Classification
Product TypeIngredient
Product FormSolid (crystalline/powder)
Industry PositionFood Additive Ingredient (Antioxidant)
Market
In Vietnam, food additives are regulated by the Ministry of Health under Circular 24/2019/TT-BYT, which sets a permitted-list framework and maximum use levels (ML) by food category and includes butylated hydroxytoluene (BHT, INS 321) as an antioxidant. Decree 15/2018/ND-CP establishes that single-ingredient food additives on the Ministry of Health’s permitted list are handled through product self-declaration supported by an in-date food safety test report from a designated/ISO 17025 laboratory. Demand is primarily business-to-business from Vietnamese food manufacturers using antioxidants in specific permitted categories (commonly fats/oils and other processed categories listed with ML). The primary constraint for this product-country pair is regulatory compliance on intended use/ML and dossier completeness, which can block market placement if mismanaged.
Market RoleImport-dependent ingredient and domestic user market
Domestic RoleIndustrial food-manufacturing input (antioxidant) used only in permitted food categories and within ML
Specification
Physical Attributes- White, crystalline or flaked solid; odourless or faint aromatic odour.
Compositional Metrics- Food-grade assay target: not less than 99.0% (JECFA monograph specification).
- Melting range reference: about 69–72°C (JECFA monograph specification).
- Heavy metal control example: lead not more than 2 mg/kg (JECFA monograph specification).
Grades- Food-grade meeting FAO/JECFA Combined Compendium (Monograph 1) specifications
Supply Chain
Value Chain- Overseas manufacturer (food-grade BHT) → international chemical distributor → Vietnam importer/food-additive trader → industrial food manufacturer formulation use → finished food supply chain
Temperature- Store in tightly closed containers in a dry, well-ventilated place; separate from strong oxidants (typical SDS/chemical safety guidance compiled in PubChem).
Shelf Life- Stable under recommended storage conditions (chemical safety references compiled in PubChem).
Freight IntensityLow
Transport ModeMultimodal
Risks
Regulatory Compliance HighVietnam market placement can be blocked if BHT (INS 321) is used outside the permitted food categories or above the maximum use levels (ML) set under Circular 24/2019/TT-BYT, or if the required Decree 15/2018/ND-CP self-declaration/registration pathway is not correctly followed for the intended use.Map the intended application to Circular 24/2019/TT-BYT food-category permissions/ML before sale; run a Decree 15/2018/ND-CP checklist to confirm self-declaration vs. Ministry of Health registration and ensure dossier completeness (including valid ISO 17025/designated-lab testing).
Documentation Gap MediumDocument inconsistencies (product identity, INS/CAS naming, assay, impurity limits, or test report validity window) can trigger non-acceptance during self-declaration review, inspection, or downstream customer audits in Vietnam.Standardize nomenclature across invoice/COA/test reports to 'Butylated hydroxytoluene (BHT), INS 321, CAS 128-37-0' and keep a controlled dossier pack with in-date testing and notarized translations where required.
Food Safety MediumFood-grade conformity failures (e.g., assay or impurity/heavy metal limits not meeting accepted specifications) can lead to rejection by Vietnamese buyers and potential regulatory action if distributed.Procure material that meets FAO/JECFA specifications (e.g., assay ≥99.0% and relevant impurity limits) and verify with a COA plus an ISO 17025-accredited test report aligned to the Decree 15/2018/ND-CP dossier requirement.
FAQ
Is butylated hydroxytoluene (BHT) permitted for use as a food additive in Vietnam?Vietnam’s Ministry of Health Circular 24/2019/TT-BYT includes butylated hydroxytoluene (BHT) under INS 321 as a permitted food additive and sets maximum use levels (ML) by food category. Use is only allowed within the specified food categories and ML limits.
What is the typical regulatory pathway to place a single-ingredient food additive like BHT on the Vietnamese market?Under Decree 15/2018/ND-CP, food additives are generally subject to product self-declaration, supported by a food safety testing result sheet issued within 12 months by a designated or ISO 17025-accredited laboratory. If a food additive is outside the permitted list or not used for intended foods, the declaration must be registered with the Ministry of Health.
What basic quality specification is commonly referenced for food-grade BHT?FAO’s JECFA food additive specification monograph for butylated hydroxytoluene states an assay of not less than 99.0% and includes purity criteria such as a lead limit (not more than 2 mg/kg). Buyers commonly use such JECFA specifications as a benchmark when assessing food-grade conformity.