Food safety and hygiene newsletter Apr. 2026

On February 26, 2026, the Ministry of Industry and Trade officially issued Circular No. 09/2026/TT-BCT together with QCVN 28:2026/BCT - the National Technical Regulation on Liquid Milk Products. This is an important regulatory document, replacing QCVN 5-1:2010/BYT which has existed for more than 15 years. The new regulation takes effect from September 1, 2026, with many changes in the classification, management, quality assessment, and labeling of liquid milk products in Vietnam.

1. Detailed product classification

QCVN 28:2026/BCT expands and defines many product types more specifically:

• Fresh milk: includes 3 types (whole, regular, skimmed) and requires ≥ 90% raw fresh milk if the label states “fresh milk”.
• Recombined milk, reconstituted milk, and composite milk: separately defined based on origin (from powder, from milk fat + milk solids, or combinations of dairy ingredients with non-dairy ingredients).
• The group of condensed milk and sweetened condensed milk is subdivided into whole, partially skimmed, skimmed, high fat, and products blended with vegetable fat.

2. Physicochemical criteria: specified for each group

2.1. Fresh milk group

2.2. Recombined - reconstituted - composite milk

2.3. Evaporated milk (TSNF = total solids non-fat)

2.4. Sweetened condensed milk

3. Contaminants

4. Microbiology

Additionally, State inspection must apply threshold M according to Circular 01/2024/TT-BKHCN.

5. Test methods

The 2026 regulation cites multiple updated international standards, such as:

• Fat: ISO 23318:2022 (gravimetric analysis method).
• Aflatoxin M1: ISO 14501:2021 (HPLC, higher sensitivity).
• Heavy metals: EN 17851:2023, EN 13806:2025, AOAC 2015.01.

6. Labeling and traceability

• Product names must reflect the true nature as defined.
• The phrases RECOMBINED MILK / RECONSTITUTED MILK / COMPOSITE MILK must be in UPPERCASE, with font size not smaller than the product name.
• Supports electronic labels/digital passports according to Decree 37/2026/NĐ-CP.

For detailed information, please see the attached file here.

The Ministry of Industry and Trade promulgates QCVN 29:2026/BCT - the new national technical regulation on refined vegetable oils

On February 26, 2026, the Ministry of Industry and Trade promulgated the National Technical Regulation QCVN 29:2026/BCT on Refined Vegetable Oils, together with Circular No. 10/2026/TT-BCT. The Circular takes effect from December 01, 2026, establishing a unified legal and technical framework for quality management and food safety of refined vegetable oil products in Vietnam.

1. Scope and Subjects of Application

The regulation applies to all organizations and individuals participating in the production, importation, and trading of refined vegetable oils within the territory of Vietnam. The document clearly defines types of oils (single oils, blended oils, palm oil fractions) and specific contaminants arising from processing (PAH, TFA, 3-MCPD, GE).

2. Requirements for Quality Indicators

Oil quality is strictly controlled through 05 key technical indicators:

• Moisture and volatile matter at 105°C: ≤ 0.2% by mass.
• Insoluble impurities: ≤ 0.05% by mass.
• Soaps content: ≤ 0.005% by mass.
• Acid value: ≤ 0.6 mg KOH/g.
• Peroxide value: ≤ 10 meq O₂/kg.

3. Food Safety Requirements

The regulation specifies limits for groups of contaminants, in compliance with current chemical safety requirements:

• Mycotoxins and heavy metals: In accordance with QCVN 8-1:2011/BYT and QCVN 8-2:2011/BYT.
• Pesticide residues: Implemented in accordance with Circular 50/2016/TT-BYT.
• Processing-induced contaminants:
  • 3-MCPD: Limit ≤ 1,250 µg/kg (for coconut, corn, rapeseed, sunflower, soybean, palm kernel, olive oils) and ≤ 2,500 µg/kg (other oils).
  • GE: ≤ 500 µg/kg (children’s products) and ≤ 1,000 µg/kg (regular products).
  • PAH: Benzo[a]pyrene ≤ 2 µg/kg; PAH4 ≤ 10 µg/kg.
  • TFA: ≤ 2 g/100 g fat.

