First appearing around 5000 BC, when the Sumerians—the founders of Mesopotamian civilization—began inscribing names on clay tools to mark their origin, product labels have since become an essential communication channel for goods, enhancing the competitiveness of manufacturers in the marketplace. From the consumer’s perspective, the right to receive timely, accurate, and sufficient information about products, goods, and services is recognized and protected by law. Based on the information provided on labels, consumers can identify the nature of the product, its ingredients, origin, and whether it suits their needs and health conditions, thereby making informed purchasing decisions. For state authorities, product labels serve as a legal basis for managing enterprises’ production and business activities. Label information is used for inspection and verification purposes, for instance, to determine the quality and condition of goods or to ensure that expired products are not circulated in the market.
In modern international trade, labeling regulations are explicitly recognized in agreements on rules of origin, technical standards, and sanitary and phytosanitary measures within the framework of the World Trade Organization (WTO), as well as in bilateral and multilateral free trade agreements among nations. Particularly for Vietnam, where goods increasingly access highly regulated markets such as the European Union, the United States, Australia, Japan, and South Korea, the proper formulation and strict implementation of labeling regulations are critical to facilitating exports and enhancing the reputation of Vietnamese enterprises.
Article 32 of the 2005 Law on Commerce stipulates that: “1. Product label means written, printed, drawn, photocopied words, drawings, or images affixed, printed, attached, cast, embossed, or engraved directly on goods, on their commercial packages, or on other materials attached to goods or their commercial packages…”. The name of the product, its ingredient list, and illustrative images on the packaging are all components of a product label. Labeling is mandatory and applies to goods circulated within Vietnam as well as imported goods (Clause 1, Article 1 of Decree No. 43/2017/ND-CP, as amended and supplemented by Decree No. 111/2021/ND-CP, hereinafter referred to as the amended Decree No. 43/2017).
Clause 2, Article 3 of this Decree further defines: “Goods labeling means the presentation of basic and necessary information about goods on their labels to enable consumers to identify, select, consume, and use such goods; to help manufacturers and traders advertise their goods; and to facilitate competent authorities in inspection and supervision.” This definition emphasizes that labeling must include fundamental and necessary information, serving the interests of consumers, producers, and regulatory bodies alike.
In addition, goods labeling must comply with relevant Vietnamese National Standards (VNS) on labeling. Under Part 2 of Vietnamese National Standard (VNS) 7078:2013, labeling is defined as “the use of various forms of presentation such as printing, writing, drawing, or graphic techniques on or near the food label to provide information about the food, including for promotional or sales purposes.” Labeling requirements apply to both domestically produced goods and imported goods circulated in Vietnam.
According to Article 3 of the amended and supplemented Government Decree No. 43/2017 (GD), goods labels are divided into two categories: primary labels and auxiliary labels.
A primary label is the label initially displayed by the manufacturer and affixed to goods or their commercial packaging (Clause 1). Meanwhile, an auxiliary label presents translated content from the original language into Vietnamese (Clause 2), or provides additional mandatory information in Vietnamese if the primary label lacks such details.
The coexistence of the auxiliary label alongside the primary label removes language barriers, ensures the consumer’s right to transparent product information, enables proper product use, and facilitates market management activities by competent authorities.
The obligation of manufacturers (MFRs) to label food products truthfully and accurately is prescribed in various legal documents. According to Article 7 of the Law on Food Safety 2010, the obligations of individuals and organizations producing food include: “(c) Providing full and accurate information about the product on labels, packaging, and accompanying documents in accordance with legal regulations on labeling.” For individuals and organizations engaged in food trading, these obligations include “checking the origin, source, and label of food products” and “providing truthful information on food safety” (Points b and c, Clause 2, Article 8).
In addition, Clause 1, Article 9 of Government Decree No. 43/2017/ND-CP, as amended and supplemented, also emphasizes that organizations and individuals responsible for labeling goods (including secondary labels for imported goods) “…must ensure that labeling is truthful, clear, and accurate, reflecting the true nature of the goods.” Thus, truthful and accurate labeling is an obligation of both domestic and foreign manufacturers and traders who import goods into Vietnam.
The mandatory contents that must appear on product labels are stipulated in Clause 1, Article 10 of Government Decree No. 43/2017/ND-CP, as amended and supplemented, including: product name, information on the organization or individual responsible for the goods, country of origin, and other compulsory information specified separately for each type of goods. For beverages (except alcohol) such as fruit juices[6], Appendix 1 provides that the label must contain:
"a) Quantity;
b) Date of manufacture;
c) Expiry date;
d) Ingredients or quantitative ingredients;
đ) Warning information;
e) Instructions for use and storage.
