Cosmetic labeling requirements in Vietnam are not just about attractive design—they play a critical role in ensuring product safety, consumer protection, and regulatory compliance. For both imported and domestically produced cosmetics, proper labeling is a legal requirement strictly enforced by Vietnamese authorities.
Each cosmetic product must display essential information that allows consumers to:
Identify the product and its intended use
Understand directions for safe and effective usage
Know the manufacturer or distributor responsible
Verify compliance with Vietnam’s cosmetic regulations
Labels may include text, images, symbols, or a combination of these. Regardless of format, all elements must conform to Vietnamese cosmetic labeling standards.
2. Main and Secondary Labels Explained
The Core Legal Framework & The Role of Label
To legally sell cosmetics in Vietnam, you must understand two levels of regulations that work together.
The Main Legal Documents:
Decree 43/2017/NĐ-CP on Goods Labeling, as amended by Decree 111/2021/NĐ-CP: This is the foundational, high-level regulation for all goods sold in Vietnam. Its most important rule is that mandatory information on labels must be in the Vietnamese language.
Circular 06/2011/TT-BYT on Cosmetic Management: This is the specialized regulation for the cosmetics industry. It details exactly what specific information (e.g., ingredients, expiry date) must be included on a cosmetic label.
Important Note: Legally, there are also Circular 32/2019/TT-BYT and Circular 29/2020/TT-BYT. These documents amend and supplement Circular 06/2011/TT-BYT. However, these amendments primarily relate to product notification procedures and the Product Information File (PIF); they do not change the list of mandatory content required on the product label for consumers. Therefore, for the purpose of label design, Circular 06 remains the primary guidance document.
Main (Original) Label in Cosmetic Labeling
The main label, also known as the original cosmetic label, is typically printed directly by the manufacturer and affixed to the product’s packaging. This label serves as the primary source of core product information, including branding, product identity, and usage details.
For imported cosmetics, the main label is often written in a foreign language—commonly English, Korean, or Japanese. While this label may comply with the exporting country’s standards, it may not fully meet Vietnamese cosmetic labeling requirements, especially regarding language and mandatory disclosures. In such cases, an additional Vietnamese secondary label is mandatory to ensure legal compliance before the product can be distributed or sold in Vietnam.
Secondary (Vietnamese) Label: Mandatory for Legal Compliance in Vietnam
The secondary label, also known as the Vietnamese cosmetic label, is required for all imported cosmetic products if the original (main) label does not fully comply with Vietnam’s cosmetic labeling regulations. A secondary label (nhãn phụ) is legally required for all imported cosmetic products…This secondary label must:
Be written entirely in Vietnamese.
Contain all the mandatory information specified in Circular 06/2011/TT-BYT.
Be securely attached…
3. Packaging Types and Their Roles
Understanding the different cosmetic packaging types is essential for businesses importing or manufacturing cosmetic products in Vietnam. Each type of packaging plays a unique role and is subject to specific labeling regulations under Vietnamese law.
Primary Packaging (Direct Contact Packaging)
The primary packaging is the innermost container that directly holds the cosmetic product. Examples include:
A plastic tube for facial cleanser
A glass jar for moisturizing cream
A pump bottle for body lotion
This type of packaging:
Must be made of materials that are safe and compatible with the cosmetic product
May carry essential labeling, especially for small items sold without outer packaging
Is often branded and designed for consumer interaction
Outer Packaging (Retail or Transport Packaging)
The outer packaging refers to the external container that encloses one or more units of primary-packaged cosmetics. Common examples include:
A printed cardboard box
A shrink-wrapped bundle
A retail display carton
This packaging:
Plays a crucial role in storage, transportation, and shelf presentation
Must include all mandatory labeling information if it is the only packaging visible to consumers at the point of sale
Becomes the primary source of product information when the product cannot be opened in-store
4. Proper Label Placement
According to Vietnamese cosmetic labeling regulations, labels must be:
Clearly visible and easily readable at the point of purchase
Affixed securely to either the primary or outer packaging
Displayed without requiring the consumer to open or remove any part of the product
If only the outer packaging is presented at the time of sale (as is common in retail), then the outer label must include all necessary product information.
Failure to place the label correctly can lead to regulatory violations, product recalls, or delays in customs clearance during cosmetic importation into Vietnam.
5. Label Design: Size, Color, and Readability
Designing a cosmetic label that meets Vietnamese regulatory standards involves careful consideration of size, color, font, and overall readability. Although Vietnamese laws do not specify exact label dimensions, manufacturers and importers must adhere to key principles to ensure legal compliance and consumer safety.
Font Size and Contrast for Maximum Readability
Text size must be large enough to be easily read by consumers without straining the eyes. While no fixed minimum font size is mandated, font should be clear and legible on all packaging types.
