On July 1, 2026, Vietnam's Ministry of Health (MOH) officially issued Circular No. 27/2026/TT-BYT, publishing the list of foods, food containers, and packaging materials in direct contact with food that are directly managed by the Ministry's Vietnam Food Administration (VFA) and classified as medium-risk. The relevant provisions take effect immediately from the date of issuance (July 1, 2026), with no transition period.
For food contact materials (FCM), the Circular applies to containers and packaging materials made of synthetic plastics and rubber that come into direct contact with food, and specifies the corresponding national technical regulations (QCVN) and management requirements: synthetic plastics must comply with QCVN 12-1:2011/BYT (National Technical Regulation on Safety and Hygiene of Synthetic Resin Utensils, Containers and Packaging in Direct Contact with Food), and rubber must comply with QCVN 12-2:2011/BYT (National Technical Regulation on Safety and Hygiene of Rubber Utensils, Containers and Packaging in Direct Contact with Food). Relevant products must complete a product self-declaration of conformity under Article 4 of Decree No. 15/2018/ND-CP, and their HS codes are determined under Circular No. 15/2024/TT-BYT and Circular No. 31/2022/TT-BTC, respectively.
This Circular is a continuation of Vietnam's risk-based management implemented under the Law on Food Safety and Decree No. 15/2018/ND-CP. Vietnam classifies and manages foods and food contact materials by risk level, with medium-risk products directly administered by the VFA, and enterprises fulfilling compliance obligations through the self-declaration of conformity procedure. In addition, Vietnam has issued corresponding technical regulations for food contact materials in categories such as metals (QCVN 12-3:2011/BYT) and glass, ceramics, and enamel (QCVN 12-4:2015/BYT).
ChemRadar Insights
This Circular explicitly brings synthetic plastic and rubber food contact materials within the scope of medium-risk, MOH-directly-administered products, with no transition period set. Enterprises engaged in the manufacture, import, or trade of food contact materials in Vietnam should immediately verify their compliance status. Relevant enterprises are advised to:
1. Verify product classification and HS codes: Check against Circular No. 27/2026/TT-BYT, Circular No. 15/2024/TT-BYT and Circular No. 31/2022/TT-BTC to confirm whether products fall within synthetic plastic or rubber food contact materials and to determine their HS codes.
2. Complete the self-declaration of conformity: Prepare and submit a product self-declaration of conformity in accordance with Article 4 of Decree No. 15/2018/ND-CP; the relevant documents must be issued in Vietnamese.
3. Implement QCVN testing compliance: Conduct safety and hygiene testing such as migration testing under QCVN 12-1:2011/BYT or QCVN 12-2:2011/BYT to ensure products comply with the corresponding national technical regulations.
4. Track subsequent updates to the list and technical regulations: Monitor the MOH's subsequent adjustments to the medium-risk list and QCVN standards, and update compliance strategies promptly.