For imported goods, the importing company must attach a Vietnamese label containing the same information as that required for domestically produced goods[7]. It can be seen that indicating the name and ingredients of the product is mandatory, while illustrative images are not. This difference arises from the type of information conveyed.
The product name is the primary identifier reflecting the nature of the product, helping consumers (CONs) recognize and distinguish between different goods. At the same time, it serves as a basis for state authorities to conduct administrative management, import–export procedures, and administrative sanctions when necessary[8].
Article 11 of Government Decree No. 43/2017/ND-CP, as amended and supplemented, stipulates that product names must be placed in a visible and legible position. The product name shown on the label is chosen by the manufacturer but must not mislead consumers about the nature, use, or ingredients of the product. In addition, Section 4 of Vietnamese National Standard (VNS) 7087:2013 on Labeling of Prepackaged Foods requires that the product name “must accurately reflect its true nature and must be specific, not abstract.”
It should be noted that the term “fruit juice” used in Vietnamese National Standard (VNS) 7946:2008 on Fruit Juices and Nectars has a different meaning from the “fruit juice” products commonly found in the market. According to Section 2.1, fruit juices and nectars are divided into six categories: (i) fruit juice, (ii) concentrated fruit juice, (iii) extracted fruit juice, (iv) fruit purée used in the production of fruit juices and nectars, (v) concentrated fruit purée used in the production of fruit juices and nectars, and (vi) fruit nectar. Accordingly, “fruit juice” refers to a product obtained from the edible part of fruits, unfermented, and retaining the flavor of the fruit. Meanwhile, commercial fruit juice may contain water and other ingredients.
Moreover, Section 3.8 of Vietnamese National Standard (VNS) 12828:2019 on Fruit Beverages uses the term “fruit beverage containing fruit juice” for products “containing fruit juice or reconstituted concentrated fruit juice with a minimum fruit juice content of 5.0% (by volume).” This definition more accurately reflects the essence of commercial “fruit juice” products, as it includes two basic components: water and juice extracted from fruit[9].
It can be observed that Vietnamese regulations on naming fruit juice products remain overlapping and unclear. While there are many types of fruit juices—pure fruit juice (99–100% juice content), diluted fruit juice (juice plus water, sugar or syrup, sweeteners, flavorings, acids, etc.), fruit-flavored drinks (very low juice content, mainly flavorings and sweeteners), and carbonated or non-carbonated fruit-flavored soft drinks (no actual juice, only flavorings)—manufacturers (MFRs) face difficulties in choosing names that accurately reflect the true nature of their products.
In practice, many manufacturers (MFRs) use inaccurate product names that mislead consumers (CONs). Among the 35 labels examined[10], the product names were distributed as follows: 9 products labeled “100% fruit juice,” 3 labeled “nectar,” 9 labeled “fruit juice…,” 1 labeled “concentrated drink,” 7 labeled “fruit-flavored drink,” 4 labeled “water + fruit name” (e.g., peach water, lemon water), 1 labeled “probiotic drink,” and 1 labeled “juice drink.” First, inconsistent naming causes confusion and misunderstanding among consumers (CONs). Second, some terms used are not defined in law or in the Vietnamese National Standards (VNS) (e.g., “nước ép,” “nước uống”). Furthermore, the product names do not reflect the actual composition or method of processing. Particularly, many manufacturers (MFRs) use the term “fruit juice” for all fruit-flavored beverages, even when the juice content is very low or nonexistent. In fact, 10 of the products labeled “fruit juice…” contained only 5–40% actual fruit juice.
“Ingredients or quantitative ingredients” refer to “the materials and the quantity of each material (including additives) used to produce goods and that remain in the product when it reaches the consumer (CON).” Article 16 of Government Decree No. 43/2017/GD as amended provides that the list of ingredients displayed on the goods label must include the names of all materials, including additives, used in production and remaining in the final product. If an ingredient is mentioned on the goods label to draw attention to the product, its quantity must be indicated. For example, for a product labeled “orange-flavored beverage,” the manufacturer (MFR) must specify the quantitative amount of natural or artificial orange flavoring or orange juice contained in the product. In cases where quantitative ingredients are declared, the manufacturer (MFR) must indicate both the ingredient and its corresponding quantity on the label.
