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In Which Cases Can a Cosmetic Product Notification Receipt Number Be Revoked? (2026)
June 30, 2026
Changing a company’s registered address during the cosmetic product notification process is not an uncommon situation for businesses preparing to place cosmetic products on the Vietnamese market. Even a seemingly minor change in legal information can affect the consistency of the notification dossier, resulting in requests for amendments, additional documentation, and a longer review process. Understanding the applicable regulations and preparing an appropriate course of action in advance can help businesses minimize risks, avoid disruptions to their commercial plans, and save considerable time and costs.
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ToggleWhy Can a Change of Company Address Affect a Cosmetic Product Notification Dossier?
When carrying out the notification procedure for imported cosmetic products, all information relating to the company acting as the notification holder must be consistent throughout the entire dossier submitted to the Drug Administration of Vietnam (DAV). This includes the Enterprise Registration Certificate, the Letter of Authorization issued by the manufacturer or product owner, and all other supporting legal documents, all of which must reflect the same legal entity information.
In practice, many companies assume that changing their registered office address is merely an administrative update and does not affect a dossier that has already been submitted. However, this is one of the details that the regulatory authority examines very carefully during the assessment process.
If the information contained in the submitted dossier no longer matches the company’s current legal information, the receiving authority may require the company to amend and supplement the dossier before continuing the review for the issuance of the Cosmetic Product Notification Receipt Number. This is one of the most common reasons why a dossier that appears to be awaiting only the final result may instead be returned for supplementation, significantly extending the overall processing time.
A Real Case Green NRJ Encountered During the Cosmetic Product Notification Process
While assisting clients with imported cosmetic product notifications, Green NRJ encountered a representative case that many businesses may face if they fail to closely monitor changes to their legal information. Initially, the notification dossier was fully prepared in accordance with the company’s legal information at that time and was submitted to the Drug Administration of Vietnam for review. During the period in which the authority was assessing the application, the company completed the procedure to change its registered office address, and the new address was officially updated on its Enterprise Registration Certificate. As a result, the company information contained in the cosmetic notification dossier no longer matched its current legal records.
During the assessment, the Drug Administration of Vietnam identified the discrepancy between the company’s updated address recorded in the official system and the address stated in the Letter of Authorization submitted with the dossier. Instead of continuing the review for the issuance of the Notification Receipt Number, the authority issued an official request requiring the company to amend and supplement the dossier. More importantly, the request was not limited to updating the address in the explanatory documents. The authority also required the company to revise the address stated in the Letter of Authorization to ensure that every document in the dossier reflected the same legal entity information. Consequently, the company had to complete several additional procedures that had not been anticipated, resulting in a considerably longer processing timeline than originally planned.
Why Did the Drug Administration of Vietnam Require the Letter of Authorization to Be Revised Instead of Simply Updating the Company Address?
Many businesses wonder why they must obtain a new Letter of Authorization when only the registered office address has changed, while the enterprise registration number and the legal entity itself remain unchanged. In practice, the Letter of Authorization (LOA) is the legal document through which the manufacturer or product owner authorizes a Vietnamese company to act as the notification holder and market the cosmetic product in Vietnam. The document identifies not only the company’s name but also its complete legal identity, including its registered office address. Once the company’s registered address changes, the information stated in the existing Letter of Authorization no longer matches the company’s current legal records. During the assessment process, the regulatory authority is responsible for verifying the consistency of all documents included in the notification dossier. If the Letter of Authorization still bears the former address while the Enterprise Registration Certificate has already been updated with the new address, the dossier contains inconsistent legal information. This is why the Drug Administration of Vietnam requires the company to obtain a revised Letter of Authorization reflecting the new registered address before the authority proceeds with the assessment of the notification dossier. The purpose of this requirement is to ensure that the dossier remains legally valid, internally consistent, and free from potential legal disputes or administrative complications during the post-market management of the cosmetic product.
Why Must the Company Obtain a New Letter of Authorization?
After receiving the Drug Administration of Vietnam’s request for amendment and supplementation, many companies assume that submitting an explanatory letter or requesting an address correction will be sufficient for the assessment to continue. However, the situation is far more complex when it comes to the Letter of Authorization. A Letter of Authorization is issued by the overseas manufacturer or product owner to authorize a Vietnamese company to act as the notification holder for cosmetic products in Vietnam. Because the document is prepared based on the legal information of the authorized company at the time it is executed, every detail contained in the Letter of Authorization must accurately reflect the company’s legal identity. Once the company’s registered address has changed, the existing Letter of Authorization no longer accurately identifies the authorized entity.
In this situation, the company cannot simply edit, annotate, or affix its own seal to the previously issued document. Any amendment must be made by the original issuing party. As a result, the company must contact the manufacturer or product owner and request the issuance of a completely new Letter of Authorization incorporating the updated registered address in accordance with the company’s current legal information. For businesses that maintain close and efficient cooperation with their overseas partners, obtaining a replacement Letter of Authorization may be relatively straightforward. However, where manufacturers operate in different jurisdictions, follow internal approval procedures, or require legal department review before issuing official documents, the time needed to obtain a new Letter of Authorization can be considerably longer than expected.
