Tiếng Việt
中文 (中国)
CIRCULAR 08/2015/TT-BYT: AMENDMENTS ON FOOD ADDITIVE MANAGEMENT AND OPERATIONAL NOTES FOR IMPORT-EXPORT BUSINESSES
Circular 08/2015/TT-BYT amended the former food additive management framework under Circular 27/2012/TT-BYT. Although it has fully expired, it remains relevant for historical dossier review, product declaration traceability and compliance checks for food additive shipments handled before replacement regulations took effect. This article places the regulation in the practical context of import-export operations, clarifying its scope, affected parties, and the checks required before it is relied on for a shipment dossier. Before implementation, businesses should verify the effective date, amendments, and relevant official guidance applicable to the transaction, while retaining the source and document version used for later explanation or audit.
QUICK SUMMARY
| Item | Operational note |
|---|---|
| What does this document regulate? | It amended rules on food additives under the Ministry of Health’s food safety management framework. |
| Key dates | Issued on 11 May 2015, effective from 1 July 2015, fully expired from 16 October 2019. |
| Affected products | Food additives, foods containing additives, and materials used for colouring, flavour enhancement, sweetening or acidity regulation. |
| Immediate action | Do not use Circular 08/2015/TT-BYT as a current legal basis; check Circular 24/2019/TT-BYT, relevant QCVNs and the current import food safety inspection list. |
DOCUMENT INFORMATION
| Field | Content |
|---|---|
| Document title | Circular 08/2015/TT-BYT amending and supplementing provisions of Circular 27/2012/TT-BYT on food additive management. |
| Document number | 08/2015/TT-BYT |
| Issuing authority | Ministry of Health |
| Date of issuance | 11 May 2015 |
| Effective date | 1 July 2015 |
| Legal validity | Fully expired from 16 October 2019; current dossiers must be checked against replacement and currently effective regulations. |
| Regulatory scope | Amending the list of permitted food additives, maximum use levels and transitional provisions of Circular 27/2012/TT-BYT. |
| Affected parties | Manufacturers/traders of foods using food additives; importers of food additives, food ingredients and foods containing additives. |
KEY CONTENT TO NOTE
| Content group | Legal / operational meaning |
|---|---|
| Supplement to Appendix 1 | Additional permitted food additives were introduced, including INS codes such as 153, 163(v), 363, 515(ii), 639, 640 and 958. |
| Amendment to Appendix 2 | Maximum levels for certain food additives were amended/supplemented under the appendix attached to the Circular. |
| Transitional provision | Food additives/foods using additives with valid conformity or food safety declaration acceptance documents issued before the effective date continued to be used until the expiry stated in those documents. |
| Implementation clause | The Circular took effect from 1 July 2015; the Vietnam Food Administration was responsible for implementation guidance. |
AFFECTED BUSINESSES / PRODUCT GROUPS
| Affected group | Operational interpretation |
|---|---|
| Importers / food manufacturers | Check additive code, functional class, permitted use level and product declaration documents before import, production or circulation. |
| Logistics / customs brokers | Review product name, HS code, composition, intended use, COA, MSDS/SDS, certificates, original label and food safety dossier before ETA. |
| Procurement / Legal / Compliance | Do not focus only on price and supplier; verify whether the additive is permitted, its use limit and current replacement regulations. |
| Affected stages | Pre-import, product self-declaration/declaration, food safety inspection, market circulation and post-clearance review. |
IMPACT ON IMPORT-EXPORT / LOGISTICS
| Stage | Risk / control point |
|---|---|
| Customs declaration | Goods description should correctly reflect additive nature, INS code/function where available; avoid generic descriptions such as “food material”. |
| Document set | Invoice, Packing List, B/L/AWB, contract, catalogue/specification, COA, MSDS/SDS, original label, C/O and declaration/self-declaration dossiers where applicable. |
| Timeline | Inconsistent additive composition or product names may trigger additional documents, storage, demurrage/detention and delayed delivery. |
| Compliance | Maintain shipment files, formulation/intended use data, origin documents and testing results when required by authorities. |
BUSINESS REVIEW CHECKLIST
| Review item | Documents/data required | Responsible team | Risk if missing |
|---|---|---|---|
| Current legal basis | Check Circular 24/2019/TT-BYT, Decree 15/2018/ND-CP, current food safety import inspection list and relevant QCVNs. | Legal/Compliance | Using an expired document as the active legal basis. |
| Goods name & HS | Cross-check additive name, INS code, function, CAS/chemical name where available and proposed HS code. | Docs/Customs | Generic goods name, wrong policy classification. |
