Classification
Product TypeIngredient
Product FormLiquid (aqueous solution)
Industry PositionFood additive (acidulant) / processing ingredient
Market
In Vietnam, phosphoric acid is a permitted food additive listed as INS 338 under Ministry of Health Circular 24/2019/TT-BYT, primarily used for acidification/pH control in food and beverage manufacturing. Trade data for HS 280920 (phosphoric acid and polyphosphoric acids) indicates Vietnam participates in both imports and exports; UN Comtrade (via World Bank WITS) reports 2023 exports of about USD 145.3 million and imports of about USD 17.3 million (note: HS data does not separate food-grade from industrial/fertilizer uses). Market access is compliance-driven: additives must align with the permitted list/conditions in Circular 24/2019/TT-BYT and product declaration requirements under Decree 15/2018/ND-CP. The product is a corrosive chemical; safe storage/handling and dangerous-goods logistics are important for warehousing and transport.
Market RoleProducer and exporter (HS 280920) with ongoing imports; regulated domestic consumer market for food-grade additive use (INS 338)
Domestic RoleB2B ingredient used by food and beverage manufacturers as an acidulant/pH control agent under Ministry of Health food-additive rules
Risks
Regulatory Compliance HighMarket access can be blocked if the product’s intended food-additive use is not aligned with Vietnam MOH Circular 24/2019/TT-BYT (permitted list/conditions, including INS 338) and if the required product declaration/self-declaration steps under Decree 15/2018/ND-CP are incomplete or inconsistent; this can trigger customs/market surveillance actions, distribution suspension, or recalls.Verify INS 338 listing and intended use conditions under Circular 24/2019/TT-BYT, prepare a Decree 15-compliant declaration dossier with valid ISO 17025 test results, and align product specs/labeling and COAs to food-additive identity/purity expectations.
Food Safety MediumOff-spec impurity profiles or inconsistent concentration/quality (relative to applicable identity/purity specifications for INS 338) can create compliance and customer acceptance risk in Vietnam’s food manufacturing supply chain.Require batch COAs, run third-party verification testing at ISO 17025 labs, and qualify suppliers against JECFA-aligned specifications for phosphoric acid (INS 338) and any Vietnam-required safety indicators.
Logistics MediumPhosphoric acid solutions are commonly shipped as corrosive dangerous goods (e.g., UN 1805, Class 8, Packing Group III shown in an example food-grade SDS), increasing transport constraints, documentation burden, and exposure to delays and cost volatility.Use experienced DG forwarders, confirm UN/DG documentation and packaging compatibility early, and ensure warehousing uses corrosion-resistant containment and spill-response readiness.
Chemical Safety MediumAs a corrosive industrial chemical, storage and trading may trigger chemical safety management obligations under Vietnam’s Law on Chemicals framework and implementing decrees (e.g., Decree 113/2017/ND-CP and amendments), affecting facility readiness and compliance workload.Conduct a Vietnam chemical compliance check for the specific concentration and classification, implement chemical safety training and documentation (including SDS availability), and confirm any licensing/declaration requirements applicable to the importer/warehouse operator.
Labor & Social- Worker safety risk from corrosive liquid handling (acid burns/eye damage and mist inhalation); requires PPE, training, and appropriate storage/handling controls (example SDS reference).
FAQ
Is phosphoric acid allowed as a food additive in Vietnam?Yes. Vietnam’s Ministry of Health Circular 24/2019/TT-BYT includes phosphoric acid in the permitted food additive list as INS 338 (Phosphoric acid), subject to the circular’s use conditions and any applicable maximum levels for specific food categories.
What is a common regulatory step before a food additive can be sold in Vietnam?Decree 15/2018/ND-CP sets product declaration/self-declaration requirements for food products including food additives before distribution. If a food additive is not on the permitted list (or is a mixed additive with new uses), it must be registered with the Ministry of Health/Vietnam Food Administration under the decree and related MOH guidance.
Why do shipments of phosphoric acid often face extra logistics requirements?Phosphoric acid solutions are corrosive and are commonly transported under dangerous-goods rules. For example, a food-grade 85% phosphoric acid SDS lists transport identification as UN 1805 (Phosphoric acid solution), Class 8, Packing Group III, which can add DG documentation, carrier restrictions, and handling requirements.