A container of registered or self-declared food can still sit at the port after the paperwork is otherwise in order, because declaration and state inspection are two separate gates. The declaration decides whether the product may be sold in Vietnam at all. State inspection decides whether this particular shipment may be released, and it runs on every import unless a specific exemption applies.
Which decree governs this, and where the product list lives
State inspection of imported food is still built on Decree 15/2018/ND-CP (Nghị định 15/2018/NĐ-CP), and which products it reaches is set out by commodity code in Circular 15/2024/TT-BYT of the Ministry of Health.
The replacement decree, Decree 46/2026/ND-CP, remains suspended under Resolution 15/2026/NQ-CP, so dossiers and shipments alike are still handled under Decree 15/2018 — the same instrument covered in our note on the food declaration route. Circular 15/2024/TT-BYT, effective from 19 September 2024, lists the food products, additives, food contact materials and packaging subject to state inspection on import, organised by the Vietnamese commodity code an importer would already be using to classify the shipment. A product not on that list, and not caught by the general definition in the decree, does not go through this gate at all — confirm the code with Customs before assuming either way.
💬 Not sure whether your commodity code is on the inspection list, or which method your shipment will draw? Send us the HS code and the product description and we will check it before the container leaves origin — contact Sunsho Trade.
The three methods, and what moves a shipment between them
Article 16 of Decree 15/2018 sets three inspection methods — tightened, normal and reduced — and Article 17 decides which one a given shipment or importer gets, based on the compliance record behind it, not on the product alone.
| Method | What it involves | When it applies |
|---|---|---|
| Tightened inspection (kiểm tra chặt) | Document review plus sampling and laboratory testing of the shipment | The default for a product or importer with no track record, or one following a prior non-conformity |
| Normal inspection (kiểm tra thông thường) | Document review, with sampling only where the reviewing body judges it necessary | The default once tightened inspection has been passed and no ground for reverting to it has arisen |
| Reduced inspection (kiểm tra giảm) | Document review only, at random on a sample of shipments rather than on every one | Available under Article 17 clause 1 once the importer holds a mutual-recognition confirmation from a partner country’s competent authority, or has passed three consecutive normal inspections within 12 months for the same product from the same origin and manufacturer, or the manufacturing site holds a current GMP, HACCP, ISO 22000, IFS, BRC, FSSC 22000 or equivalent certificate |
A mutual-recognition confirmation from a partner country’s authority, where that is the ground relied on, is a foreign public document and may need authenticating before a Vietnamese body will accept it — see apostille or consular legalisation for a Vietnam dossier for which route applies to which country.
Reduced inspection is not requested in the abstract. Article 18 has the importer file for it against a specific product and origin, attaching either the three notices of satisfactory normal-inspection results or the certified copy of the manufacturing certificate, and it stays a Article 17 case-by-case status rather than a blanket clearance for everything the same company imports.
The record resets. A shipment that fails inspection, or a food-safety warning issued against the product or the manufacturer, moves the next import back to tightened inspection regardless of how many clean shipments preceded it — the mechanism does not distinguish between a first-time importer and one that has cleared a hundred containers before the one that failed.
💬 Building an import compliance record takes more than one clean shipment. As part of our Selling into Vietnam service, we track which method your last clearance drew and what the next one needs. Tell us what you are importing.
What each method asks the importer to file
The registration dossier for state inspection is separate from the product declaration dossier, and its content changes with the method being applied for.
| Document | Tightened / normal | Reduced |
|---|---|---|
| Registration of state food inspection (per Article 18 form) | Required | Required |
| Bill of lading, invoice, packing list | Required | Required |
| Product declaration certificate or self-declaration record | Required | Required |
| Evidence supporting the reduced-inspection ground — three prior satisfactory notices, mutual-recognition confirmation, or manufacturing certificate | — | Required |
| Sample for laboratory testing | On sampling | Not applicable |
A dossier missing the declaration record is refused before the inspection method is even reached, because the receiving body has no product declaration to check the shipment against. Where an importer changes — a new distributor taking over the product, for instance — the declaration and the inspection track record generally do not transfer with it; our distributor agreement checklist covers what to settle about the registration holder before that handover happens.
The exemptions, and where they end
Article 13 exempts a defined set of imports from state inspection altogether, and each exemption is narrower than it first reads.
