Food businesses often hear several names at once: the food safety eligibility certificate, HACCP, ISO 22000, FSSC 22000. Many business owners assume these are alternatives to one another, when in fact they belong to two different groups: one is a legal requirement, the other is a voluntary management system.
Short conclusion: the food safety eligibility certificate is the basic legal requirement under Decree No. 15/2018/NĐ-CP; HACCP, ISO 22000 and FSSC 22000 are voluntary management systems, and a business that already holds one of these certifications is exempt from applying for that certificate. Decree No. 46/2026/NĐ-CP points toward making these systems mandatory for certain high-risk product groups, but it is currently suspended.
Four names, two different groups
| Food safety eligibility certificate | HACCP | ISO 22000 | FSSC 22000 | |
|---|---|---|---|---|
| Nature | A license under legal regulations | A hazard control method | An international standard for management systems | A scheme based on ISO 22000 |
| Mandatory or voluntary | Mandatory, unless exempt | Voluntary | Voluntary | Voluntary |
| Who issues / certifies | The state management authority by sector (health, agriculture, industry and trade, depending on the product) | Independent certification body | Independent certification body | Certification body licensed by FSSC |
| When commonly used | Every food production and trading facility (except the exempt group) | Hazard control needed per customer or export requirements | A complete management system is needed, often alongside ISO 9001 | International supply chains; large retailers require a GFSI-recognized standard |
HACCP focuses on hazard analysis at each production stage, following principles developed by the Codex Alimentarius Commission (FAO/WHO). ISO 22000 uses the HACCP principles as a core part, plus management system requirements under the common structure of ISO standards — meaning ISO 22000 is broader than HACCP. FSSC 22000 builds on ISO 22000, adding technical requirements for each food sector and requirements on food defense and food fraud; it is a popular choice when the customer is a supermarket chain or an international food group.
Does holding these certifications exempt a business from the food safety eligibility certificate?
Yes. Under Decree No. 15/2018/NĐ-CP, a food production or trading facility that has been issued one of these certifications — HACCP, ISO 22000, IFS, BRC, FSSC 22000 or GMP — is not required to apply for the food safety eligibility certificate, provided the certification is valid and covers the products actually being produced or traded.
This is why many factories choose ISO 22000 or HACCP from the start instead of applying separately for the food safety eligibility certificate: it meets the legal requirement while also giving a more structured management system for large customers. One point to note: the exemption applies facility by facility and product group by product group within the certification scope; a business with several production lines and product groups should check whether the certification scope covers everything, to avoid a case where some products fall outside the scope without the business knowing.
Should you choose HACCP, ISO 22000 or FSSC 22000?
There is no common answer for every business; the choice depends on who is asking and what stage the business is at:
- You only need to meet domestic customer requirements, at small or medium scale: HACCP is usually enough and leaner to start with, since it focuses on on-site hazard control.
- You already have ISO 9001 and want an integrated food safety management system as well: ISO 22000 fits because it shares the management structure, making it easy to combine documents, with the same coordinating team.
- You sell to supermarket chains, international food groups, or export to markets requiring a GFSI standard: ask the customer first whether they specifically require FSSC 22000, BRC or IFS, since each supply chain is usually familiar with one particular scheme.
- You are a new business with no specific customer requirement yet: complete the food safety eligibility certificate first, and do not rush to build an international system without a real need.
Decree No. 46/2026/NĐ-CP: issued but currently suspended
On 26 January 2026, the Government issued Decree No. 46/2026/NĐ-CP to replace Decree No. 15/2018/NĐ-CP, moving from product self-declaration to registration of a declaration of conformity, and setting a roadmap for certain high-risk product groups (health supplements, food additives and some other groups) to have a food safety management system such as HACCP, ISO 22000, GMP or equivalent.
However, implementation ran into obstacles. The Government issued two successive suspension resolutions:
- Resolution No. 09/2026/NQ-CP (4 February 2026): suspended Decree No. 46/2026/NĐ-CP until the end of 15 April 2026, allowing Decree No. 15/2018/NĐ-CP to continue to apply during this period.
- Resolution No. 15/2026/NQ-CP (6 April 2026): replaced Resolution No. 09/2026/NQ-CP and continues the suspension of Decree No. 46/2026/NĐ-CP — this time with no fixed end date, but suspended until the amended Law on Food Safety and new guiding decrees take effect. Decree No. 15/2018/NĐ-CP continues to apply during the suspension.
As of the date this article was checked (30 September 2026), the amended Law on Food Safety is still at the draft stage and has not been passed by the National Assembly. This means: the mandatory HACCP/ISO 22000/GMP roadmap of Decree No. 46/2026 does not yet apply; the document actually in force is Decree No. 15/2018/NĐ-CP, under which adopting these systems remains voluntary (except for some sectors with their own rules, which must be checked sector by sector).
Businesses in the high-risk product groups mentioned above should still follow the progress of the amended Law on Food Safety, since the policy direction is clear; building a system early will leave them less on the back foot when the new rules formally take effect.
Roadmap for building a system, if a business chooses to do so
| Step | Task | Who does it |
|---|---|---|
| 1 | Determine the reason (customer requirement, export, or proactive choice) and choose the suitable system | Business leadership |
| 2 | Assess the gap between current practice and the requirements of HACCP/ISO 22000/FSSC 22000 | The business, possibly with a consulting unit |
| 3 | Build prerequisite programs (plant hygiene, pest control, water used, etc.), analyze hazards, determine critical control points | Consulting unit together with production and quality control departments |
| 4 | Awareness training and training of the internal HACCP team | Consulting or training unit |
| 5 | Operate and create real monitoring records (temperature, time, inspection results) | Relevant departments |
| 6 | Internal audit, management review, correct non-conformities | The business |
| 7 | Choose a certification body suited to the selected system and register for the audit | The business |
| 8 | Certification audit, correct non-conformities if any, receive the certificate | Certification body |
Building and maintaining an ISO 9001 system in general (registration, audit, surveillance cycle) is covered in more detail in ISO 9001 Certification: What a Company Needs to Prepare; the principles for choosing a reliable certification body apply similarly to ISO 22000.
