Classification
Product TypeProcessed Food
Product FormPackaged shelf-stable
Industry PositionPackaged Consumer Food
Market
Milk/cream sandwich biscuits and cookies in Vietnam are a mass-market packaged snack category supplied by both domestic manufacturers and imported brands. Large branded producers operate locally (including Mondelēz/Kinh Do’s biscuit portfolio), while Vietnamese confectionery companies also market cookie and biscuit lines. As a pre-packaged processed food category, products are typically managed through Vietnam’s food safety self-declaration regime before manufacture/import, alongside import food-safety inspection processes. Label compliance is a key go/no-go issue: goods labeling rules are transitioning under Decree 37/2026/ND-CP, and nutrition facts labeling requirements under MOH Circular 29/2023/TT-BYT apply from January 1, 2026 for in-scope prepackaged foods.
Market RoleDomestic manufacturing market with significant imports
Domestic RoleMainstream packaged snack category sold nationwide through modern retail and traditional trade; domestic producers compete with global brands produced locally or imported
Market Growth
SeasonalityYear-round availability; demand can spike around major gifting/holiday periods (e.g., Tet) for assorted cookie tins and gift formats.
Risks
Regulatory Compliance HighNon-compliant labeling can block market circulation: Vietnam’s goods labeling framework has been updated under Decree 37/2026/ND-CP (with transitional provisions from prior labeling decrees), and MOH Circular 29/2023/TT-BYT prohibits manufacture/print/import/use of non-conforming nutrition labels from January 1, 2026 for in-scope prepackaged foods.Run a pre-shipment label/legal checklist with the Vietnamese importer: verify compulsory label contents, Vietnamese supplementary labeling where needed, and Circular 29 nutrition panel format/values before printing.
Regulatory Compliance HighDocumentation and self-declaration gaps can trigger delays or enforcement actions: Decree 15/2018/ND-CP requires self-declaration for prepackaged processed foods with supporting food safety test results in the required validity window, and Vietnam’s import inspection regime can include post-clearance verification.Maintain an importer-ready dossier (self-declaration form, ISO 17025-aligned lab results, product specs, label artwork, and change-control for ingredients/origin/name) and refresh testing before expiry.
Food Safety MediumNon-conformity findings (e.g., contaminants or non-compliant additives/claims) can lead to penalties and product destruction/recall costs under Vietnam’s enforcement framework for food safety violations.Implement HACCP-based controls, supplier approval for dairy and fat ingredients, and finished-goods testing aligned to Vietnam requirements; retain traceability records to support targeted recalls if needed.
Sustainability MediumEPR obligations for recycling products/packaging can create compliance workload and fees for importers/producers placing consumer packaging for food on the Vietnamese market.Confirm whether the importer will fulfill EPR (recycling organization vs. financial contribution) and incorporate EPR reporting/fees into landed-cost planning and contracts.
Logistics MediumFreight volatility and humidity exposure are material risks for this bulky, shelf-stable category; container delays and moisture ingress can damage crispness and packaging integrity.Specify moisture-barrier packaging and desiccant/liner where appropriate; use sea-freight service levels with controlled storage, and add destination QA sampling for breakage/moisture.
Intellectual Property LowBrand owners face imitation/parallel-market risks; protecting trademarks and monitoring channels matters for cookie/biscuit brands in Vietnam.Register trademarks with Vietnam’s NOIP and align distributor agreements with anti-counterfeit monitoring and takedown processes.
Sustainability- Packaging compliance and cost exposure under Vietnam’s Extended Producer Responsibility (EPR) framework for importers/producers of consumer packaging for food products
Standards- HACCP
- ISO 22000
- FSSC 22000
- Halal (company-claimed certifications for certain Vietnamese biscuit/cookie producers)
FAQ
What are the key compliance steps before importing prepackaged sandwich biscuits/cookies into Vietnam?For prepackaged processed foods, suppliers typically complete product self-declaration under Decree 15/2018/ND-CP (including required supporting test results) and then follow Vietnam’s import food safety inspection and customs clearance procedures. In parallel, labels must meet Vietnam’s goods labeling rules (updated under Decree 37/2026/ND-CP) and nutrition facts labeling rules under MOH Circular 29/2023/TT-BYT, which apply for compliant labels from January 1, 2026.
What labeling changes matter most in 2026 for biscuits/cookies sold in Vietnam?Two areas are most likely to cause shipment holds or relabeling: (1) compulsory goods label contents and imported-goods labeling/supplementary Vietnamese labeling under Decree 37/2026/ND-CP (with transitional provisions for goods labeled under earlier decrees), and (2) mandatory nutrition facts labeling requirements under MOH Circular 29/2023/TT-BYT, which prohibit import/use of non-conforming labels from January 1, 2026 for covered prepackaged foods.
Do milk/cream sandwich biscuits require pre-approval product registration in Vietnam?They are generally treated as prepackaged processed foods that use the self-declaration pathway under Decree 15/2018/ND-CP, rather than the pre-approval product declaration route that applies to categories like health supplements, medical foods, special dietary foods, and certain children’s products. Importers should still confirm the correct category and competent authority with their Vietnam partner before shipping.