Further Extension of Decree 46/2026 Proposed: Food Import Enterprises Advised to Stay Informed and Updated

Further Extension of Decree 46/2026 Proposed is currently the key concern for many food importing businesses. After being temporarily suspended until April 16, 2026, will Decree 46/2026/ND-CP officially be implemented, or will it be further extended? This is a question that many food importing businesses are concerned about, especially since new proposals from the Government suggest that this decree may not be implemented in the near future. Without staying updated on the developments, businesses may build the wrong application dossier from the start.

Decree 46/2026 Proposed for Extension: April 16th Deadline Changed

After Decree 46/2026/ND-CP was temporarily suspended by Resolution 09/2026/NQ-CP until April 16, 2026, many businesses expected this to be the date the decree would begin to be applied.

However, the latest developments suggest this possibility is changing. On March 20, 2026, the Government Office issued Notice 141/TB-VPCP, which clearly outlines the direction for resolving issues related to Decree 46 and Resolution 66.13/2026/NQ-CP. Accordingly, the Government plans to issue a new resolution to further extend the suspension period, instead of putting the decree into application immediately after the April 16, 2026 deadline. The suspension period may be extended until approximately July 15, 2026.

This extension no longer stems from implementation difficulties, but from the need for policy-level adjustments. With the revised Food Safety Law currently under development and its broad scope of changes, immediately applying Decree 46 could lead to the need for amendments in a short period and increase compliance costs for businesses. Therefore, the option of extending the suspension was chosen to maintain system stability during the transition period.

Practical Impact: Authorities Temporarily Suspend Accepting Applications

It’s important to clarify that the current suspension is not only legal but has directly impacted implementation.

Currently, many authorities are temporarily suspending the acceptance of applications for food product declarations due to the lack of detailed guidance under the new mechanism. This puts businesses in a situation where they can prepare the documents but cannot officially submit them.

Notably, according to the new policy direction, the previous “self-declaration” mechanism is likely to be eliminated. Instead, products will have to register a declaration and be granted a circulation number before importation.

Therefore, the issue is not just the suspension of the decree, but the changing management approach, which necessitates businesses adjusting their application preparation methods from this stage.

How does Green NRJ view this period?

The period until July 15, 2026, is not a “ghost period,” but a crucial transitional phase. Businesses can proactively prepare their dossiers, complete testing and technical documentation, and be ready to submit them as soon as the authorities reopen the receiving system.

During this period, preparing the dossiers correctly from the start will determine whether businesses will have to redo everything when policies change. Green NRJ is supporting businesses in processing dossiers in this way to minimize risks and ensure import progress.

If you need a clearer understanding of the content and scope of this decree, you can refer to the detailed regulations and impacts of Decree 46/2026/ND-CP.

Conclusion: This is a sign of change, not just a delay.

The continued proposal to extend Decree 46/2026/ND-CP shows that the imported food management system in Vietnam is undergoing a process of adjustment towards stricter regulations.

For businesses, the issue is not about waiting for the regulations to take effect, but about preparing the right documents and approach now. In this context, businesses that take the right approach will significantly reduce risks and maintain an advantage when the policy is officially implemented.

If you need to review your documents or develop an import plan suitable for the current context, Green NRJ can partner with you to ensure everything is on the right track from the start.