The Government has officially issued Decree 46/2026/ND-CP, guiding the implementation of the Law on Food Safety and replacing Decree 15/2018/ND-CP. This is a significant regulatory milestone, introducing substantial changes in how food-safe packaging is managed—particularly for materials that come into direct contact with food.

This article provides a comprehensive analysis of the impacts of Decree 46, emerging packaging trends, and the role of BMP Group in supporting businesses through this transition.

I. What is Decree 46/2026/ND-CP? Overview of New Food Packaging Regulations

Previously, Decree 15/2018/ND-CP allowed businesses to self-declare compliance for food-contact packaging and utensils. However, practical implementation revealed limitations, particularly in quality control and traceability.

Decree 46 was introduced to:

• Strengthen food safety management through a pre-market approval approach
• Align with international regulatory standards
• Protect consumer health
• Enhance transparency across the food supply chain

Effective date: January 26, 2026

Scope of application: Organizations and individuals involved in the production and trading of food, additives, processing aids, and food-contact packaging materials, which are subject to stricter safety requirements.

II. Key Changes Impacting Food Packaging

1. Food packaging now under stricter regulatory control

For the first time, food-contact packaging is formally recognized as a potential risk category and is subject to stricter control over:

• Technical standards
• Conformity declaration dossiers
• Government inspections (especially for imported goods)

2. Transition from “self-declaration” to “registration of conformity declaration”

This is the most critical change under Article 4 of Decree 46:

3. Mandatory government inspection for imported packaging

Under Article 20, imported food-contact packaging is now subject to official food safety inspection, with:

• Three inspection levels (strict, normal, reduced)
• Clearly defined processing timelines
• Transparent roles and responsibilities

4. Mandatory implementation of quality management systems

For the first time, Decree 46 sets a roadmap requiring the adoption of systems such as HACCP and GMP for high-risk product groups, no later than December 31, 2026.

5. Decentralized regulatory management

Provincial People’s Committees are assigned responsibility for managing food safety conditions related to food-contact packaging (Article 51).

III. Impact on Food Packaging Manufacturers

1. Immediate Challenges

a. Legal risks from non-compliant packaging

Using packaging that does not meet safety standards or contains hazardous solvents (e.g., toluene, benzene) may result in:

• Rejection of conformity registration
• Administrative penalties
• Damage to brand reputation

b. Increased compliance costs

• Testing and certification costs
• Documentation and regulatory submission costs
• Material conversion and reformulation costs

c. Time pressure

Products self-declared before January 26, 2026, may only circulate for up to 12 months.
Companies must complete new conformity registrations within this timeframe.

2. Strategic Opportunities

a. Competitive advantage through safe packaging

Early adopters of compliant packaging solutions will:

• Accelerate product approvals
• Strengthen trust with partners and consumers
• Reduce product recall risks

b. Facilitating export readiness

As domestic regulations align with international standards, businesses can:

• Access markets such as the EU, US, and Japan more easily
• Meet stringent audit requirements from global brands

c. Enhancing ESG performance

Safe and traceable packaging contributes to:

• Improved Environmental (E) metrics
• Greater Governance (G) transparency
• Stronger alignment with investor and partner expectations

IV. Future Trends in Food Packaging

1. Solvent-free packaging

A key direction for food-safe packaging is the elimination of harmful solvents such as toluene, benzene, and MEK in:

• Printing inks
• Laminating adhesives
• Surface coatings

Reasons:

• Risk of migration into food
• Non-compliance with new safety standards
• Restrictions in export markets

2. Mono-material packaging

Mono-material solutions (PE, PP, PET) are becoming essential due to:

• Recyclability and circular economy compatibility
• Compliance with EPR requirements
• Improved traceability across the product lifecycle

3. Solvent-free lamination technology

BMP applies solvent-free lamination technology across multiple product lines, delivering:

• Enhanced food safety
• Reduced VOC emissions
• Superior bonding performance and quality

4. Certified materials

Certifications are increasingly critical in conformity dossiers:

• BRCGS – Global food safety standard
• ISCC PLUS – Sustainability and circular carbon certification
• FSC® – Responsible sourcing of forest materials
• ISO 15378 – Packaging standard for pharmaceuticals

5. Integrated management systems

To meet HACCP and GMP requirements, businesses must:

• Build comprehensive quality management systems
• Adopt digital tools (ERP, MES, AI-based inspection)
• Ensure process transparency

V. BMP Group: Your Partner in Food-Safe Packaging

1. Commitment to safety and quality

BMP Group is not just a supplier, but a strategic partner delivering food-safe packaging solutions compliant with Decree 46. We commit to:

• 100% compliance with food safety standards
• Solvent-free technologies for inks and adhesives
• Full international certifications (ISO 9001, ISO 15378, BRCGS, ISCC PLUS, FSC®)

2. Toluene-free packaging solutions

BMP has proactively transitioned to non-toxic ink systems:

3. Regulatory support for customers

BMP supports clients with:

• Material selection aligned with regulations
• Complete legal documentation (test reports, conformity certificates)
• Raw material traceability
• Audit readiness for regulators and brand owners

4. Sustainable packaging solutions

BMP develops packaging solutions that integrate:

• Food safety compliance
• Recyclability (mono-material, circular materials)
• Long-term cost optimization

VI. Recommended Transition Roadmap

Phase 1: Assessment

• Review current packaging portfolio
• Check validity of conformity declarations
• Evaluate materials for hazardous substances

Phase 2: Planning (Q2–Q3 2026)

• Identify packaging requiring modification
• Collaborate with suppliers (e.g., BMP)
• Estimate costs and timelines

Phase 3: Implementation (Before Dec 31, 2026)

• Transition to compliant packaging
• Complete conformity registration
• Upgrade quality management systems (HACCP, GMP if required)

VII. Conclusion & Recommendations

Decree 46/2026/ND-CP is not a barrier but a catalyst for elevating food packaging safety standards and accelerating global integration. Businesses that proactively adapt will gain a sustainable competitive advantage.

BMP Group is proud to support enterprises throughout this transition. With advanced manufacturing capabilities, internationally recognized certifications, and a strong commitment to innovation, we deliver packaging solutions that are:

• Safe and solvent-free
• Fully compliant with Decree 46 and global standards
• Cost-efficient in the long term
• Supported by regulatory and traceability expertise

Contact Us

To explore tailored packaging solutions for your business:

• 1416 D1 Street, Phu Nhuan Residential Area, Phuoc Long Ward, Ho Chi Minh City, Vietnam
• (+84) 28 66 756 588