Resolution 66.13/2026/NQ-CP: Mandatory Roadmap for Food Product Re-declaration in Vietnam

On January 27, 2026, the Government officially issued Resolution No. 66.13/2026/NQ-CP, which regulates Vietnam food regulations 2026, including the food product declaration Vietnam. This document marks a major change in administrative procedures, replacing the “self-declaration” mechanism with “declaration of applicable standards” and setting a mandatory roadmap for businesses to resubmit their applications. To avoid legal risks, understanding Resolution 66.13/2026/NQ-CP: mandatory roadmap for food product re-declaration in Vietnam. In this article, Viet An Law Firm will analyze the new regulations in detail and guide businesses in Vietnam food compliance and food safety accurately and promptly.

When does Resolution 66.13/2026/NQ-CP take effect and which regulations does it replace?

This resolution takes effect on the date of issuance, which is January 27, 2026. The regulation is in temporary effect before the 2010 Food Safety Law is officially replaced (the effective date is February 28, 2027) regarding the declaration and registration of food products, aiming to address difficulties during the period awaiting amendment of the law.

The core of this Resolution is to establish a new order for technical standards. Accordingly, food products previously marketed based on old regulations will have to undergo a review and re-declare their products if there are changes in safety indicators. This is a strategic step to synchronize Vietnam’s food safety management system with international standards (Codex, ISO) in the period 2026-2030.

03 key legal changes tighten food regulation in Vietnam

1^st Change: Terminate the “Self-declaration” mechanism – Switch to “Declaration of applicable standards”

Resolution 66.13/2026/NQ-CP has changed the terminology and management mechanism for common food groups, specifically:

• Transition from the “Self-declaration of products” mechanism (according to Decree 15) to the “Declaration of applicable standards” procedure (Article 5 of Resolution 66.13/2026/NQ-CP).
• Applicable to: Pre-packaged foods, additives, processing aids, food contact packaging and utensils (without established technical standards), and dietary supplements containing only vitamins/minerals without health claims.

2^nd Change: Implementing the “15 Golden Days” – A mechanism of limited pre-inspection and conditional post-inspection.

• Instead of being able to start production and business immediately after self-declaring, businesses submit their applications and have to wait 15 days.
• If the regulatory agency does not provide written feedback within 15 days, the file will be publicly posted.
• Businesses are only permitted to manufacture and sell products after their application has been published on the online system of the receiving agency.

Therefore, businesses no longer have the option of “submitting and selling immediately,” but must wait at least two weeks (15 days) for their applications to be approved.

3^rd Change: Tightening testing standards

The process of preparing product registration documents has become more stringent with regulations on testing. The test results certificate must meet two prerequisites:

• The test results certificate must be valid for 12 months;
• Certified by a testing laboratory accredited to ISO/IEC 17025.
• Test certificates from internal laboratories that do not meet ISO/IEC 17025 standards or certificates that are expired will be considered invalid documentation.

In addition, the list of mandatory testing parameters has been expanded to include stricter control of residues of new-generation additives and genetically modified organisms (GMOs) for certain sensitive food groups.

Re-registration requirements and Mandatory food declaration Vietnam (Transitional provisions)

Resolution 66.13 takes effect from January 27, 2026. However, to avoid disrupting production and business activities, the Government has established a transitional roadmap (product re-registration roadmap) that business owners need to be aware of at each stage.

Article 15 of the Resolution 66.13/2026/NQ-CP clearly stipulates the transition roadmap for products already in circulation before the Resolution takes effect (January 27, 2026). Businesses need to review their product catalogs to compare them with the two compliance deadlines in Resolution 66.13/2026/NQ-CP as follows:

For products that have been declared Applicable Standards before January 27, 2026 (Ordinary food group, packaging, etc.)

• Requirement: Organizations and individuals must complete the declaration of applicable standards in accordance with the new regulations of Resolution 66.13/2026/NQ-CP.
• The deadline for completing the new procedures is 12 months from January 27, 2026 (i.e., the final deadline is January 27, 2027).

For products that already have a Registration Certificate of Product Declaration (health supplements, medical nutrition, products for children up to 36 months old, etc.)

