Proposal to remove difficulties for food processing businesses

According to the five associations (Transparency Food Association, Vietnam Association of Seafood Exporters and Producers, Food and Foodstuff Association of Ho Chi Minh City, Vietnam Business Association of High-quality goods and Phu Quoc Fish Sauce Association), a content in Decree 09/2016//ND-09 dated January 28, 2016 (later referred to as Decree 09) is and already have heavily affected food processing businesses.

Specification about fortifying micronutrients into food is specified at Point a, Clause 1, Article 6 of Decree 09: “ Salt…, used in food processing need to be fortified in Iodine” (implemented from March 15, 2017) and Point b, Article 6 Clause 1 specified: “Flour used in food processing need to be fortified in Iron and Zinc” ( in effect since March 15, 2018)

Over the period, these regulations currently and already have affected production and business activities heavily, raised costs, increased the problem of unfair competition between businesses without effective results, inappropriate with principles of risk management and international practices while also leading to risks of diminished health for a portion of Vietnamese. Therefore, immediately after the promulgation of Decree 09, associations continuously propose many recommendations to the Government and the Ministry of Health with the desire to promptly remove difficulties for businesses.

On May 15, 2018, the Government promulgated Resolution No. 19-2018/NQ-CP (later referred to as Resolution 19); which, at Point b, Clause 15, Section III, the Government has directed the Ministry of Health to “Research, amend and supplement Decree No. 09/2016/ND-CP dated January 28, 2016, of the Government on fortification of micronutrients in food towards: Deregulation “Salt used in food processing need to be fortified in Iodine” at Point a (Clause 1, Article 6); deregulation “Flour used in food processing need to be fortified in Iron and Zinc” at Point b (Clause 1, Article 6). Instead, should only encourage food processing businesses to use them.

However, associations and businesses have not seen Decree 09 amending the above important content until now.

Not only that, recently, on September 14, 2021, the Ministry of Health promulgated document No. 7658/BYT-PC sent to associations, food businesses and resume the demand for strict implementation of Decree 09, showing unchanged opinion on forcing food processing businesses to increase micronutrients.

Most recently, the Ministry of Health is constructing and soliciting comments on the Draft Plan to Fortify the implementation of Decree 09. This makes associations and food processing businesses wonder, worry, especially in the context of businesses trying to recover from the Covid-19 pandemic.

The five associations assure that associations and businesses fully support the Government to implement solutions to improve the health and fitness of Vietnamese people, that is also the tasks, goals and benefits of food processing businesses.

However, the supplementation of micronutrients needs to be performed appropriately on the principle of risk management, while ensuring people's health, reducing the rate of diseases and physical weakness caused by excess or deficiency of micronutrients, while also avoiding causing difficulties for businesses in the food processing industry in particular and the economy in general.

In that spirit, food associations propose the Prime Minister and Government to consider and direct the Ministry of Health to urgently amend Decree 09 in accordance with the guiding spirit of the issued Resolution 19/2018/NQ-CP. Only regulate that salt used in daily cooking and solid seasonings such as seasoning seeds, seasoning tablets,... to fortify the amount of Iodine and encourage food processing businesses to supplement micronutrients into food products instead of mandatory requirements, in accordance with the spirit of Resolution 19.