G. Regulatory register and routes to market

This appendix is the detailed legal register behind Rules and Policy options. It states the law as we found it on 23 September 2026. It covers food, genetically modified organisms (GMOs), feed, aquafeed, incentives, sandboxes, environment, genetic resources, intellectual property (IP) and import tariffs. It ends with a route-to-market table for 17 product types, a plain-language explainer, foreign precedents and the full list of 25 policy options.

Terms used in this appendix:

• Tự công bố sản phẩm (self-declaration): the business files its own product specification and a lab test report and may sell at once. No agency approval.
• Đăng ký bản công bố sản phẩm (registration of a product declaration): the agency reviews the dossier and issues a receipt before sale.
• Khảo nghiệm (feed trial): a controlled feeding trial under an approved protocol. A recognised result is needed before an unlisted feed ingredient can be used.
• Permitted list (danh mục nguyên liệu được phép sử dụng): the ministry list of raw materials that may be used in feed without a trial.
• Closed-production certificate: the new certificate that a GMO may be used in contained (khép kín) production.
• Sandbox, or controlled testing (thử nghiệm có kiểm soát): a time-limited, supervised permission to test a product or model that current law does not cover.
• MAE: Ministry of Agriculture and Environment. MOH: Ministry of Health. VFA: Vietnam Food Administration (MOH Food Safety Department). DLPAH: Department of Livestock Production and Animal Health (MAE). DFFI: Department of Fisheries and Fisheries Surveillance (MAE). MOST: Ministry of Science and Technology. MOF: Ministry of Finance. MOIT: Ministry of Industry and Trade.
• WD: working days. MFN: most-favoured-nation (standard) import duty.

#G.1 Ten things to know

1. Food products still enter the market under Decree 15/2018/ND-CP (self-declaration or registration). Its replacement, Decree 46/2026/ND-CP, and Resolution 66.13/2026/NQ-CP are suspended until the revised Food Safety Law and its decree take effect ^1,2 VN-directHigh.
2. Vietnam has no novel-food category. No law or decree defines novel food, history of safe use or a pre-market safety assessment for a new food source ^3,4 VN-directHigh. The public summaries of the July 2026 draft Food Safety Law do not add one ^5,6 VN-directMedium.
3. The current law carries a latent hook against new-technology food: Art 55(1)(c) lists "food that is a new-technology product not yet permitted for circulation" among foods to be recalled, but no procedure exists to obtain that permission ³ VN-directHigh.
4. A precision-fermented protein is probably a "product of a GMO" under Decree 43/2026, because the definition covers products that contain "protein from the modified gene" ^7,8 VN-directMedium.
5. Insects, duckweed, algae and inactive yeasts are already on the livestock feed permitted list, so they need no feed trial for livestock ^9,10 VN-directHigh.
6. The aquafeed permitted list has no raw-material section at all, so the legal status of new protein raw materials in shrimp and fish feed is ambiguous ^11,12 VN-directHigh.
7. Using an unlisted livestock feed raw material has cost VND 10 to 20 million per material, plus 1 to 3 months' suspension of feed production, since 5 August 2026 ¹³ VN-directHigh.
8. Precision fermentation qualifies as priority high technology (Decision 23/2026 items 60 and 92), but "alternative protein" as such is not listed ¹⁴ VN-directHigh.
9. There is no national sandbox procedure for food, but Hanoi's sandbox lists biotechnology as a priority field ^15,16 VN-directHigh.
10. Feed protein imports (soybean meal, feed maize, fishmeal) enter duty-free under MFN rates, so a domestic novel protein gets no tariff shelter ^17,18 VN-directMedium.

#G.2 Who owns what after the 2025 restructuring

The Government's new structure took effect on 1 March 2025 under Resolution 176/2025/QH15, with 14 ministries and 3 ministerial-level agencies ¹⁹ VN-directHigh. The provincial map changed on 1 July 2025, from 63 to 34 units, and the district tier ended. See P. Admin map for the full crosswalk.

What this means in practice:

• After the mergers, one ministry (MAE) holds feed, aquafeed, GMO biosafety, genetic resources and carbon, and one ministry (MOST) holds standards, the sandbox, high-tech status and IP ^19,30,20 VN-directHigh.
• The draft Food Safety Law would make MOH the single focal point for food safety. The Deputy Prime Minister asked for this question to be settled in September 2025, and MOH proposed itself as the single agency ^33,34 VN-directMedium.
• Provinces now run most day-to-day feed procedures. The choice of province can change time to market ^22,23 VN-directHigh.

#G.3 Food law

#G.3.1 Law on Food Safety 55/2010/QH12

• Status. Law 55/2010/QH12 was passed on 17 June 2010 and took effect on 1 July 2011. It was amended by Law 28/2018/QH14, and a consolidated text (61/VBHN-VPQH) was issued in 2026 ^3,35 VN-directHigh.
• Art 2 defines food broadly, as products people eat or drink, fresh or processed ³ VN-directHigh.
• Art 5(1) prohibits "sử dụng nguyên liệu không thuộc loại dùng cho thực phẩm để chế biến thực phẩm" (using raw materials not of the type used for food to process food) ³ VN-directHigh.
• Art 5(5)(h) prohibits selling food that has not been registered where registration is required ³ VN-directHigh.
• Art 15 sets safety conditions and labelling for genetically modified food (thực phẩm biến đổi gen) ³ VN-directHigh.
• Art 55(1)(c) lists "thực phẩm là sản phẩm công nghệ mới chưa được phép lưu hành" (food that is a new-technology product not yet permitted for circulation) among foods subject to recall ³ VN-directHigh.
• The gap. No implementing text defines "new-technology product" or says how permission to circulate is obtained ³ VN-directHigh. A new protein food therefore enters, in practice, through self-declaration against generic safety limits. An inspector could still argue that a fungus or alga with no food history is "not of the type used for food" (Art 5(1)) or an unpermitted new-technology product (Art 55(1)(c)). This is our interpretation. The result is legal uncertainty, not a clear route and not a ban ^3,4 VN-directMedium.

#G.3.2 Decree 15/2018/ND-CP: how market entry works today

Decree 15/2018/ND-CP of 2 February 2018 details the Food Safety Law. It applies as of 23 September 2026 ^4,2 VN-directHigh.

Self-declaration (Art 4 to 5).

