After more than 15 years of implementation, the National Technical Regulation QCVN 5-1:2010/BYT on fluid milk products is facing an urgent need for revision. Experts, businesses, and regulatory agencies unanimously agree that the current regulation no longer aligns with practical production conditions, modern processing technologies, and evolving consumer trends.
Therefore, on the morning of August 15, 2025, the Ministry of Industry and Trade organized a scientific workshop titled: “National Technical Regulation for fluid milk products ” to address existing issues, specifically:
- Lack of clear definitions among milk types such as pasteurized fresh milk, reconstituted milk, and recombined milk, leading to consumer confusion.
- No specification of minimum milk fat content, despite this being a common classification criterion in many countries (e.g., whole milk, skim milk). QCVN 5-1:2010/BYT only specifies milk protein content.
- Reconstituted and recombined milk are not subject to mandatory technical regulations, complicating post-market inspection and traceability.
- Overlapping provisions between regulations issued by the Ministry of Health and other legal documents, affecting regulatory efficiency and market transparency. For example, QCVN 5-1:2010/BYT outlines safety indicators for fluid milk products such as mycotoxins, heavy metals, microorganisms, veterinary drug residues, and pesticide residues. However, similar indicators are also regulated under QCVN 8-1:2011/BYT, QCVN 8-2:2011/BYT, QCVN 8-3:2012/BYT, Circular 24/2013/TT-BYT, and Circular 50/2016/TT-BYT.
Proposed Revisions:
The Ministry of Industry and Trade, in collaboration with the Ministry of Health and other relevant stakeholders, is currently developing a new technical regulation. This draft is being formulated with reference to international Codex standards and advanced regulations from developed countries. The new regulation aims to:
- Clearly classify processed milk products, enabling consumers to better distinguish between different types and avoid confusion.
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QCVN 5-1:2010/BYT |
Draft |
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- Supplementing regulations on physical and chemical indicators to ensure nutritional quality and better product control.
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QCVN 5-1:2010/BYT |
Draft |
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Milk protein content Density at 20°C Pasteurization efficiency (phosphatase test) |
Milk protein content Milk fat content Total solids content Density at 20°C Insolubility index |
- Adjustment of Contaminant Regulations to Align with the Current Legal Framework and Reduce Overlaps
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QCVN 5-1:2010/BYT |
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Heavy metals: Lead (Pb), Tin (Sn), Antimony (Sb), Arsenic (As), Cadmium (Cd), Mercury (Hg) Veterinary drug residues: Specific limits defined within QCVN 5-1:2010/BYT Pesticide residues: Specific limits defined within QCVN 5-1:2010/BYT |
Heavy metals: Lead (Pb), Tin (Sn) Veterinary drug residues: Regulated according to Circular 24/2019/TT-BYT – Maximum residue limits for veterinary drugs in food Pesticide residues: Regulated according to Circular 50/2016/TT-BYT – Maximum residue limits for pesticides in food |
- Supplementing regulations on traceability and transparent labeling helps to clarify information and protect consumers.
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QCVN 5-1:2010/BYT |
Draft |
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Based on Decree No. 89/2006/ND-CP on goods labeling and related guiding documents |
Based on Decree No. 43/2017/ND-CP on goods labeling Amended and supplemented by Decree No. 111/2021/ND-CP The front label of the product must clearly state the nature of the product as defined in this regulation (e.g., “Reconstituted Milk”, “Fresh Milk”) alongside the product name The percentage of milk content must be clearly indicated on the front label |
- The draft regulation encourages the application of internationally recognized quality management systems such as GMP (Good Manufacturing Practices), HACCP (Hazard Analysis and Critical Control Points), and ISO 22000 for high-risk dairy products, particularly those intended for infants.
These systems are developed based on the following principles:
- Ensuring safety for consumer health
- Aligning with the realities of production, business, and import activities in Vietnam
- Complying with national standards and Vietnamese legal regulations
- Harmonizing with international standards and regulations, avoiding the creation of technical barriers to trade between Vietnam and other countries
- Incorporating risk management recommendations from competent authorities in Vietnam and abroad, including the Food and Agriculture Organization (FAO), the World Health Organization (WHO), and the Codex Alimentarius Commission (CODEX)
Feedback submission link here.
View the draft of QCVN 5-1 here.