4. Testing Methods and Sampling

The regulation stipulates sampling in accordance with Circular 04/2025/TT-BKHCN. Testing methods are standardized based on international standards (ISO, AOCS, AOAC) and Vietnamese standards (TCVN), including:

• Oil quality: Applying TCVN 6120:2018 (moisture), TCVN 6125:2020 (impurities), TCVN 6127:2010 (acid value).
• Specific compounds: Using gas chromatography-mass spectrometry (GC-MS) for 3-MCPD, GE, PAH, and trans fatty acids to ensure the highest accuracy in quantitative analysis.

5. Management Requirements

• Labeling: In compliance with Decree 37/2026/NĐ-CP. Particularly for blended oils, it is required to clearly state the mixing ratio and strictly prohibit the use of images/names of a single-type oil to represent a blended product.
• Declaration of conformity: Mandatory for all products marketed in the market.
• Traceability: Entities must have a product traceability system to ensure legal accountability.

For detailed information, please see the attached file here.

Notification No. 141/TB‑VPCP on the handling of difficulties and shortcomings of Decree No. 46/2026/ND‑CP and Resolution No. 66.13/2026/NQ‑CP on food safety (20 March 2026)

On 20 March 2026, the Government Office issued Notification No. 141/TB‑VPCP on the conclusions of the Standing Committee of the Government regarding the handling of difficulties and shortcomings arising during the implementation of Decree No. 46/2026/ND‑CP and Resolution No. 66.13/2026/NQ‑CP on food safety.

The Notification was issued based on the meeting of the Standing Committee of the Government held on 16 March 2026, chaired by Prime Minister Pham Minh Chinh, with the participation of Deputy Prime Ministers and leaders of various ministries and agencies, including the Ministry of Health, the Ministry of Agriculture and Environment, the Ministry of Industry and Trade, the Ministry of Public Security, the Ministry of Justice, the Ministry of Finance, the Ministry of Science and Technology, and other relevant authorities.

At the meeting, the Standing Committee of the Government reviewed the report of the Ministry of Health and opinions of attendees regarding difficulties and shortcomings encountered during the implementation of Decree No. 46 and Resolution No. 66.13—two key legal instruments guiding the implementation of the Law on Food Safety in relation to product declaration, registration, and food product management.

1. Incorporation of opinions from the meeting; review and submission to the Government

At the conclusion of the meeting, the Standing Committee of the Government agreed to assign the Ministry of Health, as the lead agency, to coordinate with the Ministry of Agriculture and Environment, the Ministry of Industry and Trade, the Ministry of Justice, and other relevant ministries and agencies to promptly study and incorporate opinions raised at the meeting, conduct a review, and submit a report to the Government by 28 March 2026 for consideration and issuance of a Government Resolution aimed at:

• Extending the suspension of effectiveness until the amended Law on Food Safety enters into force: The suspension of effectiveness shall remain in effect until the amended Law on Food Safety and the Decree detailing the implementation of the amended Law on Food Safety officially enter into force.
• Strengthening regulatory responsibility and post‑market surveillance on food safety: In addition to extending the suspension period, the Standing Committee of the Government requires the strengthening of regulatory direction and administration in order to enhance the responsibility of state management authorities in the field of food safety.

This measure is considered necessary to avoid disruptions in state management activities as well as in food production and business operations during the policy transition period.

2. Accelerating the development of the amended Law on Food Safety

Notification No. 141/TB‑VPCP assigns the Ministry of Health, in coordination with relevant ministries and agencies, to:

• Expedite the completion of the Draft Law on Food Safety (amended), ensuring quality and adherence to the required timeline;
• Submit the draft law to the National Assembly for consideration at the Second Session of the 16th National Assembly;
• Concurrently develop and finalize the Draft Decree detailing the implementation of the amended Law on Food Safety, and prepare all necessary conditions to ensure synchronized implementation upon the adoption of the law.

