Packaging is not a legal bystander in food law: materials and articles in direct contact with food are an independent food-safety management object, because chemical migration from material into food is a real risk. This article sets out declaration duties and material-safety control for packaging producers and importers in Vietnam.
Food-contact packaging must be self-declared
Under Article 4 of Decree 15/2018/ND-CP, products within food-safety management scope — including utensils and packaging materials in direct food contact — require self-declaration before circulation. Domestic packaging producers and importers alike must self-declare their material lines: a declaration file, test results for material safety criteria and goods labelling. Note the separation: this duty is independent of the declaration for the food inside — food producers buying declared packaging should still keep the supplier’s declaration and test results in their traceability file, because when a finished product is found contaminated by migration, inspectors trace both sides.
Safety standards by material
Packaging safety is assessed by migration limits under national technical regulations for each material group — synthetic plastics, metals, rubber, paper and others — covering heavy-metal migration such as lead and cadmium plus material-specific criteria (for example residual monomers in plastics). When selecting a new material, require the supplier’s migration test results under simulated real-contact conditions (food type, temperature, duration), not a generic ‘food-safe material’ certificate. Imported packaging undergoes state food-safety inspection before customs clearance under Decree 15/2018/ND-CP; foreign test files must be reconciled with Vietnamese regulations because test methods and permitted limits differ between countries.
Recycled plastic: special caution
Recycled material for direct food contact is a grey zone requiring caution: use it only where the recycled material meets the same migration limits as virgin material with a technical file proving origin and a recognised-standard decontamination process. At the time of writing, Vietnamese management practice has no broad recognition mechanism for post-consumer recycled plastic in direct food contact; packaging without a full testing basis exposes the food inside to an unsafe-product conclusion.
Framework context and recommendations
The operative procedure remains Decree 15/2018/ND-CP; Decree 46/2026/ND-CP was issued to replace it but is temporarily suspended under Resolution 15/2026/NQ-CP until the amended Food Safety Law takes effect — track the switch-over to refresh files. Recommendations: maintain a packaging-material register by SKU with current migration results; make material-safety requirements a mandatory clause in packaging purchase contracts; and re-test when changing supplier, printing ink or adhesive — the three most overlooked changes, all of which alter the migration profile.
Frequently Asked Questions
Must food-contact packaging be declared?
Yes. Utensils and packaging materials in direct food contact require self-declaration under Article 4 of Decree 15/2018/ND-CP before circulation, for both domestic production and imports.
What are the safety standards for food packaging?
Chemical migration limits from material into food under national technical regulations per material group (plastics, metals, rubber, paper), including heavy metals such as lead and cadmium and material-specific criteria. Testing must simulate real contact conditions.
What is inspected when importing packaging?
Goods undergo state food-safety inspection before customs clearance under Decree 15/2018/ND-CP and need a Vietnam self-declaration. Foreign test results must be reconciled with Vietnamese regulations, as methods and limits may differ.
Can recycled plastic packaging be used for food?
Only where the recycled material meets the same migration limits as virgin material with a technical file proving a recognised-standard cleaning process. Current practice does not broadly recognise post-consumer recycled plastic for direct contact — test fully before use.
This article has been quality-reviewed by the FLAW AI Legal Council