HCMC – Proposed changes to Decree 15/2018/ND-CP on food safety could cost 12,000 food enterprises nearly VND9 trillion annually, industry experts warn. Stricter requirements for self-declaration and product registration may undo the streamlined procedures currently in place.
At a seminar held by the Vietnam Chamber of Commerce and Industry (VCCI) on March 5 in Hanoi, lawyer Nguyen Tuan Linh from EuroCham’s Nutrition Food Subcommittee expressed concern over the proposed changes to the decree. Under the new rules, self-declaration requirements would expand from five to 31 items, increasing compliance costs and prolonging approval times.
Currently, businesses can begin operations immediately after submitting registration documents. Authorities then have seven days to publish the documents online and three months to complete reviews. However, Linh pointed out that the proposed revisions allow officials to revoke registrations for any errors—even minor ones—without a clear process for correction. As a result, many firms may delay production for three months to avoid potential disruptions.
The draft decree expands product registration requirements from seven to 34 items. Lawyer Tran Ngoc Han from AmCham Vietnam warned that these changes would increase costs and slow production. Han proposed retaining Decree 15’s simpler guidelines and distinguishing between major and minor updates, so only significant product modifications would require re-registration.
Representatives from the food sector, including the Vietnam Transparent Food Association (AFT), have called for reforms that prioritize risk management over burdensome upfront approvals. Nguyen Van Chinh, an executive board member of AFT, noted that many countries, including the U.S., China, and EU nations, focus on post-market checks rather than pre-approval procedures. He suggested that Vietnam adopt a similar approach, allowing businesses to ensure compliance independently, with regulatory agencies stepping in only when violations arise.
Meanwhile, Chu Quoc Thinh, deputy director of the Vietnam Food Safety Authority at the Ministry of Health, defended the proposed changes, clarifying that the seven-day period is primarily for government agencies to publish documents online. He emphasized that once a firm submits its paperwork, it can begin operations immediately. Registrations remain valid indefinitely, and authorities have the right to conduct inspections or revoke licenses if non-compliance is detected.
In a separate statement, the Vietnam Association of Seafood Exporters and Producers (VASEP) expressed a strong opposition to what it sees as unnecessary administrative hurdles in the draft decree. In a letter to Deputy Prime Minister Le Thanh Long and relevant ministries, VASEP highlighted that Decree 15 has significantly reduced costs and processing time for businesses, contributing to the food sector’s growth, which accounts for around 15% of Vietnam’s GDP.
VASEP estimated that the proposed revisions could lead to an increase in registration requirements, forcing companies to resubmit documents and endure a longer approval wait time. The association urged the Government to maintain the risk-based approach outlined in Decree 15 and align regulations with international best practices.
VASEP criticized the draft for overemphasizing packaged food regulations, while overlooking high-risk areas such as street food, fresh produce, and communal kitchens, where food safety violations are more common.
Industry leaders have recommended that the Government amend the Food Safety Law first before revising the supporting decree. VASEP noted that amendments to the law are already planned for October 2025, after which corresponding decrees can be adjusted. They emphasized that any overhaul of Decree 15 should balance regulatory oversight with business efficiency, ensuring a competitive and well-regulated food industry.