In addition, the Ministry of Health issued Ministerial Circular No. 29/2023/TT-BYT guiding the content and manner of declaring nutritional ingredients and nutritional values on food labels. Accordingly, all food products manufactured, traded, imported, and circulated in Vietnam must state both the quantity and the energy value of the following components: energy, protein, carbohydrate, fat, and sodium (Clause 1, Article 5). Particularly for beverages such as fruit juices, in addition to these five mandatory components, the manufacturer (MFR) must also provide information on total sugar (Clause 2, Article 5). Furthermore, Vietnamese National Standard (VNS) 7946:2008 stipulates that when sweeteners are used to replace sugar in fruit nectar or mixed fruit nectar, the declaration “contains sweeteners” must appear together with or near the product name; the content of fruit juice in the nectar; the addition of carbon dioxide; the addition of flavorings; or the indication “ascorbic acid” and “added vitamin C,” depending on the intended use. All additives must comply with relevant standards and must be publicly listed on the product’s packaging label (Section 8.1.2).
Information on food ingredients is extremely important because it enables consumers (CONs) to determine whether the ingredients are suitable for their diet. This is especially significant for consumers (CONs) with specific dietary needs, such as those with allergies, diabetes, or cardiovascular diseases, who must follow strict nutritional regimes. Accurate labeling of the ingredients in fruit juice products helps consumers (CONs) make healthier choices and reduce the risk of diseases related to blood sugar, kidneys, bones, and nerves. Fruit juice products are widely consumed across all age groups, and the use of fruit beverages containing high levels of artificial sweeteners not derived from cane sugar—such as high-fructose corn syrup (HFCS), a common sweetener in sugary drinks—may negatively affect health.
According to the research data collected, 100% of the surveyed products displayed a nutrition facts table (nutritional values per 100ml or 200ml serving) and an ingredient list on the packaging, including information about total sugar, added sugar, and sweeteners (natural or artificial). However, ingredient descriptions were often vague, such as “apple juice,” “juice from concentrated apple juice,” or “apple juice 40%.” Moreover, some products presented the ingredient and quantitative ingredient information in a font size too small relative to the packaging area, making it difficult for consumers (CONs) to read. Meanwhile, product names—although sometimes not accurately reflecting the true nature of the product—were printed in large, colorful, and eye-catching fonts placed in prominent positions to attract consumer attention.
Illustrative images on product packaging, on the other hand, are not mandatory elements. They primarily serve aesthetic purposes, support brand recognition, and stimulate curiosity and purchasing intent among consumers (CONs). Many brands successfully market their products using minimalist packaging designs, even without images. Furthermore, while product names can be standardized among manufacturers (MFRs), requiring a uniform packaging design is impractical and unnecessary. For fruit juice and nectar products, Vietnamese National Standard (VNS) 7946:2008 stipulates that “the presentation of fruit images on the label must not mislead consumers” (Section 8.1.2.8). Manufacturers (MFRs) must not use images of fruits to promote a different type of fruit juice or a beverage that does not contain fruit juice or fruit flavor at all.
In practice, many cases worldwide have shown that images on packaging can mislead consumers (CONs) about the actual ingredients of the product. For example, Tropicana’s orange juice in Japan faced public backlash when its “100% orange juice” label was criticized as misleading because the product was made from reconstituted concentrate (with added water). Similarly, in the United States, consumers filed a lawsuit against Kellogg’s Pop-Tarts for using packaging featuring fresh strawberries, while the actual amount of strawberries in the product was so minimal that it was nutritionally insignificant and served only to provide flavor.
Among the 35 surveyed products, only four used drawn fruit images on their packaging, while the rest used real fruit photos. Although consumers (CONs) often distinguish fruit juices and nectars by taste (such as apple juice or grape juice), many products contained very low levels of fruit juice—or used only natural or artificial flavorings. When packaging displays images of fresh fruits, consumers (CONs) may assume that the product’s ingredients are purely natural fruit, leading to false expectations about the product’s quality and composition.
Currently, Vietnamese law allows manufacturers (MFRs) to use any images or drawings to “illustrate the product.” In other words, manufacturers (MFRs) are free to choose relevant illustrations or drawings that relate to the product or its flavor, without being required to depict the actual primary ingredients. However, consumers (CONs) tend to associate images on packaging with the real ingredients used in the product. This association can be exploited by manufacturers (MFRs) to advertise their products in a way that misrepresents the actual composition.
Finally, using packaging with colorful or playful illustrations may be considered an effective way to attract children. However, children are typically inexperienced buyers who pay little attention to manufacturing processes or nutritional factors. Their attraction to bright images and colors naturally motivates them to ask—or even insist—that their parents buy the product. The more a child expresses interest in a product, the more likely parents are to purchase it. Nevertheless, since parents ultimately make the purchasing decision, the information on product labels—alongside packaging design—plays an equally crucial role.
