According to the provisions of Decree No. 111/2021/ND-CP, nutritional ingredients, and nutritional value of food have been regulated as one of the mandatory contents that must be shown on food labels. However, currently units are still doing it arbitrarily, without following any specific, official instructions. Recently, on December 30, 2023, the Minister of Health issued Circular 29/2023/TT-BYT (“Circular 29”) guiding the content and method of recording nutritional ingredients and nutritional values on food labels. Food labels and implementation roadmap. Circular 29 has some notable contents as follows:
1. Nutritional ingredients required to be listed on food labels:
- According to the provisions of Circular 29, except in cases where the nutritional value of the ingredients is less than the level specified in Appendix I, foods produced, traded, imported, and circulated in Vietnam must be processed. Currently record at least 05 of the following nutritional ingredients:
(i) Energy;
(ii) Protein;
(iii) Carbohydrates;
(iv) Fat;
(v) Sodium.
- For soft drinks, processed milk with added sugar and other foods with added sugar, in addition to recording the 5 nutritional ingredients mentioned above, it is also necessary to record the total sugar index (the total amount of sugar in the food). foods (including natural sugars and added sugars in foods).
- Foods processed in the form of frying must record the 05 nutritional ingredients mentioned above and saturated fat.
2. How to record nutritional ingredients and nutritional values for foods
- Information about nutritional value is expressed corresponding to each nutritional ingredient in 100g or 100ml of food or in a serving of food whose content has been determined on the label or per packaged portion according to the number of portions in the package. that was announced:
- Organizations and individuals can express additional information as a percentage (%) of the reference nutritional value for nutritional ingredients, in which the reference value is determined by the Ministry of Health based on research or Current recommendations of international and national agencies and organizations on nutrition, food and health.
However, for the total sugar indicator, the Ministry of Health currently has no recommendations on reference nutritional values.
- The nutritional value of nutritional ingredients must be fully expressed in numbers, displayed in a position that can be easily identified, complete with the prescribed content and guaranteed to be accurate, easy to understand, and free of errors. cause misinterpretation and confusion.
- Ingredient information and nutritional value must be indelible.
3. Roadmap for implementing regulations on recording nutritional ingredients and nutritional values on food labels
- By December 31, 2025 at the latest, organizations and individuals producing, trading, and importing food for circulation in Vietnam within the scope of Circular 29 must record nutritional ingredients. nutrition and nutritional value according to regulations.
- Foods whose labels do not contain nutritional ingredients or nutritional values according to regulations that have been produced, traded, imported, and circulated in Vietnam before January 1, 2026 may continue to be circulated and used. Use until the expiration date stated on the food label.
4. Cases in which nutritional ingredients and nutritional values are not required to be written on food labels according to the guidance of the Ministry of Health:
4.1. Cases not subject to adjustment (nutritional ingredients and nutritional value are not required to be recorded on product labels):
• Raw materials and foods not sold directly to consumers, including food ice;
• Food has a single ingredient;
• Natural mineral water, bottled water (including those with only added CO2 and/or flavoring);
• Food salt, refined salt;
• Vinegar and vinegar substitutes including those with added flavoring only;
• Flavorings, additives, food processing aids;
• Food enzymes;
• Tea and coffee do not contain other additional ingredients except colors and flavors;
• Food to protect health;
• Acoholic drink;
• Foods that do not have to comply with regulations on labeling (Goods are fresh, raw foods, processed foods without packaging and sold directly to consumers; Goods are raw materials (agricultural products). products, aquatic products, minerals) without packaging and sold directly to consumers).
• Food produced by small food businesses registered by individuals, groups of individuals, or households and the establishment is not issued with a Business Registration Certificate or Investment Certificate private according to the provisions of law;
4.2. Cases subject to regulation but not required to record nutritional ingredients and nutritional value on product labels:
Foods that are subject to regulation but do not contain nutritional ingredients or contain nutritional ingredients but the nutritional value of that ingredient is less than the value specified in Appendix I Circular 29 are not required to be recorded. nutrition section on the food label.
Circular 29 takes effect from February 15, 2024.
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