The Vietnam Dairy Association has just sent an urgent official dispatch to Deputy Prime Minister Le Thanh Long reflecting a series of problems arising in the process of implementing Decree No. 46/2026/ND-CP and Resolution No. 66.13/2026/NQ-CP related to food safety management, announcement and registration of food products.
According to the Vietnam Dairy Association, immediately after the two documents were issued, at the conference summarizing the work in 2025 and deploying tasks for 2026 of the Association held on the morning of January 30, 2026, many member businesses reflected major inadequacies, directly affecting production and business activities.
The most prominent obstacle is the situation of customs clearance of imported goods. The Association said that all imported food shipments, including finished products and raw materials used for production, are stuck at the port due to state inspection of food safety being transferred to the People's Committees of provinces and cities from January 27, 2026. Meanwhile, localities do not have specific instructions, making it impossible for inspection agencies to take samples and issue confirmations of meeting import requirements, leading to customs authorities not having a basis for customs clearance.
In addition, the procedure for inspecting imported goods is reflected as generating more stages, prolonging customs clearance time without increasing the effectiveness of ensuring food safety. According to the Association, this situation causes great damage to the production and business activities of enterprises, and also incurs warehousing and yard storage costs and many other damages.
Another obstacle raised is that imported raw materials and packaging serving internal production, previously exempted from self-declaration procedures under Decree 15, now have to carry out conformity declaration procedures according to new regulations. This procedure takes a lot of time to prepare and review dossiers, making it impossible for businesses to respond immediately, leading to customs clearance stagnation and seriously affecting the production of the food industry.
In addition to customs clearance issues, the Vietnam Dairy Association also reflects a series of other inadequacies such as many localities stopping receiving dossiers for changing packaging and labels for products that have been registered or self-declared before; the situation of overlapping procedures when a product must both register the declaration according to Resolution 66.13 and register the declaration of conformity according to Decree 46; requiring a certificate of eligibility for food safety for production facilities abroad; as well as regulations on advertising supplementary foods while there is no appropriate transition mechanism.
The Association also clearly expressed concern about the validity period of Resolution 66.13 until February 28, 2027, while the transition time for self-declared products to register for announcement is 24 months, which may lead to legal loopholes when businesses submit dossiers after the Resolution expires.
From the above reality, the Vietnam Dairy Association proposed that the Deputy Prime Minister direct relevant ministries and sectors to urgently review and remove obstacles, especially during the peak period of production and business of goods to serve the Lunar New Year. The Association proposed that specialized ministries soon have specific guidance so that businesses have a basis for deployment, limiting congestion and stagnation of production and business activities.
Regarding the implementation of Decree No. 46/2026/ND-CP and Resolution No. 66.13/2026/NQ-CP, dated January 31, 2026, the Customs Department issued Urgent Official Dispatch No. 8012/CHQ-GSQL proposing the Ministry of Health, the Ministry of Industry and Trade, and the Ministry of Agriculture and Environment to soon have guidance to remove obstacles and difficulties above, limit damage to businesses, and avoid goods congestion causing unsafety and security at border gates.
At the same time, directing regional Customs Sub-Departments to strengthen duty shifts and promptly carry out customs clearance procedures as soon as specialized ministries have measures to remove the above-mentioned obstacles.
