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Are you interested in product declaration? Interested in procedures and regulations on product declaration?… This article will help answer all your questions!

I. WHAT IS PRODUCT DECLARATION?

1. Correct understanding of the concept: Product declaration

Product declaration is the declaration of product quality. This is one of the important steps that individuals, organizations and businesses need to take before putting products on the market.

Product declaration paper is considered as the "circulation paper" of the product on the market.

2. Which products need to be declared?

Article 6 of Decree 15/2018/ND-CP stipulates the list of product groups that need to be declared as follows:

Article 6. Registration of product declaration.

Organizations and individuals producing and trading food must register product declarations for the following products:

1. Health protection foods, medical nutritional foods, foods for special diets.

2. Nutritional food for children up to 36 months old.

3. Mixed food additives with new uses, food additives not on the list of additives permitted for use in food or not for the correct subjects of the Ministry of Health.

3. Product declaration violation - What is the impact on businesses?

In case a business does not declare its products before putting them on the market, how will it be punished?

→ When violating product declaration regulations, businesses may be subject to the following penalties:

1. A fine of 40-50 million VND for acts of not registering a product declaration if the product is subject to product declaration registration...

2. Additional penalty: Suspension of part or all of food production and import activities for 1-3 months for failure to register product declaration.

3. Violators must remedy the consequences by means such as: Forced recall of food for violations, forced change of purpose of use or recycling or forced destruction of food.

II. DECREE 15 PRODUCT DECLARATION

To strictly manage product announcements, stabilize the market, and ensure product quality, the government has also issued specific regulations on product announcements. Decree 15 2018 provides full information on the following issues:

1. List of products requiring declaration.

2. Registration form for publication

3. Procedure for registration of announcement

In the following part of this article, NanoFrance will guide you through the procedures and processes for completing the declaration to meet the requirements of the authorities. Don't forget to refer to it!

See full details of Decree 15: HERE .

III. PRODUCT DECLARATION PROCESS

1. Declaration of functional foods - Health protection foods

Where to submit?

Individuals and businesses send functional food declaration dossiers by post or submit directly to the Department of Food Safety (Ministry of Health) according to one-stop regulations.

You can also apply online at Decree 15 page HERE

Profile components

Including: Food safety compliance declaration dossier (2 sets) and General legal dossier (1 set). Specifically:

1. General legal documents include:

Business registration certificate with food production and trading industry or if it is an individual or organization importing food, a legal entity certificate is required.
Certificate of food safety qualified facility.
Certificate of conformity to HACCP or ISO 22000 standards or equivalent.

2. Food safety compliance declaration file

Domestically produced products

Imported products

Declaration of compliance with food safety regulations
Product details
Product testing results within 12 months
Product label template
Complete product sample for comparison when submitting application
Information and scientific documents proving the effects of each ingredient that creates the announced function
Product efficacy testing results for functional foods with new uses
Quality control plan
Periodic monitoring plan

Declaration of compliance with food safety regulations
Declare detailed information about the product
Certificate of Free Sale/Health Certificate/Equivalent Certificate issued by the competent state agency of the manufacturing country
Functional product testing results within 12 months from the testing date.
Periodic monitoring plan
Product labels circulated in the country of origin and secondary labels in Vietnamese
Complete product sample
Information and scientific documents proving the product's effectiveness or the effectiveness of each ingredient that makes up the functional food have been announced.

Procedure for submitting application for publication

Product declaration process:

Step 1: Submit complete legal documents as prescribed to the Department of Food Safety.

Step 2: The Food Safety Department receives and checks the application. After 30 days (upon receipt of a complete and valid application), the Ministry of Health must issue a Certificate of Acceptance of the Declaration of Compliance with Food Safety Regulations.

If the license is not issued after 30 days, the Ministry of Health must have a written response explaining the reason for not issuing the license.

Step 3: Return the receipt of the announcement to the agency, organization or individual.

2. Announcement of cosmetic product groups

Where to submit?

For each different cosmetic line, there will be a different competent authority to issue cosmetic declaration certificates:

1. Department of Drug Administration (Ministry of Health) for imported cosmetics

2. Department of Health at the place where the manufacturing plant is located for domestically produced cosmetics.

3. Economic Zone Management Board for cosmetic lines produced in special economic zones such as: Moc Bai border gate economic zone (Tay Ninh), Lao Bao special economic - commercial zone (Quang Tri).

