Proposal to add beer, dairy products, and vegetable oil to the high-risk goods category to protect public health

The Ministry of Industry and Trade is seeking public comments on a draft circular that would establish lists of medium- and high-risk goods under its regulatory authority. For high-risk goods, the draft proposes that, in addition to provenance tracing as required, regulators may apply pre-market checks and strengthen monitoring and supervision.

Proposed risk categories and scope

Under the draft circular, the list of medium-risk goods includes consumer items such as paper, tissues, and toilet paper. It also covers chemicals and products containing chemicals, industrial explosives, high-explosive materials, and industrial explosive accessories, as well as various types of machinery, equipment, and industrial supplies.

The list of high-risk goods includes explosive precursors and beverages, including both alcoholic and non-alcoholic drinks. It also classifies liquid milk, milk powder, fermented milk, processed milk without cacao, fats from milk, cheese, and vegetable oils as high-risk goods.

Rationale for classifying foods as high-risk

The ministry said defining risk categories and applying appropriate management measures helps ensure products and goods meet safety and quality requirements before entering the market. It added that this approach is intended to prevent incidents, protect people’s health and lives, and maintain order and safety in production activities.

On why beer and milk are included in the high-risk group, the ministry cited Codex risk assessment principles. These principles identify the group as having a high likelihood of exposure. The ministry noted that potential consequences could include acute poisoning or long-term public health effects, and therefore foods should be managed at a high-risk level with full-chain monitoring.

Vietnam’s risk challenges

In Vietnam, the ministry described the high-risk category as facing ongoing challenges, including foods of unknown origin, adulteration and chemical misuse, and the use of prohibited substances in farming and processing. It also said hygiene conditions at many facilities are not adequately controlled. Food poisoning incidents continue to occur, and the dispersed supply chain—often involving small-scale production—makes risk control more difficult.

Focus on paper and direct-contact products

For the paper category, including tissues and toilet paper, the ministry said the Vietnamese market is large and diverse, with both domestically produced and imported products. It highlighted that direct-contact products such as tissues and plastic items can carry risks from residual chemicals and additives, particularly where production conditions at some small facilities are not tightly controlled. While standards exist, it said compliance in practice remains uneven.

Management measures under the draft

The ministry said the medium-risk group would require enhanced conformity assessment and strict chemical safety indicators. For the high-risk group, it reiterated that—along with provenance tracing—authorities may apply pre-market checks and strengthen supervision.