Goods for export production, or for a company’s own internal use, never sold on the domestic market. The same exemption that keeps these goods off the self-declaration route under Article 4 clause 2 keeps them off state inspection too — and it fails the moment any of the same stock reaches the domestic market.
Products already covered by a Certificate of Registered Product Declaration. Once the registered declaration under Article 6 is in hand, ordinary imports of that same product are exempt from further state inspection — except where a food-safety warning has been issued, which reopens the gate regardless of the certificate.
Samples for testing, research or display, and diplomatic or personal imports within the quantities the regulations allow. These stay exempt only for the stated purpose and quantity; selling the sample commercially removes the exemption retroactively.
Goods in transit, temporary import for re-export, or held in a bonded warehouse without entering the Vietnamese market. The exemption tracks the goods’ legal status, not their physical location — the moment the customs status changes to import for domestic consumption, inspection applies.
None of these exemptions are self-certifying. Customs and the food-safety authority decide whether a shipment fits the claimed exemption at the point of clearance, so the safer position is to have the supporting document — the declaration certificate, the internal-use contract, the re-export bond — ready at the border rather than assumed.
💬 An exemption claimed without the supporting paper is treated as no exemption at all. If you want a second check on your documents before the container is booked, talk to Sunsho Trade.
Where a shipment actually gets held up
In practice, the method is rarely the surprise — the paperwork behind it is.
A commodity code that does not match the product on the ground. Circular 15/2024/TT-BYT organises the inspection list by code, and a code chosen for tariff reasons rather than for an accurate description can put a product on the list, or take it off, incorrectly. Confirm the code with Customs before the first shipment, not after a hold.
A reduced-inspection claim resting on an expired certificate. GMP, HACCP, ISO 22000 and the other accepted certificates have validity periods, and Article 17’s reduced method requires the certificate to be current on the date the dossier is filed, not on the date the goods were manufactured.
A three-consecutive-shipment claim broken by a change upstream. The Article 17 track record runs against the same product, the same origin and the same manufacturer. A supplier switching its manufacturing site, or a reformulation, restarts the count even if the importer and the product name stay the same.
Test coverage that misses an indicator the applicable technical regulation (QCVN) requires. This is the same failure mode that sends a product declaration dossier back, and it recurs at the inspection stage for the same reason — the test plan was built against the label rather than against the regulation.
Frequently asked questions
1. Does state inspection apply to every food shipment into Vietnam?
No. Circular 15/2024/TT-BYT lists the products, additives, food-contact materials and packaging that fall under it by commodity code, and Article 13 of Decree 15/2018 exempts specific categories — export-only or internal-use goods, transit and bonded-warehouse goods, and products already covered by a registered declaration, among others.
2. How does a shipment qualify for reduced inspection?
Under Article 17 clause 1, by holding a mutual-recognition confirmation from the exporting country’s competent authority, by passing three consecutive normal inspections within 12 months for the same product, origin and manufacturer, or by the manufacturing site holding a current GMP, HACCP, ISO 22000, IFS, BRC, FSSC 22000 or equivalent certificate.
3. If our last three shipments passed, are we permanently on reduced inspection?
No. A failed shipment or a food-safety warning reverts the next import to tightened inspection, and a change of manufacturing site or product formulation breaks the compliance record the reduced method relies on.
4. Is state inspection the same procedure as the product declaration?
No. The declaration — self-declared or registered under Decree 15/2018 — decides whether the product may be sold in Vietnam at all. State inspection is a separate, per-shipment check applied at import, though holding a registered declaration exempts most later shipments of that product from it.
5. Where do we find whether our product’s commodity code is on the inspection list?
Circular 15/2024/TT-BYT sets out the list by Vietnamese commodity code. Confirm your code with Customs before booking the first shipment — a code chosen for tariff purposes alone can put an otherwise exempt product on the inspected list.
Sources: Decree 15/2018/ND-CP on the Government’s legal portal, Circular 15/2024/TT-BYT of the Ministry of Health, and the Ministry of Health’s Food Safety Department clarification (Official Letter No. 1391/ATTP-TP). Requirements differ by product and change over time, so confirm the current text and your commodity code before you rely on it. Not legal advice. Checked on 25 September 2026.