What Should Businesses Do When Discontinuing a Functional Food Product in Vietnam?

Vietnam’s functional food sector, particularly health supplements (commonly referred to as Health Supplements or Health Protection Foods – HPFs), is subject to increasingly stringent regulatory oversight. In practice, many enterprises decide to discontinue certain products due to strategic restructuring, market performance, or compliance considerations.

However, unlike ordinary consumer goods, functional foods are regulated products tied to a specific set of legal approvals. Simply stopping production or sales does not automatically terminate the legal status of the product. If not handled properly, discontinued products may still pose regulatory and compliance risks years after they have left the market.

This article outlines the key legal steps businesses should take when discontinuing a functional food product in Vietnam, from a compliance and risk-management perspective.

Discontinuing a Functional Food Product Is More Than Just Stopping Sales

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Vietnamese law does not establish a standalone administrative procedure officially called “notification of product discontinuation” for functional foods. Nonetheless, a functional food that has been lawfully placed on the market remains legally “alive” as long as its regulatory approvals remain valid.

In particular, a health supplement product may still be associated with:

A Certificate of Receipt of Product Registration Dossier; and
A Certificate of Advertising Content Approval (if advertising approval was granted).

If these documents are left in force while the product is no longer commercially available, the enterprise may face compliance risks during post-market inspections or in cases where outdated product information is misused by third parties.

First Step: Cease Market Circulation and Advertising in Practice

Before addressing formal regulatory procedures, the business should ensure that the product is effectively withdrawn from commercial circulation, including:

Issuing an internal decision on discontinuation, clearly identifying the product name, batch numbers (if relevant), and the effective date of discontinuation.
Notifying distributors, agents, and e-commerce platforms to immediately stop sales and remove all listings.
Terminating all advertising and promotional activities related to the product across websites, social media platforms, e-commerce marketplaces, and printed materials.

These actions serve as important evidence of compliance should regulatory authorities conduct inspections or audits.

Revocation of the Certificate of Receipt of Product Registration Dossier

For health supplements, the Certificate of Receipt of Product Registration Dossier is the legal basis allowing the product to be circulated on the market. When a business decides to permanently discontinue a product, the most legally prudent approach is to voluntarily request the revocation of this certificate.

Competent Authority: Vietnam Food Administration (VFA) – Ministry of Health

Practical Dossier

Although current legislation does not prescribe a rigid dossier format, in practice, the authority typically requires:

A written request for revocation, stating the enterprise’s voluntary decision to discontinue production and business of the product, together with a commitment to cease circulation and advertising.
A copy of the Certificate of Receipt of Product Registration Dossier.
A power of attorney (if the submission is made through a legal representative).

Upon review, the Vietnam Food Administration will issue a Decision on Revocation of the Certificate of Receipt of Product Registration Dossier.

Processing Time

There is no statutory deadline; however, in practice, the review and issuance process usually takes approximately 10–20 working days, provided that no safety or compliance issues arise.

Should the Certificate of Advertising Content Approval Also Be Revoked?

If the product has been granted a Certificate of Advertising Content Approval, it is strongly advisable to request its revocation as well.

Although not strictly mandatory, leaving the advertising approval in effect may expose the business to risks, particularly in the digital environment where advertising materials can easily be replicated or reused without authorization.

The revocation request is usually submitted to the same authority and processed concurrently with the revocation of the product registration certificate.

Is It Necessary to “Revoke” Laboratory Test Reports?

The short answer is no.

Laboratory test reports are:

Technical documents reflecting product quality at a specific point in time;
Not administrative approvals;
Not subject to revocation under Vietnamese law.

Once the Certificate of Receipt of Product Registration Dossier is revoked, the test reports automatically lose their legal relevance for product circulation purposes. The business is only required to retain these documents for record-keeping and compliance verification.

Does Discontinuing a Product Require Closing the Production Facility?

No—provided that only a specific product is discontinued.

Where the enterprise continues to manufacture or trade other compliant food products at the same facility, there is no requirement to revoke the Food Safety Eligibility Certificate or to shut down production lines.

Such obligations only arise if the enterprise fully ceases all food production or business activities at the facility.

Key Takeaways for Businesses and Investors

Discontinuing a functional food product in Vietnam is not an overly complex process, but it must be handled carefully to avoid residual compliance risks. Best practice from a legal standpoint includes:

Effectively ceasing production, circulation, and advertising in practice;
Proactively requesting the revocation of regulatory approvals associated with the product;
Maintaining comprehensive documentation to demonstrate regulatory compliance.

For foreign investors and international enterprises, this approach ensures a clean regulatory exit for discontinued products and supports sustainable, compliant business operations in Vietnam’s regulated food sector.

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