This seemingly simple question decides the entire route for bringing an imported functional food into Vietnam, because choosing the wrong procedure means the goods can reach the port and still not be saleable. The key point is that Vietnamese food safety law does not use one single track: the more a product claims health-related functions, the heavier the procedure, and health supplements must register their product notification instead of self-declaring.
The two procedures and the line between them
Decree 15/2018/ND-CP sets two mechanisms: self-declaration of products, covering most pre-packaged processed foods, where the company takes responsibility for its own file and may trade right after declaring; and registration of the product notification, covering groups with specific risks and functions, including health supplements, medical nutritional foods, foods for special diets and nutrition products for children up to 36 months. The second group must file with the Vietnam Food Administration and may circulate only after receiving the registration receipt.
The term circulation registration belongs to pharmaceuticals, not to functional foods. A frequent error is an importer calling its product a mere food supplement to take the self-declaration track, while the functions claimed on the label and in advertising are exactly those of a health supplement. Regulators classify the product by ingredients, target users and declared functions, not by the trade name the company chooses for itself.
A special validity point at the time of writing
Decree 46/2026/ND-CP was issued to replace Decree 15/2018/ND-CP on food safety, but its application is currently suspended under Resolution 09/2026/NQ-CP and Resolution 15/2026/NQ-CP dated 6 April 2026, until the amended Food Safety Law and a new guiding decree take effect. During the suspension, product declaration and notification registration procedures continue in practice under Decree 15/2018/ND-CP.
The practical consequence is that company files must be built on the forms and process of Decree 15/2018, while compliance teams monitor when the new framework is reactivated so a procedural change does not catch them off guard. The same logic applies to advertising of health supplements, whose content must be confirmed before advertising under the framework actually in force.
The registration dossier and realistic timing
A notification registration dossier for an imported health supplement includes the product notification in the prescribed form, a certificate of free sale or equivalent from the country of origin, product test results from a designated or recognised laboratory, the product label and scientific documentation proving the functions of the ingredients. For products with new functions or new ingredients, appraisal of the scientific evidence is usually the longest part of the whole procedure.
The statutory processing time for a complete and valid file is much shorter than real elapsed time when supplementation is requested, because each supplementation round restarts appraisal of the affected part. Importers should budget a total runway of some months from locking the formula and label to holding the receipt, and should never promise shelf dates to distribution channels before the receipt is issued.
Frequently Asked Questions
Do imported functional foods need notification or full registration?
Imported functional foods in the health supplement group must register the product notification with the Vietnam Food Administration under Decree 15/2018/ND-CP; the self-declaration track does not apply, and the pharmaceutical circulation registration procedure is not used either. Only ordinary pre-packaged processed foods fall under self-declaration. Grouping follows ingredients, target users and declared functions, not the trade name.
How do the two procedures differ?
The core difference is the regulator’s role: in self-declaration the company files and takes responsibility itself and may trade immediately after declaring; in notification registration the Vietnam Food Administration must appraise the dossier and issue a receipt before the product may circulate. The registration group covers health supplements, medical nutritional foods, foods for special diets and nutrition products for children up to 36 months.
What documents are required?
The dossier includes the product notification in the prescribed form, a certificate of free sale from the country of origin, test results from a designated or recognised laboratory, the product label and scientific documents proving the functions of the ingredients in the product. Imported products also need documents evidencing that the manufacturer meets equivalent food safety conditions as required for imports.
How long does it take?
Statutory timing for a valid dossier is not long, but real timing usually stretches to some months because notification registration files are often supplemented on the function evidence and the Vietnamese label. Companies should plan the full runway from locking formula and label to receiving the receipt, and should not commit delivery dates to distribution channels before the receipt is in hand.
Bottom line for importers
For imported functional foods claiming health functions, the correct answer is registration of the product notification under Decree 15/2018/ND-CP as currently applied in practice, with the caveat that the Decree 46/2026/ND-CP framework is suspended under Resolution 15/2026/NQ-CP. Getting the product group right at the start matters more than filing speed.