As of April 2025, the United States remains the world’s largest fruit juice consumer (in 2023, total fruit juice consumption in this country reached USD 26.8 billion), followed by the Netherlands, France, and Germany. The regulations on food labeling are issued by the Food and Drug Administration (FDA or USFDA). The Federal Food, Drug and Cosmetic Act (FDCA), the Fair Packaging and Labeling Act (FPLA), and part of the Public Health Law provide the key legal foundation for labeling requirements applicable to both domestically manufactured foods and imported products entering the U.S. market.The FDA requires that information such as product name, manufacturer’s details, country of origin, nutritional content, allergenic ingredients, and any chemical or flavoring substances used must appear on the front panel of the product package. For imported goods using foreign languages, the importer must affix an English label containing all required information.
For fruit juice products, all packaging must indicate the percentage of fruit juice contained in the product. This requirement applies to both textual expressions (label statements), fruit or vegetable images, and any other elements that could create consumer (CON) expectations about the juice content of the beverage. Fruit juice is classified as follows:
- 100% juice or juice from concentrate: allowed to use the term “juice” in the product name.
- Beverages containing less than 100% juice: required to use terms such as “fruit drink” or “fruit beverage” in the product name for differentiation.
- Reconstituted juice made from concentrate: must clearly state “from concentrate” or “diluted with water” in the product name.
- Beverages with fruit flavor but no or very little juice content: not allowed to use the term “juice” in the product name and must instead display phrases such as “fruit-flavored drink.” The term “juice” may only appear in the ingredient list, e.g., “1% apple juice.”
However, regarding illustrative images on packaging, the FDA does not provide specific provisions other than the general rule that product information must not be misleading (misbranded) to consumers (CON) about the quality or composition of the product. Violations may result in penalties of up to USD 100,000 or imprisonment for one year (for individuals), and USD 200,000 for organizations.
According to a 2022 report, the consumption of pure fruit juice in Japan consistently accounts for a high proportion compared to other soft drinks. This is largely attributed to Japan’s aging population, whose members tend to maintain a high awareness of health, exercise regularly, and follow balanced dietary habits.
Japan is one of the countries with the most stringent regulations on product labeling, as part of its policy to promote a healthy diet and prevent food allergies. The Food Sanitation Act requires that all pre-packaged food products imported into Japan must meet the same standards as domestically produced goods, including labeling in Japanese. This ensures convenience for consumers (CON) when selecting appropriate products, while maintaining fair competition and the sustainability of the domestic market.
Labeling requirements are established under the Food Labeling Act No. 77/2013. Specifically, Article 4 mandates that manufacturers (MFR) affix food labels containing all necessary information so that consumers (CON) can safely consume and make informed decisions about the product. The required information includes: product name, potential allergens, storage method, expiration date, ingredients (including additives, if any), nutritional composition and caloric content, and country of origin.
Regarding product naming, nearly all fruit juice beverages in Japan are referred to as “ジュース” (juice). However, under the Fair Competition Code and Enforcement Regulations for Fruit Juice Beverages (果実飲料等の表示に関する公正競争規約及び施行規則), issued by the Fair Trade Labeling Organization and the Japan Soft Drink Association, product naming for fruit juices is clearly categorized as follows:
- Juice (ジュース): may only be used for 100% pure fruit juice or products with a minimal addition (less than 5%) of sugar or honey.
- Fruit drink (果汁入り飲料): applies to beverages containing more than 10% but less than 100% fruit juice. These cannot be labeled as “fruit juice” but must be labeled as “fruit beverage.”
- Other beverages (その他の飲料): applies to drinks containing less than 10% fruit juice, which cannot use the term “juice” in the product name. Products containing less than 5% juice must be labeled as “soft drink” (清涼飲料) and are not permitted to display the name of the fruit in the product title.
In terms of ingredients, Japan also mandates allergen labeling using pictograms for eight high-risk allergens: shrimp, crab, wheat, buckwheat, eggs, milk, walnuts, and peanuts. Additionally, 20 other potential allergens (e.g., soybeans, chicken, sesame) are recommended to be explicitly listed on the packaging. This use of allergen symbols helps consumers (CON) easily identify foods that may pose health risks, even if they cannot read the written language on the package.