The New Letter of Authorization Must Also Undergo Consular Legalization
One of the main reasons why the processing timeline is often extended is that a newly issued Letter of Authorization cannot be used immediately after it has been signed. Under the regulations governing imported cosmetic product notification in Vietnam, a Letter of Authorization issued by a foreign organization must undergo consular legalization before it can be accepted for use in Vietnam, except where an exemption applies under an international treaty or other applicable legal provisions. Since the Letter of Authorization has been reissued with updated information, it is regarded as an entirely new legal document. Consequently, it must complete the full certification and consular legalization process just like any newly issued document. In other words, changing the company’s registered address not only requires a new Letter of Authorization but also triggers the need to repeat the entire consular legalization procedure from the beginning. This stage often consumes a significant amount of time because it depends on the processing schedules of the competent authorities in the issuing country, the Vietnamese diplomatic mission responsible for consular legalization, and the international shipment of documents between countries. In practice, many companies focus only on the time required for the manufacturer to issue a new Letter of Authorization while overlooking the additional time needed for consular legalization. By the time they realize that the supplementary documents cannot be submitted within the required deadline, the overall processing schedule has often already been substantially affected.
The Dossier Must Return to the Assessment Queue After the Supplementary Documents Are Submitted
Once the new Letter of Authorization has been issued, completed the consular legalization process, and arrived in Vietnam, the company can begin preparing the supplementary dossier requested by the Drug Administration of Vietnam. This supplementary dossier includes not only the updated Letter of Authorization reflecting the company’s new registered address but also explanatory documents, amendment letters, and any other supporting documents required under the authority’s official request. After receiving the supplementary submission, the Drug Administration of Vietnam will continue reviewing the application in accordance with its standard assessment procedures. This means that the company will not receive the Notification Receipt Number immediately after submitting the additional documents. Instead, the dossier must re-enter the assessment process and continue through the prescribed review timeline. In one case handled by Green NRJ, obtaining a new Letter of Authorization from the overseas manufacturer, completing the consular legalization process, and preparing the supplementary submission extended the overall processing time by approximately 30 to 40 additional days compared with the original schedule. It is important to note that this delay was not caused by the rejection of the application itself. Rather, it resulted primarily from the need to replace legal documents affected by the company’s change of registered address.
Potential Business Impacts of a Prolonged Notification Process
An additional delay of 30 to 40 days affects far more than the processing timeline of the notification dossier. It can also disrupt the business plans that have already been carefully prepared. For products scheduled for importation, an extended notification process may require the company to postpone shipment schedules or incur warehouse storage costs while waiting for the legal procedures to be completed. If product launch campaigns, marketing activities, or distribution agreements have already been arranged, the absence of a Cosmetic Product Notification Receipt Number may delay the entire commercialization plan.
Beyond the loss of time, companies are also likely to incur additional expenses, including:
- Costs associated with obtaining a new Letter of Authorization.
- Consular legalization fees.
- International courier charges for legal documents.
- Administrative expenses for preparing and submitting supplementary documentation.
These additional costs are often entirely avoidable if the company carefully reviews its legal information before and during the cosmetic product notification process.
How Can Businesses Avoid Problems When Changing Their Registered Address During the Cosmetic Product Notification Process?
Changing a company’s registered address is a legitimate business decision and may occur at any stage of its operations. However, if the company is currently preparing or undergoing the cosmetic product notification procedure, the timing of this change should be carefully considered to minimize unnecessary complications.
Before completing the address change, the company should review all legal procedures that are currently being processed by government authorities. If a cosmetic product notification dossier has already been submitted and is still under assessment, the company should consult its regulatory advisor to evaluate the potential impact and determine the most appropriate course of action.
In many situations, postponing the address change until after the Cosmetic Product Notification Receipt Number has been issued allows the company to avoid revising previously submitted documents and prevents unnecessary delays in the assessment process. On the other hand, if changing the registered address is mandatory and cannot be postponed, the company should immediately notify its regulatory consultant so that an appropriate solution can be prepared from the outset. Contacting the manufacturer or product owner as early as possible to arrange the issuance of a new Letter of Authorization can significantly reduce the time required to prepare the supplementary dossier. Most importantly, companies should not wait until they receive an official request for amendment from the Drug Administration of Vietnam before taking action. By that stage, the processing timeline has often already been extended beyond the original expectations.
Conclusion
Changing a company’s registered address during the cosmetic product notification process may appear to be a simple administrative update. In reality, however, it can trigger a series of additional regulatory procedures if the dossier is already under assessment. Obtaining a new Letter of Authorization, completing the consular legalization process, and waiting for the supplementary dossier to be reassessed may extend the overall processing time by 30 to 40 days. If your company is preparing to submit a cosmetic product notification dossier or plans to update its legal information during the notification process, Green NRJ can help you evaluate your specific situation and determine the most suitable approach. Careful planning at the right time can minimize regulatory risks, reduce unnecessary costs, and ensure that your products are launched on the Vietnamese market without avoidable delays.
