Tiếng Việt
中文 (中国)
CIRCULAR 34/2011/TT-BYT: TECHNICAL REGULATIONS ON FOOD-CONTACT PACKAGING AND UTENSILS
Circular 34/2011/TT-BYT promulgates three national technical regulations on the safety and hygiene of packaging and utensils in direct contact with food, covering synthetic resin, rubber and metal materials. For importers of food packaging, food-contact containers or utensils, incorrect interpretation may affect product declaration, state food safety inspection, labeling, technical documentation and customs clearance planning.
QUICK SUMMARY
| Item | Details |
|---|---|
| Regulated matter | Promulgates three QCVNs for food-contact packaging and utensils made of synthetic resin, rubber and metal. |
| Effective date | Issued on 30 August 2011; effective from 1 March 2012. |
| Affected parties | Importers, manufacturers, distributors of food-contact packaging/utensils; procurement, compliance, QA/QC, documentation and logistics teams. |
| Immediate action | Review material, food-contact function, catalogue/datasheet, food safety declaration/inspection dossier, labeling, HS, C/O and clearance timeline before ETA. |
DOCUMENT INFORMATION
| Field | Content |
|---|---|
| Document name | Circular promulgating national technical regulations on safety and hygiene for packaging and utensils in direct contact with food |
| Reference | 34/2011/TT-BYT |
| Issuing authority | Ministry of Health |
| Date of issuance | 30 August 2011 |
| Effective date | 1 March 2012 |
| Signatory | Trinh Quan Huan – Deputy Minister |
| Regulatory scope | Promulgates QCVN 12-1:2011/BYT, QCVN 12-2:2011/BYT and QCVN 12-3:2011/BYT. |
| Application status | Listed as effective in available databases. For current application, enterprises should re-check amendments, replacements and the actual dossier. |
KEY CONTENT TO NOTE
Article 1 promulgates QCVN 12-1 for synthetic resin packaging/utensils, QCVN 12-2 for rubber packaging/utensils and QCVN 12-3 for metal packaging/utensils.
Material, food-contact function, temperature, type of food, coating, accessories and practical use must be identified.
Importers should review product declaration, state food safety inspection, testing results and technical documentation under current rules.
Shipments after the effective date should be reviewed against the relevant QCVN to avoid clearance delay or document supplementation.
AFFECTED ENTERPRISES / PRODUCT GROUPS
| Analysis group | Application note | Documents to check | Risk if misclassified |
|---|---|---|---|
| Importers | Importing packaging, boxes, bottles, lids, trays or utensils directly contacting food. | Invoice, Packing List, B/L/AWB, catalogue, datasheet, product images/labels, test report. | Wrong QCVN, missing testing, missing food safety dossier. |
| Food manufacturers / brand owners | Using packaging or utensils for packing, containing, processing or distributing food. | Material BOM, packaging specification, supplier certificate, testing sheet. | Quality dossier, market circulation and post-clearance compliance risk. |
| Plastic/rubber/metal products | Applies when the product directly contacts food; decorative/non-contact goods require separate review. | Catalogue, sample, use purpose, material, user manual. | Generic description may distort commodity policy and declaration dossier. |
| Logistics providers / forwarders | Need early identification of conditional products to plan dossier timeline before ETA. | Draft HS, product description, technical documents, specialized inspection requirements. | Late declaration, customs channel change, DEM/DET/storage costs. |
IMPACT ON IMPORT–EXPORT / LOGISTICS OPERATIONS
| Operational stage | Practical impact | Pre-ETA control point |
|---|---|---|
| Customs declaration | HS and product description should reflect material, function and condition. | Avoid generic descriptions such as plastic box, metal container or rubber gasket if food-contact. |
| Specialized dossier | Product declaration/state inspection, testing under QCVN, label and technical dossier may be required. | Lock the applicable QCVN by material before arrival. |
| Commercial documents | Invoice, Packing List and B/L must be consistent with product name, quantity, model, origin and technical description. | Cross-check with catalogue, datasheet, original label and test report. |
| Logistics cost | Delayed dossier may increase port storage, container detention/demurrage and warehousing costs. | Prepare dossier checklist and pre-ETA timeline. |
ENTERPRISE CHECKLIST
| Dossier group | Required document | Used for | Prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial documents | Invoice, Packing List, B/L/AWB, Contract/PO if any. | Customs declaration and value/quantity reconciliation. | Importer, supplier, forwarder. | Generic description; missing model; quantity/weight mismatch. | Compare with catalogue, package images, labels and order data. |
| Technical dossier | Catalogue, datasheet, material composition, user manual, images/labels. | Determine QCVN, food safety policy and customs description. | Supplier, QA/QC, compliance. | No evidence of food-contact use. | Ask supplier to confirm material, function and use conditions. |
| Testing/food safety dossier | Test report, product declaration/state inspection dossier if applicable. | Specialized compliance and market circulation. | Importer, legal/compliance, testing body. | Test report not matching QCVN/model/material. | Review lab scope, test items, sample and date. |
| Logistics dossier | ETA, port/warehouse data, haulage and storage plan. | Manage clearance and delivery timeline. | Operation, forwarder, warehouse. | Specialized documents unavailable at arrival. | Set documentation deadline before ETA. |
TECHNICAL TERMS
- QCVN: mandatory national technical regulation in Vietnam.
