Circular 31/2026/TT-BCT defining traceability of products and goods under management

CIRCULAR

Defining the traceability of products and goods under the management of the Ministry of Industry and Trade

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Pursuant to the Law No. 05/2007/QH12 on Product and Goods Quality, which was amended and supplemented by the Law No. 78/2025/QH15;

Pursuant to the Law No. 19/2023/QH15 on Protection of Consumer Rights, which was amended and supplemented by the Law No. 116/2025/QH15;

Pursuant to the Law No. 20/2023/QH15 on E-Transactions;

Pursuant to the Government’s Decree No. 55/2024/ND-CP detailing a number of articles of the Law on Protection of Consumer Rights;

Pursuant to the Government’s Decree No. 40/2025/ND-CP, defining the functions, tasks, powers and organizational structure of the Ministry of Industry and Trade, which was amended and supplemented by the Decree No. 109/2025/ND-CP and Decree No. 193/2025/ND-CP;

Pursuant to the Government’s Decree No. 37/2026/ND-CP detailing a number of articles, and providing measures to organize and guide the implementation, of the Law on Product and Goods Quality and the Law Amending and Supplementing a Number of Articles of the Law on Product and Goods Quality;

At the proposal of the Director of the Agency for Domestic Market Surveillance and Development;

The Minister of Industry and Trade hereby promulgates Circular defining the traceability of products and goods under the management of the Ministry of Industry and Trade.

Chapter I

GENERAL PROVISIONS

Article 1. Scope of regulation

1. This Circular provides for traceability of high-risk products and goods under the management of the Ministry of Industry and Trade.

2. Products and goods circulated on the market that do not fall within the scope of regulation prescribed in Clause 1 of this Article may voluntarily implement traceability by traders in accordance with this Circular.

Article 2. Subject of application

1. Traders manufacturing, trading in, or importing products and goods falling within the scope of regulation of this Circular.

2. Consumers.

3. State management agencies and relevant organizations and individuals.

Article 3. Interpretation of terms

For the purposes of this Circular, these terms below shall be construed as follows:

1. Goods circulated on the market means products and goods that are placed on the market for the purposes of display, sales promotion, transportation, preservation, storage, purchase and sale, including purchase and sale on digital platforms serving electronic transactions; excluding goods being transported from the border gate to the first storage warehouse and stored at such warehouse in respect of imported goods, as well as exported goods returned from the border gate to the storage warehouse.

2. Product identification code means a unique code number or symbolic code established on the basis of information provided by a trader, associated with a specific product or a group of products, for the purpose of identifying and authenticating product information and serving the administration and operation of the Ministry of Industry and Trade’s goods traceability system.

3. Application Programming Interface (API) means a set of rules and technical standards that enables different software systems to automatically exchange data, ensuring the accuracy, integrity, and security of data during the connection process.

4. The Ministry of Industry and Trade’s goods traceability system means a system comprising activities of identifying a type, batch, or unit of product or goods; collecting, storing, and sharing information on products and goods by time and location for the purpose of managing information on the quality and safety of products and goods, which is developed and operated by the Ministry of Industry and Trade.

Article 4. Principles of application

1. The traceability of products and goods shall be implemented in accordance with the following principles:

a) Mandatory application to products and goods of high risk level under the management of the Ministry of Industry and Trade as prescribed in Clause 1 Article 1 of this Circular.

b) Encouraged application to other products and goods for which traders voluntarily implement traceability.

2. Traders manufacturing, trading in, or importing products and goods as prescribed in Article 1 of this Circular shall choose either to make declarations on the Ministry of Industry and Trade’s goods traceability system or to establish an internal traceability system in accordance with Article 9 of this Circular. The traders’ internal traceability system must be connected to the Ministry of Industry and Trade’s goods traceability system.

3. Compliance with regulations on information confidentiality and cybersecurity shall be ensured during the implementation of product and goods traceability and the connection and sharing of information among parties.

Chapter II

TRACEABILITY OF PRODUCTS AND GOODS

Article 5. Requirements for product identification

1. Upon declaration of product identification, a trader shall be responsible for declaring at least the following information:

a) Name of the enterprise;

b) Enterprise registration certificate or equivalent legal documents;

c) Name and images of products and goods owned by the enterprise;

d) Industrial property protection title of the goods or dossiers and documents proving lawful ownership rights to the goods in accordance with the law regulations on intellectual property (if any);

dd) The enterprise’s digital signature.

