Food safety and hygiene newsletter August 2025

After more than 15 years of implementation, the National Technical Regulation QCVN 5-1:2010/BYT on fluid milk products is facing an urgent need for revision. Experts, businesses, and regulatory agencies unanimously agree that the current regulation no longer aligns with practical production conditions, modern processing technologies, and evolving consumer trends.

Therefore, on the morning of August 15, 2025, the Ministry of Industry and Trade organized a scientific workshop titled: “National Technical Regulation for fluid milk products ” to address existing issues, specifically:

• Lack of clear definitions among milk types such as pasteurized fresh milk, reconstituted milk, and recombined milk, leading to consumer confusion.
• No specification of minimum milk fat content, despite this being a common classification criterion in many countries (e.g., whole milk, skim milk). QCVN 5-1:2010/BYT only specifies milk protein content.
• Reconstituted and recombined milk are not subject to mandatory technical regulations, complicating post-market inspection and traceability.
• Overlapping provisions between regulations issued by the Ministry of Health and other legal documents, affecting regulatory efficiency and market transparency. For example, QCVN 5-1:2010/BYT outlines safety indicators for fluid milk products such as mycotoxins, heavy metals, microorganisms, veterinary drug residues, and pesticide residues. However, similar indicators are also regulated under QCVN 8-1:2011/BYT, QCVN 8-2:2011/BYT, QCVN 8-3:2012/BYT, Circular 24/2013/TT-BYT, and Circular 50/2016/TT-BYT.

Proposed Revisions:

The Ministry of Industry and Trade, in collaboration with the Ministry of Health and other relevant stakeholders, is currently developing a new technical regulation. This draft is being formulated with reference to international Codex standards and advanced regulations from developed countries. The new regulation aims to:

1. Clearly classify processed milk products, enabling consumers to better distinguish between different types and avoid confusion.

2. Supplementing regulations on physical and chemical indicators to ensure nutritional quality and better product control.

3. Adjustment of Contaminant Regulations to Align with the Current Legal Framework and Reduce Overlaps

4. Supplementing regulations on traceability and transparent labeling helps to clarify information and protect consumers.

5. The draft regulation encourages the application of internationally recognized quality management systems such as GMP (Good Manufacturing Practices), HACCP (Hazard Analysis and Critical Control Points), and ISO 22000 for high-risk dairy products, particularly those intended for infants.

These systems are developed based on the following principles:

• Ensuring safety for consumer health
• Aligning with the realities of production, business, and import activities in Vietnam
• Complying with national standards and Vietnamese legal regulations
• Harmonizing with international standards and regulations, avoiding the creation of technical barriers to trade between Vietnam and other countries
• Incorporating risk management recommendations from competent authorities in Vietnam and abroad, including the Food and Agriculture Organization (FAO), the World Health Organization (WHO), and the Codex Alimentarius Commission (CODEX)

Feedback submission link here.

View the draft of QCVN 5-1 here.

Draft Revision of National Technical Regulations on Infant Formula Products

After 13 years of implementation, several provisions in the current National Technical Regulations (QCVN) have become outdated and no longer align with practical realities and updated international standards, particularly those from the Codex Alimentarius. Revising these regulations is essential to enhance consumer protection and facilitate international trade.

The draft revision includes the following National Technical Regulations (QCVN):

• QCVN 11-1:2012/BYT – National technical regulation on infant formula (for children up to 12 months of age)
• QCVN 11-2:2012/BYT – National technical regulation on formulas for special medical purposes intended for infants (up to 12 months of age)
• QCVN 11-3:2012/BYT – National technical regulation on follow-up formula (for infant from 6th month on and young children up to 36 months of age)

Key Revisions

1. Scope of Application

QCVN 11-3, previously covering follow-up formula for children aged 6 to 36 months, is now divided into two distinct groups: Products for children aged 6–12 months and Products for children aged 1–3 years. This division reflects a more tailored approach to the nutritional needs of each developmental stage.

2. Updated Nutritional and Micronutrient Requirements Based on New Scientific Data

For QCVN 11-1 and QCVN 11-2, key changes include:

For QCVN 11-3, due to the reclassification into two age groups, several changes are proposed:

3. Administrative Updates

• Labeling: Updated to comply with Decree 43/2017/NĐ-CP and Decree 111/2021/NĐ-CP.
• Sampling: Replaces outdated circulars with new regulations.
• Testing Methods: Aligned with international standards and current Vietnamese standards (TCVN).
• Product Declaration: Transition from conformity announcement to product registration under Decree 15/2018/NĐ-CP.

Implementation Timeline

• Initial Draft: Late 2025 – Early 2026
• Consultation & Finalization: Throughout 2026–2027
• Official Issuance: Expected in October or November 2027

Reference link: https://emohbackup.moh.gov.vn/publish/home?documentId=10879