WHAT HAPPENED
Vietnam has launched the largest overhaul of food safety regulation in a decade and a half, and the main blow will land on the online sales channel. On January 26, 2026, the government issued Decree No. 46/2026/ND-CP, detailing the implementation of the Law on Food Safety. The document, published on the official government portal Chinhphu.vn, introduces mandatory registration and publication of food product information, strengthens control over food trading on e-commerce platforms, and requires the implementation of safety management systems (HACCP, ISO 22000, or GMP) for certain product groups by December 31, 2026. A separate clause concerns GMOs: labeling is mandatory if the share of GMO components exceeds 5%.
Then what happens in Vietnam with any harsh regulatory leap began. The sudden introduction of the norms caused trade disruptions, and the government suspended the implementation of Decree No. 46 until April 15, 2026 — this is recorded in the USDA/FAS report VM2026-0005. Vietnam Briefing describes this as "removing implementation bottlenecks" rather than abandoning the reform.
At the same time, work is underway at a higher level. On August 3, 2026, the Vietnam Food Administration under the Ministry of Health notified the WTO Secretariat of a draft complete replacement of the 2010 Food Safety Law (notification G/SPS/N/VNM/187), with the comment period closing on September 17, 2026. So Decree No. 46 is not the final point but a transitional contour: according to the USDA FAS report VM2026-0017, a unified decree is being prepared that will replace both the current Decree 15/2018 and Decree 46. In addition, in March 2026, Decree No. 90/2026/ND-CP was adopted on sanctions for administrative violations in the healthcare sector, including online drug retail — the general trend toward tightening rules for health-related goods is clearly visible.
WHAT THIS MEANS
For a Russian e-com entrepreneur who sees Vietnam as the next market after Kazakhstan and the UAE, the news sounds unpleasant but useful. Vietnam is ceasing to be a market where you "upload goods to Shopee and wait for orders." Decree No. 46 explicitly expands the powers of inspectors to work in "cyberspace," obliges sellers and platforms to declare and update product information, and requires coordination between MOH, MARD, and MOIT. In practical terms: the marketplace becomes not just a storefront but a participant in the compliance chain. If the product listing diverges from the declaration, the question will not be only for the seller.
The second layer is deadlines. The requirement to implement HACCP/ISO 22000/GMP by December 31, 2026 applies to certain product groups, and this is no longer an abstraction: just over three months remain until the deadline. For an importer, this means the supplier must either already have a certified system or you will not make it in time for the season. Rebuilding the supply chain in December is the most expensive scenario, because the number of alternative suppliers with ready documents on the market is physically limited.
The third layer is GMO labeling when the share exceeds 5%. For Russian manufacturers, this is critical in categories such as soy products, vegetable oils, snacks, baby food, and sports nutrition. Formally, the requirement looks narrow, but in practice it means redesigning the packaging layout and re-certifying the batch — that is, money and time.
And most importantly: the instability of the regulation itself. The decree came into force, then was suspended, then the process of replacing the law was launched. This is not a sign of chaos but a sign that the state is learning to manage online food trade and will continue to fine-tune the rules. Planning expansion on the assumption that "they aren't checking yet" is a strategy with a one-quarter horizon.
VIETSMART EXPERT COMMENTARY
I regularly see the same mistake among Russian teams entering Vietnam. They spend three months negotiating with a distributor and zero days checking who exactly will bear responsibility for the product declaration on the platform. In Ho Chi Minh City, at meetings with partners, it almost always turns out that no one in the chain has read the text of the current decree — everyone relies on a retelling by an acquaintance from logistics. Then an inspection by MOIT comes, and it turns out that the product listing on the marketplace does not match the conformity declaration, and the certificate expired before shipment.
If I were a Russian entrepreneur, I would do two things right now. First, I would translate Decree No. 46 and the draft new law into Russian and go through them with my lawyer, not with a registration contractor. Second, I would fix in the contract with the Vietnamese partner who is responsible for updating product data on the platform and within what timeframes. It is boring, but these two points cover 80% of the risks.
CONCLUSIONS AND WHAT TO DO
The tightening of Vietnamese regulation is not a closure of the market but its professional filtering. Weak suppliers will leave, freeing up shelves and niches on marketplaces. Below are specific steps I would put in the plan for the coming month.
- Request the HACCP, ISO 22000, or GMP certificate from the supplier and check its validity period and scope. If there is no certificate and the product falls into regulated groups, you will not meet the December 31, 2026 deadline.
- Verify the product listing on Shopee, Lazada, or TikTok Shop against the conformity declaration. A discrepancy in composition, weight, or manufacturer is a ready reason for a fine by MOIT or MOH.
- Check the composition for GMO components. If the share exceeds 5%, separate labeling and an updated packaging layout are required; for soy, vegetable oils, and snacks, this should be done first.
- Stipulate in the contract with the Vietnamese partner the responsibility for updating product data on the platform and the timeframes for responding to regulator requests. Without this clause, all risks remain with you.
- Subscribe to updates on the draft replacement of the Food Safety Law (notification G/SPS/N/VNM/187) and keep an alternative supplier with ready documents in reserve — the rules will continue to change for at least another year.
Source: Nikkei Asia dated September 25, 2026