• It covers processed pre-packaged food, food additives, processing aids, and packaging in direct contact with food ⁴ VN-directHigh.
• Exempt (Art 4(2)): products and raw materials made or imported only for export processing, or "phục vụ cho việc sản xuất nội bộ" (for the firm's own internal production) and not sold domestically ⁴ VN-directHigh. This matters for imported protein ingredients used in-house.
• The dossier is a self-declaration form plus a test report from a designated or accredited lab, dated within 12 months ⁴ VN-directHigh.
• The business may produce and sell right after filing with the authority designated by the provincial People's Committee, or after publishing the declaration ⁴ VN-directHigh.

Registration of the product declaration (Art 6 to 8).

• Required for health supplements (thực phẩm bảo vệ sức khỏe), medical foods, special-diet foods, products for children up to 36 months, and "mixed additives with new uses or additives not on the MOH permitted list or not used as permitted" ⁴ VN-directHigh.
• Health supplements are registered at MOH within 21 WD. The other categories take 7 WD ⁴ VN-directHigh.
• The authority may ask for corrections once. The applicant then has 90 WD to respond ⁴ VN-directHigh.

GM food. Art 9 refers to Decree 69/2010 for the GMO food-use certificate. Art 10 requires GM labelling when at least one GM ingredient is more than 5% of total ingredients ⁴ VN-directHigh.

What is missing. No provision covers foods with no history of use, or new ingredients ⁴ VN-directHigh.

#G.3.3 The suspended Decree 46/2026 and Resolution 66.13/2026

What Decree 46/2026 would have changed, had it not been suspended ^36,37 VN-directMedium:

• registration of conformity declarations for pre-packaged processed foods, additives, processing aids and packaging;
• declarations valid for up to 3 years;
• mandatory food safety management systems (HACCP or similar) by 31 December 2026;
• tighter import inspection, and joint liability for e-commerce platforms;
• nothing on novel foods.

Resolution 66.13/2026 would have replaced self-declaration with registration for several categories, with up to 90 days of processing and a 24-month transition ³⁸ VN-directMedium.

#G.3.4 The draft revised Food Safety Law (2026)

Timeline.

What the draft does, as described in Government press ^5,6 VN-directMedium:

• Four policy groups: reform of the management approach, stronger post-market control, digital transformation, and street food and catering.
• Two product groups. Group one: foods that must register a declaration or declare the applied standard (công bố tiêu chuẩn áp dụng) before circulation. Group two: foods that need no declaration. Both are inspected "throughout circulation on the market".
• The registration group named in the press is medical nutrition foods, foods for special diets, nutrition products for children up to 36 months, and health supplements.
• The drafters rejected requiring all pre-packaged processed foods to register a conformity declaration (the Decree 46/2026 approach) as "not suited to the management method".
• Advertising of medical nutrition foods and of products for children up to 36 months would be banned.

What it lacks. None of the draft summaries, the MOH submission or the stakeholder comments we read mentions thực phẩm mới (new food), new ingredients, history of use or a sandbox ^39,43,41,5,6 VN-directMedium. We did not read the draft text itself or the WTO attachment. We do not know whether the recall ground in Art 55(1)(c) is carried over.

Timing. A trade source gives submission to the National Assembly in October 2026 and entry into force on 1 January 2027 ^46,45 VN-directMedium. We found no National Assembly agenda document confirming whether the law will pass in one session or two. We found no enacted law in the legal database on 23 September 2026 ⁴⁰ VN-directMedium.

What it means for new proteins. Ordinary plant-based and fermented protein foods would fall in either the "declare the applied standard" group or the "no declaration" group. Neither involves pre-approval. So the new law, as described, keeps an open door but also keeps the uncertainty: there is still no way to get a new ingredient positively cleared. This is our reading ⁶ VN-directMedium.

#G.4 GMO rules and precision fermentation (Decree 43/2026)

#G.4.1 Instruments

The GMO rules sit in Decree 69/2010/ND-CP on biosafety, as amended by Decree 108/2011, Decree 118/2020 and Decree 43/2026/ND-CP ^7,48 VN-directHigh. Decree 43/2026 was issued on 26 January 2026 and took effect the same day. It amends Decree 65/2010 (Biodiversity Law) and Decree 69/2010. It does not amend Decree 59/2017 on genetic resources ^7,48 VN-directHigh.

#G.4.2 Definitions

• Gene-edited organisms (sinh vật chỉnh sửa gen) are now in scope. The Biodiversity Law, as amended by Law 146/2025/QH15, defines them as containing no new genetic material. Owners self-determine their status, report to MAE and keep records for 10 years ^7,49 VN-directHigh.
• Product of a GMO: "sản phẩm được tạo ra từ sinh vật biến đổi gen có chứa vật liệu di truyền hoặc protein từ gen biến đổi" (a product created from a GMO that contains GM genetic material or protein from the modified gene) ^7,8 VN-directHigh.
• Refined products. USDA and ISAAA report that highly refined products such as soybean oil and corn starch are excluded from "GM food" ^50,51 VN-adjacentMedium. The text extract did not show an explicit exclusion, but the definition already excludes anything with no GM DNA and no GM protein. A precision-fermented protein is not excluded, because it is itself protein from the modified gene ⁷ VN-directMedium. See DG-050.

#G.4.3 Certificate for food and feed use (merged procedure)

Decree 43/2026 merges the old Art 32 to 33 into one MAE procedure that certifies a GMO as eligible for use as food and feed ^7,24 VN-directHigh.

• Criteria. A biosafety council finds no uncontrollable risk, or at least 5 developed OECD or G20 countries allow the event ^7,52 VN-directHigh.
• Steps. 5 WD to accept the dossier and form the council; 67 WD for a full council review, or 17 WD on the 5-country route; 5 WD to decide. MOH is consulted during a 20-day public comment period ^52,53 VN-directMedium.
• Food implies feed. A GMO approved as food qualifies as feed ⁵³ VN-directMedium.
• Who runs it. MAE's procedure list places this procedure with the MAE Department of Science and Technology ²⁵ VN-directMedium.
• End-to-end time. Agency steps add up to 27 WD (5-country route) or 77 WD (full review). USDA gives 45 and 90 WD, which probably include the public comment period. We use 27 or 77 WD for agency steps and about 45 or 90 WD end to end ^50,52 VN-directMedium. See DG-049.

#G.4.4 Closed-production certificate (new Art 37a)

Decree 43/2026 adds Art 37a to Decree 69/2010: "Giấy chứng nhận sinh vật biến đổi gen đủ điều kiện sử dụng trong sản xuất khép kín" (certificate that a GMO is eligible for use in closed production) ⁷ VN-directHigh. This is the certificate a precision-fermentation plant using a GM production strain in Vietnam would need.

See DG-111 for the issuing-level conflict.

#G.4.5 What this means for precision-fermented proteins

• A purified recombinant protein contains "protein from the modified gene", so it is probably a "product of a GMO" ^7,8 VN-directMedium.
• GM labelling then applies when it is more than 5% of the product ⁴ VN-directHigh.
• Making it in Vietnam with a GM microbe needs the Art 37a closed-production certificate ^7,8 VN-directHigh.
• No article covers products made with GMOs that contain no viable GMO. The food-use certificate is written for organisms, not products. So no text says whether a purified protein also needs a food-use certificate. Imported precision-fermented ingredients face the same labelling question ⁸ VN-directMedium.
• Food-use certification of GMOs now sits fully with MAE, with MOH consulted ^24,53 VN-directMedium.

#G.5 Food additives, enzymes and processing aids

• Circular 24/2019/TT-BYT (30 August 2019, effective 16 October 2019) sets the permitted additive list. Art 4 bases the list on Codex (CAC) and JECFA ⁵⁴ VN-directHigh.
• New uses, or mixed additives with new functions, must be registered at VFA (Art 11(2)) ⁵⁴ VN-directHigh. Registration takes 7 WD under Decree 15/2018 Art 6 ⁴ VN-directHigh.
• Organisations may propose additions to the list with scientific safety evidence (Art 17(3)(d)) ⁵⁴ VN-directHigh.
• The extract did not show a separate pathway for enzymes or processing aids, or anything on GM-derived additives. Amendments after 2019 were not visible ⁵⁴ VN-directMedium.
• Route for a new additive or enzyme: registration of the product declaration at VFA, or a request to MOH to amend the list ^4,54 VN-directMedium.

#G.6 Health supplements

• Health supplements need MOH registration within 21 WD and a GMP-certified plant (Decree 15/2018 Art 7, 11 and 12) ⁴ VN-directHigh.
• This is a real route for microalgae (spirulina, chlorella) and concentrated protein ingredients sold as supplements ⁴ VN-directHigh.
• The draft Food Safety Law keeps health supplements in the registration group ⁶ VN-directMedium.

#G.7 Labelling

• Content. Decree 43/2017/ND-CP as amended by Decree 111/2021/ND-CP (effective 15 February 2022) requires on food labels: name, ingredients or quantified ingredients, nutrition (if any), thông tin cảnh báo (warning information), dates, storage and instructions for use ⁵⁵ VN-directHigh.
• No allergen list. The warning information in Appendix I item 2 has no defined content and no allergen list. Circular 05/2019/TT-BKHCN (26 June 2019; no replacement found) Art 9 covers technical specifications and warnings, also with no allergen list ^56,57 VN-directMedium. So Vietnam has no mandatory allergen declaration list of the Codex type.
• No plant-based naming rule. We found no rule on product names for plant-based foods, on chay (vegetarian) or thuần chay (vegan), or on the use of thịt (meat) or sữa (milk) ⁵⁶ VN-directMedium. Market practice (sữa đậu nành, soy milk; sữa hạt, nut milk; giò chay, vegetarian sausage) relies on general rules against misleading labels. We did not verify the text of the general rule against misleading names in Decree 43/2017.
• GM labelling: above 5% GM ingredient (Decree 15/2018 Art 10) ⁴ VN-directHigh.
• Nutrition labelling: Circular 29/2023/TT-BYT is listed in the instrument inventory but was not read ³⁵ VN-directLow.

#G.8 Halal

• Decision 10/QĐ-TTg (2024) approves the scheme to strengthen international cooperation for Vietnam's halal industry to 2030. It was listed, not read ⁵⁸ VN-directLow.
• Decree 127/2026/ND-CP (6 April 2026, effective 1 June 2026) is the first decree on halal quality management and development ³¹ VN-directHigh:
  • Certification is voluntary unless another law requires it.
  • Certifiers register with MOST (Art 13) and need at least 2 Muslim expert assessors (Art 11).
  • Standards may be national (for example TCVN 13888:2023), international or those of a partner country.
  • The state budget can support testing and certification costs for export-oriented firms (Art 23). Art 16 covers mutual recognition.
  • The decree says nothing about GM, fermentation-derived or cell-based ingredients.
• Relevance: halal certification of fermentation-derived proteins (media, strains) will follow each certifier's standard ³¹ VN-directMedium. Malaysia ruled in December 2025 that cultivated meat can be halal under conditions, the first Muslim-majority country to do so ⁵⁹ VN-adjacentMedium. We did not verify recognition of Vietnamese certificates by JAKIM (Malaysia) or BPJPH (Indonesia).

#G.9 Imports of food and feed ingredients

• Food. Under Decree 15/2018, imported food is subject to state inspection, with exemptions (Art 13) for self-declared products for own use, personal and diplomatic imports, goods for export processing, and raw materials for internal production ⁴ VN-directHigh.
• The suspended Decree 46/2026 would have tightened import inspection ^36,39 VN-directMedium.
• MOIT issued Circular 28/2026/TT-BCT on the list of imported goods under food safety inspection. It was listed, not read ³⁵ VN-directLow.
• Livestock feed. Provinces issue import licences for feed not yet published, within 10 WD, and run state quality inspection of imported feed ²³ VN-directHigh. Law on Animal Husbandry Art 37 requires a trial for certain first imports from countries whose trial procedures Vietnam does not recognise ⁶⁰ VN-directHigh.
• Aquafeed. Import licences are needed only for unlisted products imported for trials, research or fairs (Law on Fisheries Art 36) ⁶¹ VN-directHigh. Provincial chairs issue them (Decree 136/2025 Art 18(2)) ²² VN-directHigh. Circular 16/2026 Art 18(2)(c) lets firms import feed for research with an approved research outline ¹¹ VN-directHigh.
• Testing. FIRI's NACEFA laboratory holds ISO/IEC 17025 accreditation (VILAS 259) and is MAE-designated to test imported feed ingredients against QCVN 01-190:2020 ⁶² VN-directHigh.

#G.10 Livestock feed

#G.10.1 The legal chain

Law on Animal Husbandry 32/2018/QH14 (19 November 2018; effective 1 January 2020), amended by Law 146/2025/QH15 from 1 January 2026 ^60,49 VN-directHigh:

• Art 32: before circulation, commercial feed needs a published standard and conformity declaration, a certified factory, product information on the MAE portal, and a label.
• Art 33: compound and concentrate feed are self-published.
• Art 34: supplement feed is appraised before publication.
• Art 36: MAE publishes traditional feeds and single raw materials by name and technical requirements. Feed for internal use and custom orders is exempt.
• Art 37: feed trials are required for (a) certain first imports from countries whose trial procedures Vietnam does not recognise, and (b) feed containing a chất mới (new substance) not yet trialled in Vietnam, except the recognised results of state research projects. Art 37(4) empowers the Minister to issue the permitted raw-material list.
• Law 146/2025 amended Art 37 wording on the Minister's list of banned chemicals, biological products and microorganisms. The "new substance" trial trigger was not visible in the amended text ⁶³ VN-directLow.

Decree 13/2020/ND-CP (21 January 2020), amended by Decree 46/2022 and Decree 32/2026 ^64,65,23 VN-directHigh:

• Art 9 to 11: factory conditions and certificates. Art 11 is the on-site assessment of factory conditions, with surveillance every 24 months (36 months with ISO, GMP or HACCP).
• Art 13: import of feed not yet published (licensing).
• Art 15: recognition of exporting countries' trial and recognition procedures.
• Art 17 to 18: state quality inspection.
• None of these articles concerns trials of new feed. Art 31 concerns trials of livestock waste-treatment products.

#G.10.2 The permitted raw-material list

Circular 21/2019/TT-BNNPTNT (28 November 2019), amended by Circular 31/2022/TT-BNNPTNT (30 December 2022, effective 20 February 2023) ^9,10 VN-directHigh:

• Art 6: the permitted list is Appendix VI. DLPAH "tổng hợp, trình Bộ trưởng … cập nhật Danh mục … định kỳ hằng năm" (compiles and submits to the Minister to update the list periodically every year).
• Appendix VI section I.1.2 (terrestrial animal origin) names "bột xương, bột thịt, … côn trùng, động vật không xương sống …" (bone meal, meat meal, … insects, invertebrates …).
• Section I.2 (plant origin) lists among coarse feeds the aquatic plants "rong, rêu, tảo, bèo" (seaweed, moss, algae, duckweed).
• Section II lists vitamins, minerals, amino acids, enzymes, probiotics (Bacillus, Lactobacillus, Saccharomyces cerevisiae) and technical additives.
• Circular 31/2022 added inactive yeasts to section I.6: irradiated, hydrolysed or dried Torula or Candida yeast, yeast cultured on molasses, dried yeast, and by-products of amino-acid production.

Status in September 2026. The list is still Circular 21/2019 Appendix VI as amended by Circular 31/2022. Circular 94/2025 Art 18 repeals only Art 4, 5 and 6 of Circular 22/2019 (breeds) and Art 1(2) of Circular 21/2024, and has no list of its own ^67,68 VN-directHigh. We found no 2024 to 2026 amendment adding protein đơn bào (single-cell protein) or sinh khối vi sinh vật (microbial biomass) ^40,68 VN-directMedium. Search listings can miss documents, so DLPAH should confirm this.

What this means. Insects, duckweed, algae and inactive yeasts need no trial for livestock feed. They still need a certified factory, a conformity declaration against QCVN 01-190:2020 and a label ^9,10,69 VN-directHigh. We found no explicit entry for bacterial single-cell protein (SCP), fungal mycoprotein or precision-fermented proteins ^9,68 VN-directMedium.

#G.10.3 Feed trials (Circular 94/2025/TT-BNNMT)

Circular 94/2025/TT-BNNMT (31 December 2025, effective 1 January 2026), Chapter III (Art 13 to 14) ⁶⁶ VN-directHigh:

• Trial content: quality, safety or toxicity, and effects on animals. Methods suit each feed type, and duration is set in the protocol.
• DLPAH receives the protocol, forms an appraisal council within 15 WD, and approves within 5 WD after revision.
• Results recognition takes 15 + 5 WD.
• "Kết quả khảo nghiệm được công nhận là căn cứ để đưa vào danh mục nguyên liệu được phép sử dụng làm thức ăn chăn nuôi" (a recognised trial result is the basis for adding the material to the permitted list).
• It replaced parts of Circular 22/2019, Circular 21/2024 and Circular 09/2025.

The trial must be run at a qualified trial facility (Law Art 37(3)) ⁶⁰ VN-directHigh. MAE merged its livestock trial and veterinary drug testing centres into the Central Livestock and Veterinary Trial and Testing Centre I (Hanoi) by Decision 3064/QĐ-BNNMT of 4 August 2026, effective 1 October 2026. The centre runs feed trials and may sell services ⁷⁰ VN-directHigh.

#G.10.4 Safety limits (QCVN 01-190:2020/BNNPTNT)

QCVN 01-190:2020/BNNPTNT (Circular 04/2020, amended by Circulars 08/2020 and 05/2021) sets maximum limits for arsenic, cadmium, lead, mercury, aflatoxin B1, E. coli, Salmonella, HCN, gossypol and other hazards in feed and raw materials. Traditional single raw materials need a conformity declaration (công bố hợp quy) before sale, except household production and custom orders ⁶⁹ VN-directHigh.

#G.10.5 Provincial devolution (Decree 32/2026/ND-CP)

Decree 32/2026/ND-CP (effective 21 January 2026) moves several procedures to provinces ²³ VN-directHigh:

• compound and concentrate feed: self-declared on the portal;
• supplement feed: appraised by the province within 15 WD;
• import licences for feed not yet published: province, 10 WD;
• import quality inspection: provincial chair.

Decree 136/2025 had already moved other agriculture and environment powers to provinces from 1 July 2025 ²² VN-directHigh.

#G.10.6 Penalties (Decree 211/2026/ND-CP)

Decree 211/2026/ND-CP (16 June 2026, effective 5 August 2026) on administrative penalties in animal husbandry ¹³ VN-directHigh:

• Art 22(1): "Phạt tiền từ 10.000.000 đồng đến 15.000.000 đồng đối với hành vi sử dụng mỗi loại nguyên liệu không có trong Danh mục nguyên liệu được phép sử dụng" (a fine of VND 10 to 15 million for using each type of raw material not in the permitted list), when the goods are worth under VND 200 million or the illicit profit is under VND 100 million.
• Art 22(2): VND 15 to 20 million at higher values.
• Additional penalty: suspension of feed production for 1 to 3 months.
• Remedies: surrender of illicit profit and destruction of the material.

At 26,000 VND per USD, VND 10 to 20 million is about USD 385 to 770 per material (our calculation). The fine is small, but the production suspension is not. For a new SCP or fungal biomass, running the trial first (or waiting for a list update) is now clearly worth its cost.

#G.10.7 Steps for a new single raw material (for example bacterial SCP or cassava-pulp fungal protein)

1. Check the permitted list (Circular 21/2019 Appendix VI as amended). If the material fits an existing entry (for example nấm men, yeast; côn trùng, insects; bèo, duckweed), no trial is needed ^9,10 VN-directHigh.
2. If not, treat it as a "new substance". Run a trial under an approved protocol (Circular 94/2025 Chapter III) at a qualified facility. Importing trial samples may need a provincial import licence ^66,23 VN-directHigh.
3. Get the result recognised by DLPAH, then wait for the annual list update or rely on the recognition decision ^9,66 VN-directHigh. Whether recognition alone allows circulation before the list update is not stated in the texts read.
4. Get a certified factory (province), a declared standard, conformity with QCVN 01-190:2020, and a label ^60,69,22 VN-directHigh.
5. If sold as supplement feed with a functional claim, get the province's appraisal (15 WD) ²³ VN-directHigh.

Documented agency time is about 40 WD (protocol 15 + 5; results 15 + 5) ⁶⁶ VN-directHigh. This excludes dossier preparation, the trial itself (likely one grow-out cycle per species) and the wait for the annual list update. Our estimate of the total is 6 to 18 months. It is an estimate, not a documented figure.

Law Art 37(2) exempts the recognised results of state research projects from separate trials ⁶⁰ VN-directHigh. Publicly funded feed trials are therefore a high-leverage public good (policy option PO-021).

#G.11 Aquafeed

#G.11.1 The legal chain

Law on Fisheries 18/2017/QH14 (21 November 2017), amended by Law 146/2025/QH15 (aquafeed changes not visible in the extract) ^61,63 VN-directHigh:

• Art 31: before circulation, a published standard, a conformity declaration and information to MAE are needed. MAE issues the "Danh mục hóa chất, chế phẩm sinh học, vi sinh vật, nguyên liệu sản xuất thức ăn được phép sử dụng" (list of permitted chemicals, biological products, microorganisms and feed raw materials).
• Art 34: the Ministry issues factory certificates for foreign-invested firms. Whether that power moved to provinces was not verified.
• Art 35(1): aquafeed must be trialled "trong trường hợp có hóa chất, chế phẩm sinh học, vi sinh vật, nguyên liệu sản xuất thức ăn thủy sản không có tên trong danh mục quy định" (where it contains chemicals, biological products, microorganisms or aquafeed raw materials not on the prescribed list) ¹² VN-directHigh.
• Art 36: import licences are needed only for unlisted products imported for trials, research or fairs.

Decree 26/2019/ND-CP (8 March 2019), amended by Decree 37/2024 and Decree 309/2025 (the latter only on minimum catch sizes) ^71,72 VN-directHigh:

• Art 31: trial facility conditions.
• Art 32: the dossier (forms 17.NT registration, 18.NT protocol, 19.NT facility description). The authority appraises it within 20 days and issues a trial decision (form 21.NT). After the trial, results are recognised within 10 WD of the report.

Decree 136/2025 (from 1 July 2025): Art 19(2) moves recognition of aquafeed trial results to the provincial People's Committee chair; Art 18(2) moves import licences for aquafeed with unlisted substances to the provincial chair ²² VN-directHigh.

Official aquafeed trials sit with one national centre with sub-centres in Can Tho (Region I) and Ho Chi Minh City (Region II), under Decision 1109/QĐ-BNNMT of 25 April 2025 ^73,74 VN-directHigh.

#G.11.2 Circular 16/2026/TT-BNNMT and its Appendix II

Circular 16/2026/TT-BNNMT (9 March 2026, effective the same day) replaces Circular 26/2018, Art 8 and Appendices XX to XXII of Circular 01/2022, and Art 3 to 6 of Circular 10/2025 ⁷⁵ VN-directHigh. Art 12(2) says the permitted list is Appendix II. Art 19(1)(d) makes DFFI responsible for reviewing and updating it, with no stated way for firms to propose additions ¹¹ VN-directHigh.

Structure of Appendix II ("Danh mục hoá chất, chế phẩm sinh học, vi sinh vật, nguyên liệu sản xuất thức ăn được phép sử dụng trong nuôi trồng thuỷ sản tại Việt Nam") ¹¹ VN-directHigh:

• I. Chemicals: 1. minerals for aquafeed and environment products; 2. chemicals for environment treatment; 3. preservatives, antioxidants and other substances.
• II. Biological products, microorganisms, vitamins and amino acids: 1. bioactives and extracts from organisms (17 entries); 2. microorganisms (30 entries); 3. vitamins; 4. enzymes.
• There is no raw-material section, despite the title.

Entries relevant to new proteins ¹¹ VN-directHigh:

About 20 Bacillus species are listed. No methanotrophic bacteria and no microalgae are listed ¹¹ VN-directHigh.

#G.11.3 Legal consequence: a trial trigger broader than practice

Read literally, Art 35(1) with a list that holds no raw materials catches every raw material, including fishmeal and soybean meal. Conventional feeds are evidently sold without trials, so practice differs from the text ^11,12 VN-directHigh. The body of Circular 16/2026 does not say that livestock-list materials, or conventional materials, count as permitted in aquafeed ¹¹ VN-directHigh.

Our reading has two branches VN-directMedium:

• (a) the regulator treats conventional raw materials as outside the list requirement by practice, in which case insect meal and yeast protein probably are too; or
• (b) any unlisted raw material formally needs a trial.

The texts do not settle this. A written DFFI opinion is the cheapest fix. See DG-112. We found no penalty decree for aquafeed matching Decree 211/2026; this was not checked.

#G.12 Tax and investment incentives

#G.12.1 Corporate income tax

Law on Corporate Income Tax 67/2025/QH15 (14 June 2025; effective 1 October 2025; applies from the 2025 tax period) ⁷⁶ VN-directMedium:

• Art 12(2): incentives for (a) application of high technology under the High Technology Law and strategic technology; (e) high-tech enterprises, high-tech agriculture enterprises and science and technology enterprises; (i), (k), (l) agriculture and agricultural or aquatic processing meeting Art 4 conditions.
• Art 13(1): a 10% rate for 15 years for categories (a) to (e). Agricultural processing gets 10% or 15%, depending on location.
• Art 14(1): 4 years' exemption and a 50% cut for 9 years.
• Art 4: exempts some agricultural processing income in disadvantaged areas, and gives up to 3 years' exemption for products from newly applied technology.

Decree 320/2025/ND-CP (15 December 2025) guides the law and applies from the 2025 tax period ⁷⁷ VN-directHigh. Two tests matter for alternative protein:

• Art 4(1)(b): processed agricultural and aquatic products qualify for the exemption only if "tỷ lệ giá trị nguyên vật liệu là nông sản, thủy sản trên chi phí sản xuất ... từ 30% trở lên" (agricultural or aquatic raw materials are at least 30% of production cost), and the product is not subject to special consumption tax ⁷⁷ VN-directHigh. A cassava-based fermentation plant likely passes; a plant running on imported refined sugar may not. This is our interpretation VN-directMedium.
• Art 4(4)(b): "Thu nhập từ bán sản phẩm làm ra từ công nghệ mới lần đầu tiên áp dụng ở Việt Nam được miễn thuế 03 năm" (income from products made with technology applied for the first time in Vietnam is exempt for 3 years), subject to confirmation by the competent authority ⁷⁷ VN-directHigh. This could suit a first precision-fermentation or gas-fermentation plant.
• The incentive chapter (10% for 15 years; 4 years' exemption plus 9 years at 50% for new projects applying listed high technology) did not render, so the certification criteria remain unread ⁷⁷ VN-directMedium. Wave 1 reports that the decree was corrected by MOF Decision 517/QĐ-BTC (20 March 2026) ⁷⁶ VN-directLow.

VAT on feed. Under the VAT Law 48/2024/QH15 (Art 5(3), in force 1 July 2025), animal feed and aquafeed are "not subject to VAT" ⁷⁸ VN-directHigh. A plant making a feed protein therefore cannot reclaim VAT on its equipment, power and inputs; a food-ingredient plant can. Wave 1 estimated this adds roughly 5 to 10% to taxed input costs (our estimate; see Costs and benchmarks).

#G.12.2 High-tech and strategic technology lists

Decision 23/2026/QĐ-TTg (15 May 2026, effective 1 July 2026) replaces Decision 38/2020 ¹⁴ VN-directHigh. Its priority high technologies include omics (item 48), synthetic and molecular biology (49), bioinformatics (50), new-generation microbial technology (51), tissue, embryo and cell technology in medicine and agriculture (52), and "technology for producing recombinant proteins, enzymes and monoclonal antibodies" (60). Its encouraged products include recombinant proteins and enzymes (92), advanced biological products (98), and microbial strains and products for health, agriculture and environment (100). Items 49, 60 and 92 fit precision fermentation; 51 and 100 fit biomass fermentation and SCP; 52 fits cultivated meat (our mapping). There is no item for food, feed or alternative protein as such ¹⁴ VN-directHigh.

Decision 21/2026/QĐ-TTg (30 April 2026, effective 1 July 2026) replaces Decision 1131/QĐ-TTg (2025). Strategic technology item 4 is "advanced biotechnology and biomedicine". Strategic products include new-generation biologics for livestock and aquaculture (item 14) and new-generation crop, livestock and aquatic varieties from cell technology and gene editing (item 16). There is no food or feed protein item ⁷⁹ VN-directHigh.

The Law on High Technology 133/2025/QH15 is cited as the basis for both decisions. We did not read it, and its effective date (1 July 2026) is inferred ^14,79 VN-directLow. Decree 263/2026/NĐ-CP (effective 1 July 2026) lets provincial People's Committees set up hi-tech agriculture zones, with incentives that include priority for state R&D funds and up to 70% interest subsidy on loans to commercialise technology ⁸⁰ VN-directMedium.

#G.12.3 Investment Support Fund (Decree 182/2024/ND-CP)

Decree 182/2024/ND-CP (31 December 2024), Art 18 ⁸¹ VN-directHigh:

• High-tech product projects qualify with at least VND 12,000 bn of capital or VND 20,000 bn of annual revenue. Semiconductor and AI projects qualify at VND 6,000 bn or VND 10,000 bn.
• R&D centres need at least VND 3,000 bn, of which VND 1,000 bn within 3 years.
• Support: training up to 50%, R&D 20 to 30%, fixed assets 8 to 10%, high-tech products 1 to 3% of value added.
• Applications are due by 10 July of the following year.

At 26,000 VND per USD, the thresholds are about USD 460 million of capital or USD 770 million of revenue for a high-tech product project, and about USD 115 million for an R&D centre (our calculation). No alternative-protein project in Vietnam is near these sizes, so the fund is out of reach. See DG-053.

#G.12.4 Law on Investment 2025

Law on Investment 143/2025/QH15 (11 December 2025, effective 1 March 2026) ⁸² VN-directMedium:

• Incentivised sectors include science, technology and innovation (Art 15).
• Art 16 establishes the Investment Support Fund.
• Art 28 creates a special investment procedure for projects in high-tech zones and special economic zones, in which investor commitments replace technology appraisal and EIA-style steps.

#G.13 Sandboxes

Law on Science, Technology and Innovation 93/2025/QH15 (27 June 2025, effective 1 October 2025) ^83,15 VN-directHigh:

• Art 21 to 23 allow controlled testing of technologies, products and business models "not yet regulated or differing from current law".
• Art 21(1): the "cơ quan nhà nước có thẩm quyền" (competent state agency) permits testing. No single body is named.
• Art 21(3): the plan must set objectives, conditions and criteria for the technology or solution, risk management and participant protection.
• Duration: proposed by the firm, up to 3 years, extendable once by up to 3 years.
• Art 22: regulators and implementers are exempt from civil, administrative and criminal liability if they follow the rules, unless they knew or should have known of a risk and did not prevent it. Implementers remain liable to third parties.
• Art 21(6): the Government may issue detailed rules, including for sectors and for conflicts with other laws.
• Other articles: risk acceptance in R&D (Art 9); commercialisation, with at least 30% to creators where state funding is involved (Art 27 to 28); support for enterprise R&D (Art 34) ⁸³ VN-directHigh.

Implementing decrees. Four decrees of 14 October 2025 guide the law: 263/2025 (autonomy, human resources, talent), 265/2025 (finance and investment), 267/2025 (programmes, tasks, research promotion) and 268/2025 (innovation tasks, loan interest support, vouchers, startups). Decree 268/2025 has no controlled-testing provisions, and we found no general sandbox decree ^84,85 VN-directMedium.

Resolution 193/2025/QH15 (19 February 2025; parts to 31 December 2030) is a pilot mechanism for science and technology. Its only controlled-testing item is low-earth-orbit satellite services (Art 13), so it is not usable for food ⁸⁶ VN-directHigh.

Sandboxes that exist ^87,16 VN-directMedium:

The Hanoi list of priority fields is read at High confidence ¹⁶ VN-directHigh.

A food product today. There is no national route. The practical path is a Hanoi sandbox application under the biotechnology field, with MOH or VFA consulted. Whether a city sandbox can set aside national food safety rules has not been tested. This is our interpretation ^87,16 VN-directMedium.

#G.14 Strategies

None of the strategies below names alternative, novel or microbial protein ^88,89,90 VN-directHigh.

The agriculture strategy 2021 to 2030 (Decision 150/QĐ-TTg, 2022) and the feed-industry plans were not read. Hanoi's strategic technology list 2026 to 2035 (Decision 4217/QĐ-UBND, 12 August 2026) is a lead we did not check ³⁵ VN-directLow. See O. Outlook data for the dated calendar of these targets.

#G.15 Environment and carbon

• Environmental impact assessment (EIA). The Law on Environmental Protection 72/2020/QH14 is amended by Law 146/2025 from 1 January 2026. Decree 08/2022/ND-CP is amended by Decree 05/2025 (6 January 2025) and Decree 48/2026 (29 January 2026). Decree 48/2026 changes permit adjustment and phased EIA ⁹⁶ VN-directMedium.
• The EIA gap. The appendices with capacity thresholds for food, fermentation, feed and seafood processing (Appendices II to V) did not render in either wave. We can confirm only that Appendix II classifies activities by capacity (large, medium, small) and that Group I projects need an EIA. So we cannot say at what size a fermentation or feed plant needs a full EIA ^96,97 VN-directMedium. Decree 05/2025 moved some EIA appraisal and permitting to provinces from 6 January 2025 ⁹⁷ VN-directMedium.
• Carbon market. Decree 06/2022 as amended by Decree 119/2025 (9 June 2025) runs a pilot carbon market until the end of 2028, with full operation from 2029. Pilot quotas cover thermal power, steel and cement. Offsets can cover up to 30% of quotas, and Article 6.2 and 6.4 mechanisms are provided for. The extract says agriculture and food processing are not in the initial quota scope ²⁷ VN-directMedium. Direct carbon revenue for alternative protein is unlikely before 2029, except through voluntary or Article 6 credits under an approved method. Whether any large food or feed facility is on the greenhouse gas inventory list is unresolved (DG-054).
• Grid emissions. The latest official grid emission factor is 0.6592 tCO2/MWh for 2023, published on 3 December 2024 ⁹⁸ VN-directHigh. A power-intensive process in Vietnam carries a high Scope 2 footprint unless it buys renewable power.

#G.16 Biodiversity, access and benefit sharing

• Law on Biodiversity 20/2008/QH12, amended by Law 146/2025/QH15 (effective 1 January 2026), adds a definition of gene-edited organisms and restructures Art 57: a permit is needed for foreign access, domestic commercial access and export of genetic resources ^49,99 VN-directMedium.
• Decree 59/2017/ND-CP (12 May 2017) is still in force ²⁶ VN-directHigh:
  • Commercial research and product development need a licence (Art 7).
  • Registration is confirmed in 10 days. Non-commercial review takes 30 days. For commercial use, a council reviews within 90 days and a decision follows within 15 days.
  • A contract with the provider is certified by the commune People's Committee.
  • Benefit sharing is at least 1% of annual product revenue, or at least 2% of the value of an IP transfer (Art 22). The split is 30% to the provider and 70% to the state budget.
  • Derivatives are defined (Art 3(6)), and obligations pass on transfer (Art 14).
  • There is no provision on digital sequence information.
  • Microorganisms are not excluded, so microbes isolated from Vietnamese environments (for example from fermented foods or cassava waste) are in scope.
  • The licensing ministry is now MAE.
• Practical point. A startup that commercialises a strain isolated in Vietnam should budget for the licence and for benefit sharing of at least 1% of product revenue ²⁶ VN-directHigh.

#G.17 Intellectual property

• Law 131/2025/QH15 amending the IP Law (10 December 2025, effective 1 April 2026) adds rules on AI-created subject matter, a text and data mining exception, and non-physical industrial designs. Nothing on biotech exclusions was visible in the extract ¹⁰⁰ VN-directMedium.
• We did not verify in this study how the IP Law treats microorganisms, microbiological processes and fermentation processes, or the rules on disclosing the origin of genetic resources in patent applications. These questions matter for strain-based ventures and are listed in the gaps below.

#G.18 Import tariffs

MFN rates for feed and food protein inputs, from tariffs.csv. The base schedule is Decree 26/2023/ND-CP, amended by Decrees 144/2024, 21/2025, 73/2025, 108/2025, 260/2025, 72/2026 and 201/2026. Only Decree 73/2025 was checked line by line ^101,102 VN-directMedium.

Reading the table:

• Novel feed proteins compete against duty-free soybean meal and fishmeal, so they get no tariff shelter ^17,18 VN-directMedium.
• An imported dried SCP entering under 2102.20 would pay about 7%. That is a small edge for local SCP producers over imported SCP, but no edge over the incumbent proteins. The HS classification of SCP and precision-fermented proteins is our assumption, not a customs ruling ¹⁸ VN-directMedium.
• 2026 rates were not verified for the WITS 2023 lines. Confirm on the customs tariff lookup before relying on them.

See DG-114 for a minor disagreement on the pre-2025 soybean meal rate.

#G.19 Route-to-market table (as of 23 September 2026)

This is the full content of routes.csv (17 rows). Rows RT-001 to RT-016 come from the wave 2 table, matched to wave 1. RT-017 is a wave 1 row for a product type not in the wave 2 table. "Changed" marks rows that wave 2 changed.

#G.20 How a new protein gets to market: a plain-language explainer

These are the routes as the law stood on 23 September 2026. They may change when the new Food Safety Law and its decree take effect, possibly from 1 January 2027 ⁴⁶ VN-directMedium. Each step below is described in detail, with sources, in sections G.3 to G.13.

1. Plant-based food from known ingredients (tofu, textured soy, wheat gluten, jackfruit, đồ chay, plant milks). Make it in a food-safe factory. Test the product at an accredited lab. File a self-declaration with the authority named by the province. You can sell right away ⁴ VN-directHigh. No rule stops you calling it chay or using words such as sữa hạt, but do not mislead ⁵⁶ VN-directMedium. Because Vietnam has no mandatory allergen list, add soy and wheat warnings voluntarily. Many brands already use this route.

