On February 4, 2026, the Government issued Resolution No. 09/2026/NĐ-CP on the temporary suspension and adjustment of the implementation timeline of Decree 46/2026/NĐ-CP, which provides detailed guidance for the Law on Food Safety. This decision aims to address regulatory bottlenecks, ensure policy stability, and reduce operational pressure on businesses, particularly those operating in logistics, transportation, and food supply chains.

Explanation and Timeline of Application

Under the resolution, the Government has decided on the Temporary Suspension of Decree 46 from January 26, 2026, along with Resolution No. 66.13/2026/NQ-CP dated January 27, 2026, regarding food product declaration and registration procedures. The suspension will remain in effect until April 15, 2026. From April 16, 2026, these regulations are expected to resume enforcement.

During this suspension period, Decree 15/2018/NĐ-CP and its guiding documents will continue to serve as the primary legal framework for food safety compliance.

This transitional approach allows both regulators and businesses to maintain operational continuity while addressing inconsistencies in the newer regulatory system.

Key Challenges That Required Policy Adjustment

The decision on the Temporary Suspension of Decree 46 stems from several practical challenges faced by enterprises.

One major issue is the requirement to carry out both product self-declaration and product registration simultaneously. This creates unnecessary duplication, as manufacturers already bear full legal responsibility for their products, leading to increased administrative burden without clear added value.

In addition, tightened import inspection procedures have caused significant disruptions in supply chains. The removal of exemptions, prolonged inspection timelines, and the lack of readiness among local authorities have contributed to congestion at ports and delays in goods circulation.

Another critical concern lies in transitional gaps and labeling requirements. Businesses are unable to continue using existing labels, yet there is no clear mechanism to update them in compliance with new regulations. This creates operational uncertainty and increases the risk of non-compliance.

Furthermore, ambiguous regulatory provisions have led to inconsistent interpretation and enforcement. Vague definitions increase legal risks for businesses, especially those operating across multiple jurisdictions.

Finally, the enforcement system itself has shown signs of overload. Bottlenecks in testing, data management, and advertising registration processes have created delays across the entire compliance chain, from product verification to market entry.

Benefits for Businesses During the Suspension Period

The Temporary Suspension of Decree 46 demonstrates the Government’s responsiveness and willingness to adjust policies in line with real-world conditions.

For businesses, this creates immediate relief by reducing compliance costs and minimizing the risk of production and distribution disruptions. Logistics and transportation companies, in particular, benefit from smoother cargo flow and reduced regulatory uncertainty.

At a broader level, the suspension serves as a policy stabilization measure. It prevents businesses from having to continuously adapt to short-lived or unclear regulations, allowing them to focus on long-term planning and operational efficiency.

At the same time, the Government has emphasized the need to strengthen post-market inspection and supervision. This shift indicates a move toward more effective regulatory enforcement while maintaining flexibility in administrative procedures.

What Businesses Should Prepare

In light of the Temporary Suspension of Decree 46, enterprises should take this opportunity to strengthen their internal systems and ensure readiness for future regulatory enforcement.

Businesses should begin by reviewing their entire legal compliance framework, including product declaration dossiers, ingredient specifications, quality standards, and labeling practices. This ensures alignment with both current and upcoming regulations.

At the operational level, standardizing management systems is essential. Applying internationally recognized standards such as HACCP, ISO 22000, and Food Safety Management Systems helps improve consistency and compliance readiness.

Traceability systems should also be enhanced. This includes production batch coding, data integration across supply chain stages, and the adoption of digital technologies to ensure transparency and accuracy.

Finally, companies must prepare for stricter post-market inspections. Maintaining well-organized documentation, ensuring data transparency, and training personnel on compliance procedures will be critical to minimizing risks during inspections.

The Temporary Suspension of Decree 46 represents a strategic policy adjustment aimed at balancing regulatory control with business practicality. By addressing immediate challenges and allowing time for refinement, the Government is creating a more stable and predictable environment for enterprises.

For logistics and food-related businesses, this period is not only a relief but also an opportunity to reinforce internal capabilities, ensuring long-term compliance and resilience in an evolving regulatory landscape.

Source: VGP News

06/02/2026