Circular 29/2023/TT-BYT guiding the food labels

To guide the food labels following Decree 15/2018/ND-CP and the Law on Food Safety, and to specify labeling regulations applicable to the food sector, the Ministry of Health issued Circular 29/2023/TT-BYT guiding the content and method of labeling nutritional composition and nutritional value on food labels on December 30^th 2023. This Circular comes into force from February 15^th 2024. In this article, Viet An Law Firm will present how to label nutrition on products according to the latest updated regulations.

Basic information about Circular 29/2023/TT-BYT guiding the food labels

• Circular Number: 29/2023/TT-BYT
• Date of Issuance: December 30^th 2023
• Effective Date: February 15^th 2024
• Type of Document: Circular
• Issuing Authority: Ministry of Health
• Signatory: Do Xuan Tuyen

What should be noted in Circular 29/2023/TT-BYT guiding the food labels?

Scope of application

Article 1 of Circular 29/2023/TT-BYT guides contents and presentation of nutrients and their values (hereinafter referred to as “nutrition facts”) on food labels, and the roadmap for implementation concerning prepackaged foods that are manufactured, sold, imported into, circulated in Vietnam.

In addition, this Circular does not apply to the following ingredients and foods:

• Ingredients and foods that are not directly sold to consumers, including ice; Any food that has only one ingredient; Mineral water, bottled water (including those with add CO₂ and/or flavorings); Edible salt, refined salt; Vinegar and vinegar substitutes, including those with added flavorings; Flavorings, additives, food processing aids; Food enzymes; Tea and coffee that do not contain any ingredient other than colorings and flavorings; Health supplements; Alcoholic drinks;
• Food prescribed in Article 1(2) of the Government’s Decree No.43/2017/ND-CP on goods labeling, which is amended and supplemented by the Government’s Decree No.111/2021/ND-CP dated December 9^th 2021 , and foods prescribed in Clause 1 and Clause 2 Article 25 of the Government’s Decree 15/2018/ND-CP dated February 2^nd 2018 elaborating the Law on Food Safety.
• Food manufactured by micro food businesses defined in Article 3(1) of Decree 15/2018/ND-CP.

Organizations and individuals prescribed in Clause of this Article that voluntarily specify nutrition facts on their food labels shall implement this Circular.

Regulated entities

According to Article 2 of this Circular, the following entities will adjust and apply including:

Definition of key terms

The terms in Circular 29/2023/TT-BYT guiding the food labels are constructed as follows:

• Energy means the chemical energy absorbed by the human body from food to sustain life, function and grow. Energy is calculated by using the energy conversion factor and energy-generating elements in the foods.
• Protein is an organic compound that contains nitrogen and consists of amino acids. Protein plays a crucial role in building and developing muscles, skin, hair, nails, and other tissues. Protein is calculated by using conversion factors of organic nitrogen in the food.
• Carbohydrate are compound of carbon, oxygen, and hydrogen arranged in the form of simple sugars (monosaccarid) or multiples of monosaccharides and do not contain fiber.
• Total Sugars are total amount of monosaccharides and disaccharides in food (including natural sugar and added sugar).
• Total Fat is an organic compound that does not contain nitrogen, contains mainly triglycerides, fatty acids, cholesterol and phosphthe olipids.
• Saturated Fat is a type of fat in which the fatty acid chains do not have double bond.
• Dietary reference values are recommendations for nutritional intake for Vietnamese people based on scientific date in order to maintain optimal nutrition and reduce the risk of non-communicable diet-related diseases.

Content of nutritional ingredients on food labels

According to Article 5 of Circular 29/2023/TT-BYT guiding the food labels, the following nutrient contents shall be specified on labels of foods that are manufactured, sold, imported into, circulated in Viet Nam:

• Energy (kcal);
• Protein (g);
• Carbohydrate (g);
• Fat (g);
• Sodium (mg).

Labels of soft drink and processed milk with added sugar prescribed in Decree 15/2018/ND-CP and other foods with added sugar shall specify the total sugar content.

Labels of fried foods shall additionally specify the saturated fat content.

Regarding foods that do not contain or contain the specified nutritional components but their nutritional values are smaller than the values specified in Appendix I hereof, they can be exclude from the food labels.

Therefore, nutritional components must be expressed per 100g/100ml of food in 01 serving, with the nutrient content clearly indicated on the label/per package when the number of servings in the package is declared.

Presentation of nutrition facts

According to Article 6 of Circular 29/2023/TT-BYT, nutritional information must be presented in numerical form, including all mandatory nutritional components, using the following units:

• Energy value: kilocalories (kcal)
• Protein, Carbohydrate, Fat, Total Sugars: grams (g)
• Sodium: milligrams (mg)

Nutritional information may be expressed per 100g or 100ml of food, per serving as serving sized is specified on the label, or per package when a package has a certain number of packs.

Percentage (%) of dietary reference values of the nutrients specified Article 5 of this Circular can also be specified. In which case instructions in Appendix II hereof shall be followed.

Tolerance of nutritional values shall comply with Clause 1 Article 17 of Decree 43/2017/ND-CP.

The Ministry of Health emphasizes that the labeling of nutritional composition and nutritional value on food labels must strictly adhere to the provisions of this Circular, as well as relevant regulations concerning labeling and food safety. Nutritional information on food product labels must be easily identifiable, understandable, and tamper-proof.

Implementation organization

According to Article 11 of this Circular, the responsibilities of units of and affiliated to the Ministry of Health:

Implementation roadmap

As clearly stated in Article 8 of this Circular: “By December 31^st 2025, organizations and individuals that manufacturer, sell, import foods that are regulated by this Circular for circulation in Vietnam shall specify nutrition facts on goods labels in accordance with regulations of this Circular”.  

From January 1^st 2026, organizations and individuals must not manufacture, print, import, and use labels that are not comfortable with this Circular.

Food Labeling Consultation Services of Viet An Law Firm

• Providing expert advice on legal regulations related to food labeling content.
• Guiding clients in implementing labeling practices that align with the latest legal updates.
• Offering consultation and support on food proclamation procedures.
• Regular legal consultation for food trading company.

For expert guidance on the legal requirements for labeling nutritional composition, food safety laws, civil laws, and related decrees and circulars, please contact Viet An Law Film for the best support.