Address on CFS/GMP Differs from Cosmetic Label in Vietnam: Is It Acceptable?

Address on the CFS/GMP differs from the cosmetic label is a recurring compliance concern for enterprises preparing cosmetic product notification dossiers for import into Vietnam.

This issue often arises at the intersection between the general requirement for consistency with CFS/GMP documents and Vietnam’s mandatory labeling regulations.

Address on CFS/GMP Differs from Cosmetic Label: General Consistency Requirement

In practice, when preparing dossiers for imported cosmetic product notification in Vietnam, a principle consistently applied by both enterprises and authorities is that the information displayed on product labels must be consistent with the information stated in the CFS and/or GMP certificates, particularly with respect to core details such as the manufacturer’s name, address, and country of manufacture.

Based on this principle, many enterprises assume that all label information must match the wording shown on the CFS/GMP exactly, including abbreviations and formatting. This understanding is generally correct in most standard cases.

However, in practice, complications frequently arise where the manner in which information is presented on the CFS/GMP does not comply with Vietnam’s labeling regulations, especially in cases where country names or geographical locations are written in abbreviated form in accordance with the administrative practices or international conventions of the issuing country.

Practical Issue: Abbreviations on the CFS/GMP vs. Vietnam’s Labeling Requirements

Under Vietnam’s labeling regulations, particularly Decree No. 43/2017/NĐ-CP, specific requirements apply to the presentation of names and addresses of organizations and individuals responsible for goods.

Article 12 of Decree No. 43/2017/NĐ-CP expressly provides that proper names of organizations, individuals, and geographical locations shown on goods labels must not be abbreviated. In parallel, Article 9 of the same Decree requires that labeling information must be truthful, clear, accurate, and properly reflect the nature of the goods.

In addition, Clause 1, Article 39 of Decree No. 37/2026/NĐ-CP further reinforces this principle by requiring that the name of the country or territory of manufacture must not be abbreviated on goods labels circulated in Vietnam.

By contrast, in actual practice, CFS or GMP certificates issued by competent foreign authorities may present the country name or manufacturer’s address in abbreviated form, following the administrative standards or conventions of the issuing jurisdiction.

This divergence places enterprises in a practical “dilemma” when preparing cosmetic labels for circulation in Vietnam:

• If the label strictly follows the abbreviated wording shown on the CFS/GMP, it may fail to comply with Vietnam’s mandatory labeling regulations.

• If the label is adjusted to comply with Vietnamese labeling requirements, the wording may no longer be identical to that shown on the CFS/GMP.

This raises a common question in practice:
Is a cosmetic label that does not match the exact wording of the CFS/GMP acceptable?

Are Differences in Wording Between the Label and the CFS/GMP Acceptable?

In practical application, differences in wording in the above circumstances are generally accepted, provided that certain conditions are clearly satisfied.

Vietnamese authorities do not require enterprises to retain abbreviated expressions shown on the CFS/GMP where such expressions are inconsistent with mandatory labeling requirements under Vietnamese law. On the contrary, enterprises are required to adjust the presentation on the label to comply with domestic labeling regulations, even if this results in the label not being identical in wording to the CFS/GMP.

The key consideration in these cases is that the substantive information remains unchanged: the country of manufacture and the manufacturer are the same, and the difference lies solely in the form of expression (abbreviated versus full wording) adopted to comply with Vietnam’s labeling requirements.

For example, in practice, a CFS/GMP may indicate the country name in abbreviated form such as “P.R. China”, while the cosmetic label in Vietnam states “People’s Republic of China” or “China”. This adjustment does not alter the product’s origin but reflects mandatory compliance with Vietnamese labeling regulations.

Similar situations may arise in relation to products originating from Korea, Taiwan, or other countries, where differences in legal requirements and language conventions lead to variations in how country names or addresses are presented between the CFS/GMP and the label.

When Is a Difference Between the CFS/GMP and the Label Not Acceptable?

It should be emphasized that not all discrepancies between label information and the CFS/GMP are considered acceptable exceptions.

In practice, differences are only accepted where the adjustment is required by Vietnam’s mandatory labeling regulations and does not change the country of manufacture, the manufacturer, or the substantive origin of the product.

Conversely, if the adjustment results in the indication of a different country, a different legal entity, or creates a misleading impression regarding the product’s origin, such discrepancy would constitute a legal risk during the cosmetic notification process or in post-market inspections conducted by the authorities.

Compliance Perspective and Practical Recommendation

Where the CFS/GMP uses abbreviated forms that are inconsistent with Vietnam’s labeling regulations, enterprises should not mechanically replicate the wording shown on the CFS/GMP. Instead, priority should be given to compliance with labeling requirements applicable to goods circulated in Vietnam.

In such cases, differences in wording are regarded as a legitimate and acceptable exception, provided that the information continues to accurately reflect the nature and origin of the product.

From a practical advisory perspective, Green NRJ recommends that enterprises review both the CFS/GMP and label design at an early stage to identify potential discrepancies and make necessary adjustments in advance. This proactive approach helps minimize the risk of explanation requests, dossier amendments, or compliance issues during the cosmetic notification process and subsequent post-market inspections.