Classification
Product TypeIngredient
Product FormPowder (food-grade additive)
Industry PositionFood Additive (Antioxidant)
Market
Sodium erythorbate (INS 316) is regulated in Vietnam as a permitted food additive under the Ministry of Health’s Circular 24/2019/TT-BYT, with use conditions tied to specified food categories and maximum levels/GMP in its appendices. Market access is primarily compliance-driven: the additive must be on the permitted list, used within allowed conditions, and meet applicable technical requirements referenced by Vietnamese rules (including Codex/JECFA where relevant). For products marketed domestically in Vietnam, food additives are generally subject to product self-declaration procedures under Decree 15/2018/ND-CP, which require a dossier and recent test results. As a compact, high-value ingredient, supply is typically handled through B2B importers/distributors to industrial food processors rather than consumer retail channels.
Market RoleImport-dependent ingredient market (net importer)
Domestic RoleRegulated antioxidant additive supplied B2B to food processors under Vietnam Ministry of Health food-additive management rules
Specification
Compositional Metrics- CAS number: 6381-77-7 (WHO JECFA database entry for sodium erythorbate).
- Functional class: Antioxidant (Codex/GSFA and JECFA references).
- ADI: Not specified (JECFA evaluation history for sodium erythorbate).
Grades- Food-grade material meeting applicable identification and purity specifications referenced by Vietnamese rules (national regulations/standards, or Codex/JECFA where applicable).
Packaging- Labeling for additives in Vietnam is expected to include the additive category, additive name, and INS number where applicable, consistent with Vietnam goods-labeling rules.
Supply Chain
Value Chain- Overseas manufacturer → Vietnam importer/distributor (product self-declaration for domestic sale) → industrial food processor use in permitted food categories
- Where repackaging/portioning occurs in Vietnam: written producer consent and compliant additive labeling practices are required under Vietnam’s food-additive management and goods-labeling rules
Freight IntensityLow
Transport ModeMultimodal
Risks
Regulatory Compliance HighFood additives marketed domestically in Vietnam are generally subject to product self-declaration requirements, and additives must be permitted and used within the applicable maximum levels/GMP conditions; failures in declaration or permitted-use alignment can block market access and trigger enforcement actions.Confirm Sodium erythorbate (INS 316) is listed and match intended applications to Circular 24/2019/TT-BYT appendices; complete Decree 15/2018/ND-CP self-declaration with a valid (≤12 months) ISO/IEC 17025 test report and maintain an internal compliance file for inspections.
Labeling MediumLabeling that omits required additive identification elements (including additive category/name and INS number where applicable) can result in non-compliance findings during market surveillance or import-related checks.Run Vietnamese label/secondary label review against Decree 43/2017/ND-CP requirements for additives and ingredient listings before distribution.
Food Safety MediumIf the additive does not meet applicable identification/purity or contaminant limits referenced by Vietnamese rules (national requirements or Codex/JECFA where applicable), it can be treated as non-conforming and lead to sanctions or product handling measures under Vietnam’s food-safety enforcement regime.Require supplier specifications aligned to JECFA/Codex references for INS 316, and implement periodic verification testing consistent with the parameters used for the self-declaration dossier.
Documentation Gap MediumSelf-declaration support testing is time-bounded (test results issued within 12 months); expired or mismatched test documentation can delay filing, disrupt distribution, or weaken the defense in inspections.Set a compliance calendar for test report renewal and ensure product naming consistency across labels, COAs, and declaration dossiers (e.g., Sodium erythorbate / Sodium isoascorbate / INS 316).
FAQ
Is sodium erythorbate permitted for use as a food additive in Vietnam?Vietnam’s Ministry of Health Circular 24/2019/TT-BYT promulgates the permitted food additive lists and related maximum use levels/GMP appendices, and it includes sodium erythorbate (INS 316) as an antioxidant additive.
What is the key compliance step to sell imported food additives in Vietnam?For food additives marketed domestically, Decree 15/2018/ND-CP sets out a product self-declaration process that includes a self-declaration form and a food-safety test report issued within the prior 12 months by a designated or ISO/IEC 17025-compliant laboratory.
How should sodium erythorbate be identified on labels in Vietnam?Vietnam’s goods-labeling rules (Decree 43/2017/ND-CP) require that additives be presented with the additive category and the additive name, and the International Numbering System (INS) number where applicable, alongside other mandatory labeling information.