3. Establishment of an inter‑ministerial task force on food safety

To effectively implement the above tasks, the Standing Committee of the Government agreed to establish an inter‑ministerial task force, chaired by the Minister of Health, with members comprising leaders from the Ministries of Agriculture and Environment, Industry and Trade, Public Security, Finance, Justice, Science and Technology, and other relevant agencies.

The task force is responsible for advising, reviewing, and proposing feasible solutions to address difficulties in food safety management, ensuring consistency and coherence within the legal framework.

For further details, please refer to the attached Notification No. 141/TB‑VPCP.

China

Issuance of Announcement No. 27/2026 on the Implementation of Decree No. 280 on the Registration of Overseas Food Manufacturers (18 March 2026)

On 18 March 2026, the General Administration of Customs of China (GACC) issued Announcement No. 27 of 2026, providing detailed guidance on the implementation of the “Regulations on the Registration Administration of Overseas Manufacturers of Imported Food” (Decree No. 280).

These Regulations will officially enter into force on 1 June 2026, marking a new phase of strengthened regulatory control over the imported food supply chain into China.

Announcement No. 27/2026 clarifies the following key aspects:

• Categories of food subject to registration management
• Customs declaration requirements for imported food
• Official channels for registration and information enquiries.

1. Categories Subject to Registration Management

According to the Announcement, GACC determines the categories of imported food that are subject to official recommendation for registration, the list of food categories not eligible for automatic registration renewal, and the scope of overseas warehousing enterprises required to register under the Registration Regulations, based on multiple factors such as raw material sources, production and processing methods, food safety history, consumer groups, and consumption practices, in combination with international practices.

1.1 Food Categories Required to Be Registered through Official Recommendation

These product categories are considered to involve relatively high food safety risks or have a direct impact on consumer health, and therefore must be registered through official recommendation by the competent authority of the exporting country or region.

1.2 Food Categories Not Eligible for Automatic Registration Renewal

• Meat and meat products
• Edible bird’s nest and bird’s nest products

1.3 Overseas Food Storage Enterprises Also Subject to Registration

A notable new requirement is that not only overseas food manufacturers, but also overseas enterprises engaged in the storage of imported food may be required to register.

Specifically, cold storage facilities used for storing terrestrial animal-origin foods and aquatic products shall be subject to the registration requirements under Decree No. 280.

2. Customs Declaration Requirements for Imported Food

2.1 Information Declaration Requirements

For food imported into China for human consumption or for use as raw materials in food processing, enterprises must:

• Accurately and completely declare the China registration number of the overseas food manufacturer corresponding to the country (region) of origin in the field “Registration of Overseas Manufacturer of Imported Food” (进口食品境外生产企业注册, document code 519) on the customs declaration form;
• Clearly declare the intended use as “food” (食用).

Where information is not declared in accordance with the requirements, Chinese Customs will not accept the declaration. Any false declaration intended to obtain improper benefits may be subject to legal penalties.

2.2 Import Declaration Requirements for Food

The Announcement further clarifies common practical scenarios:

• For overseas food manufacturers subject to official recommendation registration, products manufactured within the valid registration period may be declared for import, including products manufactured during the registration validity period by enterprises whose registrations have expired but were not renewed, provided that the products are still within their shelf life;
• For overseas food manufacturers that apply for registration on their own initiative, the registration must be valid at the time of import declaration;
• For overseas food manufacturers whose registrations have been suspended, cancelled, or revoked, food products shipped prior to the effective date of such regulatory action will not be affected in terms of import declaration.

Where GACC has special requirements, such requirements shall prevail.

3. Registration and Information Enquiry Channels

GACC reaffirms that the Overseas Manufacturer Registration Management System for Imported Food (CIFER) is the sole official platform for:

• Submitting new registration applications
• Making changes to registration information
• Applying for extension, suspension, or restoration of registration
• Tracking application progress and official feedback

System access link: https://cifer.singlewindow.cn

4. Other Notes

• Registration of overseas enterprises under Decree No. 280 and Announcement No. 27/2026 is free of charge
• Requirements applicable to fresh and primary agricultural food products continue to be governed by GACC Announcement No. 219 of 2025
• Enterprises are advised to review their product categories, registration status, validity periods, and to prepare timely renewal plans ahead of 1 June 2026.

