Labeling and updates on food labeling regulations

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What is labeling of goods and products?

According to Decree 43/2017 ND-CP, labeling of goods and products is to express basic and necessary content about the goods on the labels for consumers to recognize and serve as a basis for choosing, consuming and use; for manufacturers, traders, to inform and promote their goods and for authorities to carry out inspection and control;

Product labels help recognize, choose and control

According to Decree 43/2017/ND-CP and amended and supplemented in Decree 111/2021/ND-CP

Mandatory content is shown on product labels for all goods:

• Goods name;
• Name and address of the organization or individual responsible for the goods;
• Origin of goods.

Mandatory content shown on food labels (Appendix I)

• Quantitative;
• Date of manufacture;
• Expiry;
• Ingredients or ingredient quantities; nutritional ingredients, nutritional value (if any); The content, method of recording nutritional ingredients, nutritional value and implementation roadmap follow the instructions of the Minister of Health;
• Warning information;
• Instructions for use, instructions for storage.

Includes the following contents

Name of food

Must be placed in a visible, easy-to-read position on the product label. The writing of the product name must be the largest letter size compared to other mandatory content on the product label. The name of the goods recorded on the label is set by the organization or individual producing the goods. The name of the goods must not mislead the nature, uses and ingredients of the goods. In case the name of an ingredient is used as the name or part of the product name, the quantity of that ingredient must be recorded.

Name and address of the organization or individual responsible for the goods

• Proper names of organizations, individuals and places on product labels cannot be abbreviated, words denoting administrative units can be shortened.
• For domestically produced goods, the name of the organization or individual and the address of the facility producing the goods must be recorded.

1. 1. A goods production facility that is a member of an organization such as a company, corporation, corporation, association and other organizations has the right to write the name or name and address and other contents of that organization. on labels when permitted by these organizations.
   2. For goods with the same brand that are produced at many different production facilities, the organization or individual responsible for the goods may have the name and address of that organization or individual written on the goods label if the goods are of high quality. The quality of the goods is consistent with the goods quality standards announced or registered for circulation by the organization or individual responsible for the goods and must ensure traceability of the origin of the goods.

• Goods imported for circulation in Vietnam must have the name and address of the producing organization or individual and the name and address of the importing organization or individual on the goods label.
• For goods of organizations or individuals acting as direct sales agents for foreign traders importing goods into Vietnam, the name and address of the producing organization or individual and the name and address of the organization and individual must be recorded.
• For goods whose labels are franchised by an organization or individual, in addition to complying with the provisions of the above articles, the name and address of the franchising organization or individual must also be recorded.

Origin of goods

• Organizations and individuals producing, exporting, and importing determine and record the origin of their goods to ensure honesty, accuracy, and compliance with legal regulations on the origin of exported and imported goods. goods produced in Vietnam or international commitments that Vietnam participates in.
• The origin of the goods stated on the label is shown by one of the following phrases: "made in"; “manufactured in”; “manufacturing country”; "origin"; "made by"; “product of” with the name of the country or territory producing the goods or written according to the law on origin of goods.
• In case the origin of the goods cannot be determined, write down the place where the final step was performed to complete the goods. Expressed by one of the phrases or a combination of phrases expressing the stage of completing the goods as follows: “assembled at”; “bottled at”; “mix at”; “complete at”; “packed at”; “labeled at” with the name of the country or territory where the final step to complete the goods is performed.
  The name of the country or territory where the goods are produced or where the final step to complete the goods is performed must not be abbreviated.";

Ingredients, ingredient quantities

• In case the name of an ingredient is written on the product label to attract attention to the goods, the quantity of that ingredient must be shown. The quantity is not required to be written with the corresponding ingredient but must be listed in other sections of the label.

In case the product label emphasizes the absence, non-containment or non-addition of one or more ingredients:

• That ingredient does not exist in the goods and in the materials used to produce the goods;
• The goods do not contain ingredients of the same group that have similar properties or uses to that ingredient, unless the nature of the substitution is noted.

If an international treaty or international standard to which Vietnam is a member has provisions on the absence level of a component, the provisions of that international treaty or international standard shall apply.

• Labeling ingredient quantities means writing the ingredients along with the quantity of each ingredient. Depending on the nature and status of the goods, the quantitative ingredient is written as the mass of that ingredient in a unit of product or written in one of the following ratios: Weight to volume; mass with volume; volume with volume; mass percent; volume percent.

In case the composition of goods is quantified by measuring quantities, the quantity must be recorded according to the provisions of Vietnamese law on measurement.

