Cosmetic Classification in Vietnam: How to Determine if Your Product Qualifies (2026 Guide)

Cosmetic classification in Vietnam is always a confusing step for many businesses when launching products onto the market. Not all skincare or beauty products are considered cosmetics according to regulations. In fact, simply misunderstanding the intended use or how to describe the product’s function can lead to it being classified in an unexpected category. This not only slows down the process of obtaining cosmetic product registration from the Drug Administration but also poses many legal risks during circulation. Therefore, correctly identifying the product category from the outset will help businesses process their applications smoothly and save considerable time.

Legal Regulations Regarding Cosmetics and the Essential Boundaries to Understand

According to Circular 06/2011/TT-BYT, cosmetics are defined as products intended for contact with external body parts such as skin, hair, nails, lips, teeth, and oral mucosa. Their purpose is limited to cleansing, fragrance, improving appearance, protection, or maintaining the body’s normal condition.

While this sounds simple, the key point is that cosmetics must not be intended to treat or affect physiological functions. This is the most important boundary distinguishing cosmetics from medicines or other product groups. Understanding this principle makes evaluating a product clearer, rather than relying on subjective feelings.

Look at the intended use to correctly identify the nature of the product.

In practice, the easiest way to differentiate is to look at the product’s actual intended use. If the product is only for external care, to soften skin, clean hair, or improve appearance, it is likely a cosmetic. Products like moisturizers, lipsticks, or shampoos usually fall into this category because they do not interfere with the body’s mechanisms.

However, things change when the product begins to be associated with therapeutic uses. When a product is advertised as being able to cure acne, treat dermatitis, or kill fungi, its nature is no longer simply about care. At this point, even if the appearance resembles a cosmetic, the product may still be classified into a different category according to regulations.

Cosmetic classification in Vietnam: The role of usage and ingredients in product classification

Besides the intended use, the method of product use is also a crucial factor in determining its classification. Cosmetics are always limited to external use. Products taken orally or applied internally, even if intended for beauty purposes, are not classified as cosmetics.

Ingredients are also an important factor. A product may be designed as a cream or gel, similar to cosmetics, but if it contains strong active ingredients or is not on the permitted list, its classification will need to be reconsidered. This is why some products that “look like cosmetics” are not accepted in the application process.

Common Misconceptions in Practice

In the market, many products fall on the boundary between cosmetics and other categories, making classification unclear. Products for acne-prone skin, anti-dandruff shampoos, or strong skin whitening products are typical examples. Simply changing the wording of the product’s function can lead to two completely different interpretations.

For instance, a product described as cleansing and reducing oiliness falls within the cosmetics category. However, if the wording shifts to a therapeutic approach, such as treating inflammatory acne, it risks being classified in a different category. The difference is sometimes small, but it directly affects whether the application is accepted.

Why is accurate classification crucial from the outset?

Correct classification from the beginning not only saves processing time but also avoids risks during product distribution. Incorrect classification can lead to the need for complete document revisions, changes to the declared content, or even penalties during regulatory inspections.

Conversely, accurate classification from the start ensures a smoother declaration process and allows the product to reach the market on schedule.

Conclusion

Classifying cosmetics in Vietnam isn’t an overly complex process, but it requires a proper understanding of the product’s nature. By clearly defining the boundaries between skincare and treatment, and between external use and internal effects, businesses can be more confident in preparing their documentation. For products in “sensitive” areas, thorough testing before publication is always the safest option.

If you need assistance in accurately determining whether your product is a cosmetic, Green NRJ can support you from the outset, helping you implement the right strategy and minimize risks.

📩 Contact Green NRJ for specific advice tailored to your product.