Exporting Cosmetics to Vietnam: Notification, CFS and Labels
Every cosmetic product sold in Vietnam needs a notification receipt number from the Drug Administration of Vietnam (DAV) before it goes on sale. The notification is filed by a Vietnamese company responsible for placing the product on the market, usually your importer or distributor, using your letter of authorisation and, in most cases, a Certificate of Free Sale (CFS).
Checked against official sources: 2026-09
At a glance
Who files the notification, and where
Only a Vietnamese organisation or individual whose business scope covers cosmetics can file. The foreign manufacturer or brand owner authorises it with a letter of authorisation (LoA).
Imported products are notified to DAV, online through the National Public Service Portal, in person or by post. A complete dossier with the fee paid gets its receipt number within 3 working days; otherwise DAV lists the defects within 5 working days.
The number is valid for 5 years and must be renewed by notifying again before it expires. Some product changes need a new notification.
Certificate of Free Sale and legalisation
The CFS must be issued by a competent authority in the country of manufacture or export and still be valid; if it has no expiry date, it must be under 24 months old.
No CFS is needed for products made in a CPTPP country (such as Japan, Canada or Australia) or already notified in an ASEAN country; proof of that authorisation is filed instead.
The CFS must be consular-legalised unless a treaty exempts it, the issuing authority confirms it to DAV, or it can be verified on the issuer's website. The LoA must be signature-certified and legalised unless a treaty exempts it.
The Apostille Convention has applied to Vietnam since 11 September 2026, except with Germany, Austria and Czechia. The cosmetics rules still refer to consular legalisation, so confirm with DAV before relying on an apostille.
Ingredients and claims
Formulas must meet the ASEAN Cosmetic Directive annexes, which are updated regularly (most recently in June 2026), so re-check at each update.
Since Circular 34/2025, the notification lists ingredients by INCI name in descending order, with percentages for restricted ones. Claims must follow ASEAN guidelines; untrue or non-cosmetic claims, such as treating a disease, risk rejection or withdrawal.
- Annex II: prohibited substances
- Annex III: restricted substances and conditions
- Annex IV: permitted colourants
- Annex VI: permitted preservatives
- Annex VII: permitted UV filters
Labels and Vietnamese sub-labels
The label must show name and function, directions, full ingredients, country of manufacture, the Vietnamese responsible company's name and address, net quantity, batch number, manufacturing or expiry date and warnings. At least the directions, company details and warnings must be in Vietnamese.
Under Decree 37/2026/ND-CP, which replaced Decrees 43/2017 and 111/2021, the original label of imported goods must show product name, origin and manufacturer name and address. A Vietnamese sub-label carrying the mandatory content is added before sale without covering the original.
Product Information File (PIF)
Each product needs a PIF in four parts (administrative and summary, raw materials, finished product, safety and efficacy), kept at the Vietnamese responsible company's address.
Part 1 must be shown immediately on inspection, the rest within 15 to 60 days as required. A missing PIF is a ground for withdrawing the number, so agree that the manufacturer supplies the technical parts.
Customs clearance and pending changes
Importers no longer present the paper notification to customs; they declare the number and customs checks it electronically. Keep product names consistent across invoice, packing list and notification; Triplicate's free invoice and packing list generator and HS code lookup can help.
A new cosmetics decree was still in draft in September 2026. Rules change, so confirm current requirements with DAV or a licensed customs broker or regulatory consultant before shipping.
Step by step
- Appoint a Vietnamese importer or distributor with cosmetics in its business scope as the responsible company.
- Check formulas and claims against the current ASEAN annexes and claim guidelines.
- Obtain the CFS (or CPTPP/ASEAN evidence) and LoA, and legalise them.
- Have the Vietnamese company file the notification with DAV online and pay VND 500,000 per product.
- Prepare the Vietnamese sub-label and check it against the notification.
- Ship after the number is issued, with invoice, packing list, transport document and any certificate of origin.
- Apply sub-labels before sale, keep the PIF in Vietnam, and track expiry and annex updates.
Documents you usually need
- DAV notification receipt number (filed by the Vietnamese company)
- Letter of authorisation, signature-certified and legalised
- Certificate of Free Sale, or CPTPP/ASEAN authorisation evidence
- Full ingredient list with INCI names and concentrations
- Original label artwork and Vietnamese sub-label
- Product Information File (kept in Vietnam)
- Commercial invoice and packing list
- Bill of lading or air waybill
- Certificate of origin, if claiming a preferential tariff
- Import customs declaration (filed by the importer)
Common problems and how to avoid them
What to do: Order the CFS with exact product names, legalise it early and check dates.
What to do: Ship only after DAV issues the number; goods cannot be sold without it.
What to do: Watch annex updates and reformulate in time.
What to do: Draft it from the notified data and have the Vietnamese company review it.
What to do: Keep claims within ASEAN cosmetic claim guidelines.
What to do: Supply the complete PIF at notification and keep it updated.
Sources
- Consolidated Circular 06/2011/TT-BYT on cosmetics management (07/VBHN-BYT) Ministry of Health, Government of Viet Nam
- Circular 34/2025/TT-BYT amending Circular 06/2011/TT-BYT Ministry of Health (text via Thu Vien Phap Luat)
- Decision 2393/QD-BYT (2025) on cosmetics administrative procedures Ministry of Health (text via Thu Vien Phap Luat)
- Original labels of imported goods (Decree 37/2026/ND-CP Q&A) Ministry of Science and Technology
- Notes on goods labelling under Decree 37/2026/ND-CP Tap chi Kinh te Tai chinh (Thue Hai quan)
- Viet Nam accedes to the 1961 Apostille Convention HCCH
- ASEAN Cosmetic Directive and annexes Health Sciences Authority, Singapore
- No need to present the cosmetic notification at import (Decree 155/2018/ND-CP) VietNamNet
- Vietnam: Apostille Convention simplifies cross-border public documents Baker McKenzie
- Cosmetics management: draft decree status (September 2026) Suc khoe & Doi song (Ministry of Health newspaper)
Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.
Common questions
Can a foreign brand hold the notification itself?
No. The holder must be a Vietnamese organisation or individual with cosmetics in its business scope.
Does an apostille replace consular legalisation?
Since 11 September 2026 it can for public documents from most Convention members (not Germany, Austria or Czechia). DAV's cosmetics rules have not been updated to say so, so confirm first.
Can I send samples before notification?
Yes, for research or testing: the importer applies to the provincial health authority, up to 10 samples per product, not for sale.
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