Self-declaration of products is a procedure in which an organization or individual declares its own food products and bears full responsibility for product safety — it is not a “license application”: the state authority only receives, archives and publishes the information; it issues no certificate, conducts no quality appraisal, and collects no fee. This article details the covered products, the dossier (only 2 components), the procedure and validity of self-declaration under Decree 15/2018/ND-CP (amended by Decree 155/2018/ND-CP) — which remains in force as of 14/10/2026 (Decree 46/2026/ND-CP has been suspended by Resolution 15/2026/NQ-CP).
1. Which products are subject to self-declaration? (Article 4 of Decree 15/2018/ND-CP)
Organizations and individuals self-declare the following products:
- Pre-packaged processed foods;
- Food additives;
- Food processing aids;
- Food containers and packaging materials in direct contact with food.
Excluded — registration of product declaration required (Article 6): dietary supplements; mixed food additives with new uses or not on the permitted list; foods for special medical purposes; foods for special dietary uses; nutritional products for children up to 36 months of age. These require registration of the product declaration, with the state authority appraising the dossier and issuing a Receipt of Registration.
Exempt: products and raw materials manufactured or imported solely for producing or processing export goods, or for the organization’s own internal production, without domestic market consumption.
2. The dossier has only 2 components (Article 5, amended by Decree 155/2018/ND-CP)
- (a) The product self-declaration form using Form No. 01 (Appendix I issued with Decree 155/2018/ND-CP);
- (b) The food-safety testing report of the product within 12 months up to the submission date, issued by a designated testing laboratory or an ISO 17025-accredited laboratory (original or certified copy).
Self-declaration is free of charge — no fees.
3. Procedure and timeline
Step 1: The organization/individual publishes the self-declaration on its own mass media or website, or posts it publicly at its head office; and simultaneously submits 01 dossier set (in person or by post) to the competent state authority designated by the provincial People’s Committee for archiving.
Step 2: Within 7 working days of receiving the dossier, the receiving authority publishes the names of the declaring organizations/individuals and their self-declared products on its website.
Immediately after self-declaration, the organization/individual may manufacture and trade the product and bears full responsibility for its safety.
4. Validity of the self-declaration
- A product self-declaration has no expiry date;
- If the product name, origin or composition changes, the organization/individual must re-declare the product;
- For other changes: notify the receiving authority in writing of the changes, then manufacture and trade immediately.
5. The core distinction: self-declaration vs registration of declaration
- Self-declaration: the enterprise bears responsibility; the state authority only receives, archives and publishes; no certificate issued; no fee; applies to ordinary products (Article 4).
- Registration of declaration: applies to higher-risk products (Article 6: dietary supplements, medical-nutrition foods, special-diet foods, nutrition for children up to 36 months…); the authority appraises the dossier and issues a Receipt of Registration of Product Declaration; fees apply as prescribed.
FAQs
Q: Must I “apply for a self-declaration license”?
A: No. “Applying for a self-declaration license” or “being granted a self-declaration” is fundamentally wrong — self-declaration is performed by the enterprise itself at its own responsibility; no license is issued.
Q: Can I use a testing report older than 12 months, or from a non-accredited lab?
A: No. The report must be within 12 months of submission and issued by a designated or ISO 17025-accredited laboratory — otherwise the dossier is invalid.
Q: Can dietary supplements or infant formula for children under 36 months be self-declared?
A: No. These fall under Article 6 and require registration of product declaration.
Legal basis: Decree 15/2018/ND-CP (02/02/2018), amended by Decree 155/2018/ND-CP (12/11/2018) — in force; Resolution 15/2026/NQ-CP (06/4/2026) suspending Decree 46/2026/ND-CP; Food Safety Law 55/2010/QH12 (amended by Law 28/2018/QH14). Checked on 14/10/2026.
This article is for general reference only and does not constitute legal advice for any specific case. The content has been reviewed by the QA Council.
Transparency note: This article was drafted with AI assistance and quality-checked by FLAT’s AI Legal Council; it has not been reviewed by a human lawyer.
See also: Contact FLAT Law Firm
