Vietnam suspended Decree 46 on Food Safety on February 4, 2026, after trade disruptions forced a rapid policy reversal. The Government of Vietnam reinstated the previous framework, Decree 15, to restore normal import flows until April 15, 2026. Authorities are now reviewing potential amendments before any decision on resumption.
Background: Vietnam’s Food Safety Regulatory Framework
Decree 15/2018 had governed food safety inspection procedures for imported goods in Vietnam for several years. It established a workable compliance structure that trading partners and industry associations understood well. However, Vietnamese authorities began drafting revisions in 2025, signalling intent to tighten import safety controls.
The Ministry of Health notified the World Trade Organization of proposed amendments to Decree 15 in March 2025. An updated draft followed in June 2025. Nevertheless, neither notification indicated major changes to import inspection or product registration procedures.
Decree 46: Rapid Enactment and Immediate Disruption
The Government of Vietnam issued Decree 46 on January 26, 2026, through an expedited process. It took effect immediately upon publication, replacing Decree 15 in full. Decree 46 introduced new food safety certificate requirements and a more complex product registration process for all imported foods.
Furthermore, Vietnam did not notify the World Trade Organization of the replacement before enactment. This omission drew formal objections from trading partners, who cited Vietnam’s WTO commitments on regulatory transparency.
Trade Impact and Supply Chain Disruption
Importers and food processors faced immediate compliance challenges after Decree 46 took effect. Within ten days of implementation, multiple industry associations submitted urgent petitions to the Government of Vietnam. These petitions cited risks of significant business disruption and financial loss.
Additionally, key members of the Standing Committee of the National Assembly called publicly for a prompt evaluation of the decree’s impact. The speed and scale of the business community response reflected serious supply chain strain across Vietnam’s food import sector.
Government Suspension and Policy Drivers
In response to industry pressure, the Government issued Resolution 09 on February 4, 2026, suspending Decree 46 until April 15, 2026. Decree 15 was simultaneously reinstated to maintain continuity of food and agricultural trade. The suspension acknowledged that the abrupt regulatory shift had caused unacceptable disruption.
On March 5, the Vietnam Chamber of Commerce and Industry recommended extending the suspension period. The Chamber cited ongoing amendments to Vietnam’s broader Food Safety Law as grounds for delay. Consequently, the business community is pressing for reduced compliance costs and greater reliance on post-clearance controls rather than pre-import inspection requirements.
Stakeholder Reactions and International Pressure
A coalition of approximately twelve trading partners formally requested that Vietnam notify the WTO of all regulatory changes affecting trade. They also requested structured opportunities to submit comments before new measures take effect. This joint diplomatic effort reflects broad concern about Vietnam’s approach to regulatory transparency.
Meanwhile, the Ministry of Health confirmed ongoing review of Decree 46 at a meeting with the USDA Foreign Agricultural Service in Hanoi on March 11, 2026. The Vice Minister of Health stated that the Ministry, working with relevant ministries, would report directly to the Prime Minister for further instructions.
Global Context
Vietnam is a major destination for food and agricultural exports from the United States, the European Union, Australia, and Southeast Asian neighbours. Any permanent changes to Vietnam’s food import inspection framework carry significant implications for global agri-food supply chains. Therefore, trading partners are monitoring the April 15, 2026 deadline closely.
Market Outlook
In the near term — the 30 days leading to April 15, 2026 — the most critical watch point is whether Vietnam’s government extends the Decree 46 suspension or allows it to resume in original or amended form. The VCCI recommendation to extend the suspension, combined with active Prime Minister-level review, suggests a further delay is possible. However, the Ministry of Health is simultaneously preparing industries for potential resumption, creating genuine policy uncertainty.
Over the next 6 to 12 months, Vietnam may introduce a revised version of Decree 46 with phased implementation timelines and advance WTO notification. A transparent, consultation-based process could reduce trade disruption significantly. Nevertheless, exporters shipping food products into Vietnam should maintain contingency compliance plans and monitor USDA FAS Hanoi updates closely through the April 15 deadline and beyond.








