Jun 18, 2026 by Mark Dingley
Vietnam has just rewritten the rules for anyone exporting food into the country, with dairy manufacturers squarely in the spotlight.
If you’re sending product to Vietnam, or you’re looking at it as a growth market, this isn’t a “watch this space” regulation. It’s already in force, it has hard connection deadlines attached, and it asks a question that most Australian production lines haven’t had to answer before: can you prove, in real time, exactly where every batch came from and where it went?
Here’s what's changed, what it means in practice, and what it actually takes to get a production line exportready.
Image credit: Sankai
In February 2026, Vietnam’s Ministry of Industry and Trade issued Circular 11/2026/TT-BCT, a binding regulation covering traceability for all food products under its remit — including imported dairy. It took effect from 16 April 2026.
The core principle is “one step forward, one step back”: every business in the chain has to be able to identify who supplied them and who they supplied, batch by batch. Production and import facilities are required to keep structured records covering raw materials, production data, testing results and distribution — not just paperwork, but a connected dataset that can be pulled on demand.
The part that will land hardest on export teams is the connection deadline. Food-production facilities must be linked into Vietnam’s national traceability system by 1 December 2026. Importers follow on 1 March 2027. That’s a government-run database, not an internal compliance file – and your batch and traceability data has to be able to talk to it.
Image credit: Sidedesign78
Vietnam isn’t applying one blanket rule across every food category. Dairy has its own new technical regulation – QCVN 28:2026/BCT, covering liquid milk products specifically – replacing a regulation that had been in place since 2010. It takes effect from 1 September this year and tightens classification (fresh milk now needs at least 90% raw fresh milk to use the term), labelling and quality assessment. Traceability is called out as a standalone requirement for which businesses must have systems in place.
If you’re exporting milk powder, UHT, or other dairy lines into Vietnam, you're working against two overlapping clocks: the general food traceability connection deadline and the dairy-specific technical standard. Both assume the same thing underneath: that your batch identity is solid enough to stand up to scrutiny at the border and beyond.
Image credit: SarapulSar38
Vietnam’s approach leans heavily on machine-readable codes carrying real traceability data, not just a SKU lookup. A scanned code needs to resolve to origin, production information and supply chain history – readable by both regulators and, increasingly, consumers.
This is the same direction that the rest of the world has been moving in for a while. Vietnam’s regulators have explicitly aligned the framework with GS1 global standards – GTINs, GS1 DataMatrix and EPCIS event-based tracking – rather than inventing a local-only system. If you’re already producing GS1-compliant codes for Australian retailers, you’re not starting from zero. But “compliant for Coles and Woolworths” and “compliant for a Vietnamese customs and traceability platform” aren't automatically the same thing. The gap is usually in the data that the code carries and how reliably it’s applied – not the barcode symbology itself.
We've written before about the broader shift to 2D barcodes carrying richer data in our 2D Barcode Learning Centre; Vietnam’s move is a clear example of why that shift matters well beyond Australian retailer compliance.
Vietnam’s circular defines what traceability has to achieve. It doesn’t tell exporters how to apply that at the level that bulk product actually moves – bag by bag, drum by drum, pallet by pallet.
That’s the part that usually gets underestimated. Most exporters can already trace a finished pallet. Fewer can prove, with a code physically applied to the product, that bag 4 of batch 1182 came from a specific production run, on a specific date, tested against specific results — and that the code on that bag will still scan cleanly after a container voyage, a customs inspection, and a Vietnamese warehouse floor.
Matthews helped Chobani to integrate all of their coding and labelling equipment into one single database using our iDSnet software package.
In practice, getting from “we have the data” to “the data is physically on the product and verifiable” usually comes down to a few things:
1. Reliable batch and date coding at the point of production: applied consistently, every unit, every shift, without relying on an operator to catch mistakes.
2. A code structure that carries more than a SKU: GS1 DataMatrix or QR symbols built to carry batch, production date and traceability references, not just a product identifier.
3. Software that connects the dots: linking what’s printed on the product to the underlying production and batch data, so that a scan actually resolves to something useful, rather than a code that looks right but doesn’t connect to anything.
4. Print quality that survives the journey: a beautifully structured traceability code is worthless if it’s unreadable by the time it reaches a Vietnamese distribution centre or border inspection point.
None of this is exotic. It’s the same discipline that Australian manufacturers have already built for retailer compliance and domestic recall-readiness, but applied to a new market with its own deadlines and its own platform to connect into.
We see this pattern across the food and beverage manufacturers we work with. Chobani Australia, for instance, runs multiple Matthews coding technologies alongside software for date and batch coding specifically, because traceability and ease of use for operators both had to hold up at scale – not just on a good day, but every shift, on every line. The lesson translates directly: traceability that works under pressure is built into the line, not bolted on as an afterthought.
It’s a similar story with growth-stage exporters. When Remedy Kombucha scaled rapidly to become a market leader, what mattered to their operations team wasn't a custom-built system – it was a proven platform that could keep up with retailer and compliance requirements as volume increased. Vietnam’s traceability framework is asking Australian exporters the same underlying question: not “can you build something clever”, but “can you prove it works, reliably, at production speed”.
Vietnam has also formally defined “counterfeit food” in law and is increasing inspections and penalties, with a particular focus on mislabelled origin and fraudulent claims. Traceability isn’t just a market-access requirement here, it’s the enforcement mechanism. A traceability system that can’t stand up to scrutiny doesn’t just risk a compliance notice,it risks your product being treated as a counterfeit-control target.
For genuine, well-run Australian exporters, that’s actually good news. Strong traceability is a competitive advantage in a market that’s actively trying to separate verified product from the rest.
Pull the threads together and the practical checklist looks like this:
Image credit: Dreamlapse Imagery
This is exactly the kind of problem we’re built to solve end to end, rather than one piece at a time. Coding and labelling puts reliable, structured codes on product at production speed. Inspection verifies every code before it leaves the line, so what’s printed is actually what scans. iDSnet connects that code back to the batch, production and testing data that traceability regulations are built around. And Care 24x7 keeps it running when a missed shift isn’t an option.
Vietnam has set the destination. Getting there is a production-line problem, and that’s the part we know well.
If you’re exporting to Vietnam, planning to, or simply tightening up traceability to meet whatever’s coming next, we’re offering a free on-site production line audit for Australian food and beverage manufacturers. We’ll look at your current coding, labelling and traceability setup against what Vietnam’s new requirements actually demand, and tell you plainly where you’re covered and where the gaps are.
Image credit: Thanadon Naksanee
