Can You Authorize Notification or Registration for Dietary Supplements, Medical Devices, and Cosmetics in Vietnam? Unlock 3 Critical Insights!

Authorize Notification or Registration for importation is a common compliance question faced by many foreign manufacturers and local distributors in Vietnam. The question often arises:
“If we already hold a Notification number or a Registration Certificate, can we authorize another company to use it for importation?”

The answer depends on the product category. In Vietnam, the rules are not uniform for dietary supplements, medical devices, and cosmetics. Below, Green NRJ explains the legal framework under the latest regulations.

1. Medical Devices: Authorization Allowed in Certain Cases

According to Decree 98/2021/ND-CP, businesses or individuals importing medical devices must either:

• Be the holder of the Registration Certificate, or

• Be formally authorized by the Registration Certificate holder to carry out the importation.

This means the Registration Certificate holder has the legal right to issue a written authorization letter for another company to act as the importer. However, the applicable documents differ depending on device classification:

• Class A & B medical devices → Declaration of Applied Standards number. Class C & D medical devices → Marketing Authorization (MA) Registration

Conclusion for medical devices: A company may legally authorize another business to use its medical device registration (Class A–D) to import into Vietnam.

⚠️ Important note: Old-style Import Licenses issued under previous regulations (e.g., Circular 30/2015/TT-BYT) cannot be transferred or authorized.

2. Dietary Supplements (Functional Foods) : Authorize Notification Permitted

Under Decree 15/2018/ND-CP, dietary supplements (functional foods) are subject to Product Declaration Registration with the Ministry of Health. Once approved, the enterprise becomes the holder of the Certificate of Registered Product Declaration.

According to Article 11 of the Decree, the goods owner is defined as either:

• the entity responsible for the registered product declaration, or

• an organization or individual authorized to import or export the food product.

This means that the holder of the Certificate of Registered Product Declaration may legally issue a written authorization allowing another company to act as the importer.

Conclusion for dietary supplements: Authorization of importation is legally permitted, provided it is documented in writing and clearly defines the scope of rights granted.

3. Cosmetics: Authorization Not Allowed

Cosmetics are regulated under the ASEAN Cosmetic Directive, as implemented in Vietnam by Circular 06/2011/TT-BYT, and as newly amended by Circular 34/2025/TT-BYT.

For cosmetics, the importer must obtain a Cosmetic Product Notification (CPN) by submitting a Notification Dossier to the Ministry of Health. Once accepted, the enterprise becomes the Notification Dossier Holder and is issued a Cosmetic Product Notification number.

Vietnamese law does not provide any mechanism that allows the Notification Dossier Holder to authorize another company to use its Cosmetic Product Notification number.

Conclusion for cosmetics: Only the company holding the Cosmetic Product Notification is legally permitted to import and handle customs procedures. Authorization is not permitted.

Why Work with Green NRJ?

Navigating Vietnam’s regulatory framework can be challenging, as requirements differ by product type, classification, and documentation. Green NRJ is here to simplify the process. We offer:

• Comprehensive regulatory consulting,

• Market Authorization Holder (MAH) and authorized importer solutions,

• End-to-end support with product registration and notification,

• Compliance assessment for dietary supplements, medical devices, and cosmetics.

📌 Looking for reliable guidance on product registration or authorized importation in Vietnam?
Get in touch with Green NRJ today for expert, tailored support.