How to Group Multiple Cosmetic Products Notification in Vietnam?

Group Multiple Cosmetic Products Notification in Vietnam is an essential procedure for businesses wishing to legally import and sell several cosmetic products under a single notification dossier in Vietnam. This requirement is governed by Circular No. 06/2011/TT-BYT and its amending circulars (most recently updated by Circular 34/2025/TT-BYT), issued by the Ministry of Health of Vietnam, in line with the ASEAN Cosmetic Directive.

The purpose of this process is to ensure that all cosmetic products placed on the Vietnamese market are safe for consumers and compliant with both local and regional regulatory standards.

According to the regulations, each cosmetic product must be properly notified through the Vietnam Drug Administration (DAV) online portal, which is the official electronic system for cosmetic product registration in Vietnam. Foreign manufacturers who wish to sell their cosmetics in Vietnam are required to either establish a legal entity in the country or appoint an authorized local representative (also known as a cosmetic notification holder) to submit the registration dossier on their behalf.

The notification dossier must include key documents such as:

• Product Information File (PIF)

• Detailed formula breakdown

• Letter of Authorization (LOA)

• Certificate of Free Sale (CFS) or equivalent

Once approved, the cosmetic product receives a Notification Number, which serves as a license for its importation, distribution, and sale in Vietnam.

When Can You Register Multiple Products in One Notification?

Vietnamese cosmetic regulations allow companies to group multiple cosmetic variants into a single notification, but only under specific conditions. This is particularly beneficial for international cosmetic brands that offer product lines with minor variations.

You can register several cosmetic products under one notification if and only if they share the same base formulation, and differ only in non-functional characteristics, such as:

• Color (e.g., lipsticks with different shades)
• Fragrance (e.g., body lotions with lavender vs. rose scent)
• Packaging size (e.g., 50ml vs. 100ml bottles)

These products are considered product variants or line extensions of the same cosmetic item, and thus may be submitted together in one cosmetic notification file.

Example: If you are importing a facial cleanser that comes in three scents, green tea, aloe vera, and lemon, but all three have the same formula aside from the fragrance, they may be grouped under a single notification.

However, grouping is only allowed when specific regulatory conditions are met (explained in the next section). Failure to follow these rules may result in the rejection of your notification application or legal issues during customs clearance.

Conditions for Grouping:

According to Vietnam’s cosmetic regulations and the ASEAN Cosmetic Directive, companies are allowed to group multiple cosmetic products into one notification file, provided that they meet certain strict criteria. This approach is often used by cosmetic brands with multiple variants of the same product, as it helps reduce cost and processing time during the notification process.

To qualify for grouping under a single notification, the following conditions must be met:

1. Identical Base Formula:
   All product variants must have the same core formulation. Only minor differences are allowed, such as changes in:

   • Fragrance (e.g., floral, citrus, herbal)

   • Coloring agents (e.g., pigment for lipsticks or eyeshadows)

   • Packaging volume or size
     No changes are permitted in active ingredients or base composition.

2. Same Commercial Name or Product Line:
   The grouped products must be sold under one brand name or belong to the same product line. For example, “SoFresh Lip Balm” available in different flavors still falls under one commercial identity.

3. Same Manufacturer and Country of Origin:
   All variants must be manufactured by the same production facility located in the same country. If products are made in different countries, even if by the same company separate notifications are required.

4. Clear Listing of Variants in Notification Form:
   The product variants must be declared in the notification dossier using appropriate language. Ingredients that may vary—such as fragrance or coloring, should be indicated using the phrase “may contain” in the product formula section. This ensures transparency and regulatory compliance.

Example: A lip balm line with the same moisturizing formula but offered in strawberry, vanilla, and mint scents can be grouped under one notification provided all are produced by the same manufacturer in, say, South Korea, and only the fragrance differs.

When Is Separate Notification Required?

While grouping cosmetic products can be efficient, not all products are eligible to be registered under a single notification. In the following scenarios, separate cosmetic notifications are mandatory under Vietnamese law:

1. Different Product Formulas: Even a small change in the concentration of active or inactive ingredients will result in the product being classified as a distinct formula. Examples include:

   • Change in preservatives or emulsifiers

   • Adding or removing a functional ingredient (e.g., vitamin C, SPF)

2. Different Manufacturing Facilities or Countries: If product variants are produced in different factories or different countries, each must be notified separately. Authorities consider manufacturing location as a factor affecting product quality and traceability.

