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Vietnam’s rapidly expanding cosmetics market is attracting an increasing number of international brands. To legally import and distribute cosmetic products in Vietnam, businesses are required to complete the mandatory cosmetic product notification process. A key document in this procedure is the Certificate of Free Sale (CFS), which confirms that a cosmetic product is legally manufactured, marketed, and freely sold in its country of origin. Understanding the role of the Certificate of Free Sale in Vietnam is essential for ensuring regulatory compliance and avoiding delays in market entry. In this article, Green NRJ provides a comprehensive overview of the Certificate of Free Sale, including its definition, required contents, applicable legal regulations, validity and legalization requirements, as well as important considerations for businesses preparing cosmetic registration dossiers in Vietnam.
What Is a Certificate of Free Sale (CFS)?
A Certificate of Free Sale (CFS) is an official document issued by a competent government authority or an organization lawfully authorized by such authority in the exporting country. The CFS confirms that the cosmetic product is lawfully manufactured and legally placed on the market of the exporting country at the time of issuance.
The Certificate of Free Sale serves as evidence of lawful circulation in the country of origin. However, it does not constitute a safety assessment or quality certification of the product, nor does it replace the regulatory evaluation required by Vietnamese competent authorities.
In the context of importing cosmetics into Vietnam, the Certificate of Free Sale (CFS) plays a crucial role, as it demonstrates regulatory compliance in the exporting country. Under Vietnamese regulations, a Certificate of Free Sale (CFS) is generally required as part of the cosmetic product notification dossier for imported cosmetics. The submission of a valid notification dossier is a prerequisite for the lawful importation, distribution, and circulation of cosmetic products in the Vietnamese market, subject to applicable exemptions or alternative documentation accepted by the competent authority.
Legal Basis for CFS Requirements
The legal framework governing the Certificate of Free Sale (CFS) requirements for imported cosmetics in Vietnam is clearly defined by several key regulatory documents, ensuring compliance with national and international trade laws. These documents include:
Circular No. 06/2011/TT-BYT issued by the Ministry of Health on cosmetic management, as amended and supplemented by Circular No. 34/2025/TT-BYT, which currently governs cosmetic product notification and regulatory requirements in Vietnam.
Decree No. 69/2018/NĐ-CP, which provides general regulations on Certificates of Free Sale for imported and exported goods under the Law on Foreign Trade Management. This Decree applies to cosmetics only to the extent relevant to CFS issuance and legalization, while cosmetic-specific requirements are governed by regulations of the Ministry of Health.
Law on Foreign Trade Management (2017), the primary legal act regulating foreign trade activities in Vietnam.
Circular No. 29/2020/TT-BYT, which amends and supplements Circular No. 06/2011/TT-BYT, introducing updates on cosmetic product notification procedures and clarifications on CFS exemptions.
According to these regulations, the Certificate of Free Sale (CFS) is generally required in the cosmetic product notification dossier for imported cosmetics in Vietnam. However, certain exemptions apply to products imported from CPTPP member countries, where alternative proof of legal sale and circulation may be accepted.
Key Information Required in a Valid CFS
According to Clause 3, Article 10 of Decree No. 69/2018/NĐ-CP and Circular No. 06/2011/TT-BYT issued by the Ministry of Health, a valid Certificate of Free Sale (CFS) for imported cosmetics must include comprehensive and specific information to be accepted by Vietnamese authorities during the cosmetic product notification process.
The essential details that a valid CFS must clearly state include:
| Key Information | Description |
|---|---|
| Name of the Issuing Authority | The competent government agency or authorized body responsible for issuing the CFS in the exporting country. |
| Certificate Number and Date | The official reference number of the CFS along with the exact date it was issued. |
| Product Name(s) | The exact name(s) of the cosmetic product(s) covered by the certificate. |
| Product Type or Category | Clearly specify that the product falls under the cosmetics category. |
| Manufacturer’s Name and Address | Full legal name and physical address of the manufacturer producing the cosmetic product. Where the manufacturing country differs from the exporting country, the manufacturing location should be clearly indicated. |
| Exporter’s Name and Address | The name and address of the exporter, if such information is stated in the Certificate of Free Sale. |
| Declaration of Free Sale | A formal statement confirming that the product is legally sold and lawfully circulating in the exporting country’s market. |
| Signature, Full Name, and Official Stamp | The certificate must be signed by an authorized official, including their full name and bear the official seal or stamp of the issuing authority. |
In addition to its basic function, a Certificate of Free Sale (CFS) must satisfy several important requirements to be considered valid for cosmetic product notification in Vietnam. First, the CFS must be valid at the time of submission to the Vietnamese authorities. In cases where the Certificate of Free Sale does not specify an expiration date, Vietnamese regulatory practice generally requires that the CFS be issued within an acceptable time frame prior to submission, commonly within the preceding 24 months. This requirement is based on regulatory practice rather than an explicit statutory provision.
