Vietnam Traceability Mandate — Quality Law and Risk Tiers

For Japanese manufacturers with plants in Vietnam, 2026 is the year the rules changed for what information has to travel with a product. Law No. 78/2025/QH15, the amendment to the Law on Product and Goods Quality, took effect on January 1 2026, and when the transition period closed on July 1 the new risk-based three-tier classification became fully mandatory. This sequence of amendments is the moment traceability clearly emerged as a regulatory requirement in Vietnam. This article walks through what the law and its implementing decree actually say, which technologies are accepted, what the Ministry of Industry and Trade portal expects, and what a factory should be preparing on the ground.

What Vietnam’s amended quality law actually changed

Two product groups were replaced by three risk tiers

The heart of the amendment is that the logic of product classification itself was swapped out. Before the change, products in Vietnam were managed under two categories, Group 1 and Group 2. Those two categories were abolished and replaced with a three-tier risk classification of low, medium and high risk.

The legal basis is Law No. 78/2025/QH15, passed by Vietnam’s National Assembly on June 18 2025. It amends and supplements a number of articles of the Law on Product and Goods Quality, and it took effect on January 1 2026. Because the axis of classification shifted from “which group does this belong to” to “how much risk does this product carry”, every business that manufactures, imports or distributes in Vietnam now has to re-read where its own products land.

The important thing here is that this is not a change of vocabulary. As covered below, for the high-risk tier the traceability obligation is written into the definition of the tier itself. The situation is not “the labels on the classification changed but the work is the same”. It is “which tier you fall into determines what information has to be attached to the product”.

Decree No. 37/2026/ND-CP set the implementing rules and technical standards

Statute text alone does not run a factory. The operational detail sits in Decree No. 37/2026/ND-CP, dated January 23 2026. This decree provides the implementing rules for the amended law, and within it sets the technical standards for traceability codes.

The technologies accepted and recommended as technical standards are QR codes, data matrix codes, RFID and NFC. In other words, no single method is imposed. If your product is marked at the individual pack level, QR codes or data matrix are a natural fit; if you need to track at the outer carton or returnable container level, RFID or NFC are equally available under the rules. QR codes tend to come up first in practice because existing marking and printing steps can usually absorb them, and because the reading side rarely needs new dedicated hardware.

The legal basis, the effective dates and the ministry’s own framing are laid out alongside the intent of the scheme in this Nhan Dan report. The fact that several technologies are listed side by side tells you what the regulation is really after. It is not asking you to buy a particular device. It is asking that the information behind the code be complete.

The transition period and full enforcement on July 1 2026

A transition period was built into the switchover. From January 23 to June 30 2026, the old and new classifications ran in parallel. On July 1 2026 the old classification lapsed and the three-tier risk classification became fully mandatory. Note that Vietnam’s separate e-commerce law also took effect on that same July 1. Any business with an online sales channel had to look at both at once.

Laying the dates out in a single table makes it easier to see where your own operation currently stands.

The date worth circling in this table is January 23 2026, because it carries two meanings at once. It is the start of the transition period, and it is also the cut-off date for the grandfather provisions discussed later. How your existing stock and your already-printed labels are treated depends on which side of that date they fall.

The diagram above shows the move from the old two-group system to the three-tier risk classification, and how that maps onto the timeline. From here we look at how traceability is treated differently in each of the three tiers.

How the three risk tiers relate to the traceability obligation

For the high-risk tier, the obligation is inside the definition

If there is one design point to understand about this scheme, it is this one. For the high-risk tier, traceability is not bolted on afterwards as an additional requirement. It is built into the definition of the risk tier itself.

That distinction changes what the rule means in practice. When something is an additional requirement, there is room to ask when it applies and whether there is any grace period. When it is inside the definition of the tier, traceability is simply assumed the moment a product is classified there. And in fact, traceability became mandatory immediately for high-risk items. The categories named are chemicals, industrial explosive precursors and tobacco products.

For other areas, traceability is recommended for now, which is to say voluntary. Reading that as “nothing to do yet” is risky, though. Vietnam already has a live official portal, and the machinery for listing products and mandating traceability is already turning. As long as that machinery is running, the scope of covered items can widen.

Here is how the three tiers compare.

Even if your products sit in a recommended tier, the fact that the lists came first is not something to shrug off. Being on a list means the authorities have already identified that item through a risk lens.

