about the flavour reference you are evaluating.