- Food-contact packaging/utensils: containers, packaging or utensils used directly with food.
- Migration: transfer of substances from packaging/utensil material into food or food simulants.
- Test report: testing result used to demonstrate compliance with the applicable QCVN.
- DEM/DET/Storage: demurrage, detention and storage charges potentially incurred when documents are delayed.
RELATED LEGAL DOCUMENTS TO REVIEW
| Document group | Document name/reference | Issuing authority | Effective/application timing | Role in procedure | Key provisions/appendices | Review note |
|---|---|---|---|---|---|---|
| Law | Law on Food Safety 55/2010/QH12 | National Assembly | Effective from 1 July 2011 | General food safety legal framework including food-contact packaging and utensils. | Review obligations for food safety assurance. | Check consolidated/amended versions if any. |
| Law | Law on Standards and Technical Regulations 68/2006/QH11 | National Assembly | Applies to standards and QCVN system | Legal basis for issuing QCVNs. | Review mandatory application of technical regulations. | Useful for understanding QCVN nature. |
| Law | Law on Product and Goods Quality 05/2007/QH12 | National Assembly | Applies to product/goods quality management | Quality control basis for imported/circulated goods. | Review responsibilities of importers/manufacturers/distributors. | Check actual product group. |
| Decree | Decree 127/2007/ND-CP | Government | Details the Law on Standards and Technical Regulations | Basis for QCVN application. | Review promulgation/application of technical regulations. | May have amendments; re-check current application. |
| Decree | Decree 132/2008/ND-CP | Government | Details the Law on Product and Goods Quality | Product/goods quality management basis. | Review declaration, inspection and post-market control. | Consider amending decrees such as Decree 74/2018/ND-CP. |
| Decree | Decree 15/2018/ND-CP | Government | Details certain articles of the Law on Food Safety | Relevant to declaration and state food safety inspection dossier. | Review product group and food-contact packaging obligations. | Do not conclude without actual catalogue/HS/use purpose. |
| Circular/QCVN | Circular 34/2011/TT-BYT; QCVN 12-1, 12-2, 12-3:2011/BYT | Ministry of Health | Effective from 1 March 2012 | Main document regulating synthetic resin, rubber and metal food-contact packaging/utensils. | Article 1, Article 2, technical tables in QCVNs. | Determine the correct material and use condition. |
| Labeling | Decree 43/2017/ND-CP; Decree 111/2021/ND-CP | Government | Applies at market circulation stage | Goods labeling and Vietnamese supplemental label requirements. | Review product name, origin, responsible party and warnings/instructions if any. | Important for imported goods for sale. |
VIEW / DOWNLOAD ORIGINAL DOCUMENT
Priority sources for cross-checking: Vietnam Food Administration/Ministry of Health, legal lookup pages and the PDF files of QCVN 12-1, QCVN 12-2 and QCVN 12-3. Enterprises should re-check validity, amendments and dossier requirements for the actual product group before application.