“Industrial machinery, equipment and materials” is one of the seven medium-risk categories

On June 18 2026 the Ministry of Industry and Trade (MoIT) published the list of medium-risk products falling under its own management responsibility. There are seven categories.

The one that lands directly on Japanese manufacturing is number six, industrial machinery, equipment and materials, because it maps straight onto plant equipment procurement and supplier management. Whether you are installing equipment at a Vietnamese site, sourcing materials locally, or manufacturing and selling industrial machinery, equipment and materials yourself, designing your procurement or sales approach without knowing this category exists is not realistic. The scope of the original list is documented in this Product Compliance Institute summary.

Note that chemicals and explosive precursors also appear by name on the high-risk side. The same words show up in both tiers, but the way a list is organised and the way a risk tier is defined do not always line up one to one. Where your specific product actually falls has to be judged by comparing the wording of the list against what the product really is. Deciding a tier solely because a name looks similar is the unsafe route.

What to build while you are still in a “recommended” tier

If your products fall into medium or low risk and stay voluntary for the time being, the preparation work does not change. What will be demanded when the obligation arrives is the ability to produce raw material origin, manufacturing process data and distribution information in a unified data format. That is not something you assemble in the six months after a rule starts. It depends on how far your internal records are already joined up at the product level.

Put differently, the recommended period is usable as preparation time. Between shaping outward-facing data to match what the scheme wants and connecting internal records at the product level, the second job takes far longer. On building those internal records, our traceability implementation guide covers how to choose between in-house builds and packaged systems, down to how to evaluate vendors.

What you actually register on the verigoods.vn portal

Launch and role

verigoods.vn is the official traceability portal operated by the Ministry of Industry and Trade. It went live on December 23 2025. The fact that it was live before the amended law’s effective date of January 1 2026 says something about how prepared this scheme was.

What companies do on the portal is register and update raw material origin, manufacturing process data and distribution information in a unified data format. On top of that, they attach an electronic authentication code or electronic label, in practice something like a QR code, to the product. Consumers and authorities can then verify the registered information from that code. For the overall shape of the scheme and its covered products, this VnEconomy article is a solid account of the position as of entry into force.

The real weight of the words “unified data format”

The phrase “register on the portal” makes people picture filling in a web form, but that is not where the workload is. The workload is in whether your organisation is in any state to match a unified data format at all.

To produce raw material origin, you need to be able to trace internally which incoming lot went into which product. To produce manufacturing process data, you need records of when, on which equipment and under which conditions that product was made, held at the product level. To produce distribution information, you need shipped lots linked to the customers who received them. In a plant where those three are not connected internally, the act of registering on the portal becomes manual work every single time.

Which means that responding to Vietnam’s traceability scheme looks like an outward-facing registration task but is really an internal traceability project. Rather than “the rule started, so we register”, the faster route in the end is “build the internal state that makes registration possible”.

How to collect shop-floor data

When a plant in Vietnam tries to hold manufacturing process information at the product level, the first wall most sites hit is that equipment data and production results live in separate places. The equipment keeps its logs inside the machine builder’s software, while production results sit in daily reports or another system. Until those two are joined by production lot, you cannot say under which conditions a given lot was made.

Much of what gets described as IoT adoption in Vietnamese factories is, in substance, the work of creating that join. The goal is not to add more sensors. It is to attach the production lot as a key to the data the equipment already emits, so it can be pulled back later on a per-product basis.

The diagram above shows the three record types, raw material origin, manufacturing process and distribution information, being joined by a product code and then presented externally through an electronic authentication code. The quality of the data you push to the portal is decided by how far that join has actually been made.

Labelling and the grandfather provisions in practice

The four items that must be printed regardless of tier

Label requirements also vary by risk tier. The practical dividing line is between the items that must be physically printed and the items that are allowed to move to electronic display.

Only four items are guaranteed to require printing regardless of tier.

Items other than these four may in some cases be moved to electronic display. You can read that as a gain in label design freedom, because information that used to be crammed onto the printed face can potentially be offloaded. For small components and products with little available surface area, that difference matters.

At the same time, anything moved to electronic display has to stay reliably retrievable from the code. It is more accurate to see this as a trade. You reduce what goes on the printed face, and in exchange you take on heavier responsibility for the data behind it.

Grandfather provisions with January 23 2026 as the cut-off

The changeover comes with transitional relief for existing stock and already-printed labels, commonly called a grandfather clause. There are two parts to it.

