Vietnam Flavouring Regulations Reference

Decree 37/2026: the current labelling rule

Decree 37/2026 took effect on signing. Article 97(4) repeals Decree 43/2017 on goods labelling and Decree 111/2021 amending it from the effective date. The decree is dated Ha Noi, 23 January 2026. When checking new label artwork, use Decree 37/2026 as the reference. See the transition section below for existing labels and stock.

Label language

Article 39(1) requires the mandatory content on a goods label circulating in Vietnam to be in Vietnamese, except export goods not consumed domestically and except certain content listed in Article 39(4). Article 39(4) permits specified content in Latin-script foreign languages: international or scientific names where no Vietnamese name exists, certain international or scientific ingredient names that cannot meaningfully be translated, and the names and addresses of foreign enterprises. For goods produced and circulated domestically, foreign-language lettering must not be larger than Vietnamese lettering (Article 39(2)). Imported goods whose labels lack mandatory Vietnamese content must carry a supplementary Vietnamese label and retain the original label; the Vietnamese content must correspond to the original (Article 39(3)).

Product name

Article 43(1) requires the product name to be in a visible position, easy to see and read, with the product-name lettering having the largest size compared with other mandatory label content. Article 43(2) provides that the name is set by the responsible entity and must not cause misunderstanding about the nature, use and composition of the goods.

How a food lists its flavouring ingredient

Decree 37/2026 Article 48(3)(a) addresses the ingredient-list wording where a food additive is a flavouring. It requires “hương liệu” followed by one or more of “tự nhiên” (natural), “giống tự nhiên” (nature-identical), “tổng hợp” (synthetic) or “nhân tạo” (artificial) to clarify its nature. Ask your supplier which qualifier applies to the flavour you are using. Self-declaration requirements are governed separately by Decree 15/2018, including the exceptions in Article 4(2) and Article 6.

The gazette text of Article 48(3)(a) contains a repeated word; this page paraphrases the provision rather than claiming a verbatim sentence quotation.

Origin

Article 47(2) allows origin to be shown with wording such as “sản xuất tại”, “chế tạo tại”, “xuất xứ”, or “Origin”, “Made in”, “Produced in”, “Product of”, followed by the country name. Check that the country stated agrees with the product documentation.

The transition for existing labels and stock

Article 98(4) allows labels and commercial packaging bearing labels that comply with Decrees 43/2017 and 111/2021 and that were produced or printed before 23 January 2026 to continue being used for no more than two years from that date. The two-year limit falls on 23 January 2028. Check both prior production or printing and compliance with the earlier decrees. Article 98(3) separately allows goods labelled in compliance with Decrees 43/2017 and 111/2021 and produced, imported, circulated or used before the effective date to continue circulating and being used until the expiry date shown on their labels. The transition for finished stock and the transition for pre-printed packaging are different provisions with different conditions. Record which one you are applying.

Self-declaration for the domestic market

Decree 15/2018 Article 4(1) provides for self-declaration of prepackaged processed foods, food additives, processing aids, food containers and packaging materials in direct contact with food, except products covered by Article 4(2) or Article 6 (our translation). Article 4(2) exempts products and raw materials manufactured or imported solely for producing or processing export goods, or for internal production not sold domestically. Article 5(1)(b) requires the self-declaration dossier to include a food safety test report on the product issued within 12 months before filing, by a designated laboratory or one accredited to ISO 17025 (our translation). Article 5(3) requires the documents to be in Vietnamese, with foreign-language documents translated and notarised, and valid at the time of the declaration. Resolution 15/2026 suspended Decree 46/2026, and Article 2 of that resolution keeps Decree 15/2018 in effect during the suspension. Confirm with the competent authority which rules apply to your product.

What to check with your supplier

Before you use a flavouring in a Vietnamese product, confirm the qualifier (which of the four terms in Article 48(3)(a) applies), the ingredient wording the supplier proposes, whether the supplier can provide documentation in Vietnamese or with a notarised Vietnamese translation (Article 5(3) of Decree 15/2018), the origin statement on the flavouring's own label (Article 47(2)), and the food safety test report for the self-declaration dossier if filing is required (Article 5(1)(b) of Decree 15/2018).