Common pitfalls for food businesses
- Thinking ISO 22000 can replace every sector license. Some products also have sector-specific requirements (for example product declaration, periodic testing); ISO 22000 only exempts the food safety eligibility certificate, not the other obligations.
- Choosing a system by trend, without asking what customers need. FSSC 22000 takes more effort than HACCP, but if the customer only needs HACCP, there is no need to go for FSSC 22000 right away.
- Not updating when the facility changes scale or adds production lines. The certification scope must match actual production; new products outside the certification scope still need a food safety eligibility certificate for that portion.
- Ignoring policy tracking. For high-risk product groups, follow the progress of the amended Law on Food Safety instead of waiting until the rules take effect to start preparing.
How Thái Tín supports you
Thái Tín receives your needs and works with the business to determine whether to pursue the food safety eligibility certificate, HACCP, ISO 22000 or FSSC 22000 based on customer requirements and actual scale; connects consulting, training units and certification bodies suited to the specific food sector; and tracks progress until the agreed scope is completed. Consulting on building the system is carried out by the consulting unit; assessment and issuance of the certificate are decided by the certification body; issuance of the food safety eligibility certificate is decided by the state management authority by sector.
Costs include consulting fees, training (if hired) and certification audit fees; a quote is given once the product line, scale and intended system are clear. See also ISO, standards and certification services.
If your business is weighing options, send the product type, the sales market (domestic or export) and any specific customer requirements to get advice on which system to choose first.
Questions and answers
If we already have ISO 22000, do we still need the food safety eligibility certificate?
Under Decree No. 15/2018/NĐ-CP, a facility that has been issued one of the HACCP, ISO 22000, IFS, BRC, FSSC 22000 or GMP certifications is not required to apply for the food safety eligibility certificate. The business should keep a valid copy of the certification to present when regulators inspect, and should reconfirm with its own sector regulator, since each sector has its own contact point.
How do HACCP and ISO 22000 differ?
HACCP is a hazard analysis and critical control point method based on Codex Alimentarius principles, focused on controlling hazards in the production process. ISO 22000 is an international standard for food safety management systems that uses the HACCP principles as a core part, plus management system requirements under the common ISO structure. In short: HACCP is one component, ISO 22000 is the overarching management system.
Is FSSC 22000 a certification issued by the Vietnamese state?
No. FSSC 22000 is a private scheme based on ISO 22000, with additional sector-specific requirements and food defense requirements, recognized by the Global Food Safety Initiative (GFSI). Certification is carried out by independent certification bodies, not by a Vietnamese state authority.
Does Decree 46/2026 make ISO 22000 or HACCP mandatory for businesses?
Decree No. 46/2026/NĐ-CP contains provisions directed at making a food safety management system mandatory for certain high-risk product groups, but this decree is suspended under Resolution No. 15/2026/NQ-CP until the amended Law on Food Safety and new guiding decrees take effect. As of the date this article was checked (30 September 2026), the document in force is Decree No. 15/2018/NĐ-CP, under which adopting these systems remains voluntary.
Where should a small business new to food start?
It should start by applying for the food safety eligibility certificate under its own managing sector, since this is the basic legal requirement. Only when a major customer or an export plan requires more should it consider building HACCP or ISO 22000; building a system too early without a real need easily leads to the system being neglected.
Legal basis · verification date
Verified 30 September 2026 · next review 30 December 2026. The content is general guidance and does not replace advice for a specific case.
- Decree No. 15/2018/NĐ-CP of 2 February 2018 detailing the implementation of a number of articles of the Law on Food Safety No. 55/2010/QH12: point k, clause 1, Article 12 (a facility that has been issued one of the valid GMP, HACCP, ISO 22000, IFS, BRC, FSSC 22000 or equivalent certifications is not subject to issuance of the food safety eligibility certificate).
- Decree No. 46/2026/NĐ-CP of 26 January 2026 detailing a number of articles and measures to organize and guide the implementation of the Law on Food Safety (expected to replace Decree No. 15/2018/NĐ-CP).
- Resolution No. 09/2026/NQ-CP of 4 February 2026 suspending Decree No. 46/2026/NĐ-CP until the end of 15 April 2026, allowing Decree No. 15/2018/NĐ-CP to remain in force during the suspension.
- Resolution No. 15/2026/NQ-CP of 6 April 2026, replacing Resolution No. 09/2026/NQ-CP: continuing to suspend Decree No. 46/2026/NĐ-CP and Resolution No. 66.13/2026/NQ-CP until the amended Law on Food Safety and new guiding decrees take effect; Decree No. 15/2018/NĐ-CP continues to apply.
- Law on Food Safety No. 55/2010/QH12: as of 30 September 2026 it remains the law in force; the draft amended law is still being developed and has not been passed by the National Assembly.
- ISO 22000:2018 Food safety management systems — Requirements for any organization in the food chain, confirmed in 2023 (iso.org).
- FSSC 22000 Scheme, based on ISO 22000:2018, recognized by the Global Food Safety Initiative (GFSI) (fssc.com).
Official texts and standards
- ISO 22000:2018 — standard page on iso.org iso.org
- FSSC 22000 Scheme — official FSSC page fssc.com
- Decree No. 15/2018/NĐ-CP — Government Portal vanban.chinhphu.vn
- Decree No. 46/2026/NĐ-CP — Government Portal vanban.chinhphu.vn