• Products manufactured before January 23 2026 may continue circulating until their expiry
• Labels printed by that same date may be used for up to two years

Both are practical measures to avoid scrapping inventory at the switchover. They do expire, though. The two-year window on printed labels is best treated as time to redo artwork, line up your print supplier and swap the marking procedure on the floor. For a practical reading of the transition timeline, the grandfather provisions and the labelling requirements, this Cleo Labs breakdown organises them clearly.

On the inventory side, watch out for the common confusion between manufacturing date and receipt date. The reference point is when the product was manufactured. If your warehouse ledger only holds receipt dates, you cannot state from the product side whether the relief applies. That, again, comes back to whether manufacturing records exist at the product level.

How to run the implementation at a Vietnamese plant

Some areas will not accept a Thailand template as-is

For Japanese companies with several ASEAN sites, rolling out to Vietnam what was already built in Thailand is the natural instinct. And it is effective. Production management and quality management thinking has a great deal in common across sites, so horizontal rollout genuinely works.

The parts tied to regulation are different, though. Vietnam has its own legislation and its own official portal. Carrying over a quality record format built in Thailand still leaves you rebuilding the mapping to the unified data format on the Vietnamese side. The broader theme of Vietnam-specific conditions breaking a Thailand-designed spec also comes up from the power supply and cross-border regulatory angles in our piece on equipment monitoring at Vietnamese plants. Across the regulatory scheme, the infrastructure and cross-border rules alike, separating the layers you can standardise from the layers you cannot, and doing it early, is what saves you from rework.

The same separation applies when headquarters looks at overseas plant traceability from Japan. What should be standardised is the foundation, the product code scheme, the granularity of records and how data is held. Each country’s filing formats and labelling requirements ride on top of that foundation as a country-specific adapter. Structure it that way and when a country moves, as Vietnam just did, the blast radius stays inside the adapter layer.

It overlaps with what customers and export markets already ask for

The other thing that gets missed in practice is how much regulatory compliance overlaps with customer requirements. The traceability Vietnam’s quality law demands and the traceability your export markets or customers demand have different legal bases, but the data they need overlaps heavily. Raw material origin, manufacturing conditions and shipment records are the same substance either way.

For supply into the EU, for example, the requirement to evidence raw material origin for covered products arrives through a separate framework. That structure is the same shape as the one we covered using natural rubber sourcing in Thailand as the subject, in our article on EUDR compliance. Stand up a separate mechanism for each regime and you will keep rebuilding the same data. Bundle your internal records into one and you are only adding output destinations.

Cost and sequencing

The question that always surfaces at the evaluation stage is how far you have to go and what it costs. Even limiting the scope to Vietnamese compliance, the work splits into three broad parts.

• Joining internal records at the product level. Mostly acquiring process data and linking it with production lot as the key
• Assembling the data for external presentation. Mostly conversion into the unified data format and designing the update cadence
• Applying and reading codes on the product. Mostly marking or applying QR codes and the operating procedure on the floor

The first of these absorbs most of the cost and most of the schedule. The third tends to get discussed first because it is a visible investment, but installing a marking device is meaningless if the information behind the code does not exist internally. For a breakdown of costs by layer and how to get to a running system, our article on traceability system build cost sets it out as a four-layer model with a 90-day roadmap.

As a sequence, it works to first pin down which risk tier your products fall into, then take inventory of which of your current records can and cannot be retrieved per product, and only then decide the order in which to close the gaps. If you let the regulatory dates chase you into starting from the third part, you will end up with codes on products and nothing behind them.

The photo above shows the shop-floor step of applying a code to a product and reading it back. What the regulation is asking for is not the scan itself, but the correct records waiting on the other side of it.

Frequently asked questions

Which products does Vietnam’s traceability obligation apply to

Traceability became mandatory immediately for the high-risk tier, which names chemicals, industrial explosive precursors and tobacco products. Other areas are recommended for now, which is to say voluntary. Because the high-risk tier has the traceability obligation built into the definition of the tier itself, however, a change in tier assessment brings the obligation with it. Confirming which tier your products fall into is the first piece of work.

What happened to the old classification under the amended quality law

Law No. 78/2025/QH15 was passed by the National Assembly on June 18 2025 and took effect on January 1 2026. The old two-category system of Group 1 and Group 2 was abolished and replaced with three tiers of low, medium and high risk. From January 23 to June 30 2026 the old and new classifications ran in parallel as a transition period, and on July 1 2026 the old classification lapsed and the three-tier classification became fully mandatory.

