Self-declaration is the lighter of Vietnam’s two food procedures, and it is also the one importers get wrong by treating it as paperwork rather than a publication act. There is no certificate to wait for, but there is a specific place the declaration has to appear before the goods may legally sell — and getting that step wrong leaves a shipment technically undeclared even after the form is filled in correctly.
Whether your product qualifies for self-declaration at all, versus the registered route reserved for health supplements, medical nutrition foods and infant nutrition, is a routing question answered in full in which declaration route your food product takes. This page assumes the answer came back “self-declare” and walks through what that procedure actually requires for an ordinary processed food, food additive, processing aid, or food-contact container or packaging material.
💬 Already know your product self-declares, and want the dossier built and published correctly the first time? Tell us what you are importing.
What self-declaration is not
Self-declaration is not a submission for approval — under Article 5 clause 2 point a of Decree 15/2018/ND-CP, the company publishes its own declaration and may produce or trade the product immediately afterward, without waiting for any authority to issue anything.
That is the entire difference from the registered route. A registered declaration cannot circulate until the Ministry of Health or the designated provincial body issues a certificate of receipt. A self-declaration has no such gate: the act of publishing it correctly is what makes the product legal to sell, on the same day.
This also means there is nothing to chase up if it goes quiet — no application sitting in a queue, no officer to follow up with. The only thing that can go wrong afterward is a market inspection finding the publication was incomplete, the test report inadequate, or the product outside what the declaration actually covers.
The dossier
A self-declaration dossier is built on three things: the declaration form itself, a food-safety test report from a qualified laboratory, and the label content the declaration has to match.
| Item | What it has to contain |
|---|---|
| Declaration form (Annex I, Form 01) | Product name, specification, shelf life, packaging, and the name and address of the organisation making the declaration |
| Food-safety test report | Issued within 12 months of the date of submission, by a laboratory designated for food testing or one accredited to ISO/IEC 17025, covering the safety indicators the applicable technical regulation (QCVN) requires for that product category |
| Label content cross-check | The product name, composition and quantities on the declaration form must read identically to what appears on the label and, separately, on the test report |
Checked against the published text on 15 September 2026.
The test report window is measured to the submission date, not to when the sample was drawn — a report commissioned early in a long supplier negotiation can be stale by the time the goods actually ship. Build the indicator list from the QCVN that applies to your product category before commissioning the test, rather than accepting whatever a laboratory’s standard package happens to cover; a report that is complete but missing one required indicator is still an incomplete self-declaration.
💬 Sunsho Trade checks the indicator list against the applicable QCVN before the sample goes to the laboratory, so the report is not built to the wrong list — see our Selling into Vietnam service.
Who files it
Article 2 of Decree 15/2018/ND-CP applies to organisations and individuals producing or trading food in Vietnam, so the party publishing the self-declaration has to be established here — usually the importer or the appointed Vietnamese distributor.
The publication stands in that party’s name, not the foreign brand’s. If the importer of record changes later, the new party publishes its own self-declaration rather than inheriting the old one — the same principle that applies on the registered route, covered in the food-supplement declaration article linked above, and the same principle behind choosing the trading structure in the first place, set out in who can legally import your product into Vietnam.
Exactly where the declaration has to appear
Article 5 clause 2 point a names three channels — mass media, the company’s own website, or a public notice at its premises — and requires the same information to also be published on the national food-safety data system; where that system is unavailable, one copy goes to the provincial-designated body to be held on file instead.
| Channel | What it satisfies |
|---|---|
| National food-safety data system | The primary publication channel — this is what a market inspector checks first |
| Company’s own website, mass media, or a notice at company premises | At least one of these has to run alongside the data-system entry |
| Paper copy to the provincial-designated body | Only where the data system itself is unavailable at the time of filing |
A self-declaration published only internally — a document sitting in a compliance folder, never actually posted anywhere public — is not a self-declaration in the sense the decree requires, whatever the file says. The word “declare” in Vietnamese food law is a publication requirement, not a record-keeping one. Keep a dated screenshot or printout of the published entry; it is the evidence that the publication step, not just the paperwork, happened on time.
💬 Not sure whether your last shipment’s self-declaration was ever actually published, versus only drafted? We can check the national data-system entry against your file — contact Sunsho Trade.
What sends a self-declaration back at inspection
Because there is no pre-market review, the checking happens afterward, at customs or at market inspection, and it looks for the same three gaps every time.
The publication step was skipped or incomplete. A declaration form exists but was never posted to the national data system, or was posted without the accompanying website or premises notice.
The test report does not cover what the applicable QCVN requires. A generic test package that omits one mandated safety indicator is not a defence — the requirement is the QCVN’s list, not a laboratory’s default panel.
The product on the shelf does not match the product on the form. A reformulation, a new pack size, or a supplier change to a different manufacturing site is a different product for this purpose, and it needs its own declaration under Article 5 clause 4 rather than being sold against the old one.
None of the three is a paperwork inconvenience once goods are already in a Vietnamese warehouse — each one can stop a batch moving until it is fixed, which is why the publication and the test report are worth confirming before the shipment leaves the country of origin, not after it lands.
When self-declaration stops being available
If a product turns out to sit in a category Article 6 reserves for the registered route — health supplements, medical nutrition foods, foods for special dietary use, or nutrition products for children up to 36 months — self-declaration is not an option regardless of how the product is described.
Classification runs on composition, dosage form and the purpose stated on the label, not on what the product is called in its home market. Which declaration route your food product takes sets out the five questions that decide it and the fuller registered-route document list, including why a product that reads as an ordinary food elsewhere can still land in the pre-approval category here.
The instrument itself is also worth watching. Decree 46/2026/ND-CP was issued to replace Decree 15/2018/ND-CP but remains suspended, with dossiers continuing to be built to Decree 15/2018 for now — the currency detail is set out in full in the same linked article, since restating it here would only get out of date in two different places instead of one.
Frequently asked questions
1. Do I need to wait for approval before selling a self-declared food product?
No. Article 5 clause 2 lets you produce and trade the product immediately after publishing the self-declaration — there is no certificate to wait for on this route.
2. Where exactly does a self-declaration have to be published?
On the national food-safety data system, together with at least one of: your own website, mass media, or a public notice at your premises. If the data system is unavailable when you file, a paper copy goes to the provincial-designated body instead.
3. How old can the test report be when I submit the declaration?
No older than 12 months, measured to the date of submission — not to the date the sample was tested. A report commissioned early in a long negotiation can fall outside the window by the time you actually file.
4. If I change my product’s pack size, do I need a new self-declaration?
Generally yes, if the change affects what is on the declaration form or the label — Article 5 clause 4 requires a fresh declaration for changes to the product itself. Minor administrative changes are handled separately by written notice.
5. Can a health supplement ever use this self-declaration route instead of registering?
No. Article 6 reserves health supplements, medical nutrition foods, special dietary foods and infant nutrition products for the registered route regardless of how simple the self-declaration procedure looks by comparison — see the routing article linked above for the full test.
Sources: Decree 15/2018/ND-CP (vanban.chinhphu.vn); national food-safety data system (Vietnam Food Administration). Checked on 25 September 2026.