High contrast between text and background colors is essential. For example, dark text on a light background or vice versa ensures better visibility and reduces reading errors.
Avoid overly decorative fonts that may hinder quick comprehension of important information.
Label Durability and Legibility Throughout Product Use
Labels must be made from durable materials that resist smudging, fading, or peeling during typical storage and usage conditions (e.g., exposure to moisture or oils).
Information on the label should remain clearly legible from the point of purchase until the product is completely used.
Durable printing techniques (such as embossing, waterproof inks, or laminated labels) are recommended for long-lasting clarity.
Accuracy and Truthfulness of Label Claims
All claims on the cosmetic label—including product benefits, ingredient functions, and certifications—must be truthful, accurate, and scientifically verifiable.
Misleading or exaggerated claims that deceive consumers are strictly prohibited under Vietnam’s cosmetic regulations.
Labels must comply with the content guidelines specified in relevant legal documents like Circular 06/2011/TT-BYT
Prohibition of Misleading or Deceptive Information
Any label content that could create false impressions about the product’s effectiveness, safety, or origin is banned.
This includes exaggerated claims such as “miracle cure,” “100% natural,” or unsubstantiated “anti-aging” promises without scientific backing.
Proper verification and documentation must be kept by manufacturers and importers to support all label statements in case of regulatory audits.
6. Essential Information Every Label Must Include
To ensure full legal compliance with Vietnamese cosmetic labeling regulations, every cosmetic product label must clearly display the following mandatory information. This guarantees transparency for consumers and facilitates regulatory inspections and product tracking.
Mandatory Cosmetic Label Information
Detailed Description
Product Name and Function
The label must clearly display the exact name of the cosmetic product along with its intended function or purpose, such as “facial moisturizer” or “shampoo.” This helps consumers easily identify what the product is and how it should be used.
Instructions for Use
Clear and concise instructions on how to properly use the product must be provided. This ensures that consumers understand the correct method of application to maximize effectiveness and safety. For products with obvious use, like soap bars, this section may be brief or omitted.
Full Ingredient List (INCI)
All ingredients must be listed using the International Nomenclature of Cosmetic Ingredients (INCI) or other internationally recognized names. Ingredients should be ordered by their concentration, starting with the highest. This transparency allows consumers to check for allergens or substances they wish to avoid.
Country of Origin
The label must state the country where the cosmetic was manufactured, for example, “Made in France” or “Manufactured in Vietnam.” This information helps with regulatory compliance and provides consumers with transparency about the product’s origin.
Distributor/Importer Information
The full name and address of the organization or individual responsible for bringing the product to the Vietnamese market. This is crucial for accountability, allowing authorities or consumers to contact the responsible entity if necessary.
Net Quantity (Weight or Volume)
The exact net amount of the cosmetic product must be clearly indicated on the label, usually in metric units such as grams (g) or milliliters (ml). The inclusion of imperial units (such as ounces) is optional. This information helps consumers compare product sizes and values.
Batch Number (Lot Code)
Each product must have a unique batch number or lot code to identify the specific production run. This is critical for quality control, product recalls, and tracking in case of any safety issues.
Manufacture Date and Expiry Date
The date of manufacture and the expiration or “best before” date must be clearly printed on the label, often in the format DD/MM/YYYY. This helps consumers avoid using products that are past their safe or effective period. Some products may alternatively show a “period after opening” (PAO) symbol.
Safety Warnings and Precautions
Any necessary safety information should be included, such as “For external use only,” “Avoid contact with eyes,” or allergy warnings. These precautions protect consumers and reduce risks associated with improper product use.
Manufacturer’s Name and Address
The full name and physical address of the manufacturing company or factory must be provided. This establishes the source of the product and allows for accountability in case of regulatory review or quality issues.
7. Language Requirements for Labels
As mandated by Decree 43/2017/NĐ-CP (amended by Decree 111/2021/NĐ-CP), all mandatory information on cosmetic product labels must be clearly presented in the Vietnamese language to ensure full legal compliance and consumer understanding. This language requirement applies regardless of whether the original product label is in Vietnamese or another language.
Importers and distributors must prepare and print compliant Vietnamese secondary labels and ensure they are properly attached before marketing the product.
8. Final Thoughts
Labeling is not just a legal requirement—it is the gateway to consumer trust and brand longevity. Whether you are a domestic brand or an international exporter, complying with Vietnam’s core labeling laws: Decree 43/2017/NĐ-CP (as amended by Decree 111/2021/NĐ-CP) and the detailed guidelines in Circular 06/2011/TT-BYT is mandatory for operating in the Vietnamese cosmetic market.