Profile components

Domestically produced cosmetics

Imported cosmetics

The dossier includes:

Cosmetic declaration form according to the form of the licensing authority
Certified copy of business registration certificate of the manufacturer or authorized distributor.
Original or copy of the Manufacturer's Authorization Letter to the distributor authorized to make the announcement on behalf of the Manufacturer.
Test report and published formula of cosmetics
Cosmetic quality standards and testing methods.
Test report
Product Label
Technical or clinical data to demonstrate the special uses of the product (if any)

Cosmetic declaration form according to the form of the licensing authority
Certified copy of Business Registration Certificate of the organization or individual responsible for bringing the product to market
Certificate of free circulation registration and Authorization letter from the manufacturer or product owner authorizing an organization or individual to make the announcement on behalf of the manufacturer.
Technical or clinical data to demonstrate the special uses of the product (if any)
Scientific documents or manufacturer's explanation of the uses and ingredients of the cosmetic product (in case the ingredients or uses have specific characteristics that need to be clarified at the request of the registration authority).

Time of publication

According to regulations, the time to receive documents and issue cosmetic declaration numbers from the date the documents are submitted and accepted as valid is 03 working days. However, in reality, this time often lasts from 15-20 days.

3. Milk declaration

Where to submit?

Milk is a special nutritional food, the state also has specific regulations as follows:

Submit to the competent state management agency designated by the Provincial People's Committee for medical nutritional foods, foods for special diets, nutritional products for children up to 36 months of age.

Profile components

Domestic milk	Imported milk
Business registration certificate Product Label Test results are valid for 12 months. Product sample for testing Certificate of food safety and hygiene qualified facility or HACCP or ISO 22000 certification Scientific documentation proves the effects.	Business registration certificate Product Label Test results are valid for 12 months. Product sample for testing Certificate of Free Sale (Or Export Certificate or Health Certificate) Scientifically proven to work.

IV. WHEN MAKING PRODUCT DECLARATIONS - WHAT DIFFICULTIES ARE COMMONLY ENCOUNTERED?

1. Failure to correctly identify the competent authority to make the announcement

In part 3 of this article, NanoFrance has emphasized the issue of “Where to submit” – Which competent authority is responsible for receiving and processing your application. For each different product, you need to go to the correct unit in charge to process the application.

2. Preparing the components of the dossier not in accordance with the regulations of the competent authority

Although Decree 15 has very clear regulations on the components required in the declaration dossier. However, most non-professional individuals often get stuck in completing each type of document inside. This unintentionally leads to longer processing time.

3. Problems related to labeling, ingredients, and the unit responsible for the product

Specifically:

→ Regarding label names: Regulations on product naming are in Article 6, Joint Circular No. 34/2014/TTLT-BYT-BNNPTNT-BCT, such as: Must not distort or mislead consumers, Product names can be accompanied by other supporting words to help consumers correctly understand the nature and natural conditions of the product...

→ For structural components: The structural components must be listed on the product label, the order of the components...

→ For the unit responsible for the product: There is a difference between domestically and internationally produced products.

V. WHY SHOULD YOU CHOOSE A THIRD PARTY TO PROVIDE PUBLICATION SERVICES?

1. Three advantages of choosing an external publication service

There are three important reasons why we recommend you choose the publication service of a professional document preparation unit instead of completing it directly:

1. Quick and simple procedure, no effort on your part

2. Professional service, save time, get numbers faster

3. Help products reach the market sooner, without affecting your business plan thanks to quick completion of paperwork.

2. NanoFrance provides Professional - Fast - Accurate publication services!

In addition to providing core services: Production of Functional Foods, Cosmetics, Milk - Nutritional Foods, Medical Equipment, NanoFrance also supports customers in completing declaration documents for products in 4 groups:

Functional food declaration
Cosmetic declaration
Milk announcement – Nutritional food
Medical Device Declaration

With experience in cooperating with many product distributors, and having completed legal documents for nearly 500 different product lines, NanoFrance is confident in bringing you the best quality of service!

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