2. Product identification shall be carried out in accordance with Clause 1 Article 18 of this Circular.

Article 6. Requirements for traceability of products and goods

1. When declaring traceability of products and goods circulated on the domestic market, a trader shall be responsible for declaring at least the following information:

a) Name of the product or goods;

b) Origin of the product or goods;

c) Images of the product or goods;

d) Name of the manufacturing or trading entity;

dd) Address of the manufacturing or trading entity;

e) Traceability code (if any);

g) Critical tracking events and the time of occurrence of such events in the supply chain in accordance with National Standard TCVN 12850 or the GS1 Global Traceability Standard;

h) Brand, trademark, batch/lot number, or serial number of the product or goods (if any);

i) Expiry date of the product or goods (if any);

k) Applicable national standards, national technical regulations, international standards, regional standards, and manufacturer standards.

2. For imported goods, in addition to the information prescribed in Clause 1 of this Article, a trader shall additionally declare the following information:

a) Name, address, and tax identification number of the importing entity;

b) Information on the official distributor in Vietnam (if any).

3. Products and goods shall be declared for traceability on the trader’s internal traceability system and/or have their information updated on the Ministry of Industry and Trade’s goods traceability system before being placed into circulation on the market.

4. The traceability of products and goods shall be carried out in accordance with Clause 2 Article 18 of this Circular.

Article 7. Consumers’ right to access information

1. Consumers are entitled to search for and access, free of charge, basic information on products and goods through the Ministry of Industry and Trade’s goods traceability system, including:

a) Name of the product or goods;

b) Origin of the product or goods;

c) Images of the product or goods;

d) Name of the manufacturing or trading entity;

dd) Address of the manufacturing or trading entity;

e) Brand, trademark, batch/lot number, or serial number of the product or goods (if any);

g) Expiry date of the product or goods (if any);

2. Consumers have the right to provide feedback on the authenticity of information displayed on the system to the Ministry of Industry and Trade or competent agencies in accordance with the law on protection of consumer rights.

Article 8. Storage of traceability records and data

1. Traceability data must be retained for a minimum period of 12 months for goods with an expiry date, calculated from the date on which such goods expire; and 60 months for goods without an expiry date.

2. Data stored in the trader’s internal traceability system must be connected and shared with the Ministry of Industry and Trade’s goods traceability system, ensuring data integrity, incorporating mechanisms for change control and recording the history of updates, and being available for provision to competent authorities upon request.

3. Traceability records and data must be stored by electronic means, ensuring safety, confidentiality, and data integrity, and must be readily accessible and retrievable upon request by competent state agencies or when traceability is required.

Article 9. Requirements for a trader’s internal traceability system

1. A trader’s internal traceability system must comply with Article 23 of the Government’s Decree No. 37/2026/ND-CP dated January 23, 2026.

2. The trader’s internal traceability system must be capable of connecting to and sharing data with the Ministry of Industry and Trade’s goods traceability system through the Application Programming Interface (API).

3. Requirements for data security and integrity: The internal traceability system must store and transmit data in a manner that ensures security and prevents alteration or distortion; and must incorporate a logging mechanism to facilitate inspection and tracing.

4. Capability to retrieve and provide data: The trader must ensure that the system is capable of retrieving and providing data within 24 hours from the time a request is made by the Ministry of Industry and Trade or a competent state management agency. The method of providing data shall be specified in the written request of the Ministry of Industry and Trade or the competent state management agency.

Chapter III

THE MINISTRY OF INDUSTRY AND TRADE’S GOODS TRACEABILITY SYSTEM

Article 10. The Ministry of Industry and Trade’s goods traceability system

1. The Ministry of Industry and Trade’s goods traceability system is centrally operated at https://verigoods.vn. The system receives, records, stores, and manages traceability data of products and goods updated by traders; and generates codes for the display, retrieval, and linkage of data.

2. Traders shall create their accounts and update information on the System in accordance with the functions, data fields, and technical instructions provided by the System.

