Circular 11/2026/TT-BCT on traceability of food under Ministry of Industry and Trade's management

CIRCULAR

On traceability of food under the Ministry of Industry and Trade's management

Pursuant to the Law on Food Safety No. 55/2010/QH12, amended and supplemented under the Law Amending and Supplementing a Number of Articles of Eleven Laws Related to the Planning Law No. 28/2018/QH14;

Law on Protection of Consumer Rights No. 19/2023/QH15;

Pursuant to the Law on Organization of the Government No. 63/2025/QH15;

Pursuant to the Government’s Decree No. 46/2026/ND-CP detailing a number of articles of, and providing measures for organizing and guiding the implementation of, the Law on Food Safety;

Pursuant to the Government's Resolution No. 66.13/2026/NQ-CP on announcement and registration of food products;

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. 15/2018/ND-CP detailing a number of articles of the Law on Food Safety;

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, amended and supplemented under Decree No. 109/2025/ND-CP and Decree No. 193/2025/ND-CP;

Pursuant to the Government's Resolution No. 09/2026/NQ-CP on suspension of effect and adjustment of the effective date of the Government’s Decree No. 46/2026/ND-CP dated January 26, 2026, detailing the implementation of a number of articles of, and providing measures for organizing and guiding the implementation of, the Law on Food Safety, and the Government’s Resolution No. 66.13/2026/NQ-CP dated January 27, 2026, on announcement and registration of food products;

At the proposal of the Director of the Industry Agency;

The Minister of Industry and Trade hereby promulgates the Circular on traceability of food under the Ministry of Industry and Trade's management.

Chapter I

GENERAL PROVISIONS

Article 1. Scope of regulation

This Circular provides for food traceability activities, food traceability system, and responsibilities of relevant organizations and individuals in the implementation of food traceability for foods under the scope of state management of the Ministry of Industry and Trade as prescribed in Appendix IV to Decree No. 46/2026/ND-CP.

Article 2. Subjects of application

1. This Circular applies to organizations and individuals engaged in food production and trading activities (hereinafter referred to as establishments) under the scope of state management of the Ministry of Industry and Trade in Vietnam, and other relevant organizations and individuals.

2. This Circular does not apply to:

a) Foods falling within the cases exempted from state inspection of food safety for certain imported foods (except for cases where there are food safety warnings) as prescribed in Article 19 of Decree No. 46/2026/ND-CP.

b) Foods produced or processed by households or individuals for consumption and not traded on the market.

Article 3. Interpretation of terms

In this Circular, the terms below are construed as follows:

1. Food traceability means the ability to trace the formation and circulation process of food.

2. Food product identification code means a sequence of digits or alphanumeric characters used to indicate that a food production or import establishment has completed the provision of initial information of the food product on the food traceability portal of the Ministry of Industry and Trade (hereinafter referred to as the traceability portal).

3. Food traceability code means the final identification code at each stage of the traceability process (comprising a continuous sequence of digits or alphanumeric characters constituted from the food product identification code, location code, time of occurrence of the event, batch/lot number or serial number), encoded in a data carrier, displaying public and transparent information on the food product in the market and providing information for traceability.

4. Traceability event means an activity that changes the status or characteristics of a product, the storage or preservation location of the product, or the ownership of the product during the course of food production and trading.

5. “One step forward - one step back” principle means a traceability principle under which an establishment must retain information to ensure the ability to monitor and identify the preceding stage and the subsequent stage in the production and trading process of a food product subject to traceability.

Article 4. Principles of application

1. Food traceability activities shall be carried out in accordance with the “one step forward - one step back” principle. Traceability information after each stage must be encoded and identified by an appropriate method in order to serve food traceability.

2. Information serving food traceability must be regularly established and stored in full as a database of relevant information during the production and trading process at food production and trading establishments. Food production and trading establishments shall use information extracted from the existing database established by the establishment in accordance with Article 5 of this Circular and other relevant information sources when conducting food traceability activities.

3. The connection of food databases of food production and trading establishments to the food traceability system of the Ministry of Industry and Trade (hereinafter referred to as the traceability system) shall be implemented in accordance with the roadmap prescribed in Article 15 of this Circular.

Chapter II

FOOD TRACEABILITY ACTIVITIES

Article 5. Food traceability information

1. Food production and trading establishments shall establish and maintain relevant sufficient information, ensuring readiness to provide at least the following information and documents regarding production and trading activities:

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

b) Business registration certificate or enterprise registration certificate or other certificates in accordance with the law on business registration;

c) Certificate of food safety eligibility, in cases subject to the issuance of a certificate of food safety eligibility.