Are traceability QR codes mandatory in Vietnam

QR codes are not the only method specified. Decree No. 37/2026/ND-CP sets the technical standards for traceability codes, and QR codes, data matrix, RFID and NFC are all accepted and recommended. QR codes dominate the conversation in Vietnam because marking and reading are easy to implement and consumer-side devices are already everywhere. Depending on product form and distribution unit, there is room to choose another method.

What do you register on verigoods.vn

It is the official traceability portal operated by the Ministry of Industry and Trade, live since December 23 2025. Companies register and update raw material origin, manufacturing process data and distribution information in a unified data format, and attach an electronic authentication code or electronic label to the product. Consumers and authorities can verify the registered content from that code. The practical burden is less the registration itself than whether your internal records are in a state that can be matched to the unified data format.

What happens to existing stock and labels already printed

Transitional relief applies. Products manufactured before January 23 2026 may continue circulating until their expiry, and labels printed by that same date may be used for up to two years. The catch is that the reference point is the date of manufacture. If your inventory ledger only holds receipt dates, you cannot evidence from the product side whether the relief applies, so manufacturing records are needed. When designing new labels, note that only four items are guaranteed to require printing regardless of tier, namely product name, responsible party information, origin and warning labels. Other items may in some cases move to electronic display, but anything moved there must stay reliably retrievable from the code.

Can overseas plant traceability run on the same system as our Thailand site

The foundation can be standardised, but the parts tied to regulation have to be separated out. Keep the product code scheme, the granularity of records and how data is held common across countries, and carry each country’s filing formats and labelling requirements as an adapter above that foundation. Structured that way, a regulatory move in any one country stays contained. In Vietnam’s case, there is country-specific legislation and a country-specific official portal, so a Thai format cannot simply be carried over.

Summary

Vietnam’s Law on Product and Goods Quality was amended by Law No. 78/2025/QH15, effective January 1 2026, replacing the old two-category system of Group 1 and Group 2 with a three-tier risk classification of low, medium and high risk. After a transition period running from January 23 to June 30 2026, the old classification lapsed on July 1 and the three-tier classification became fully mandatory.

The implementing rules come from Decree No. 37/2026/ND-CP, dated January 23 2026, which accepts and recommends QR codes, data matrix, RFID and NFC as technical standards for traceability codes. The operational home of the scheme is verigoods.vn, the Ministry of Industry and Trade’s official portal, live since December 23 2025. Companies register and update raw material origin, manufacturing process data and distribution information in a unified data format, and attach an electronic authentication code to the product.

How heavy the obligation is depends on the tier. The high-risk tier has traceability built into the definition of the tier itself, and it became mandatory immediately for chemicals, industrial explosive precursors and tobacco products. Other areas are recommended for now. That said, the seven medium-risk categories the Ministry of Industry and Trade published on June 18 2026 for products under its own management responsibility include industrial machinery, equipment and materials, which bears directly on plant equipment procurement and supplier management in manufacturing. On labelling, only four items are guaranteed to require printing regardless of tier, namely product name, responsible party information, origin and warning labels, with other items allowed in some cases to move to electronic display. Products manufactured before January 23 2026, and labels printed by that date, are covered by transitional relief.

The practical takeaway is that the work does not start with printing codes because the regulatory dates are looming. Pin down your products’ tier, build the internal state where raw material origin, manufacturing process and distribution information can be retrieved per product, and then line up the portal and customer requirements as output destinations for that. Assembled in that order, the next regulatory update will not force you to rebuild the foundation.

At your Vietnamese site, how much of what you already record is joined at the product level, and where does the chain break. Sorting that out usually takes very little time once we can hear how your current production management works and how records are captured on the floor. Having worked across both Thai and Vietnamese sites, TOMAS TECH typically starts by mapping which foundations can be shared and which parts have to stay country-specific. It is fine to reach out at an early exploration stage, before any internal direction has been settled, through our Contact page.

References

• Vietnam officially implements product traceability system – VnEconomy
• Implementing traceability codes enhances market transparency – Nhan Dan
• Law No. 78/2025/QH15 amending the Law on Product and Goods Quality – LuatVietnam
• Vietnam list of medium-risk and high-risk products under the Ministry of Industry and Trade – Product Compliance Institute
• Vietnam risk tier classification 2026 – Cleo Labs