• For some types of goods, the recording of ingredients and quantity of ingredients is as follows:
  1. For foods, write ingredients in order from highest to lowest in volume
     1. If the ingredient is additive, write the name of the additive group, the name of the additive or the INS international code (if any);
     2. In case the additive is a sweetener or coloring agent, write the name of the group of sweeteners or coloring substances, write the name of the substance or the international INS code (if any) and add the substance as "natural", "nature Identical", “synthetic” or “artificial”.
     3. In case the additive is a flavoring, write "fragrance" with one or more of the following phrases to clarify the meaning: "natural", "naturally identical", "synthetic"; or "artificial".
        In case the national additive code coincides with the international code (INS), the national code can be written instead of the international code (INS);
  2. For drugs for human use, veterinary drugs, plant protection drugs, insecticidal and antibacterial products used in the household and medical fields, write the ingredients and content of active ingredients.";
     • Ingredients and quantitative ingredients of goods have a different way of recording than prescribed in Clause 3 of this Article specified in Appendix IV of Decree 111/2021/ND-CP

Manufacture date, expiry date

• Production date and expiry date of goods are written in the order of day, month and year of the calendar year. In case of recording in a different order, there must be an explanation of that order in Vietnamese.
  • Each number indicating the day, month, and year is written in two digits; the number indicating the year is allowed to be written in four digits. The day, month, and year numbers of a timeline must be written on the same line.
  • In case it is prescribed to write the month of production, write it in the order of month and year of the calendar year.
  • In case the regulation states the year of manufacture, write four digits indicating the year of the calendar year.
  • “production date”, “use date” or “expiry date” on the label is written in full or abbreviated in capital letters (in Vietnamese): “NSX”, “HSD” or “HD”.
• In case the goods are required to have the date of manufacture and expiration date written on them as prescribed in Appendix I of Decree 111/2021/ND-CP and the goods label has the date of manufacture recorded as prescribed in the above article, the expiration date The allowed use date is the period from the date of manufacture, and vice versa, if the product label has an expiration date, the manufacturing date is allowed to be recorded as the period before the expiration date.
• Goods that are divided, extracted, loaded, and repackaged must have their date of manufacture and expiration date recorded according to the provisions in Appendix I issued with Decree No. 111/2021/ND-CP. Specifically, 03 contents must be fully shown: Date of production, Date of division, extraction, filling, and packaging must not be abbreviated; Expiry.
• How to record the production date and the expiration date is specifically specified in Section 1, Appendix III of Decree 43/2017/ND-CP.

Goods with a time stamp different from the provisions in Clause 1 of this Article are specified in Section 2, Appendix III of Decree 43/2017/ND-CP.

Circular 29/2023/TT-BYT on nutrition labeling guidelines

On December 30, 2023, the Ministry of Health issued Circular No. 29/2023/TT-BYT. This Circular guides the content, writing of nutritional ingredients, nutritional value and implementation roadmap for packaged foods. pre-packaged and produced, traded, imported and circulated in Vietnam.

From January 1, 2026, organizations and individuals are not allowed to produce, print, import and use labels that do not comply with the provisions of this Circular.

According to the provisions of the circular, mandatory nutritional ingredients listed on the label include:

• Energy (kcal/kj)
• Protein (g)
• Carbohydrates (g)
• Fat (g)
• Sodium (Sodium) (g)
• Total sugars (g) in the case of soft drinks, processed milk with added sugar and other foods with added sugar.
• Saturated fat (g) in case of foods processed in the form of frying.

In case the content of nutritional ingredients according to Appendix I of the circular is not required to be shown on the food label

Content of ingredients according to Circular 29/2023/TT-BYT

Technical specifications, warning information

Technical specifications and tolerances of this parameter (if any), warning information must comply with relevant legal regulations. In the absence of specific regulations, organizations and individuals responsible for labeling goods themselves determine technical specifications, tolerances and warning information. Warning information is written on the label in words, images or symbols according to international practices and relevant regulations.

The tolerance range value shown on the label must comply with relevant legal regulations and applicable published standards. In case a specific value is expressed, it should not be recorded in a way that creates an advantage for the goods themselves.

• Organizations and individuals responsible for the goods recording nutritional values ​​on the labels must ensure compliance with applicable announced standards and compliance with relevant laws.

If you write a specific nutritional value, write the average value of the nutritional value range. The mean value for a nutritional claim is the mass average of the characteristic values ​​obtained from the analysis of product samples representative of the product to be labeled.

• Ingredients or substances in complex ingredients of special goods that use preservatives with prescribed dosages and are listed as irritating and toxic to humans, animals and the environment. The name of the preservative must be listed with these ingredients.
• Goods or components of goods that have been irradiated or have applied genetic modification techniques are recorded under the provisions of law and international treaties to which Vietnam is a member.

Guidelines for use and storage

Usage Guidelines and Goods Storage Guidelines are information related to how to use and necessary conditions for using and preserving goods; warning of danger; How to handle when dangerous incidents occur;

In case the goods are required to have Instructions for use and storage instructions, see the provisions in Appendix I of Decree No. 111/2021/ND-CP

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Eurofins Sac Ky Hai Dang is an independent testing laboratory with more than 10 certificates from the BOA and the governmental competent authorities such as the Ministry of Health, Ministry of Agriculture and Rural Development, Ministry of Industry and Trade, Ministry of Natures Resources and Environment.

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Read more and download the full version of Decree 111/2021/ND-CP in the attached document below

• Decree 111/2021/ND-CP- amending and supplementing a number of articles of Decree 43/2017/ND-CP 14/4/2017

Visit our service article for more information

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