Circular 27/2026/TT-BYT: Ministry of Health lists medium-risk foods and food-contact materials
The Ministry of Health places eight product groups at medium risk: infant and young-child formula products, plastic and rubber food-contact materials, bottled water and ready-to-use ice. The Circular took effect on 1 July 2026.
On 1 July 2026, the Ministry of Health issued Circular 27/2026/TT-BYT. It lists the foods, food containers and packaging materials in direct contact with food that the Ministry classifies as medium risk under its management. The list has eight product groups. For each group it gives the applicable national technical regulation (QCVN), the basis for HS-code identification and the matching management requirement: registration of a product declaration, or product self-declaration, under Decree 15/2018/ND-CP. The Circular took effect on the day it was signed and was published in Official Gazette No. 420 on 20 July 2026.
The document and its issuer
The Circular was signed by Deputy Minister Do Xuan Tuyen on behalf of the Minister of Health, at the proposal of the Director of the Vietnam Food Administration. Its legal bases are:
- Law on Food Safety No. 55/2010/QH12;
- Law on Product and Goods Quality No. 05/2007/QH12, as amended by Law No. 78/2025/QH15;
- Decree 37/2026/ND-CP, which details the Law on Product and Goods Quality;
- Decree 15/2018/ND-CP, which details the Law on Food Safety;
- Decree 42/2025/ND-CP on the functions and organisation of the Ministry of Health.
What the list covers
The Annex (issued under Article 1) splits the eight product groups between two management requirements:
Registration of a product declaration (Article 6, Decree 15/2018/ND-CP):
- Formula nutrition products for infants up to 12 months (QCVN 11-1:2012/BYT);
- Formula nutrition products for special medical purposes for infants up to 12 months (QCVN 11-2:2012/BYT);
- Formula nutrition products for complementary feeding of children aged 6 to 36 months (QCVN 11-3:2012/BYT);
- Processed cereal-based nutrition products for children aged 6 to 36 months (QCVN 11-4:2012/BYT).
Product self-declaration (Article 4, Decree 15/2018/ND-CP):
- Synthetic plastic food containers and packaging in direct contact with food (QCVN 12-1:2011/BYT);
- Rubber food containers and packaging in direct contact with food (QCVN 12-2:2011/BYT);
- Bottled drinking water (QCVN 6-1:2010/BYT);
- Ready-to-use ice (QCVN 10:2011/BYT).
For the infant formula group, the Annex also applies other management measures under the Law on Food Safety and its implementing documents, on top of declaration registration.
The HS-code column gives no specific codes. It refers to Circular 15/2024/TT-BYT (the Ministry of Health's list of imported foods subject to state food-safety inspection) and Circular 31/2022/TT-BTC of the Ministry of Finance (Vietnam's export and import goods nomenclature). See the signed PDF for the full table.
What changes and for whom
The Circular formally places these eight groups in the medium-risk category. It affects manufacturers, importers and traders of the listed products. Note that both management requirements in the Annex (declaration registration and self-declaration) point to existing provisions of Decree 15/2018/ND-CP. The Circular does not say how this differs from the previous approach. It also does not explain any legal effect of the medium-risk classification beyond the requirements in the Annex.
Under Article 2, if any referenced legal document is amended, supplemented, replaced or newly issued, the new version applies.
Implementation responsibilities
Under Article 3:
- The Vietnam Food Administration organises, guides and inspects implementation. It also continues to review and propose updates to the lists of medium-risk and high-risk products (clause 1);
- Provincial and city People's Committees implement the Circular locally and direct their specialised agencies to manage and inspect the listed products (clause 2).
The Circular mentions a high-risk list but does not issue one. It also does not say whether such a list already exists.
Effective date and transitional provisions
The Circular took effect on 1 July 2026 (Article 4), the same day it was signed. It was published in the Official Gazette on 20 July 2026. It contains no transitional provisions and does not address products declared or on the market before that date.
What affected companies should do
- Check whether your products fall into any of the eight Annex groups, against the relevant QCVN;
- Infant and young-child formula products: confirm a product declaration has been registered under Article 6 of Decree 15/2018/ND-CP;
- Plastic and rubber food-contact materials, bottled water and ready-to-use ice: confirm a self-declaration has been made under Article 4 of Decree 15/2018/ND-CP;
- Importers: check HS-code classification against Circular 15/2024/TT-BYT and Circular 31/2022/TT-BTC;
- Prepare for inspections by provincial specialised agencies;
- Report any difficulties to the Ministry of Health through the Vietnam Food Administration (Article 4), and watch for updates to the list.