Packaging imagery is also strictly regulated. Article 1(i) of the Act against Unjustifiable Premiums and Misleading Representations prohibits business operators from making claims that exaggerate the quality of their products compared to actual performance in order to attract customers. Article 4 of the Fair Competition Code and its Enforcement Regulations for Fruit Juice Beverages, which implement Article 6 of the Act, provide detailed guidance: (i) If a product contains less than 5% fruit juice, the manufacturer (MFR) is not allowed to use real fruit images on the packaging. (ii) For products containing between 5% and less than 100% juice, real fruit images may be used, but cross-sectional images of the fruit are prohibited. (iii) Only 100% pure fruit juice may display cross-sections of real fruit. These detailed rules allow consumers (CON) to accurately determine the juice content of a product and make informed purchasing choices. The following images illustrate this rule as applied to two products: Tropicana orange juice (by Coca-Cola) and Natchan orange-flavored drink (by Suntory).
Thus, Japan has very strict and consistent regulations on the names of goods and their illustrative images. Unlike in Vietnam, the illustrative image of goods plays an extremely important role in Japanese production and is tightly regulated by specific legal documents. Illustrative images help consumers (CON) easily recognize the type of product they want without having to read the product name. This is very convenient for consumers (CON) who are elderly, have visual impairments (such as myopia or dyslexia), or are illiterate.
Germany is also a country with very specific regulations on the labeling of fruit juice products. These regulations are set out in the “Regulation on Fruit Juice, Fruit Nectar, and Caffeinated Carbonated Beverages” (FrSaftErfrischGetrV). This document was developed based on the internalization of the European Union’s regulations on goods labeling, including Directive No. 2001/112/EC of the European Community on fruit juices and similar products for human consumption, and Regulation No. 1169/2011 of the European Parliament and Council on the provision of food information to consumers (which officially took effect on December 13, 2014).
Regarding product naming, Article 3 of the FrSaftErfrischGetrV – based on Article 1, Annex I of Directive 2001/112/EC – provides that the name of the product must accurately reflect the juice content. The term “juice” (Saft) may only be used for pure juice. For example, “apple juice” (Apfelsaft) may only refer to 100% juice from apples. “Nectar” (“Nektar”) may be used to name nectar products but must meet the minimum fruit content for each fruit type (at least 25% for peach or apricot nectar, and 50% for apple or pear nectar). If the product is reconstituted from concentrate, it must include the phrase “aus Fruchtsaftkonzentrat” (from fruit juice concentrate). For beverages with low fruit content, only the phrase “Fruchtsaftgetränk” (fruit juice drink) may be used.
Regarding packaging images, Regulation No. 1169/2011 of the European Union allows the use of fruit images on beverage packaging if the product contains more than 50% of its flavoring mass derived from the fruit depicted. However, unlike Japan, this 50% includes both the actual fruit juice content and added food flavorings, as long as it does not mislead consumers (CON) about the product’s flavor. In other words, the fruit images on the product only need to accurately represent the actual flavor of the product.
Regulations on the labeling of fruit juice products are prescribed by the Government of Singapore under the Sale of Food Act (SFA) and the Food Regulations (Cap. 283) promulgated by the Singapore Food Agency. According to the SFA, a label includes any tag, mark, word, image, diagram, or any other form of representation attached to, printed on, or otherwise presented on the commercial packaging of goods. The mandatory information to be displayed on labels must include basic details about the goods, such as their origin, nature, composition and ingredients, quantity, and quality. These details must accurately reflect the nature of the goods and must not be used for the purpose of misleading or confusing consumers (CON) about the products.
Regarding the product name, Section 56(1), Chapter 283 of the Sale of Food Act stipulates the labeling names for fruit juices and other fruit beverages as follows:
- Article 171: Fruit juices – defined as unfermented liquids extracted from ripe and fresh fruits, without the addition of sugar, preservatives, sweeteners, food colorings, preservatives, or acids. Reconstituted juice made from fruit juice concentrate is also recognized as fruit juice.
- Article 173: Nectar – defined as unfermented juice containing between 25% and less than 100% fruit content, depending on the fruit type. For example, lemon nectar must contain 50% fruit content, peach and pear nectar 40%, apricot nectar 35%, and other fruits 25%.
- Article 174: Fruit cordials, squashes, or syrups – applied to beverages containing fruit juice, sugar, and water, with possible additions of acids, stabilizers, flavoring agents, food colorings, and preservatives. These beverages contain less than 15% pure fruit content and less than 25% sugar.
- Article 175: Fruit drinks or fruit crushes – applied to beverages containing small amounts of fruit content and suitable for direct consumption without further dilution.
