Tiếng Việt
中文Short answer: (1) A domestic enterprise conducting export/import business does not need a “sub-license” — this is an enterprise right under Clause 5, Article 7 of the Law on Enterprises 2020; only when importing/exporting specific goods subject to specialized management must separate conditions be satisfied. (2) A coffee roasting establishment must obtain a Certificate of Food Safety Eligibility, except for the exempted cases in Article 12 of Decree No. 15/2018/ND-CP (such as small-scale primary production or small-scale food trading).
Legal basis
- Law on Enterprises 2020 (Clause 5, Article 7), as amended by Law No. 76/2025/QH15 (effective from 1 July 2025);
- Law on Food Safety 2010 (Articles 35, 36); Decree No. 15/2018/ND-CP (Articles 11, 12).
1. Must import-export businesses obtain a sub-license?
No. Conducting export/import business is an enterprise right (Clause 5, Article 7 of the Law on Enterprises 2020); Vietnam’s economic sector system has no separate code for “import-export”, so domestic enterprises do not need to register this business line and do not need a sub-license.
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However, when importing/exporting specific goods, the enterprise must comply with separate conditions if the goods fall under the list of prohibited or temporarily suspended goods, goods requiring a license, or goods subject to specialized management (quarantine, quality inspection, announcement of conformity, etc.).
2. Does coffee roasting need a Certificate of Food Safety Eligibility?
Pursuant to Article 11 of Decree No. 15/2018/ND-CP, food production and trading establishments must obtain a Certificate of Food Safety Eligibility when operating, except for the cases in Article 12:
- Small-scale primary production; food production or trading without a fixed location; small-scale preliminary processing; small-scale food trading; trading of pre-packaged food;
- Establishments already granted valid GMP, HACCP, ISO 22000, IFS, BRC, FSSC 22000 or equivalents;
- Certain other cases (restaurants within hotels, collective kitchens not registered in the food sector, street food trading, etc.).
A coffee roasting establishment of ordinary scale is not exempted and must therefore apply for the Certificate.
Dossier and issuing authority
Pursuant to Article 36 of the Law on Food Safety 2010, the dossier includes: an application form; a copy of the Enterprise Registration Certificate; a description of physical facilities and equipment; health certificates of the establishment owner and persons directly engaged in production and trading; certificates of food safety knowledge training. Within 15 days from the date of receipt of a complete and valid dossier, the competent authority conducts an on-site inspection and issues the Certificate if the conditions are satisfied. The authority to issue and revoke is regulated by the Ministers of Health, of Agriculture and Environment, and of Industry and Trade according to their assigned sectors (Article 35).
Frequently asked questions
Does a small coffee shop roasting on site need the certificate?
It depends on the scale: if it qualifies as “small-scale food production and trading” under Article 12, it is exempted, but must still comply with the corresponding food safety conditions. Check with the local managing authority to determine correctly.
How long is the Certificate valid?
03 years from the date of issuance; 06 months before expiry, the establishment must submit a dossier for re-issuance.
To determine whether your establishment is subject to the Certificate requirement, you should contact ANT Legal’s lawyers at 0966.475.966 for review and advice before proceeding.