FULL TEXT OF THE DOCUMENT
MINISTRY OF HEALTH
——–
THE SOCIALIST REPUBLIC OF VIETNAM
Independence – Freedom – Happiness
—————
CIRCULAR
PROMULGATING NATIONAL TECHNICAL REGULATIONS ON SAFETY AND HYGIENE FOR PACKAGING AND UTENSILS IN DIRECT CONTACT WITH FOOD
THE MINISTER OF HEALTH
Pursuant to the Law on Food Safety dated June 17, 2010;
Pursuant to the Law on Standards and Technical Regulations dated June 29, 2006 and Decree No. 127/2007/ND-CP dated August 1, 2007 detailing a number of articles of the Law on Standards and Technical Regulations;
Pursuant to the Law on Product and Goods Quality dated November 21, 2007 and Decree No. 132/2008/ND-CP dated December 31, 2008 detailing a number of articles of the Law on Product and Goods Quality;
Pursuant to Decree No. 188/2007/ND-CP dated December 27, 2007 defining the functions, tasks, powers and organizational structure of the Ministry of Health;
At the proposal of the Director of the Vietnam Food Administration, the Director of the Department of Science and Training and the Director of the Legal Department,
PROVIDES:
Article 1. The following National Technical Regulations on safety and hygiene for packaging and utensils in direct contact with food are promulgated together with this Circular:
QCVN 12-1:2011/BYT – National technical regulation on safety and hygiene for synthetic resin packaging and utensils in direct contact with food;
QCVN 12-2:2011/BYT – National technical regulation on safety and hygiene for rubber packaging and utensils in direct contact with food;
QCVN 12-3:2011/BYT – National technical regulation on safety and hygiene for metal packaging and utensils in direct contact with food.
Article 2. This Circular takes effect from March 1, 2012.
Article 3. The Director of the Vietnam Food Administration, heads of units under the Ministry of Health, affiliated units of the Ministry of Health, Directors of provincial Departments of Health and relevant organizations and individuals shall implement this Circular.
FOR THE MINISTER
DEPUTY MINISTER
Trinh Quan Huan
Note: The short Circular text is rendered above. The three technical regulations QCVN 12-1, QCVN 12-2 and QCVN 12-3 contain multiple technical limit tables, testing methods and annexes; therefore, each is provided through a separate PDF preview below so that the full content can be reviewed without shortening the tables.
Display note: the original PDF file hosted by the Vietnam Food Administration may not render reliably when embedded directly in a WordPress iframe, which can create a blank/dark preview box. To avoid a broken layout, the Circular text is provided above and the original PDF can be opened/downloaded using the buttons below.
Primary source for cross-checking: Vietnam Food Administration / Ministry of Health. The QCVN 12-1, QCVN 12-2 and QCVN 12-3 PDF previews remain embedded below because those files render more reliably in browsers.
Reference source for the technical regulations: PDF files from Vietnamese state/specialized technical sources. Enterprises should re-check validity, amendments and actual product dossiers before application.
Reference source for the technical regulations: PDF files from Vietnamese state/specialized technical sources. Enterprises should re-check validity, amendments and actual product dossiers before application.
Reference source for the technical regulations: PDF files from Vietnamese state/specialized technical sources. Enterprises should re-check validity, amendments and actual product dossiers before application.
FAQ – FREQUENTLY ASKED QUESTIONS
1. When does Circular 34/2011/TT-BYT take effect?
It takes effect from 1 March 2012.
2. What products does it apply to?
Food-contact packaging and utensils made of synthetic resin, rubber and metal under the relevant QCVNs.
3. Should importers review by product name or material?
Both. Material, food-contact function, use condition and technical dossier must be reviewed; trade name alone is insufficient.
4. Does this Circular directly change HS code or duty rate?
No. It is not a tariff schedule. However, correct material and function description may affect HS classification and specialized policy.
5. What if the product has multilayer materials or accessories?
Each food-contact component should be reviewed against the applicable QCVN, test report and declaration/inspection dossier.
6. What should be done if applicability is uncertain?
Request supplier catalogue, datasheet, material composition, label images, use purpose and test report; review before ETA.
SOLUTIONS FROM TGIMEX
Review Circular 34/2011/TT-BYT, QCVN 12-1/12-2/12-3, the Law on Food Safety, Decree 15/2018/ND-CP and labeling rules by material, function and import purpose.
Cross-check Invoice, Packing List, B/L/AWB, Contract/PO, catalogue, datasheet, original label, test report, C/O and food safety dossier to avoid mismatch.
Set a documentation timeline before arrival; identify risk blockers in customs declaration, specialized inspection, haulage, port/warehouse handling and contingency response.
Archive shipment dossiers, prepare data for post-clearance audit, review Vietnamese labels and product declaration/testing obligations where required.
Enterprises should review legal requirements, QCVNs and technical dossiers before finalizing documents and before ETA to reduce storage, channeling, supplemental dossier and delivery delay risks.
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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