HANOI DEPARTMENT OF JUSTICE
TLK LAW FIRM

The Minister of Industry and Trade has recently issued Circular No. 11/2026/TT-BCT regulating food traceability under the management of the Ministry of Industry and Trade.

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Regarding the application principles, food traceability shall be implemented in accordance with the 'one step forward, one step back' principle. Following each stage, food traceability information must be encoded and identified using an appropriate method to facilitate the traceability process.

Information serving food traceability must be continuously established, and all relevant data must be fully stored as a database throughout the production and trading processes at food establishments. Food production and trading establishments shall utilize information extracted from their existing databases, established in accordance with the provisions in (*) below, along with other relevant information sources when conducting traceability activities.

The food databases of production and trading establishments shall be connected to the Food Traceability System of the Ministry of Industry and Trade.

Image 1. Food Traceability Information Effective April 16, 2026_Hotline: 0972118764 

Food Traceability Information 

According to the Circular, food production and trading establishments must establish and fully store relevant information, ensuring readiness to provide the following minimum information and documents regarding their production and trading activities:

a) Name, address, contact information, and enterprise identification number of the food production and trading establishment;

b) Business Registration Certificate, Enterprise Registration Certificate, or other certificates in accordance with the law on business registration;

c) Certificate of Establishment Meeting Food Safety Conditions for cases subject to the issuance of such a certificate.

The Circular specifies that food production establishments must establish and fully store relevant information, ensuring readiness to provide the following minimum information and documents regarding the food:

a1) Product name and image;

b1) Brand, trademark, reference code, and product serial number (if any);

c1) Identification code and food traceability code (if any);

d1) Information on packaging specifications, packaging materials, and food ingredients;

đ1) Shelf life of the product for foods subject to mandatory expiration date labeling;

e1) Applied national standards, national technical regulations, international standards, regional standards, and in-house standards;

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Image 2. Food Traceability Information Effective April 16, 2026_Hotline: 0972118764

g1) Declaration of conformity accompanied by the Conformity certification result for foods subject to technical regulations on quality and safety indicators; or Declaration of standards accompanied by the Product testing result sheet issued by a Testing laboratory accredited to ISO/IEC 17025 for foods not subject to technical regulations on quality and safety indicators, or where no organization is available to conduct certification of conformity with the corresponding national technical regulations in accordance with the law on standards and technical regulations, or where no conformity assessment method is available (if any);

h1) Information on the weight, quantity, and code of the product lot/batch;

i1) Location and time of the traceability event conducted by the production establishment;

k1) Name, address, contact information, and enterprise identification number of customers, agents, distributors, transporters, preservers, warehousing units, and suppliers of raw materials/semi-finished products (if any);

l1) Information on the lot/batch of raw materials and semi-finished products (name, weight, quantity, delivery and receipt time, shelf life, packaging materials, additives); testing results of the lot/batch of raw materials/semi-finished products conducted by the supplier of raw materials/semi-finished products, the production establishment, or the testing laboratory (if any);

m1) Testing results of the finished food product lot/batch conducted by the production establishment or the testing laboratory (if any).

Food trading establishments must organize the receipt of information and documents from food production establishments and continuously establish and fully store relevant information. They must ensure readiness to provide the minimum information and documents regarding food products as stipulated in points a1, b1, c1, d1, đ1, e1, and g1 above, and supplement information on the location and time of the traceability event conducted by the food trading establishment.

For imported food products, in addition to the information stipulated in points a1, b1, c1, d1, đ1, e1, and g1 above, food trading establishments must continuously establish and fully store relevant information, ensuring readiness to provide the following supplementary information:

a2) Name, address, and contact information of the manufacturer/exporter;

b2) Name, address, contact information, and enterprise identification number of the importer;

c2) Certificate of Origin (C/O) or testing results from the country of origin;

d2) Information on the weight, quantity, and code of the imported consignment.

For exported food, food production and trading establishments shall implement food traceability in accordance with the regulations of the importing country; foods that are both exported and circulated domestically must comply with the provisions of this Circular when consumed in the Vietnamese market.

Food production and trading establishments shall establish and store databases at their premises to synthesize the prescribed information and documents in the form of electronic document forms and other necessary related data formats in accordance with regulations, in order to provide and update product information on the Traceability System.

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Regarding the food traceability activities of food production and trading establishments, food production establishments shall conduct food traceability immediately upon self-monitoring and discovering unsafe food or legal violations, or upon the request of competent state authorities, following these steps:

Based on initial information (product name, lot code, date of manufacture), accurately identify the relevant information of the food product lot subject to traceability.

Review the production records and testing records of the food product lot to determine the cause.

Immediately contact the supplier(s) of raw materials/semi-finished products and packaging for the food product lot to request relevant information.

Send urgent notifications to distributors and agents who have received the food product lot, requesting reports on the quantity sold and the quantity in stock to carry out a voluntary product recall.

Analyze and determine the cause of the safety hazard for the food product lot subject to traceability.

Prepare a report on the results of the food traceability implementation, clearly stating the results of the recall and handling of the food product; the causes, and the results of applying corrective measures in accordance with the Form in Appendix 1 issued together with this Circular, and submit it to the competent authority as prescribed by law.

Food trading establishments are responsible for sending urgent notifications to food production establishments immediately upon self-monitoring and discovering unsafe food or legal violations, or upon the request of competent state authorities; and must coordinate closely with food production establishments to conduct food traceability as stipulated above.

Supervision, inspection, and handling activities of competent state authorities

During the process of inspection, supervision, and handling by competent state authorities, if food violating legal regulations on food safety is detected, the competent state authority shall send a written notice requiring the food production and trading establishments to conduct food traceability as stipulated above, and post a warning regarding the food concluded to be in violation of food safety laws on the Traceability Information Portal.

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