Comparative Halal governance in Southeast Asia: policy lessons for strengthening Vietnam’s regulatory system
Minh Phuong Dang, Nhu Ha Nguyen, Tien Dat NguyenPurpose
This paper aims to analyze the policies and certification frameworks governing Halal standards in three leading Southeast Asian countries, namely, Malaysia, Indonesia and Singapore, which are recognized for their advanced Halal governance models. Drawing on institutional isomorphism and policy transfer theory, the study comparatively evaluates these governance systems to identify the legal, institutional and regulatory factors that shape Halal governance. From that, the study derives concrete policy lessons for enhancing Vietnam’s current Halal standards policy, highlighting institutional and legal gaps and proposes policy implications to enhance Vietnam’s competitiveness in the global Halal economy.
Design/methodology/approach
The study adopts a comparative legal and institutional analysis, examining primary sources including legal documents (e.g. Malaysia’s Trade Descriptions Act 2011, Indonesia’s Law No. 33/2014 and Singapore’s Administration of Muslim Law Act), policy reports from national Halal authorities (Jabatan Kemajuan Islam Malaysia [JAKIM], Badan Penyelenggara Jaminan Produk Halal [BPJPH] and Majlis Ugama Islam Singapura [MUIS]) and relevant Vietnamese National Standard in Vietnamese (TCVN). The analysis focuses on three evaluative dimensions: the legal framework, primary regulatory bodies and the Halal standards system.
Findings
The results reveal distinct yet effective models: Malaysia boasts a centralized, state-driven system under JAKIM, renowned for its comprehensive standards (e.g. MS 1500:2019) and global leadership. Indonesia leverages a mandatory certification model enforced by BPJPH, supported by the religious authority of the Indonesian Ulema Council (Majelis Ulama Indonesia [MUI]). Singapore, through MUIS, exemplifies a high-integrity system within a secular state, accredited to international benchmarks such as ISO 17065. In contrast, Vietnam’s framework is fragmented and underdeveloped, characterized by the absence of a dedicated Halal law, a nascent and non-mandatory standards system (TCVN) and the lack of a centralized religious authority, resulting in limited international recognition and market access. The comparative analysis indicates that no single governance model can be directly transferred to Vietnam. Instead, Vietnam requires a context-specific approach that combines Malaysia’s institutional coordination, Indonesia’s regulatory coherence and Singapore’s internationally recognized certification practices while adapting these elements to Vietnam’s environment.
Social implications
Strengthening Vietnam’s Halal governance framework has broader implications for trade and development. Enhancing Halal certification credibility will not only support Vietnam’s ambition to expand exports to Muslim-majority markets but also foster economic diversification and integrate Vietnam more effectively into global value chains.
Originality/value
This paper is one of the first, to the best of the authors’ knowledge, structured comparative legal-institutional studies of Halal governance covering all four countries and contributes to the limited scholarship on Halal policy in Vietnam by offering a structured comparative analysis with regional leaders. Unlike previous comparative studies that primarily describe national Halal systems, this study identifies governance elements that are transferable to Vietnam while recognizing the importance of institutional context. It provides policy-oriented recommendations for legal, institutional and technical reforms necessary to position Vietnam as a credible participant in the global Halal economy.