3. The Ministry of Industry and Trade shall manage and operate the System; conduct inspections during the operation of the System regarding the completeness and technical conformity of recorded data; and suspend the validity of traceability codes on the System in accordance with Article 11 of this Circular.

4. The Ministry of Industry and Trade’s goods traceability system shall ensure the capability to connect to and share data with the national product and goods traceability portal.

Article 11. Management and use of product identification codes and traceability codes

1. Traders shall be responsible for managing and using codes for their intended purposes and affixing such codes to data carriers in accordance with Article 12 of this Circular.

2. Upon detecting signs of violations, risks of unsafe conditions, or upon receipt of a written request from a competent state agency, the Ministry of Industry and Trade shall conduct a review of information on the System.

In case signs of violations arise from feedback provided by organizations or individuals, the Ministry of Industry and Trade shall notify the information to the related trader so that the trader provides explanation and clarification within 24 hours, except where it is necessary to immediately apply a measure to suspend the display of traceability information in order to prevent risks, protect consumers’ rights and interests, or at the request of a competent agency.

The suspension of the display of traceability information shall be carried out on the Ministry of Industry and Trade’s goods traceability system and shall be restored upon the issuance of a conclusion by a competent agency.

3. The Ministry of Industry and Trade shall revoke the confirmation of the display of traceability information on the System in the following cases:

a) The trader provides inaccurate or untruthful traceability information or commits acts that distort the nature of information relating to products or goods;

b) Failure to maintain or fully and continuously update traceability data in accordance with this Circular;

c) There is a conclusion of a competent state agency regarding violations of law relating to products or goods associated with the traceability information;

d) The trader fails to implement or incompletely implements remedial measures within the time limit notified by the Ministry of Industry and Trade.

Article 12. Provisions on data carriers

1. Product identification codes and traceability codes shall be printed on or affixed to traceability data carriers and directly displayed on goods or goods packaging through sticking, printing, pinning, casting, embossing, engraving, or other appropriate forms.

2. The use of data carriers must comply with National Standard TCVN 13275:2020 Traceability – The format of data carriers.

3. Traders may choose the form of presentation of data carriers appropriate to the characteristics of the goods, provided that the ability to identify and retrieve traceability information is ensured.

Chapter IV

ORGANIZATION OF IMPLEMENTATION

Article 13. Responsibilities of traders subject to product and goods traceability requirements

1. Traders may choose one of the following methods for implementing product and goods traceability:

a) Establishing and operating an internal traceability system, ensuring compliance with the prescribed requirements, and connecting to and sharing data with the Ministry of Industry and Trade’s goods traceability system;

b) Updating and declaring product and goods traceability information on the Ministry of Industry and Trade’s goods traceability system in accordance with the technical instructions provided by the System.

2. Establish and maintain and operate an internal traceability system for products and goods manufactured, traded in, or imported by the traders, ensuring compliance with the requirements prescribed in Article 9 of this Circular.

3. Declare and update information on the Ministry of Industry and Trade’s goods traceability system; ensure two-way connection and data sharing with the Ministry of Industry and Trade’s goods traceability system.

4. Take responsibility before law for the product and goods traceability information prescribed in this Circular.

5. Be subject to inspection and supervision by competent state agencies in charge of product and goods traceability in accordance with law regulations.

6. Responsibilities for implementing traceability by category of subjects:

a) For traders subject to mandatory application as prescribed at Point a Clause 1 Article 4 of this Circular: Traders shall implement traceability before placing products and goods into circulation on the market.

b) For traders implementing traceability on a voluntary basis: Traders are encouraged to fully implement traceability in accordance with this Circular.

7. Print or affix traceability codes to data carriers and display them on products and product packaging in accordance with Article 12 of this Circular.

8. Ensure the accuracy, completeness, and integrity of traceability data; take responsibility before law for all declared information and for the use of traceability codes.

9. Be responsible for requiring and ensuring compliance with the law regulations on information security and safety when using technological solution services provided by third parties; ensure the collection, storage, and transmission of traceability data in accordance with agreements and the technical requirements of the System.

10. Coordinate with state management agencies in the inspection and verification of product and goods information and relevant information upon request.

