Vietnam's Draft Food Safety Law Imposes Residue Limits at Slaughter

Food sold in Vietnam after harvesting, fishing, or slaughter must meet residue limits for veterinary drugs, pesticides, and other contaminants under the draft Food Safety Law presented to the National Assembly on October 24.

Minister of Health Dao Hong Lan presented the amended bill, which runs to 74 Articles, 9 Chapters, and 2 Appendices. The requirement that products clear residue thresholds at the point of harvest or slaughter is one of several additions that change what compliance means for farms, slaughterhouses, and food processors.

What changes in the draft law?

The bill replaces the term "testing" with "experimentation" to align the statute with the Law on Standards and Regulations, the Law on Product and Goods Quality, the Law on Investment, Government Resolution 66.17/2026/NQ-CP on reducing business conditions, and Prime Minister's Decision No. 36/2025/QĐ-TTg on the System of Vietnamese Economic Sectors. The terminological shift matters for laboratories and certification bodies because it harmonizes food-safety procedures with Vietnam's broader regulatory framework.

The draft also updates terminology according to Codex guidelines, including the definitions of food safety, food processing aids, food additives, scientific evidence, and risk analysis.

New substantive obligations include:

• E-commerce food businesses now fall under explicit food-safety duties.
• Food businesses must meet Good Hygiene Practices (GHP) and advanced management systems such as GMP, HACCP, and ISO 22000.
• Food processing and service establishments, including group meal providers, must maintain records, make commitments, and notify local authorities under Resolution 184/2026/NQ-CP.
• Individuals and organizations providing collective meals for non-commercial purposes acquire defined responsibilities.
• The establishment registering a product declaration and product standard declaration bears responsibility for that registration.
• Businesses pay sampling and testing fees under a policy shift from pre-inspection to post-inspection.

Where does the reviewing committee push back?

Nguyen Thanh Hai, Chairwoman of the Committee on Science, Technology and Environment, delivered the verification report. Her committee agreed on the necessity of comprehensively amending the 2010 Food Safety Law, noting that the draft institutionalizes major policies: the shift to post-inspection, supply chain management, and digital transformation.

But the committee flagged a structural gap. Several contents identified as "breakthroughs" — the roadmap for applying GHP and advanced food safety management systems, the roadmap for implementing risk analysis, and the application and transformation of state inspection methods for imported food — are left to the Government to regulate in detail. The result, the review states, is that even after National Assembly approval, many substantive contents would not yet be specifically reflected.

The committee also questioned the organizational structure. The draft names the Ministry of Health as the focal agency and assigns responsibilities to other Ministries and People's Committees at all levels. Yet many Ministries retain specialized state management, and the boundaries at overlapping stages — slaughtering, preliminary processing, wholesale markets, and export — remain unclear. For a veterinary audience, that ambiguity lands squarely at the slaughterhouse gate, where drug-residue enforcement meets multiple agencies.

What questions remain open?

The committee endorsed supply chain management based on risk analysis but asked that decentralization be concretized with criteria defining authority between central and local levels, and between the Ministry of Health and specialized ministries.

It proposed reviewing all labeling errors and deviations from self-declared quality standards as prohibited acts. It also asked the drafters to clarify whether repackaging or re-selling already-labeled products counts as a prohibited act — a question with direct consequences for wholesalers and distributors.

The draft law now moves through further National Assembly consideration, with the Government expected to fill in the roadmaps and inspection-method details that will determine how residue limits for veterinary drugs are enforced in practice.