How to Group Multiple Cosmetic Products Notification in Vietnam?

When Can Multiple Cosmetic Products Be Registered Under One Notification in Vietnam?

Under Vietnamese cosmetic regulations and the ASEAN Cosmetic Directive, multiple cosmetic product variants may be registered under a single notification dossier only when a set of strict regulatory conditions is fully satisfied. This grouping mechanism is intended to support cosmetic brands, particularly international manufacturers, that offer product lines with minor, non-functional variations, while maintaining rigorous standards for consumer safety, quality control, and regulatory traceability.

In practice, grouping is permitted only when all products share an identical base formulation. The core composition of the product, including all functional and active ingredients, must remain completely unchanged across every variant. Any variation between the products must be strictly limited to non-functional elements that do not affect the product’s intended cosmetic function, safety profile, or regulatory classification. Such permissible differences typically include variations in fragrance, color, or packaging volume, provided that these changes do not introduce new cosmetic claims, functional effects, or regulatory risks.

From a regulatory standpoint, products meeting these criteria are considered cosmetic variants or line extensions of the same cosmetic product rather than separate products. As a result, they may be submitted together under one cosmetic notification file, supported by a single Product Information File (PIF) and issued one notification number by the Drug Administration of Vietnam (DAV). To ensure transparency and compliance, any variable ingredients, most commonly fragrances or coloring agents, must be clearly disclosed in the formula section of the dossier, usually through the use of appropriate “may contain” statements.

In addition to having the same base formulation, all grouped products must be marketed under the same commercial name or belong to the same product line, reinforcing their identity as variations of a single cosmetic product. Furthermore, all variants must be manufactured by the same production facility and originate from the same country. If products are produced in different factories or different countries, even if under the same brand or corporate group, they are not eligible for grouping and must be notified separately.

For example, a lip balm range sharing the same moisturizing formula but offered in different flavors, such as strawberry, vanilla, and mint, may qualify for Group Multiple Cosmetic Products Notification if all variants are produced by the same manufacturer in the same country and the only difference lies in the flavoring component. Similarly, a facial cleanser available in several fragrance options may be grouped under one notification, provided the formulation and manufacturing process remain identical.

It is important to emphasize that grouping multiple products under a single notification is a conditional regulatory allowance rather than an automatic right. The Drug Administration of Vietnam carefully assesses whether the proposed grouping complies with both national regulations and the ASEAN Cosmetic Directive. Any deviation from the required conditions may result in rejection of the notification dossier, delays during customs clearance, or compliance issues identified through post-marketing inspections. For this reason, companies are strongly advised to evaluate grouping eligibility carefully and ensure full regulatory alignment before submitting their cosmetic notification.

When Is Separate Cosmetic Notification Required in Vietnam?

Although Group Multiple Cosmetic Products Notification can significantly improve regulatory efficiency, Vietnamese cosmetic regulations clearly stipulate that not all products are eligible to be registered under a single notification. In many situations, companies are legally required to submit separate cosmetic notifications to ensure accurate regulatory assessment, traceability, and post-market control.

Separate notification is mandatory whenever there is any difference in product formulation. Even a minor adjustment to the concentration of active or inactive ingredients may result in the product being classified as a distinct formula under Vietnamese law. Changes such as modifying preservatives or emulsifiers, or adding or removing functional ingredients, such as vitamin C, sunscreen agents, or whitening actives, are considered material differences that directly affect the product’s safety profile and cosmetic function. In these cases, each formulation must be notified independently.

Manufacturing location is another critical factor that triggers the requirement for separate notification. If cosmetic product variants are produced in different factories or originate from different countries, they cannot be grouped under one notification, even if the formulations appear identical or are owned by the same brand. The Drug Administration of Vietnam treats the manufacturing facility and country of origin as essential elements for quality assurance, traceability, and regulatory accountability, making separate notification compulsory.

In addition, certain cosmetic categories are subject to stricter regulatory control due to their higher risk profile. Products such as hair dyes and perfumes commonly require individual notifications for each color or fragrance variant. In the case of perfumes, each distinct fragrance composition is generally considered a separate product for notification purposes, regardless of similarities in the base formula. These categories are closely monitored because variations in colorants or fragrance components can significantly impact consumer safety.

Separate notification is also required when products differ in commercial identity or intended cosmetic use. Products marketed under different brand names, or positioned for different purposes such as a facial mist versus a skin toner, or a cleanser versus a moisturizer are treated as distinct cosmetic products under Vietnamese regulations. Even if the formulations share similarities, differences in naming, claims, or intended use invalidate eligibility for grouping.

Failure to submit the correct number of cosmetic notifications may lead to serious regulatory consequences, including rejection of the notification dossier, delays or refusal during customs clearance, and administrative penalties imposed during market surveillance or post-marketing inspections. For this reason, companies are strongly advised to conduct a thorough regulatory assessment before submission to determine whether products qualify for grouping or must be notified separately under Vietnamese cosmetic law.

Need Support with Group Multiple Cosmetic Products Notification in Vietnam?

Group Multiple Cosmetic Products Notification is a practical regulatory solution for cosmetic brands offering multiple variants with the same base formula, helping reduce registration costs and accelerate market entry in Vietnam. However, successful grouping requires strict compliance with Vietnamese cosmetic regulations and the ASEAN Cosmetic Directive to avoid rejection, delays, or post-market enforcement risks.

At Green NRJ, we specialize in supporting foreign cosmetic companies with Group Multiple Cosmetic Products Notification in Vietnam. Our team reviews product formulas, assesses grouping eligibility, prepares compliant notification dossiers, acts as your authorized local representative, and provides end-to-end guidance on labeling, import procedures, and regulatory compliance.

Contact Green NRJ today to streamline your cosmetic notification process and enter the Vietnamese market with confidence and full regulatory assurance.