2. Food production establishments shall establish and maintain complete records of relevant information, ensuring readiness to provide at least the following information and documents concerning food products:

a) Product name and image;

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

c) Food product identification code and food traceability code (if any);

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

dd) Shelf life of the product for foods required to indicate a shelf life;

e) Applied national standards, national technical regulations, international standards, regional standards, or manufacturer standards;

g) Declaration of conformity accompanied by the result of conformity certification for foods subject to technical regulations on quality indicators and safety indicators; or a declaration of standards accompanied by a product test result sheet issued by a testing organization accredited in accordance with ISO/IEC 17025 for foods without technical regulations on quality indicators and safety indicators, or for which no organization conducts certification of conformity with the corresponding national technical regulation in accordance with the law on standards and technical regulations, or where no conformity assessment method is available (if any);

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

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

k) Name, address, contact information, and enterprise code of customers, agents, distributors, transportation units, storage or warehousing units, and suppliers of raw materials/semi-finished products (if any);

l) Information on raw material or semi-finished product batches/lots (name, weight, quantity, delivery time, shelf life, packaging materials, additives); and test results of raw material/semi-finished product batches/lots conducted by the raw material/semi-finished product supplier, the production establishment, or a testing establishment (if any);

m) Test results of finished food product batches/lots conducted by the production establishment or a testing establishment (if any).

3. Food trading establishments shall organize the receipt of information and documents from food production establishments and regularly establish and maintain relevant sufficient information, ensuring readiness to provide at least the following information and documents concerning food products as prescribed at Points a, b, c, d, dd, e, and g Clause 2 of this Article, and shall additionally include information on the location and time of traceability events conducted by the food trading establishment.

4. For imported food products, in addition to the information prescribed at Points a, b, c, d, dd, e, and g Clause 2 of this Article, food trading establishments shall regularly establish and maintain relevant sufficient information and ensure readiness to provide the following additional information:

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

b) Name, address, contact information, and enterprise code of the importer;

c) Certificate of origin (C/O) or test results issued in the country of origin;

d) Information on the weight, quantity, and code of the import batch.

5. For exported foods, food production and trading establishments shall conduct food traceability in accordance with the regulations of the importing country. Foods that are both exported and circulated domestically shall, when distributed in the Vietnam market, comply with the provisions of this Circular.

6. Food production and trading establishments shall establish and maintain a database at the establishment to consolidate the information and documents prescribed in this Article in the form of electronic document templates and other necessary related data formats as prescribed, in order to provide and update product information on the traceability system.

Article 6. Retention of traceability records and data

1. The minimum retention period for dossiers and data related to food traceability shall be 12 months from the expiry date of the product for foods with a shelf life, and 60 months from the date of production for foods not required to indicate a shelf life.

2. Food production and trading establishments shall ensure the ability to provide dossiers and documents related to food traceability within 24 hours from the time a competent agency makes a request.

Article 7. Food traceability activities of food production and trading establishments

1. A food production establishment shall conduct food traceability immediately upon self-monitoring and detecting that food fails to ensure safety or violates the provisions of law, or upon request of a competent state agency, in accordance with the following steps:

a) Based on initial information (product name, batch code, production date), accurately identify the relevant information of the food product batch subject to traceability;

b) Review the production dossiers and testing dossiers of the food product batch in order to determine the cause;

c) Immediately contact the supplier(s) of raw materials/semi-finished products, and packaging of the food product batch to request relevant information;

d) Send an urgent notification to distributors and agents that have received the food product batch, requesting reports on quantities sold and quantities remaining in inventory in order to carry out voluntary product recall;

dd) Analyze and determine the cause of the unsafety of the food product batch subject to traceability;

e) Prepare a report on the results of the food traceability process, clearly stating the results of product recall and handling; the causes; and the results of the application of remedial measures in accordance with the Form provided in Appendix I to this Circular, and submit such report to the competent agency in accordance with the law.

2. A food trading establishment shall be responsible for sending an urgent notification to the food production establishment immediately upon self-monitoring and detecting that food fails to ensure safety or violates the provisions of law, or upon request of a competent state agency; and - Coordinating agencyshall closely coordinate with the food production establishment to conduct food traceability in accordance with Clause 1 of this Article.

