On January 26, 2026, the Government officially issued Decree No. 46/2026/ND-CP, marking a historic turning point in Food Safety (FS) management in Vietnam.
This is not a minor amendment or technical adjustment.
Decree 46/2026/ND-CP represents a comprehensive RESET, completely abolishing Decree 15/2018/ND-CP.
The era of “Self-declaration” has officially come to an end, replaced by a stricter governance framework:
Standardization – Evidence-based compliance – Controlled management
So how should food manufacturers and import–export enterprises adapt to this new “rule of the game”?
Let Songwin Logistics walk you through the core changes below.
1. Complete Abolition of Decree 15/2018/ND-CP
Decree 15/2018 was once considered a “revolution” in administrative reform, featuring a relaxed post-inspection mechanism. However, Decree 46/2026/ND-CP officially terminates this model.
This is not merely a regulatory adjustment, but a fundamental shift in regulatory philosophy:
-
From a model where the State fully trusted enterprises’ commitments
-
To a system of selective pre-inspection combined with strict post-inspection
2. Elimination of “Self-Declaration” – Establishment of “Registration of Conformity Declaration”
This is the most disruptive change for the business community.
Previously:
Enterprises could self-declare products, assume responsibility, and immediately place them on the market.
Now (Articles 4, 5, and 6 – Decree 46/2026):
The Self-declaration mechanism no longer exists.
Instead, enterprises are mandatorily required to conduct Registration of Conformity Declaration for the following product groups:
-
Processed and pre-packaged foods
-
Food additives and processing aids
-
Utensils and packaging materials in direct contact with food
Key features of the new mechanism:
-
Dossiers must fully comply with regulatory standards
-
Applications must be received and appraised by competent authorities
-
Certificates are valid for a limited period only (maximum 03 years), no longer indefinite as before
3. Risk-Based Management in Line with International Standards (Codex / EU)
Decree 46/2026 eliminates the “one-size-fits-all” approach.
High-risk product categories — such as:
-
Health supplements
-
Medical nutrition products
-
Foods for special dietary uses
— are subject to stricter requirements regarding GMP compliance, qualified personnel, and technical dossier evaluation.
Importantly, the Decree clearly distinguishes between:
-
Product management: via Registration of Conformity Declaration
-
Facility management: via Certificates of Food Safety Compliance
Note: ISO or HACCP certification can no longer be misunderstood as a substitute for product conformity registration.
4. Stricter Imported Food Safety Inspection
For importers, state inspection procedures at the border are significantly upgraded based on data and compliance history.
Three inspection methods apply:
-
Strict inspection
-
Normal inspection
-
Reduced inspection
The applicable method is determined by actual import performance and compliance records, eliminating subjective judgment and enhancing transparency.
5. Quick Comparison: Decree 15/2018 (Old) vs. Decree 46/2026 (New)
| Criteria | Decree 15/2018 (Abolished) | Decree 46/2026 (Effective) |
|---|---|---|
| Core mechanism | Self-declaration | Registration of conformity declaration |
| Role of the State | Post-inspection (trust-based) | Selective pre-inspection + strict post-inspection |
| Validity of dossiers | Indefinite | Maximum 03 years |
| Procedures | Simple, enterprise-driven | More complex, subject to appraisal |
Solutions for Enterprises in the “New Era”
The introduction of Decree 46/2026/ND-CP will undoubtedly cause short-term administrative shocks.
Preparing a compliant Registration of Conformity Declaration dossier now requires deep expertise in technical standards, testing, and legal compliance to avoid repeated rejections.
Songwin International Logistics Vietnam is fully prepared to accompany enterprises through this transition:
-
In-depth legal consulting: Continuous updates on the latest forms and procedures under Decree 46
-
Dossier standardization: Accurate, first-time-right preparation of conformity registration dossiers
-
End-to-end logistics services: International transportation, freight consultation, HS code classification, and specialized inspection under the new framework
Do not let regulatory changes disrupt your supply chain.
Actively transition today to stay compliant tomorrow.
Contact Songwin for Professional Consultation
For detailed guidance on transitioning from Self-declaration to Registration of Conformity Declaration, please contact:
SONGWIN INTERNATIONAL LOGISTICS VIETNAM CO., LTD
📍 Address: 344 Nguyen Trong Tuyen Street, Tan Son Hoa Ward, Ho Chi Minh City, Vietnam
📞 24/7 Hotline: +84 83 681 3969 – +84 373 262 105
📧 Dossier submission email: Sales2@songwinlog.com
Songwin International Logistics – Master the new regulations, move forward with confidence.