For details, please refer to the official announcement: http://www.customs.gov.cn/customs/2026-03/18/article_2026031809353159843.html

EU

Amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and Repealing Directive 94/62/EC on Packaging and Packaging Waste 22/01/2025

On 16 December 2025, the European Commission published the draft Simplification Omnibus Package on the simplification of food and feed safety regulations (Food and Feed Safety Simplification Omnibus).

This draft package forms part of the EU’s overall strategy for the 2024–2029 period, aiming to modernise the food safety regulatory framework, reduce administrative burdens for businesses, while maintaining a high level of protection for public health and the environment.

Main objectives of the Omnibus Package

• Reduce administrative burdens by 25% for businesses and 35% for small and medium-sized enterprises (SMEs) during the 2024–2029 mandate;
• Enhance competitiveness, innovation capacity and resilience of the EU food chain in the context of climate change and evolving global supply chains;
• Maintain a high level of protection for human and animal health and the environment, without weakening the principle of science-based risk assessment.

Notwithstanding its overall simplification objective, with regard to Maximum Residue Levels (MRLs), the EU is taking a significantly more stringent approach, particularly for products imported from third countries.

1. Stricter MRLs for Imported Products

One of the most important and impactful elements of the draft concerns changes to the MRL policy for plant protection product active substances that are not approved in the EU or are classified as highly hazardous.

Specifically:

• Active substances that are not approved in the EU, or that are categorised as having high hazard properties (e.g. carcinogenic, mutagenic, toxic to reproduction, endocrine disruptors, POPs, PBT, vPvB), will no longer be eligible for MRLs based on:

• • Import tolerances, or
  • Codex Alimentarius (CAC) international standards.

• The proposed MRL would be reduced to 0.01 mg/kg, corresponding to the Limit of Quantification (LOQ), also referred to as “technical zero”.

In practical terms, any detectable residue at quantifiable levels may render a consignment non-compliant for entry into the EU, regardless of:

• Whether the agricultural practice in the exporting country is lawful; or
• Whether the active substance is authorised for use in the country of production.

2. Removal of the “Import Tolerance” Concept

• The draft proposes to eliminate the term “import tolerance”, which has often been misinterpreted as meaning that the EU allows the use of non‑EU‑authorised active substances for imported products.

Instead, the EU adopts a new wording:

• MRL based on a Good Agricultural Practice implemented in a third country.
• However, for highly hazardous active substances, this approach will no longer apply, and the EU may lower the applicable MRL to the LOQ level.

3. Withdrawal and Reduction of Existing MRLs

Under the draft, the EU is empowered to:

• Review previously established MRLs, including those applicable to imported products already on the market;
• Withdraw or lower existing MRLs where: New scientific assessments become available, or There is a change in the risk management approach.
• As a result: MRLs can no longer be considered long-term stable thresholds, but may be adjusted more rapidly in the future.

4. Fundamental Shift in Regulatory Approach

A key strategic and long-term change introduced by the draft is the shift in regulatory philosophy:

• Previously: The EU primarily applied a risk-based approach → assessing risks based on actual consumer exposure levels.
• Under the draft: The EU increasingly applies a hazard-based approach → where the mere presence of hazardous properties may justify restriction or prohibition, without the need to demonstrate exposure above safety thresholds.

As a consequence, EU standards are diverging further from Codex, requiring exporters to comply specifically with EU requirements rather than relying solely on Codex compliance.

5. Transitional Measures

Despite the stricter MRL regime, the draft provides for transitional measures aiming to limit unnecessary economic losses:

Products may continue to be placed on the market and sold until the end of their shelf life, provided that:

• They were produced or placed on the market before the new MRL became applicable; and
• They complied with the applicable MRL at the time of production.

However:

• Transitional measures are not automatically granted; and
• EU authorities may exclude transitional arrangements where:  MRLs are lowered due to serious concerns for consumer health.

Further details are available in the attached document.