Thus, Singapore’s regulations on the naming of fruit juice products are highly detailed, categorized based on the percentage of fruit content and the additives present in the final product. The number of product types is also greater than that of other countries. However, since Singapore has no specific provisions on the illustrative images displayed on product packaging, it instead prohibits non-compliance with labeling requirements or the use of false or misleading information or claims regarding product quality (“misleading claims for food products”). The penalties may reach up to 5,000 Singapore dollars and three months of imprisonment. Therefore, there is currently no legal basis to determine whether the use of illustrative images intended to mislead consumers (CON) about the actual juice content constitutes a violation of the SFA.
Vietnam can selectively learn from and incorporate key experiences from the United States, Japan, Germany, and Singapore when developing regulations on the labeling of fruit juice products. These include establishing consistent naming conventions based on the percentage of fruit juice content and regulating the use of illustrative images on product packaging. The following are several proposals for Vietnam:
First, it is necessary to establish a comprehensive classification system for product names and illustrative images used on packaging. Currently, Vietnam’s regulations remain rather general and are primarily based on the Codex Alimentarius (CODEX). Meanwhile, the proportion of fruit juice in beverages is a decisive factor in determining the quality and function of each product. Therefore, the CODEX standards should be concretized through the promulgation of detailed guidance specifically for fruit juice products, accompanied by a more precise classification system.
Below are several reference-based classification suggestions drawn from the United States and Germany:
- 100% fruit juice: permitted to use the term “juice” in the product name.
- Nectar: containing 25% to below 100% fruit content depending on the type of fruit.
- Fruit drink: containing between 5% and 25% fruit content, and must include the term “drink” or “fruit drink” in the product name to distinguish it from 100% pure fruit juice.
- The name “fruit-flavored beverage” should be used for products containing less than 5% fruit content or no natural fruit content at all.
In addition, beverages containing added sugar must include the phrase “Added sugar” on the label to help distinguish 100% fruit juice from other fruit drinks. This also assists consumers (CON) with health conditions (such as diabetes, obesity, or metabolic disorders) in selecting suitable products. Information on ingredients—especially the percentage of fruit juice content—should be printed in a readable font size, placed in a visible location on the packaging, and, most importantly, expressed quantitatively (e.g., apple juice content: 50%).
Second, the use of illustrative images on commercial packaging should be mandatory and must accurately reflect the true nature of the product. Currently, regulations on illustrative images remain broad and are treated merely as part of the labeling system. Furthermore, the requirement that information not be misleading regarding the nature of goods has not been explicitly codified. For fruit juice products, the true nature of the goods must be linked to their composition, function, and nutritional value—that is, beverages containing fruit juice intended for human consumption—not merely drinks with fruit flavor as commonly understood. In other words, the current legal focus on ensuring consistency between the fruit name and the image on the packaging is insufficient to fully reflect the relationship between labeling and the actual nature of the product.
Therefore, new provisions should be introduced requiring that illustrative images on commercial packaging accurately reflect the true nature of the goods (whether it is fruit juice, nectar, fruit drink, or fruit-flavored beverage). These provisions should also specify the degree of authenticity of fruit content, represented through a standardized visual depiction of the fruit on the packaging. Japan’s approach—specifying when manufacturers (MFR) may use real fruit images, illustrative images, or none at all—provides a reasonable reference point for Vietnam.
Third, ensure transparency and honesty in the provision of product information on labels. For imported products, manufacturers (MFR) typically comply with both domestic labeling regulations and those of Vietnam as the export market. Customs clearance procedures also help enforce compliance. However, for domestically produced goods—especially those from small-scale manufacturers or Original Equipment Manufacturers (OEMs)—legal awareness and compliance capabilities remain limited.For example, in OEM production, generic product bases are produced by small factories in multiple quality grades at low cost, often without quality control or market research, and based solely on consumer trends. Buyers determine the brand name and labeling specifications, and the manufacturer (MFR) simply prints the required information. Consequently, the accuracy of labeling is not prioritized or verified, as the MFR has no decisive role or control over labeling. To prevent such practices, it is essential to strengthen legal education among manufacturers (MFR) and to enhance inspection and supervision by competent state authorities at beverage production facilities, distribution centers, and retail outlets (markets, supermarkets, convenience stores, etc.) to ensure that product information on packaging is accurate and that violations are promptly addressed.