• Requirement: Organizations and individuals must revise their product declaration registration documents according to the new regulations.
• The deadline for completing the new procedures is 24 months from January 27, 2026.

Goods already produced

In terms of legal consequences, after the aforementioned transition period (12 or 24 months) expires, the old documents (Self-declarations or registration certificates) will no longer be valid for production or imported food.

However, to minimize economic losses, the Resolution allows products manufactured during the transitional period to continue circulating until their expiration date.

• The deadline for completing the new procedure is when the product expires.
• Requirement: Products manufactured within 12 months (for previously self-declared goods) or 24 months (for previously registered goods) after the effective date of the Resolution (January 27, 2026) may continue to be circulated until their expiration date.

A guide to updating the 3-stage of Food product re-declaration roadmap for businesses

Phase 1 (Review Phase): From January 27, 2026 to January 27, 2027

During this period, businesses need to proactively review their entire product portfolio. They should compare the current basic standards with the new regulations in the Resolution to classify their products:

• The group needs to declare applicable standards (self-declaration as regulated before).
• The group needs to re-register.
• The group is permitted to continue distributing the product until the expiration date of the manufactured batch.

Phase 2 (Peak period for re-registration): From January 27, 2027 to January 27, 2028

For businesses with food products requiring re-registration, this is the “golden time” to complete the online application process after declaration of applicable standards and preparing the necessary conditions according to the new regulations. Viet An Law recommends that clients complete the procedures during this period to avoid system congestion at the last minute.

Phase 3 (Execution and Post-Execution Phase): From January 27, 2028 onwards.

All products manufactured after this date are required to have a declaration of applicable standards as stipulated in Resolution 66.13. Products manufactured during this transitional period will be allowed to circulate until their expiration date. Authorities will conduct specialized inspections and post-inspection campaigns to address violations.

Comparing the “Publication of Applicable Standards” process (Resolution 66.13) with the “Self-Declaration” process (Decree 15/2018)

Below is a table comparing the core differences between the new mechanism in your document and the current regulations:

Latest guide on preparing the “Declaration of Applicable Standards” for the food product declaration Vietnam

To ensure a smooth application process and avoid rejection during the 15-day waiting period, businesses need to prepare a complete set of documents as per Article 6 of the Resolution, including:

• The applicable standard declaration: Use precisely Form No. 01 issued with the Appendix of Resolution 66.13/2026/NQ-CP.
• Test results certificate: A certified copy bearing the company’s seal or a certified electronic copy.
• Authorization letter: Required if the entity making the announcement is not the manufacturer.
• Product label sample: Ensure the information on the label matches the Declaration (Ingredients, product name, origin).

Legal risks associated with delayed updates under Vietnam food compliance

Failure to comply with the product re-publication roadmap as stipulated in Resolution 66.13/2026/NQ-CP not only puts businesses at risk of business disruption but also subject them to severe penalties. The 2026 management mechanism will focus strongly on post-inspection and administrative penalties with high fines to deter violations.

• Fines: Failure to re-publish information when there are changes in technical standards or when required by law may result in a food safety violation fine ranging from VND 40,000,000 to VND 50,000,000 for organizations.
• Additional penalties include: suspension of production and import of infringing products for a period of 1 to 3 months;
• Remedial measures: Businesses are required to recall food products circulating in the market that violate regulations on product labeling. This not only causes significant economic losses but also seriously affects brand reputation and consumer trust. For products with incorrect labeling (lacking nutritional information), businesses are required to recall them for relabeling or destroy them if the issue cannot be rectified.

Resolution 66.13/2026/NQ-CP: mandatory roadmap for food product re-declaration in Vietnam is a landmark legal document requiring proactive and strict compliance from the business community. With an effective date of January 27, 2026, businesses have a limited time to prepare and transition. Accurately understanding the regulations regarding documentation, testing procedures, and the online application process is key to businesses maintaining a stable supply chain and achieving sustainable development.

Viet An Law Firm, with its extensive experience in food product registration and a team of experts deeply knowledgeable about the latest regulations in 2026, is committed to accompanying businesses in strictly complying with the new regulations, ensuring that your food products circulate legally in the market.