| Technical dossier | COA, specification, MSDS/SDS, catalogue, original label, formulation/intended use. | Procurement/QA | Unable to prove the nature of the additive. |
| Food safety dossier | Self-declaration/declaration, testing results and state food safety inspection dossier if applicable. | Compliance/Operation | Missing documents during clearance or market circulation. |
| Operational milestones | Lock the document set before ETA; review conditions before booking/pickup. | Operation/Logistics | Late supplementation, DEM/DET/storage risk. |
RELATED LEGAL DOCUMENTS TO REVIEW
| Group | Document | Authority | Effective period | Role | Review note |
|---|---|---|---|---|---|
| Law | Law on Food Safety 55/2010/QH12 | National Assembly | Effective from 1 July 2011 | Foundational law on food safety, production/business conditions and circulation. | Check by product type and intended use. |
| Decree | Decree 38/2012/ND-CP | Government | Expired under Decree 15/2018/ND-CP | Former decree cited in Circular 08/2015/TT-BYT. | Use for historical legal review only. |
| Decree | Decree 15/2018/ND-CP | Government | 2 February 2018 | Detailed guidance on the Law on Food Safety; relevant to self-declaration/declaration and import food safety inspection. | Check current status at filing time. |
| Circular | Circular 27/2012/TT-BYT | Ministry of Health | 1 February 2013 | Original food additive management circular amended by Circular 08/2015/TT-BYT. | Replaced in the later food additive management framework. |
| Circular | Circular 08/2015/TT-BYT | Ministry of Health | 1 July 2015 – expired 16 October 2019 | Main document analysed; amended additive lists and maximum levels under Circular 27/2012/TT-BYT. | Do not use as current legal basis. |
| Replacement circular | Circular 24/2019/TT-BYT | Ministry of Health | 16 October 2019 | Provides rules on management and use of food additives; replaces relevant older documents. | Review for current dossiers. |
| QCVN / Circular | Circular 31/2020/TT-BYT | Ministry of Health | 1 September 2021 | Promulgates QCVNs on food additives. | Review by additive type, limits and technical criteria. |
| List / HS | Circular 15/2024/TT-BYT | Ministry of Health | 2 November 2024 | List of foods, food additives and food-contact articles subject to import food safety inspection under MOH scope. | Check by HS code, product name and intended use. |
VIEW / DOWNLOAD ORIGINAL DOCUMENT
Use the signed PDF and legal-validity lookup page for source verification before applying this document to any dossier.
FULL TEXT OF CIRCULAR 08/2015/TT-BYT
OPEN FULL TEXT OF CIRCULAR 08/2015/TT-BYT
Preferred official source: the Government legal document portal. The PDF frame is for original-text verification and does not replace legal advice for a specific shipment.
FULL TEXT / OPERATIONAL REFERENCE TRANSLATION
The original Vietnamese full text is displayed in the signed PDF preview above. In summary, Circular 08/2015/TT-BYT amended and supplemented Circular 27/2012/TT-BYT by adding permitted food additives, amending maximum use levels for certain additives and setting transitional provisions for products that had obtained food safety declaration acceptance documents before the effective date.
This reference translation is intended to support import-export, logistics, compliance and operations teams in understanding the document. It is not an official legal translation.
SPECIALIZED TERMINOLOGY NOTES
| Term | Brief explanation |
|---|---|
| Food additives | The substance is actively added to food to achieve certain technological purposes, not used as normal food. |
| INS | International Numbering System – international coding system for food additives. |
| COA | Certificate of Analysis – coupon/certificate of analysis of ingredients/quality criteria. |
| MSDS/SDS | Material Safety Data Sheet/Safety Data Sheet – chemical/material safety data sheet. |
| DEM/DET/Storage | Storage fee container/storage/storage arises when documents or progress of receiving goods is slow. |
FAQ
Is Circular 08/2015/TT-BYT still effective?
No. It has fully expired from 16 October 2019. Current dossiers must be reviewed under replacement and currently effective regulations.
What products did it affect?
Mainly food additives and foods using food additives, including additive names, INS codes, functions and maximum use levels.
What should importers check before ETA?
Additive name, INS/function, COA, specification, MSDS, original label, HS code, declaration dossier and current import food safety inspection rules.
Can it be used as a legal basis for current dossiers?
It should not be used as the current legal basis. It is only suitable for historical legal review.
Does it change HS code or tax?
It is not a tariff document, but the additive description/function may affect HS classification and food safety inspection policy.
Where should current validity be checked?
Check the Government portal, national legal database, Ministry of Health/Vietnam Food Administration and the actual product dossier.
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.
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