Fourth, require manufacturers (MFR) to publicly disclose product declarations (including product name, ingredients, main quality criteria, packaging specifications, and labeling information) via public information channels. Pursuant to Clauses 2 and 4, Article 5 of Government Decree No. 15/2018/ND-CP detailing the implementation of several provisions of the Law on Food Safety, and Clauses 2, Article 1 and Clause 1, Article 3 of Government Decree No. 155/2018/ND-CP amending and supplementing several regulations on business investment conditions under the management of the Ministry of Health, the procedure for self-declaration of products is as follows:
“Organizations and individuals shall self-declare their products on mass media, on their websites, or publicly at their offices, and publish the declaration on the Food Safety Data Information System…”
However, not all consumers (CON) can visit the manufacturer’s (MFR) premises to verify the authenticity of labels against the information publicly declared and certified by competent authorities. Moreover, packaging space is limited and cannot display all product information. Additionally, the problem of manufacturers (MFR) advertising products inconsistently with declared information has become increasingly common, causing public confusion and seriously affecting consumer (CON) rights.To enable consumers (CON) to access product declaration information, the state should introduce mandatory information disclosure requirements through digital transformation, including: (i) Implementing QR codes for traceability (origin, ingredients, nutritional value, etc.); and (ii) Updating product information through digital platforms (MFR websites, e-commerce platforms) to enhance transparency and foster consumer (CON) trust in manufacturers (MFR).
Fifth, promote a culture of smart consumption. A crucial factor in protecting consumer (CON) rights and fostering fair competition lies in consumers (CON) themselves. In many cases, consumers (CON) rely on advertisements, fail to examine product ingredients, and engage in spontaneous online purchases. When they are “misled” or purchase the wrong product, they often ignore or accept it due to low prices. Therefore, state agencies should launch campaigns to promote a culture of smart consumption, encouraging consumers (CON) to actively seek product information, read and understand labels, assess and make purchasing decisions based on complete and objective information, thereby optimizing economic, health, and sustainability benefits.
Experiences from advanced countries such as the United States, Germany, Japan, and Singapore show that when information about product names and ingredients is disclosed truthfully and clearly, consumers (CON) have a sound basis for choosing products that suit their nutritional needs and health conditions. From the practices of these countries, Vietnam can refer to several important solutions, such as developing a specific list of names for fruit juice products based on the fruit juice content and the proportion of water, sugar, and additives; ensuring that product names and illustrative images are consistent with the true nature of the goods.At the same time, it is necessary to establish regulations requiring manufacturers (MFR) to use digital technologies to publicly disclose product information to consumers (CON), enabling them to verify the accuracy of product labels conveniently. Finally, in the long term, it is important to foster a culture of smart consumption, emphasizing consumers’ (CON) habits of actively seeking and verifying product information, thereby contributing to a fair competitive market and improving the health of future generations in Vietnam.
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* Dr, Email: vanpmt@due.edu.vn, approved for publication on October 28, 2025
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[3] Clause 2, Article 4 of the Law on Protection of Consumers’ Rights 2023.
[4] Pham Kim Hoan, Handling Fraudulent Indications of Origin of Goods under Vietnam’s Administrative Law, Journal of Procuracy Science, No. 4 (76) (2024).
[5] The Vietnamese National Standards (VNS) are developed by the Vietnam Institute of Standards and Quality (under the Directorate for Standards, Metrology and Quality) and relevant ministries/agencies, and promulgated by the Ministry of Science and Technology. The VNS are not legal documents but a collection of reference standards used to classify and evaluate products, goods, services, and other socio-economic entities in order to enhance their quality and effectiveness.
[6] In this paper, the term "fruit juice" refers to beverages containing juice extracted from the edible part of fruits, diluted with water, sugar, and other additives (if any). The term "fruit extract" refers to the liquid obtained from fruits through processes such as pressing, grinding, sieving, or filtering. Fruit extract may be cloudy or clear after filtering residues; it serves as a semi-finished ingredient and may or may not be directly consumable.
[7] Clause 4, Article 9 of Government Decree No. 43/2017/ND-CP, as amended and supplemented.
[8] For example, Ministerial Circular No. 33/2023/TT-BTC dated May 31, 2023, of the Minister of Finance, stipulates in Section D “Goods requested for advance determination of origin” that organizations and individuals must specify (1) description of goods and (2) HS codes for each specific product (Code 2009: Fruit juices and vegetable juices, unfermented and not containing added alcohol, whether or not containing added sugar or sweeteners).