3. High-Risk Product Categories: Specific cosmetic categories often require separate notifications due to the nature of their ingredients:

   • Hair dyes (especially with varying colorants)

   • Perfumes (with different scent compositions) must be notified per fragrance or color variant, regardless of whether the base formula is the same.

4. Different Commercial Names or Intended Uses: If the products have different brand names or are marketed for different cosmetic purposes, they require individual notification. For example:

   • “Aqua Face Mist” vs. “Aqua Skin Toner”

   • One product for cleansing, another for moisturizing

Failing to file the appropriate number of notifications can lead to regulatory rejection, import delays, or fines from Vietnamese authorities during customs clearance or market surveillance.

Legal Reference

The practice of grouping multiple cosmetic product variants under one notification in Vietnam is clearly supported by the country’s regulatory framework and official interpretations. Businesses seeking to register cosmetics in Vietnam must understand the legal documents that govern this process to ensure full compliance and avoid potential rejections.

The key legal references include:

• Circular No. 06/2011/TT-BYT and its amendments (including Circular 34/2025/TT-BYT) issued by the Ministry of Health of Vietnam, which outlines the procedures for cosmetic product notification and conditions for product safety and labeling.
• The ASEAN Cosmetic Directive (ACD), a regional agreement harmonizing cosmetic regulations across ASEAN member states, including Vietnam. The ACD provides guidance on how product variants (e.g., different colors or scents) may be grouped.
• Official interpretations and guidelines from the Drug Administration of Vietnam (DAV), the competent authority that reviews and approves all cosmetic product notifications in the country.

In practice, the DAV may request additional supporting documents to verify the eligibility of products for grouping under a single notification. These documents may include: detailed product formulation tables, ingredient breakdowns highlighting variable components, technical specifications or testing results and label artwork samples showing commercial names and packaging sizes

Ensuring your documentation aligns with the above regulations increases your chances of successful approval and faster market access in Vietnam.

Benefits of Grouping Products in One Notification

The consolidation of multiple cosmetic product variants into a single notification dossier in Vietnam provides significant regulatory and operational benefits for foreign cosmetic companies. This approach is particularly applicable when the products share an identical base formulation and differ only in non-functional characteristics such as fragrance, color, or packaging size.

By submitting a unified notification rather than multiple separate dossiers, the responsible entity can substantially reduce administrative workload, minimize registration fees, and avoid repetitive documentation, thereby enhancing the overall efficiency of the regulatory process. In addition, the use of a single dossier facilitates compliance with labeling and documentation requirements, as grouped products typically share one commercial identity and one set of core technical materials, with permissible variations appropriately disclosed through “may contain” declarations.

Grouping also expedites regulatory clearance, supporting faster market entry and improved responsiveness to commercial timelines. Moreover, reducing the number of dossiers minimizes the risk of inconsistencies or discrepancies that could lead to clarification requests, delays in approval, or formal rejection by the Drug Administration of Vietnam (DAV).

It is important to note, however, that grouping is only permitted when all regulatory conditions are strictly met. Non-compliant grouping may result in dossier refusal, disruption of import procedures, or enforcement measures during post-marketing surveillance. Accordingly, organizations are strongly encouraged to seek advice from qualified cosmetic regulatory professionals to ensure full compliance with Vietnam’s legal requirements and the ASEAN Cosmetic Directive.

Need Help? Let Green NRJ Guide You

At Green NRJ, we support foreign cosmetic brands in completing product registration and notification in Vietnam, ensuring all dossiers meet regulatory requirements and enabling a smoother market entry. We review product formulas, prepare compliant documentation, advise on grouping eligibility, act as your authorized local representative, and provide guidance on labeling and import procedures.

Contact Green NRJ today to streamline your cosmetic notification process with confidence.

Summary

Cosmetic products with the same base formula but different colors or fragrances can often be grouped under a single notification in Vietnam if they meet specific conditions. Understanding these rules can help your business save resources and expand faster in a competitive beauty market.

Related Articles: