Chapter 12 · Part III
12. Policy options
Most of what would move alternative protein forward in Vietnam is cheap: a one-line delegation clause in the Food Safety Law expected before the National Assembly in late 2026, a joint note on precision-fermented proteins, and two feed-list fixes. The expensive items are shared infrastructure: a pilot fermentation line and trial and testing capacity. We set out 33 options, rank the 24 that are current by impact, effort and timing, and name the owning agency and the instrument to amend for each.
On this page
In one paragraph. Vietnam does not need a new law or a new agency to give alternative protein a workable path. The most valuable step is also one of the cheapest and most time-bound: a short clause in the Food Safety Law expected before the National Assembly (October to November 2026 session according to the WTO notification and a deputy's statement, not yet confirmed on the agenda; possibly in force from 1 January 2027) that lets the Government regulate "new foods and new food ingredients", so that the detail can sit in a decree. Three other low-effort steps follow closely: a joint note from the agriculture and health ministries on the status of precision-fermented proteins under the new GMO decree, a raw-material section in the aquafeed list, and generic entries for microbial biomass in the livestock feed list. The costly options are about shared infrastructure: a pilot fermentation line, public feed trials and a protein-quality laboratory. This chapter sets out 33 options, ranks the 24 current ones (the other nine are earlier versions superseded by more specific options), and names, for each, the owning agency, the instrument to amend and a precedent. It is policy analysis, not legal advice.
12.1 Principles behind the ranking
- Proportionate, not permissive or prohibitive. Most new proteins are ordinary foods or feeds with a new source. Rules should gate what is new, not everything that is different (Rules).
- Rely on others' work. Vietnam already fast-tracks GMOs approved in five developed OECD or G20 countries under Decree 43/2026; the same logic can apply to novel foods and feeds 1,2 .
- Publish timelines and fees. The regional study's most specific recommendation for Vietnam is to publish procedures and statutory timelines 3 . Korea's published fee and review period, even before any approval, gave applicants something to plan around 4 .
- Share capital, not only tax. Capital is most of the cost of fermentation (Economics), and the regional study ranks capital grants and loan guarantees above tax holidays 3 .
- Use windows while they are open. The Food Safety Law revision is a one-off opportunity; the next revision may be years away 5,6 .
12.2 The ranked options
Ranked by impact on investability, feasibility and time-criticality. Effort: Low = a letter, guidance or list update; Medium = a circular or decree amendment; High = a new chapter of law, a new regime or major spending. The full table, with sources and notes, is policy_options.csv.
Tier 1: cheap and time-critical (2026 to 2027)
| Rank | Option | Owner | Instrument | Precedent | Effort | Timeline |
|---|---|---|---|---|---|---|
| 1 (PO-015) | A short delegation clause in the new Food Safety Law: "The Government shall regulate the management of new foods and new food ingredients", with a definition based on history of use | MOH (Vietnam Food Administration) as drafter; National Assembly Committee on Science, Technology and Environment | Draft Law on Food Safety (amended) | Singapore FSSA 2025; Thailand Notification 376 | Low | October to November 2026 session |
| 2 (PO-016) | Joint MAE and MOH note: a purified protein made by a GM microorganism in contained use, with no viable GMO or recombinant DNA in the product, carries a GM label above 5% but needs no GMO food-use certificate | MAE (biodiversity and science departments); MOH | Official letter now; later a definitions amendment | Decree 43/2026 already separates organisms from products | Low | 3 to 6 months |
| 3 (PO-017) | Add a raw-material section to the aquafeed list, or state that livestock-list raw materials are allowed in aquafeed; add insect meal, inactivated yeast, microalgae, duckweed and fermented soybean meal | MAE Department of Fisheries | Circular amending Circular 16/2026 Appendix II | Circular 31/2022 added yeasts to the livestock list | Low | Next list update (2027) |
| 4 (PO-018) | Generic livestock-list entries for inactivated microbial biomass from safe strains (bacterial, fungal, microalgal), relying on foreign feed authorisations | MAE Department of Livestock Production and Animal Health | Circular amending Circular 21/2019 Appendix VI | Circular 31/2022 | Low | Next annual update (2027) |
| 5 (PO-019) | Novel-food procedure in the decree implementing the new law: a "not novel" determination on request; a traditional-food lane with a fixed objection window; a reliance lane for foods approved by two or more reference regulators; full assessment by recognised assessment units with a public positive list | MOH; Government | Decree replacing Decree 15/2018 | Thai assessment units; EU traditional-food notification; Decree 43/2026 fast-track | Medium | Drafting Q4 2026; in force 2027 |
Sources: 7,5,6,8,1,2,9,10,11 .
Why these first. Option 1 only works while the law is being drafted and debated, expected in the October to November 2026 session. Options 3 and 4 fix ambiguities that became costly once Decree 211/2026 introduced fines of VND 10 to 20 million per unlisted material, plus one to three months' suspension (Rules). Option 2 removes the biggest legal unknown for precision fermentation at the cost of a letter.
Tier 2: moderate effort, high value (2027 to 2028)
| Rank | Option | Owner | Instrument | Effort | Timeline |
|---|---|---|---|---|---|
| 6 (PO-020) | One supervised novel-food pilot in the Hanoi sandbox, with MOH in the appraisal; in parallel a decree naming MOH as approving agency for food tests under the Law on Science, Technology and Innovation | Hanoi People's Committee; MOST; MOH | Hanoi decision; Government decree | Medium | 6 to 12 months (Hanoi); 12 to 24 months (national) |
| 7 (PO-021) | Publicly funded feed trials of microbial protein in whiteleg shrimp, pangasius, broilers and pigs, run as state science tasks so results qualify for the state-research exemption from separate trials | MAE; MOST | S&T task; Law on Animal Husbandry Art 37(2) | Medium | 12 to 24 months |
| 8 (PO-022) | Publish the timeline, fee and issuing level of the closed-production GMO certificate, with a model form for industrial fermentation strains | MAE | Guidance note | Low | 3 months |
| 9 (PO-023) | Tax guidance confirming that precision-fermentation and biomass-fermentation plants qualify as high-technology projects, and clarifying the agricultural raw-material test for fermentation on cassava or sugar | MOF (Tax Department); MOST | Guidance letter | Low | 3 to 6 months |
| 10 (PO-026) | Shared food-grade pilot fermentation line plus a tolling programme on existing industrial tanks | MOST; MAE; Ho Chi Minh City; Saigon Hi-Tech Park or FIRI | S&T programme or city investment | High | 24 to 36 months |
| 11 (PO-031) | Shift biomanufacturing support towards capital grants, loan guarantees and feedstock-cost support | MOF; MOST | Investment-support decrees | Medium | 12 to 24 months |
| 12 (PO-030) | Name alternative protein and biomanufacturing as priorities in the national, Ho Chi Minh City and Hanoi venture funds, with a first-loss window for pilot plants | MOF; MOST; city People's Committees | Fund charters under Decree 264/2025 | Low | 6 to 12 months |
Sources: 8,12,13,14,15,3,16,17,18,19,20 .
Tier 3: supporting options
| Rank | Option | Owner | Effort |
|---|---|---|---|
| 13 (PO-027) | Accredit amino-acid and protein-digestibility (DIAAS or PDCAAS) testing at a national reference laboratory | MOH (NIFC); MAE (FIRI NACEFA) | Medium |
| 14 (PO-028) | Yearly national by-product atlas | MAE; National Statistics Office | Low |
| 15 (PO-029) | Input-VAT neutrality for new feed ingredients | MOF | Medium |
| 16 (PO-024) | Codex priority allergens on labels, and a short naming rule for plant-based and fermentation-based analogues (qualifier required) | MOST with MOH | Low |
| 17 (PO-009) | Name alternative and novel protein ingredients in biotechnology programmes | MOST; MAE; MOH | Low |
| 18 (PO-007) | Provincial one-stop desks and published target timelines for feed procedures now decentralised to provinces | Provincial People's Committees | Low |
| 19 (PO-013) | Transition rules in the new Food Safety Law that protect existing self-declared products | MOH | Low |
| 20 (PO-032) | Publish grid emission factors for 2024 and 2025; signal capacity-charge levels early | MAE; MOIT | Low |
| 21 (PO-011) | Simplified access and benefit-sharing procedure and model contracts for public microbial collections | MAE; VAST; VNU; FIRI | Low |
| 22 (PO-033) | Pilot-plant access and regulatory cooperation with Thailand and Singapore | MOST; MOH; Ministry of Foreign Affairs | Low |
| 23 (PO-014) | Co-lead ASEAN work on common principles and reliance for novel foods | MOH; MOST | High |
| 24 (PO-025) | Review import duties on food protein inputs not made in Vietnam at scale (wheat gluten 10%, protein concentrates 5%), weighing the effect on local yeast and microbial-protein producers | MOF | Low |
Sources: policy_options.csv . The remaining wave-1 options (PO-001 to PO-006, PO-008, PO-010, PO-012) are kept in the data file and superseded by the more specific options above.
Policy options by effort and impact
Ranked options; colour shows tier
Evidence:
Show dataHide data
| Rank | Tier | Option | Effort | Impact | Owner | Timeline |
|---|---|---|---|---|---|---|
| 1 | 1 | Put a short delegation clause in the new Food Safety Law: "The Government shall regulate the management of new foods and new food ingredients" (thực phẩm mới, nguyên liệu thực phẩm mới), with a definition based on history of use. This keeps the law short and lets the decree carry the detail | Low | High | MOH/VFA (drafter); National Assembly Committee on Science, Technology and Environment (review) | October to November 2026 session; law in force 1 Jan 2027 |
| 2 | 1 | Joint MAE and MOH guidance on precision-fermented proteins: GM label above 5% applies, but no GMO food-use certificate is needed for a purified protein made in contained use with no viable GMO or recombinant DNA in the product | Low | High | MAE Department of Nature Conservation and Biodiversity and Department of Science and Technology; MOH/VFA | 3 to 6 months |
| 3 | 1 | Add a raw-material section to the aquafeed list, or state that raw materials on the livestock list (Circular 21/2019 App VI) are permitted in aquafeed. Add insect meal, inactivated yeast biomass, microalgae biomass, duckweed and fermented soybean meal | Low | High | MAE DFFI | Next list update (2027) |
| 4 | 1 | Add generic entries to the livestock list for inactivated microbial biomass from safe strains (bacterial SCP, fungal biomass, microalgae), relying on foreign feed authorisations. This matters more now that Decree 211/2026 fines unlisted use | Low | Medium | MAE DLPAH | Next annual update (2027) |
| 5 | 1 | Novel-food procedure in the implementing decree of the new law: (a) a "not novel" determination on request; (b) a traditional-food notification lane for foods with long safe use abroad, with a fixed objection window; (c) a reliance lane for foods approved by 2 or more reference regulators (Singapore, US, EU, Australia/New Zealand, Thailand); (d) full assessment by recognised assessment units, with a public positive list | Medium | High | MOH/VFA; Government | Drafting Q4 2026; in force 2027 |
| 6 | 2 | Use the Hanoi sandbox for one supervised novel-food pilot (e.g. precision-fermented dairy protein or cultivated seafood tasting), with MOH in the appraisal. In parallel, a Government decree under Law 93/2025 Art 21(6) naming MOH as the approving agency for food tests | Medium | Medium | Hanoi People's Committee and Hanoi Department of Science and Technology; MOST; MOH | 6 to 12 months (Hanoi); 12 to 24 months (national) |
| 7 | 2 | Publicly funded feed trials of SCP in whiteleg shrimp, pangasius, broilers and pigs, run as state S&T tasks so results qualify for the state-research exemption from separate trials | Medium | High | MAE (DLPAH, DFFI, research institutes); MOST | 12 to 24 months |
| 8 | 2 | Publish the closed-production certificate timeline, fee and issuing level, and a model Form 33 for industrial fermentation strains | Low | Medium | MAE Department of Nature Conservation and Biodiversity | 3 months |
| 9 | 2 | Tax guidance confirming that precision-fermentation and biomass-fermentation plants qualify as "new projects applying high technology" (Decision 23/2026 items 60, 92, 100) and for the 3-year first-technology exemption (Decree 320/2025 Art 4(4)(b)); clarify the 30% agri raw-material test for fermentation on agricultural sugars or cassava | Low | Medium | MOF (Tax Department); MOST | 3 to 6 months |
| 10 | 2 | Shared food-grade pilot fermentation line plus a tolling programme on existing industrial tanks, open to startups and researchers | High | High | MOST; MAE; Ho Chi Minh City People's Committee; Saigon Hi-Tech Park or FIRI as host | 24 to 36 months |
| 11 | 2 | Shift biomanufacturing incentives towards capital grants, loan guarantees and feedstock-cost support rather than further tax holidays | Medium | High | MOF; MOST; MPI functions now in MOF | 12 to 24 months |
| 12 | 2 | Name alternative protein and biomanufacturing as priorities in the rules of the national, Ho Chi Minh City and Hanoi venture funds, and add a first-loss window for pre-revenue pilot plants | Low | Medium | MOF; MOST; Ho Chi Minh City and Hanoi People's Committees | 6 to 12 months |
| 13 | 3 | Accredit amino-acid profiling and protein-digestibility (DIAAS or PDCAAS) testing at a national reference laboratory | Medium | Medium | MOH (NIFC); MAE (FIRI NACEFA) | 12 to 24 months |
| 14 | 3 | Publish a yearly national by-product atlas (volume, location, price, composition of cassava pulp, bran, okara, spent grain, seafood by-products) | Low | Medium | MAE with the National Statistics Office; provincial departments | 12 months |
| 15 | 3 | Input-VAT neutrality for new feed ingredients: allow input-VAT credit for makers of feed ingredients, or offset through duty and CIT incentives | Medium | Medium | MOF | Next VAT amendment |
| 16 | 3 | Adopt the Codex list of priority allergens for food labels, and a short rule on names for plant-based and fermentation-based analogues (qualifier required, e.g. "thực vật", "chay") | Low | Low | MOST (labelling decree owner) with MOH | 2027 |
| 17 | 3 | Name alternative and novel protein ingredients for food and feed explicitly in biotech programmes (Resolution 189/NQ-CP tasks, Decision 429 follow-up) and the next high-tech product list update | Low | Medium | MOST; MAE; MOH | |
| 18 | 3 | Provincial one-stop desk and published target timelines for feed and aquafeed procedures now decentralised | Low | Medium | Provincial People's Committees and Departments of Agriculture and Environment (e.g. Dong Nai, Ho Chi Minh City, Can Tho) | |
| 19 | 3 | Transition rules in the new Food Safety Law: grandfather existing self-declarations and set realistic deadlines | Low | Medium | MOH/VFA | |
| 20 | 3 | Publish official grid emission factors for 2024 and 2025, and signal capacity-charge levels of the two-part power tariff early | Low | Low | MAE (Department of Climate Change); MOIT | 3 to 6 months |
| 21 | 3 | Simplified ABS procedure and model material transfer and benefit-sharing contracts for public microbial culture collections | Low | Medium | MAE (biodiversity); VAST, VNU, FIRI collections | |
| 22 | 3 | Negotiate pilot-plant access and regulatory cooperation with Thailand and Singapore (EECi access for Vietnamese firms; observer role in regional novel-food and cultivated-food safety work) | Low | Medium | MOST; MOH; Ministry of Foreign Affairs | 12 months |
| 23 | 3 | Vietnam to co-lead ASEAN work on common principles and reliance for novel foods | High | Medium | MOH; MOST (ASEAN ACCSQ) | |
| 24 | 3 | Review MFN duties on food protein inputs not made in Vietnam at scale (wheat gluten 10%, protein concentrates 5%), while weighing the effect on local producers of SCP and yeast (2102.20 at 7%) | Low | Low | MOF | Next MFN amendment |
12.3 Trade-offs to weigh
- Speed against caution. A reliance lane (option 5) speeds access for foods approved elsewhere but imports other regulators' judgements. Limiting it to two or more reference regulators and keeping a veto for Vietnamese-specific concerns (diet patterns, allergens) is a common middle path.
- Gate against open door. Today, new protein foods enter through self-declaration with legal uncertainty (Rules). A new procedure adds a gate for genuinely new ingredients. If it lacks timelines and assessor capacity, it could slow products that are legal today. Transition rules (PO-013) and a "not novel" determination reduce that risk.
- Tariffs. Lower duties on gluten and protein concentrates would cut costs for Vietnamese food makers but also weaken a domestic textured-protein play (T1) and local yeast producers. The data do not settle this; it is a choice between downstream and upstream industry.
- Fermentation GMO status. A light-touch reading for purified proteins (option 2) follows the product-based logic Decree 43/2026 already applies, but some consumers and trading partners may expect GM labelling. The option keeps labelling above 5%.
- Public money. A pilot line (PO-026) is the one large public outlay. The case rests on use by several firms and research groups; without an anchor host and operator it risks becoming an idle asset, as has happened elsewhere.
12.4 Who does what
| Agency | Top actions |
|---|---|
| Ministry of Health (Vietnam Food Administration; NIFC) | Delegation clause and novel-food decree (1, 5); joint PF note (2); transition rules; protein-quality laboratory |
| Ministry of Agriculture and Environment (livestock and fisheries departments; biodiversity) | Aquafeed and livestock list fixes (3, 4); public feed trials (7); closed-production certificate guidance (8); by-product atlas; emission factors |
| Ministry of Science and Technology | Sandbox decree (6); high-tech criteria; pilot-line programme; labelling rule; regional cooperation |
| Ministry of Finance | Tax guidance (9); incentive design (11); fund priorities (12); VAT neutrality; tariff review |
| Ho Chi Minh City, Hanoi and cassava provinces (Tay Ninh and the Central Highlands) | City venture funds; sandbox; pilot-line host; co-location of fermentation with starch |
| National Assembly | Delegation clause during the October to November 2026 session |
After the 2025 mergers, one ministry (MAE) holds feed, aquafeed, GMO biosafety and genetic resources, and one (MOST) holds standards, the sandbox, high-tech status and IP, which makes coordination simpler than before (Rules, P. Admin map).
12.5 What this means
- Policy makers: options 1 to 4 cost little, need no new agency and should be acted on in 2026 and 2027. Option 1 closes once the law is passed.
- International bodies: the most useful support is technical: drafting help for the novel-food decree (through regulator-to-regulator agreements), funding for public feed trials and the protein-quality laboratory, and co-funding of a pilot line.
- Research bodies: options 7, 13 and 14 are research-led public goods; proposals ready before the next funding round will move faster.
- Investors and companies: track options 1 to 5 as signposts (Outlook). A written ministry opinion on your specific ingredient is still the cheapest risk reduction available today.
Related: G. Regulation (full legal register and route-by-route tables), Rules, Policy makers, International.
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