[9] Beverages are defined in Clause 3.1 of Vietnamese National Standard (VNS) 12828:2019 as “Ready-to-drink products intended for refreshment, processed from water, possibly containing sugar, food additives, flavors, and may include ingredients of natural origin, vitamins, and minerals, either carbonated or non-carbonated.”
[10] For fruit juice products not distributed through supermarket systems, the author relied on information disclosed on the manufacturers’ (MFR) or distributors’ official websites and product images available on e-commerce platforms (Shopee, Lazada, Tiki, Tiktokshop). Data collected include: brand name, product name, quantitative composition (focusing on the percentage of fruit extract in the product), and packaging images or illustrations. The names of products and manufacturers (MFR) are coded to ensure confidentiality.
[11] Clauses 12 and 13, Article 3 of Government Decree No. 43/2017/ND-CP, as amended and supplemented.
[12] No later than December 31, 2025, organizations and individuals engaged in the production, business, or importation of food products for circulation in Vietnam must declare nutritional composition on food labels as required by this Circular.
[13] Energy values are calculated in kcal, g, or mg depending on the type of food, as stipulated in Article 6 of Ministerial Circular No. 29/2023/TT-BYT.
[14] According to the explanatory report of the Ministry of Finance in the Draft Law on Special Consumption Tax (June 2025), available at https://duthaoonline.quochoi.vn/dt/luat-thue-tieu-thu-dac-biet-sua-doi/E3829D1F936D.
[15] Tropicana’s Japanese Licensee in Hot Juice for Cartons That Boast “100% Melon Taste” - Japan Today, https://japantoday.com/category/business/tropicana%E2%80%99s-japanese-licensee-in-hot-juice-for-cartons-that-boast-'100-melon-taste'-2 (updated March 2025).
[16] A. B. C. News, New York Woman Sues Kellogg’s for $5 Million over Frosted Strawberry Pop-Tarts, ABC News, https://abcnews.go.com/Business/york-woman-sues-kelloggs-million-frosted-strawberry-pop/story?id=80812161 (cập nhật 05/2025).
[17] Paola Letona et al., A Qualitative Study of Children’s Snack Food Packaging Perceptions and Preferences, 14 BMC Public Health 1274 (2014).
[18] Su Chang & Fauzi Naeim, Visual Design and Consumer Psychology of Children’s Food Packaging in China, 13 International Journal of Academic Research in Business and Social Sciences 145 (2023).
[19] Naser Azad, Mojtaba Rafiee & Leila Hamdavipour, The Role of Children’s Food Packaging Characteristics on Parent’s Purchasing Decision, 2 Manag. Sci. Lett. 827, trang 831 (2012).
[20] Global: Juices Market Revenue by Country 2024, Statista, https://www.statista.com/forecasts/758678/revenue-of-the-juices-market-worldwide-by-country (updated May 2025).
[21] Japan: Fruit Juice Consumption Index, Statista, https://www.statista.com/statistics/654176/japan-consumption-index-fruit-juice/ (updated May 2025).
[22] Hiroshi Akiyama, Takanori Imai & Motohiro Ebisawa, Chapter 4 - Japan Food Allergen Labeling Regulation—History and Evaluation, 62 in Advances in Food and Nutrition Research 139 (Steve L. Taylor ed., 2011).
[23] Food Labeling Act (食品表示法, Shokuhin Hyōji Hō) – Act No. 77/2013, promulgated on June 13, 2013, effective from April 1, 2015. This Act mandates the disclosure of food label contents, including product name, list of ingredients, net weight, storage instructions, expiration date, etc.
[24] Act against Unjustifiable Premiums and Misleading Representations, officially enacted in 2009 and amended twice in 2014. The 2016 amendment empowered the Consumer Affairs Agency of Japan to impose monetary penalties on individuals and organizations violating this Act.
[25] 果汁飲料のパッケージ表示ルールを徹底解説！正しいデザインで信頼を守る, 千巻印刷産業株式会社 (May 13, 2025), https://chimaki.co.jp/fruit-juice-package-labeling-rules/.
[26] ©️KIRIN. Illustrations copyrighted by KIRIN.
[27] ©️SUNTRY. Illustrations copyrighted by SUNTRY.
[28] Verordnung über Fruchtsaft, Fruchtnektar und koffeinhaltige Erfrischungsgetränke (Fruchtsaft- und Erfrischungsgetränkeverordnung - FrSaftErfrischGetrV)
[29] Council Directive 2001/112/EC relating to fruit juices and certain similar products intended for human consumption, amended by Directive 2012/12/EU of the European Parliament on April 19, 2012.
[30] According to Annex IV of Directive 2001/112/EC.
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