Vietnam retired its old two-tier product classification on 1 July — the same day an unrelated new law added a second compliance regime on top of it

What actually changed on 1 July

Vietnam's National Assembly passed Law No. 78/2025/QH15, amending the Law on Product and Goods Quality, on 18 June 2025; it took effect 1 January 2026. The government followed with Decree No. 37/2026/NĐ-CP on 23 January 2026, the implementing text that replaces the old binary classification — Group 1 goods that manufacturers self-declare, Group 2 goods that require mandatory state inspection — with a three-tier risk model: low, medium, and high. The decree gave the old system a six-month runway: from 23 January through 30 June 2026, Decrees 132/2008/NĐ-CP, 74/2018/NĐ-CP and 13/2022/NĐ-CP remained usable in parallel with the new risk tiers. On 1 July 2026, that runway ended. The old decrees expired, and every product a brand places on the Vietnamese market now has to sit in one of the three risk tiers to be compliant at all.

Two laws, one date: risk tiers meet a new disclosure regime

Decree 37/2026 does more than rename the old two-bucket system. High-risk products come with a mandatory traceability obligation attached to the tier itself, not bolted on separately. The decree also defines a "Product Digital Passport" — an electronic dataset covering product name, a GTIN code, the responsible enterprise, origin and traceability data, quality certification, and production/expiry dates — that producers can use in place of an electronic label where the underlying requirements are met. None of that determines what a brand actually has to do without one prior step: knowing which of the three risk tiers a given SKU falls into, since the tier is what decides the inspection burden and the label content. Layered on top, from the same 1 July date, the Law on E-Commerce requires every online marketplace and seller to publicly disclose product data — including expiry dates and lot numbers — and ends anonymous selling by requiring verified seller identity. It is a second statute, passed by a different vote six months after the product-quality decree, that happens to converge on the identical compliance date.

The real subject: a SKU's risk tier decides what must stay on paper

Under the old regime, a product was either self-declared or state-inspected — a binary flag that, once set, rarely needed revisiting. Under the risk-tier system, that flag is a spectrum, and it is the input to two separate downstream decisions: how much of the label content is legally required to stay physically printed versus how much can move to an electronic label or a Product Digital Passport, and whether the product carries a mandatory traceability obligation because it landed in the high-risk band. Getting the tier wrong does not just misclassify a product on paper — it can mean printing a label that omits content the physical-label rule actually requires, or skipping a traceability system a high-risk classification actually demands. None of that is visible from a product's name or category alone; it has to be assigned, tracked, and kept current at the SKU level, market by market, as Vietnam's own guidance on tier boundaries develops.

Why it matters for brands

For a global brand selling into Vietnam — directly or through marketplaces like Shopee, Lazada or TikTok Shop — 1 July stacked two obligations that most compliance calendars tracked separately, if at all. Every SKU already on the Vietnamese market needs a risk-tier assignment now that the old Group 1/Group 2 flag no longer means anything, which in turn determines what has to stay on a physical label versus what can move to an electronic one. At the same time, any product sold through a marketplace now depends on that platform correctly disclosing product data — expiry dates, lot numbers, licenses — under a law the brand does not control but is exposed to. A grandfather rule softens the immediate edge: goods manufactured, imported or already circulating before 23 January 2026 can keep moving until their existing expiry, and labels printed before that date remain usable for up to two years. But that window is a countdown, not a pass — and it runs out well before most brands' next packaging cycle would have addressed it otherwise.

Two ways to read 1 July