Article 8. Supervision, inspection, and handling activities of competent state agencies

During the course of inspection, supervision, and handling by competent state agencies, where food is detected to be in violation of the provisions of the law on food safety, the competent state agency shall send a written notice requesting the food production or trading establishment to conduct food traceability in accordance with Article 7 of this Circular and issue a warning regarding food determined to be in violation of the provisions of the law on food safety on the traceability portal.

Article 9. Food traceability activities of consumers and other organizations and individuals

1. Consumers and other organizations and individuals may search for and access, free of charge, basic information on food through the traceability portal or mobile applications serving food traceability activities, including:

a) Product name and image;

b) Origin of the product according to the information recorded or disclosed by the establishment;

c) Name, address, contact information, and enterprise code of the production or trading establishment;

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

dd) Shelf life of the product (if any);

e) Applied national standards, national technical regulations, international standards, regional standards, or manufacturer standards.

2. Where food showing signs of failing to ensure food safety is detected, consumers and other organizations and individuals may report such information via the traceability portal or submit written reports to the Ministry of Industry and Trade or to a competent state agency in accordance with the of law for timely verification and handling.

3. After a competent state agency issues a conclusion that food fails to ensure food safety, such information shall be disclosed on the traceability portal.

Chapter III

FOOD TRACEABILITY SYSTEM

Article 10. Traceability system

1. The traceability system is an information technology system developed, managed, and operated by the Ministry of Industry and Trade for the purpose of collecting, storing, processing, and providing information serving food traceability, comprising:

a) The traceability portal, which serves as the single centralized access point integrating information and services from multiple sources and displaying them in a unified manner to support the Ministry of Industry and Trade’s food traceability activities;

b) Professional and operational applications for receiving, storing, and processing food data provided by food production and trading establishments, and for serving the requirements of data transmission and receipt for shared use with relevant ministries and sectors in the state management of food safety;

c) Applications for the aggregation, analysis, and evaluation of classified and processed data sources for forecasting, policy formulation, and sectoral management and development of the Ministry of Industry and Trade;

d) Applications serving food traceability activities on mobile devices.

2. The development, management, operation, and utilization of the traceability system shall comply with the law on the management, connection, and sharing of digital data used in common by state agencies; data protection and information security; cybersecurity; prevention of information misuse; protection of personal data and trade secrets; and other relevant laws.

Article 11. General technical requirements of the traceability system

1. The provision and updating of food traceability information on the traceability system shall be carried out through electronic forms and electronic documents.

2. The traceability system shall operate on the basis of technical specifications regarding data structure, data format, data packets, connection, and shared data exchange established and promulgated by the Ministry of Industry and Trade.

3. The traceability system shall strictly comply with regulations and technical standards on data backup, redundancy, and recovery mechanisms in order to ensure stable and continuous system operation.

4. The traceability system shall ensure data management, access authorization, and data exploitation based on the roles of each level and subject, specifically as follows:

a) The central level, including the Ministry of Industry and Trade and its affiliated units with assigned functions and duties, may access, exploit, and manage the entire system and assign authorization to other subjects within their competence;

b) The local level, including People’s Committees at all levels and their affiliated units with assigned functions and duties, may access data generated within their respective localities and exploit reports serving management activities;

c) Food production and trading establishments may provide, update, manage, and exploit data relating to food products in their traceability events;

d) Consumers and other organizations and individuals may access, free of charge, basic information on food through the traceability portal or traceability applications in accordance with Clause 1 Article 9 of this Circular.

5. The traceability system shall ensure the capability for integration and expansion and shall be ready for connection and data sharing in accordance with Article 14 of this Circular.

Article 12. Food traceability code

1. Food production and import establishments shall provide basic information in accordance with Clause 1 and Points a, b, c, d, dd, e, and g Clause 2 Article 5 of this Circular on the traceability portal.

2. Food production and trading establishments shall fully update new information related to traceability events in accordance with Article 5 of this Circular on the traceability system within a maximum of 24 hours from the occurrence of the traceability event.

3. After each traceability event, new information on the food product shall be updated and encoded into the food traceability code through the professional and operational applications of the traceability system.

