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Vietnam Ministry of Health Promulgates List of Medium-Risk Food Contact Materials

The circular sets compliance requirements for synthetic plastic and rubber food contact materials, including self-declaration obligations and applicable QCVN standards.

On July 1, 2026, the Ministry of Health of Vietnam officially promulgated Circular No. 27/2026/TT-BYT. This document officially issues the list of foods, food containers, and direct food contact packaging materials classified as having a medium level of risk, which fall under the direct management and responsibility of the Food Safety Department under the Ministry of Health.

Regulated FCMs and Compliance Requirements

Regarding Food Contact Materials (FCM), this Circular specifically applies to food containers and direct food contact packaging materials made of synthetic plastics and rubber. It outlines specific management requirements and applicable National Technical Regulations (QCVN) for medium-risk FCMs. The specific requirements are detailed below:

Product Group

Governing National Technical Regulation (QCVN)

Compliance & Management Requirements

Food containers and direct food contact packaging materials made of synthetic plastic

QCVN 12-1:2011/BYT (National technical regulation on safety and hygiene for synthetic plastic packaging and containers in direct contact with food)

Perform self-declaration of products in accordance with Article 4 of Decree No. 15/2018/NĐ-CP. HS codes are specified under Circular No. 15/2024/TT-BYT and Circular No. 31/2022/TT-BTC.

Food containers and direct food contact packaging materials made of rubber

QCVN 12-2:2011/BYT (National technical regulation on safety and hygiene for rubber packaging and containers in direct contact with food)

Perform self-declaration of products in accordance with Article 4 of Decree No. 15/2018/NĐ-CP. HS codes are specified under Circular No. 15/2024/TT-BYT and Circular No. 31/2022/TT-BTC.

Circular No. 27/2026/TT-BYT officially came into effect on July 1, 2026. Enterprises are advised to adhere to the requirements immediately, as no delayed transition period is specified in the document.

The original text can be accessed here.

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