11. Traders shall perform other responsibilities relating to product and goods traceability in accordance with Decree No. 37/2026/ND-CP and relevant law regulations.

Article 14. Policies encouraging the application of product and goods traceability

1. Traders implementing product and goods traceability on a voluntary basis in accordance with this Circular shall be entitled to the following incentive policies:

a) To be granted a green check mark indicating the voluntary application of traceability, and to use such green check mark on products, product packaging, product introduction materials, and e-commerce platforms during the validity period of the green check mark.

The green check mark shall be displayed in association with traceability information; it shall not replace quality certifications, certificates of standard conformity, certificates of regulation conformity, or certifications of products and goods as prescribed by law regulations; the green check mark shall not be displayed in case the traceability information does not satisfy the prescribed requirements.

b) To be given priority in receiving technical support and guidance relating to connection with the Ministry of Industry and Trade’s goods traceability system.

c) To be promoted and publicized regarding the application of traceability through mass media or in activities introducing and promoting products and goods organized by the Ministry of Industry and Trade.

2. The Ministry of Industry and Trade shall develop and implement a program to support traders in carrying out product and goods traceability.

Article 15. Responsibilities of units under the Ministry of Industry and Trade

1. The Agency for Domestic Market Surveillance and Development

a) Organize the provision of guidance on, implementation of, and inspection of the implementation of this Circular;

b) Assume the prime responsibility for developing, managing, operating, and improving the Ministry of Industry and Trade’s goods traceability system, ensuring data connectivity and synchronization with the national product and goods traceability portal;

c) Organize the provision of guidance and support to traders and relevant units in the use of the Ministry of Industry and Trade’s goods traceability system;

d) Organize communication and dissemination of law regulations and raise awareness among manufacturing and trading organizations and individuals and consumers regarding product and goods traceability;

dd) Consolidate and assess the implementation of product and goods traceability activities falling within the scope of regulation of this Circular;

e) Assume the prime responsibility for, and coordinate with relevant units in, conducting inspection, supervision, and handling violations relating to product and goods traceability in accordance with law regulations;

g) Assume the prime responsibility for and organize the research and propose the formulation and implementation of programs, schemes, and tasks relating to product and goods traceability serving state management activities within the industry and trade sector.

2. Units under the Ministry

a) Coordinate with the Agency for Domestic Market Surveillance and Development in providing guidance on and organizing the implementation of regulations on goods traceability for products and goods under the management of the Ministry of Industry and Trade;

b) Coordinate with the Agency for Domestic Market Surveillance and Development in organizing the inspection and supervision of compliance with regulations on traceability, and in detecting and handling, or proposing the handling of, violations in accordance with law regulations.

Article 16. Responsibilities of People's Committees of provinces and centrally-run cities

1. Organize the implementation of this Circular and relevant guiding documents within their localities.

2. Provide guidance on, communicate, and disseminate law regulations to manufacturing and trading organizations and individuals in their localities regarding goods traceability. Provide support in supplying information and guiding enterprises during the implementation of product and goods traceability (if any).

3. Direct competent forces within their localities to inspect, supervise, and handle violations relating to goods traceability in accordance with law regulations.

CHAPTER V

IMPLEMENTATION PROVISIONS

Article 17. Transitional provision

Traders that have established and operated traceability systems before the effective date of this Circular may continue to apply such systems. Before January 01, 2027, traders shall review, update, and supplement requirements concerning product identification, data structures, and connectivity to ensure that their systems are compatible with the Ministry of Industry and Trade’s goods traceability system.

Article 18. Roadmap for application

1. Phase 1: Product identification

From the effective date of this Circular, traders shall register their accounts, obtain product identification codes, and authenticate product information.

2. Phase 2: Traceability of products and goods

From January 01, 2027, traders shall fully implement traceability before placing products and goods into circulation on the market.

3. Traders established or commencing their manufacturing or trading activities after January 01, 2027 must fully comply with the traceability requirements prescribed in this Circular immediately upon commencement of operations.

Article 19. Effect

1. This Circular takes effect on July 01, 2026.

2. During the implementation, in case legal normative documents mentioned herein are amended, supplemented or replaced, these amending, supplementing or replacing documents shall apply./.