4. The food traceability code shall not replace product or goods labels as prescribed by law and must satisfy the following requirements:

a) Ensuring data integrity, verifiability, and independent traceability in accordance with the technical requirements of the database. The food traceability code must conform to national standards, national technical regulations, and technical requirements for data transmission and receipt prescribed by competent state agencies;

b) The use of the food traceability code must ensure the capability for identification, connection, and synchronization with the data systems of food trading establishments and the traceability system;

c) The use of the food traceability code must ensure security and prevent forgery, duplication, or misuse.

5. The Minister of Industry and Trade shall promulgate a list of food products to which appropriate traceability methods are applied according to the characteristics of each group or type of product.

Article 13. Data carriers containing food traceability codes

1. Data carriers containing food traceability codes are means used to encode information or encode links to food product data (including barcodes, QR codes, Datamatrix, RFID, NFC, and other appropriate methods). The Ministry of Industry and Trade shall assume the prime responsibility for, and coordinate with relevant ministries and sectors in, designing and issuing standardized templates for data carriers in accordance with the law on data carriers.

2. Data carriers containing food traceability codes shall be affixed, printed, attached, molded, engraved, or otherwise appropriately applied directly on food products, on/within the commercial packaging of food products, or on other materials attached to food products, ensuring that the encoded data can be read by devices.

3. Food production and trading establishments shall decide on the use of data carriers containing food traceability codes that have been connected and activated with the traceability system. Food production and trading establishments are encouraged to use advanced data carriers (such as RFID, NFC, etc.) to enhance the transparency and effectiveness of the traceability system.

4. Enterprises producing data carriers shall ensure the supply of data carriers in accordance with the templates designed and issued by the Ministry of Industry and Trade and shall regularly and continuously report the quantity of data carriers supplied to food production and trading establishments on the traceability portal.

5. Data carriers containing food traceability codes must be confirmed and activated by the traceability system in order to ensure that information is accurately and fully displayed on reading devices or traceability applications when consumers or other organizations and individuals scan the food traceability code to access the information prescribed in Clause 1 Article 9 of this Circular.

6. Food production and trading establishments shall use data carriers in accordance with the roadmap prescribed in Article 15 of this Circular.

Article 14. Intersectoral data connection and sharing

1. The traceability system shall be designed to connect, share, and interoperate data with domestic and international database systems, the national platform for identification, authentication, and traceability of products and goods, and food safety management systems of localities and ministries, including the Ministry of Public Security, the Ministry of Health, the Ministry of Agriculture and Environment, and other relevant ministries and sectors, ensuring synchronization, consistency, and avoidance of duplication.

2. Intersectoral data connection and sharing shall be implemented on the following principles:

a) Two-way data synchronization, whereby the traceability system provides data serving sectoral management while also receiving necessary data from the Ministry of Industry and Trade and other relevant ministries, sectors, and agencies;

b) Compliance with the laws on information security, cybersecurity, data confidentiality, and management competence by sector, field, and locality;

c) Data that have been declared shall be used multiple times for different state management purposes on the principle of “declare once, use multiple times”.

3. Intersectoral data connection and sharing shall be implemented on the basis of the provisions of law, coordination agreements, and technical capabilities of relevant parties, ensuring effective service to state management activities.

Article 15. Roadmap for connecting information to the traceability system

The connection and provision of food traceability information by food production and trading establishments to the traceability system shall be implemented in accordance with the following roadmap:

1. Food production establishments shall connect and provide information to the traceability system from December 1, 2026, except for small-scale food production and trading establishments.

2. Food import establishments shall connect and provide information to the traceability system from March 1, 2027, except for small-scale food trading establishments.

3. Other food production and trading establishments are encouraged to connect and provide information to the traceability system.

Article 16. Support for food traceability

Food production and trading establishments connecting to and sharing data and providing food traceability information on the traceability system shall receive the following support:

1. Technological solution support:

a) Technical assistance and guidance on connecting data to the traceability system for food production and trading establishments that have developed and operated their own traceability systems from October 1, 2026;

b) Support for integrated solutions on e-invoice issuance, invoice transmission and receipt, and tax finalization for food production and trading establishments upon request.

2. Training and advisory support:

a) Training and guidance on regulations and the use of the traceability system for food production and trading establishments;

b) Establishment and maintenance of regular advisory and technical support channels (hotlines, online support groups, and local support points) to provide guidance and resolve technical issues for food production and trading establishments during implementation.

3. Communication and promotion support:

a) Priority consideration for food production and trading establishments that comply well with regulations on food traceability and data connection in the approval for participation in industrial promotion programs and other quality certification programs of the state and local authorities;

b) Priority support for communication and promotion of the application of food traceability through mass media and on the portal of the Ministry of Industry and Trade.

