Short answer: To import food from Vietnam into the US, the foreign facility must be registered with the FDA, the importer files Prior Notice before the shipment arrives, and the US importer must have a Foreign Supplier Verification Program (FSVP) for most foods. The product also needs compliant US labeling, and duties are checked by HTS code. Plan these before you finalise your factory and packaging, not after the goods ship. This is general information, not legal advice. Rules change, so confirm with FDA and a licensed customs broker. Last checked: 13 November 2026 against FDA and eCFR pages (sources at the end).
The main requirements
| Requirement | Who is responsible | Notes |
|---|---|---|
| FDA food facility registration | The foreign manufacturer/packer/holder | Required for facilities that manufacture, process, pack or hold food for US consumption. Needs a US Agent. Registration must be renewed between 1 October and 31 December of every even-numbered year; the current renewal period runs 1 October to 31 December 2026. A unique facility identifier (UFI) is required, and FDA recognises a DUNS number for this. |
| Prior Notice | Importer or customs broker | Submitted to FDA before arrival; the confirmation number accompanies the shipment. Minimum lead time before arrival: 2 hours by road, 4 hours by rail, 4 hours by air, 8 hours by water. Prior notice can be submitted up to 30 calendar days before arrival through ABI/ACE (15 days through the FDA’s PNSI). (21 CFR 1.279) |
| FSVP | US importer | The importer must verify that the foreign supplier produces food meeting US safety standards. Each food and each foreign supplier needs an FSVP, which must be re-evaluated at least every three years. Exemptions include juice and seafood covered by their own HACCP rules, alcoholic beverages, food for personal consumption, and food imported for processing and re-export; very small importers have modified requirements. FDA publishes the full list. |
| Labeling | Brand owner / importer, with factory input | Must comply with FDA labeling rules (Nutrition Facts, allergens, English). |
| Customs entry and duty | Importer or broker | Based on HTS classification and country of origin. |
| Special categories | Depends | Low-acid canned foods, acidified foods, seafood HACCP, dietary supplements, dairy and meat have extra rules. |
Step by step
- Choose the factory and confirm export experience to the US. Ask whether it is FDA registered and whether it has shipped to the US before.
- Confirm registration and the US Agent. The facility registers with FDA; it does not mean FDA approved or inspected the factory.
- Set up FSVP. The US importer, or a service company acting for it, writes the supplier verification plan: hazard analysis review, supplier approval, audits or records review, corrective action.
- Prepare the label. Nutrition Facts, ingredient list, allergen statement (the nine major allergens are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame; sesame was added on 1 January 2023), net quantity, manufacturer/distributor, country of origin (CBP marking rules apply).
- Classify the product (HTS) and check duties with US Customs and any special measures on the product or origin. US tariff measures on Vietnam-origin goods changed several times in 2025 and 2026; we could not confirm the current rate from a primary source on the check date, so confirm the current duty with your broker and CBP before quoting costs.
- File Prior Notice and the customs entry through your customs broker.
- Clear the shipment. FDA may examine, sample or detain a shipment; detained products are listed on FDA’s import alerts if issues repeat.
Traceability and new rules
FDA’s food traceability rule under FSMA Section 204 applies to foods on the Food Traceability List and has had its compliance date extended. The original compliance date was 20 January 2026. FDA has extended it by 30 months to 20 July 2028, and Congress directed FDA not to enforce the rule before that date (FDA page updated 4 November 2026). Confirm the current date before you plan. Ask your factory whether it already keeps lot-level traceability records.
Common mistakes
- Using a US Agent that does not respond to FDA. Registration can be suspended.
- Assuming a Vietnamese certificate replaces FSVP. It does not.
- Printing labels before the nutrition panel and allergens are validated.
- Not checking HTS classification and duty at quoting stage.
- Not checking the product category for extra rules, for example seafood or canned goods.
Where we can help
We shortlist Vietnamese factories with US export experience and ask them for registration status and supporting documents. We do not act as customs broker or legal adviser; use a licensed US customs broker and an FSVP qualified individual or service. See How it works.
Related: certifications compared, 20-point factory checklist, private label coffee for Amazon and DTC.
Sources (last checked 13 November 2026)
- FDA: Food facility registration renewal
- eCFR: 21 CFR Part 1 Subpart I, Prior Notice
- FDA: FSVP final rule
- FDA: Food traceability rule (FSMA 204)
- FDA: Food allergies
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