Metal packaging and utensils are widely used in the food industry due to their high durability, good heat resistance, and convenience during storage and transportation. However, if the materials are not safe, metal substances or chemicals may migrate into food and affect consumer health.

Therefore, the Ministry of Health issued QCVN 12-3:2011/BYT to regulate hygiene and safety requirements for metal packaging and utensils that come into direct contact with food. Let ISSQ Quality Institute explore this regulation, its technical requirements, and the conformity certification process in the article below.

What are metal packaging and utensils?

Metal packaging and utensils are products manufactured from metal materials or metal alloys and used for containing, preserving, processing, or directly contacting food during production and use.

Commonly used metal materials include: stainless steel, aluminum, tin, coated steel, and other metal alloys.

Today, metal packaging and utensils are commonly used in many food and daily-life applications such as canned food containers, metal food containers, stainless steel trays, pots, pans, spoons, forks, knives, metal water bottles, and metal food containers.

Thanks to their durability, heat resistance, and reusability, metal products are widely chosen by businesses and consumers. However, if the raw materials or surface coatings do not meet quality requirements, substances such as lead, cadmium, or other chemical compounds may migrate into food during use.

Therefore, metal packaging and utensils that directly contact food must comply with safety requirements under QCVN 12-3:2011/BYT before being circulated on the market.

Why do metal packaging and utensils require conformity certification according to QCVN 12-3:2011/BYT?

Metal packaging and utensils that directly contact food are often used under conditions involving high temperatures, high humidity, or acidic and oily environments. If manufacturing materials do not meet quality requirements, heavy metals or residual chemicals may migrate into food during use.

Common risks include:

• Metal packaging being oxidized or corroded after a period of use
• Food-contact utensils containing lead or cadmium exceeding allowable limits
• Inner coatings of packaging not meeting food safety requirements
• Products unsuitable for acidic foods or high-temperature conditions

These factors not only affect food quality but may also pose risks to consumer health through long-term exposure.

In addition, under current regulations, metal packaging and utensils that directly contact food are subject to conformity declaration in compliance with QCVN 12-3:2011/BYT before being placed on the market. Conformity certification helps businesses control product quality, comply with state management requirements, and build trust with customers and partners.

What is QCVN 12-3:2011/BYT?

QCVN 12-3:2011/BYT is the National Technical Regulation on hygiene and safety for metal packaging and utensils that directly contact food, issued by the Ministry of Health together with Circular No. 34/2011/TT-BYT dated August 30, 2011.

This regulation specifies technical and management requirements on hygiene and safety for metal packaging and utensils that directly contact food (hereinafter referred to as metal packaging and utensils).

QCVN 12-3:2011/BYT applies to organizations and individuals importing, manufacturing, trading, and using metal packaging and utensil products; state management agencies; and other related organizations and individuals.

Technical Requirements for Metal Packaging and Utensils

Notes

[1] Samples used for containing fats, edible oils, and fatty foods.

[2] Samples used for containing alcoholic beverages.

[3] Samples used for containing foods with pH greater than 5.

[4] Samples used for containing foods with pH less than or equal to 5.

[5] For utensils used at temperatures above 100°C, the extraction condition shall be 95°C for 30 minutes.

[6] Dry residue content shall not exceed 90 μg/ml where the sample is a canned product internally coated with a layer mainly composed of natural oils or fats and where the zinc oxide content in the coating exceeds 3%.

[7] The quantity of chloroform-soluble substances (limited to 30 μg/ml or less) shall be determined when a sample can be used similarly to [6] and the quantity exceeds 30 μg/ml.

[8] Not applicable to uncoated metal packaging and utensils that do not have a synthetic resin layer directly contacting food.

[9] The eluate solution has been concentrated 5 times, although the concentration in the eluate does not exceed 25 μg/ml.

Benefits of Conformity Certification for Metal Packaging and Utensils according to QCVN 12-3:2011/BYT

Conformity certification according to QCVN 12-3:2011/BYT not only helps businesses comply with state management requirements but also provides many benefits in production, business operations, and brand reputation building.

• Meeting market circulation requirements: Metal packaging and utensils that directly contact food belong to the group of products required to carry out conformity declaration under current regulations. Conformity certification provides a basis for businesses to complete related procedures before products are marketed.
• Controlling product quality and safety: Through evaluation and testing according to QCVN 12-3:2011/BYT, businesses can control risks of heavy metal or chemical migration affecting food safety, thereby improving product quality.
• Enhancing credibility with customers and partners: Certified products help build trust among customers, partners, and distributors. This also supports businesses in strengthening brand image in the packaging and food utensil industry.
• Minimizing legal and quality risks: Compliance with technical requirements under the regulation helps businesses reduce risks related to quality inspections, product recalls, or customer complaints.
• Supporting market expansion: Many distribution systems, supermarkets, and food manufacturing partners prioritize products with clear quality documentation. Conformity certification is also one of the factors supporting smoother cooperation and market expansion.

It can be seen that implementing conformity certification according to QCVN 12-3:2011/BYT not only helps businesses comply with quality management and food safety requirements but also enhances brand reputation, increases competitiveness, and builds customer trust in the market.

This also serves as a basis for businesses to proactively control product quality and move toward sustainable development in the production and trading of food-contact packaging and utensils.

Conformity Certification Process for Metal Packaging and Utensils according to QCVN 12-3:2011/BYT

To certify metal packaging and utensils in compliance with QCVN 12-3:2011/BYT, the process generally includes the following steps:

Step 1: Receive certification registration documents

Step 2: Sign scientific and technological service contract

Step 3: Conduct survey and assessment

Step 4: Complete post-assessment documentation

Step 5: Review documents and issue certificate (if compliant)

Step 6: Conduct surveillance assessment at intervals not exceeding 12 months

Step 7: Conduct recertification assessment (certificate validity expires after 3 years)

Metal packaging and utensils that directly contact food are products that directly affect food quality and safety during use. Therefore, compliance with QCVN 12-3:2011/BYT not only helps businesses comply with current regulations but also contributes to improving product quality and building trust with customers and partners.

Through conformity certification activities, businesses can proactively control risks of chemical migration, complete legal documentation, and enhance market reputation.

If your company needs QCVN 12-3:2011/BYT conformity certification for hygiene and safety of metal packaging and utensils that directly contact food, please contact ISSQ Quality Institute via hotline: +84 981851111 or email: vienchatluong@issq.org.vn | tcvn@issq.org.vn for support.

Published date: 06/05/2026