2. Koji or other traditional mould fermentation on a food substrate (Aspergillus oryzae, Rhizopus). The route is the same as for plant-based food. The organisms have a long history of food use in Vietnam (tương, nước tương) and elsewhere, so legal risk is low ⁴ VN-directMedium. Keep strain identity and safety data on file. The science matters here: A. oryzae cannot make aflatoxin but can make cyclopiazonic acid, so use a characterised strain (see J. Science).

3. Fungal biomass or mycoprotein food. Legally, the only route is the same self-declaration. There is no way to get the ingredient pre-approved ⁴ VN-directHigh. If the fungus has no food history, an inspector could argue it is "not a food-type raw material" (Law Art 5(1)) or a "new-technology product not yet permitted" (Art 55(1)(c)) ³ VN-directMedium. Edible-mushroom species carry lower risk than new strains. Build a safety dossier and talk to VFA before launch.

4. Microalgae food (spirulina, chlorella). Either self-declare as an ordinary food, or register as a health supplement at MOH (21 WD, GMP-certified factory) ⁴ VN-directHigh. Newer algae species carry the same uncertainty as new fungi.

5. Precision-fermented protein food. An imported ingredient can be self-declared, or is exempt from declaration if used only in your own production ⁴ VN-directHigh. Label it as GM if it is more than 5% of the product, because a recombinant protein is probably a "product of a GMO" ^4,8 VN-directMedium. If it works as an additive or enzyme not on the MOH list, register it with VFA (7 WD) ^4,54 VN-directHigh. Making it in Vietnam with a GM microbe needs MAE's new closed-production certificate: Forms 32 and 33, a contained facility that prevents release, licensed waste treatment and OECD or G20 standards ⁸ VN-directHigh. The certificate's timeline and fee are not published. No text says whether a GMO food-use certificate is also needed, so ask MAE and MOH in writing before investing.

6. Cultivated meat or seafood. There is no national route. The law implies that new-technology food needs "permission to circulate", but there is no procedure to obtain it ³ VN-directHigh. Any genetically modified cell line adds GMO questions. The most concrete option is a supervised pilot in Hanoi's sandbox under the biotechnology field, with MOH consulted ^87,16 VN-directMedium. Whether a city sandbox can set aside national food law is untested.

7. Insect meal for livestock and poultry feed. Insects are on the permitted raw-material list, so no feeding trial is needed ⁹ VN-directHigh. You need a certified feed factory (province), a declared standard, conformity with the QCVN 01-190:2020 limits, and a label ^60,69,22 VN-directHigh. Entobel has used this route since 2019 ¹⁰⁴ VN-directMedium.

8. Insect meal, yeast protein, duckweed or microalgae for shrimp and fish feed. None of these is on the aquafeed list as a raw material, because the list has no raw-material section. The Fisheries Law, read literally, requires a trial for any unlisted raw material ^11,12 VN-directHigh. Practice evidently differs, because conventional feeds are sold without trials. Ask DFFI in writing whether your ingredient needs an aquafeed trial before you build a product on it.

9. Duckweed or algae meal for livestock feed. Bèo (duckweed) and tảo (algae) are on the livestock list, so the route is the same as for insect meal ⁹ VN-directHigh. If grown on wastewater, test heavy metals and pathogens against QCVN 01-190:2020 ⁶⁹ VN-directHigh.

10. Yeast protein for livestock feed. Inactive yeasts, including Torula or Candida yeast and yeast grown on molasses, and by-products of amino-acid fermentation, have been on the livestock list since February 2023. The route is the same as for insect meal ¹⁰ VN-directHigh.

11. Bacterial SCP or another new microbial protein for livestock feed. This is probably a "new substance". Run a feed trial under a DLPAH-approved protocol (15 + 5 WD to approve), then get the result recognised (15 + 5 WD). The material then enters the permitted list at the next annual update ^60,9,66 VN-directHigh. Our estimate of the total is 6 to 18 months; that is an estimate, not a legal deadline. Do not sell it before it is listed: since 5 August 2026 the fine is VND 10 to 20 million per unlisted material, plus 1 to 3 months' suspension of feed production ¹³ VN-directHigh.

12. SCP for aquafeed. Register an aquafeed trial (20-day dossier appraisal), run it, and get the results recognised by the provincial People's Committee chair (10 WD). Importing trial material needs a provincial licence. Then declare the aquafeed products that contain it ^61,71,22 VN-directHigh.

13. A new food additive, enzyme or processing aid. Register the product declaration at VFA (7 WD), or ask MOH to amend the additive list with safety evidence ^4,54 VN-directMedium.

#G.21 Foreign precedents and what Vietnam could copy

Full country comparisons are in N. Regional. This section covers only the regulatory mechanisms.

Three lessons from the regional record ^112,113,108 VN-adjacentMedium:

• Korea shows a route that does not need a new law. A safety-assessment step can be added inside an existing instrument, with a published fee and review time.
• Thailand shows how to borrow assessors. An existing science body can be designated as the assessment unit instead of building a new agency.
• A framework is not enough. Thailand and Korea have routes but had no cultivated-meat approval by September 2026. Staff capacity and statutory timelines matter as much as the legal text.

#G.22 Policy options

This is the full content of policy_options.csv (25 rows): 11 options ranked by the wave 2 regulation review and 14 options from wave 1. The wave 2 ranking multiplies impact on investability by feasibility and time-criticality. Effort: Low = a letter, guidance or list update; Medium = a circular or decree amendment; High = a new law chapter or regime. Policy options discusses them.

#G.22.1 Ranked options (wave 2)

Options 1 to 4 are cheap and time-critical. Option 1 only works during the October to November 2026 session. Options 3 and 4 fix ambiguities that Decree 211/2026 has made costly ¹³ VN-directMedium.

#G.22.2 Wave 1 options

#G.23 Gaps and how to close them

Each gap is also in open_questions.csv and Q. Open questions.

#G.24 Related data files

• instruments.csv: 64 instruments (laws, decrees, circulars, decisions, resolutions, foreign reference rules), with status, key provisions, sources and a change log where wave 2 corrected wave 1.
• routes.csv: the 17-row route-to-market table in section G.19.
• policy_options.csv: the 25 policy options in section G.22, with cross-links between waves.
• tariffs.csv: the 10 tariff lines in section G.18.
• ministries.csv: the six ministry and provincial rows behind section G.2 (see also P. Admin map).
• disagreements.csv: DG-046 to DG-055 and DG-111 to DG-114 cover the regulatory conflicts cited here (see R. Disagreements).
• open_questions.csv: the gaps in section G.23 (see Q. Open questions).
• Working papers: working-papers/wave1/regulation/regulation.md and working-papers/wave2/regulation2/regulation2.md.