Article 17. Fundings for implementation

1. Fundings for the research, development, and operation of the traceability system include:

a) State budget funds allocated for science and technology, information technology application, and digital transformation;

b) Socialized resources in accordance with the Political Bureau's Resolution No. 57-NQ/TW dated December 22, 2024, on breakthroughs in the development of science and technology, innovation, and national digital transformation; and the Political Bureau's Resolution No. 68-NQ/TW dated May 4, 2025, on the development of the private sector economy;

c) Other lawful sources as prescribed by law.

2. The Ministry of Industry and Trade shall act as the project owner responsible for the research, development, and operation of the traceability system as prescribed in Clause 1 Article 10 of this Circular, including the technical infrastructure.

Chapter IV

RESPONSIBILITIES OF AGENCIES, ORGANIZATIONS AND INDIVIDUALS

Article 18. Responsibilities of food production and trading establishments

1. To ensure sufficient resources (including personnel, financial resources, technology, etc.) to effectively carry out food traceability activities. To comply with the roadmap on food traceability promulgated by the Ministry of Industry and Trade.

2. To establish and maintain food databases serving food traceability, and to store and update complete information on food products, their origin, raw materials, and production, processing, and trading processes in accordance with Article 5 of this Circular.

3. To be responsible before law for the timeliness, legality, truthfulness, and accuracy of data provided to the traceability portal; and to coordinate with the Ministry of Industry and Trade (the Industry Agency) and relevant units in implementing and maintaining data on the traceability system.

4. To provide necessary, complete, valid, and timely records and documents to state management agencies upon request. To strictly comply with traceability requirements and decisions on product recall and handling issued by competent state agencies and to bear all costs related to such activities.

5. To use data carriers containing food traceability codes that have been issued for affixing/integrating onto products or product packaging to serve food traceability activities.

Article 19. Responsibilities of units under the Ministry of Industry and Trade

1. The Industry Agency:

a) To advise on the formulation and amendment of legal documents on food traceability within the scope of state management of the Ministry of Industry and Trade;

b) To assume the prime responsibility for, and coordinate with relevant units in, developing the traceability system and managing, operating, and exploiting the traceability system database;

c) To assume the prime responsibility for, and coordinate with relevant units in, organizing the application, providing guidance, disseminating information, conducting training and capacity-building, and implementing activities related to food traceability as prescribed in this Circular;

d) To consolidate and report on the implementation status and results, as well as difficulties and obstacles (if any) arising during the implementation of this Circular.

2. Units under the Ministry of Industry and Trade shall, within the ambit of assigned functions, duties, and management responsibilities, coordinate with the Industry Agency in implementing this Circular.

Article 20. Responsibilities of provincial-level People’s Committees

1. To organize the implementation of this Circular and relevant guiding documents within their respective localities; to coordinate with the Ministry of Industry and Trade (the Industry Agency) and relevant units in providing guidance on application, dissemination, training, capacity-building, and the implementation of activities related to food traceability within the locality; to support food production and trading establishments and other relevant organizations and individuals in implementing food traceability within the locality.

2. Annually before December 25, or upon request, provincial-level People’s Committees shall consolidate and report on the status and results of inspection and supervision of compliance with regulations on traceability, recall, and handling of food failing to ensure safety by food production and trading establishments; difficulties, obstacles, and recommendations or proposals (if any) arising during the implementation of this Circular, using the Form provided in Appendix II to this Circular, and submit such report to the Ministry of Industry and Trade (the Industry Agency shall act as the focal point).

Chapter V

IMPLEMENTATION ORGANIZATION

Article 21. Transitional provisions

1. Food production and trading establishments that have developed and operated traceability systems before the effective date of this Circular may continue to apply such systems and shall ensure connection and provision of information in accordance with Article 15 of this Circular.

2. Food products that have been produced, imported, and placed into circulation before the dates specified in Article 15 of this Circular shall not be required to comply with Article 13 and Clause 5 Article 18 of this Circular.

3. In case any legal documents cited in this Circular are amended, supplemented or replaced in the course of implementation, the new ones shall apply.

Article 22. Effect

1. This Circular takes effect from April 16, 2026.

2. During the implementation of this Circular, should any difficulties or issues arise, the Minister of Industry and Trade shall provide guidance for specific cases or amend and supplement this Circular where necessary./.