Furthermore, the Certificate of Free Sale is generally subject to consular legalization by the Vietnamese embassy or consulate in the exporting country, unless such legalization is waived pursuant to applicable international agreements or treaties to which Vietnam is a party, or replaced by other accepted authentication methods in accordance with Vietnamese regulations and the competent authority’s practice.
Compliance with these requirements is essential to ensure the acceptance of the Certificate of Free Sale and the successful completion of cosmetic importation and product notification procedures in Vietnam.
Special Case: Import from CPTPP Member Countries
According to Circular No. 29/2020/TT-BYT issued by the Ministry of Health of Vietnam, cosmetic products imported from member countries of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) may not be required to submit a Certificate of Free Sale (CFS), provided that equivalent documentation evidencing lawful circulation is accepted by the Vietnamese competent authority on a case-by-case basis.
This regulatory provision is intended to facilitate international trade, streamline cosmetic import procedures, and reduce administrative burdens for businesses importing cosmetics from CPTPP markets that are considered to have reliable regulatory frameworks.
The CPTPP currently comprises Japan, Canada, Australia, New Zealand, Mexico, Singapore, Malaysia, Chile, Brunei, and Peru. Cosmetic products originating from these countries may benefit from the flexible CFS documentation mechanism applied in practice, which can simplify import documentation and facilitate market entry in Vietnam, subject to regulatory review, reduces paperwork, and accelerates market entry in Vietnam, while still ensuring compliance with applicable Vietnamese cosmetic regulations.
To qualify for the Certificate of Free Sale (CFS) exemption, imported cosmetic products must meet the regulatory conditions applied in practice by the Vietnamese competent authority. In principle, the cosmetic product must be lawfully manufactured or lawfully placed on the market of a member country of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), and evidence of such lawful circulation must be provided.
Accordingly, importers are required to submit alternative documentation issued by a competent authority in a CPTPP member country that clearly demonstrates the cosmetic product is legally placed on the market and permitted for circulation. Such documentation may include licenses, certificates, official regulatory confirmations, or other legally valid documents, depending on the regulatory framework of the exporting country, and is subject to acceptance by the Vietnamese competent authority on a case-by-case basis.
In situations where the Certificate of Free Sale is exempted, importers must provide alternative documentation to substantiate the product’s legal circulation in the exporting country. Depending on the specific case, these substitute documents may still be subject to consular legalization or authentication by the Vietnamese embassy or consulate in the exporting country, unless legalization requirements are waived.
Exemptions from consular legalization may apply where Vietnam is a party to relevant bilateral or multilateral international treaties that waive or simplify legalization requirements. In certain cases, written confirmation or official certification issued by a competent authority of the exporting country may also be considered as supporting evidence.
Where information is obtained from official government or regulatory authority websites, such information may be used for reference purposes only and remains subject to verification and acceptance by the Vietnamese competent authority on a case-by-case basis. The acceptance of such information does not automatically waive consular legalization requirements unless explicitly permitted under applicable regulations or international agreements.
How Green NRJ Can Help
With extensive expertise in cosmetic import-export procedures and strict adherence to Vietnamese legal compliance, Green NRJ provides comprehensive support to help your business successfully navigate the complex process of cosmetic product notification and market entry in Vietnam.
Our professional services include:
- 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
By partnering with Green NRJ, you can confidently ensure that your cosmetic products fully comply with all Vietnam cosmetic import regulations, avoiding costly delays and facilitating smooth entry into the Vietnamese market.
✅ Need assistance with cosmetic product notification?
Contact Green NRJ today for reliable and cost-effective solutions!
