Important Notes on the Certificate of Free Sale (CFS) in the Notification of Imported Cosmetics

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Important Notes on the Certificate of Free Sale (CFS) in the Notification of Imported Cosmetics

Vietnam’s booming cosmetics market is attracting an increasing number of international brands. To legally circulate imported cosmetics in Vietnam, businesses are required to complete the cosmetic product notification process. One essential document in this procedure is the Certificate of Free Sale (CFS).

In this article, Green NRJ provides insights into what a CFS is, what it must include, legal references, and exceptions under international trade agreements such as CPTPP.

What Is a Certificate of Free Sale (CFS)?

A Certificate of Free Sale (CFS) is an official document issued by a competent authority in the exporting country. It certifies that the cosmetic product is legally sold and freely circulating in the domestic market of that country. The CFS ensures that the product has met basic safety and quality standards.

Legal Basis for CFS Requirements

The legal foundation for CFS requirements in Vietnam is established under the following documents:

  • Circular No. 06/2011/TT-BYT (Ministry of Health): On the management of cosmetics.
  • Decree No. 69/2018/NĐ-CP: Detailing the implementation of several articles of the Law on Foreign Trade Management.
  • Law on Foreign Trade Management (2017).
  • Circular No. 29/2020/TT-BYT: Amending and supplementing Circular 06/2011/TT-BYT.

These documents confirm that the CFS is a mandatory part of the notification dossier for imported cosmetics, except in certain cases under CPTPP.

Key Information Required in a Valid CFS

According to Clause 3, Article 10 of Decree 69/2018/NĐ-CP and Circular 06/2011/TT-BYT, a valid Certificate of Free Sale must contain the following information:

  1. Name of the issuing authority (a competent government body).
  2. Number and date of issuance of the CFS.
  3. Name of the product(s) for which the certificate is issued.
  4. Type or category of product (in this case, cosmetics).
  5. Name and address of the manufacturer.
  6. Name and address of the exporter (if different).
  7. Confirmation that the product is freely sold in the country of issuance.
  8. Signature, full name of the signatory, and stamp of the issuing body.

📌 Validity: The CFS must be valid at the time of submission. If no expiration date is provided, it must have been issued within 24 months.

📌 Consular Legalization: Required unless exempted under international agreements.

Special Case: Import from CPTPP Member Countries

According to Circular No. 29/2020/TT-BYT, products imported from CPTPP member countries may be exempt from submitting the CFS in the following cases:

  1. Products manufactured in a CPTPP member country that has ratified the agreement.
  2. Products exported from and legally circulated in a CPTPP country, with supporting documents such as:
    • Cosmetic product licenses issued by local authorities.
    • Notification receipts of cosmetic products.
    • Other legal documents showing the product is sold in that country.

📌 In such cases, instead of the CFS, the importer must submit documents proving legal circulation, and these documents may still need consular legalization, unless exempted under:

  • Bilateral or multilateral international treaties.
  • Written confirmation by the foreign competent authority.
  • Verified information from official websites (with enterprise’s seal and documentation of the search).

🔎 CPTPP members include: Japan, Canada, Australia, New Zealand, Mexico, Singapore, Malaysia, Chile, Brunei, and Peru.

How Green NRJ Can Help

With deep expertise in import-export procedures and legal compliance, Green NRJ offers:

  • Review and preparation of cosmetic notification dossiers
  • Guidance on obtaining or verifying the Certificate of Free Sale
  • Consulting on CPTPP-related exemptions and origin certification

We ensure that your products meet all legal requirements to smoothly enter the Vietnamese market.

Need assistance with cosmetic product notification?
Contact Green NRJ today for reliable and cost-effective solutions!

 

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