Goods labeling Under Decree No. 37/2026/ND-CP: What Should Businesses Know?

Goods labeling may seem like a simple step of providing information on a product, but for imported goods, it is an issue that businesses need to pay particular attention to. Even a small mistake in the labeling information can affect the process of putting goods into circulation in Vietnam. So, how should imported goods be labeled to comply with the regulations?

What Does Decree No. 37/2026/ND-CP Provide on Goods Labeling?

For imported goods, labeling is not simply about providing information to consumers. It is also part of the regulatory process for managing goods before they are placed on the Vietnamese market. Importers need to ensure that the information shown on the label is consistent with the actual goods, relevant documents, and the legal requirements applicable to each product category.

Decree No. 37/2026/ND-CP dated January 23, 2026 provides requirements on the content and manner of goods labeling, including specific requirements applicable to imported goods. One of the issues businesses commonly encounter is determining what constitutes an original label, when Vietnamese labeling must be added, and where a supplementary label should be placed.

Clearly distinguishing between the different types of labels from the outset can help businesses take a more proactive approach when preparing their goods, particularly for products that are fully manufactured and packaged overseas.

How Is the Original Label of Imported Goods Defined?

The original label of goods is the label that is first displayed on the goods or their commercial packaging. Simply put, this is the label originally placed on the product or its commercial packaging by the manufacturer or the entity responsible for the goods. For imported goods, the original label is generally affixed in the country of manufacture before the goods are shipped to Vietnam.

A supplementary label, meanwhile, contains additional information added to the goods or their commercial packaging to meet Vietnam’s labeling requirements.

These two types of labels serve different purposes. A supplementary label is not part of the product’s original label, nor does it mean that businesses are free to alter the information shown on the original label. When adding information in Vietnamese, businesses must still ensure that the information is accurate, truthful, and consistent with the actual goods. Therefore, when preparing for importation, businesses should review the original label in advance to determine what information is already available and what information needs to be added after the goods arrive in Vietnam.

What Requirements Apply to Imported Goods with Original Labels in a Foreign Language?

For goods imported into Vietnam with original labels in a foreign language, businesses need to pay attention to the physical labeling requirements at the time of customs clearance.

Imported goods bearing original labels in a foreign language must have a physical label showing the mandatory information in either the foreign language or Vietnamese when customs clearance procedures are carried out. In particular, businesses should carefully check the product name, origin, and the full name or abbreviated name and address of the overseas manufacturer or the organization or individual responsible for the goods.

These are basic pieces of information, but they are particularly important for imported goods. Businesses should compare the information shown on the label with the documents and records relating to the shipment to minimize inconsistencies between the actual product and the import documentation. In particular, businesses should not rely solely on label designs or images provided by suppliers. Before the goods are shipped to Vietnam, the actual label affixed to the product or its commercial packaging should be checked to ensure that it meets the applicable requirements.

When Must Vietnamese Labeling Be Added to Imported Goods?

One issue that can easily cause confusion is when information in Vietnamese must be displayed on imported goods.

The fact that goods bear an original label in a foreign language does not mean that the importer must ask the overseas manufacturer to replace the entire original label with a Vietnamese version. Decree No. 37/2026/ND-CP places the responsibility for adding Vietnamese labeling on the organization or individual importing the goods before the goods are placed into circulation in the Vietnamese market. Therefore, it is important to distinguish between the time of customs clearance and the time when the goods are placed into circulation.

At the time of customs clearance, imported goods bearing original labels in a foreign language must satisfy the applicable labeling requirements. After importation, the importer must add the required Vietnamese labeling before the products are placed into circulation in the Vietnamese market.

This point is particularly important for businesses importing goods that have already been packaged overseas. Businesses should proactively prepare the supplementary label content and the labeling method instead of waiting until the goods arrive in Vietnam before starting the process.

How Should Supplementary Labels Be Affixed to Imported Goods?

Once it has been determined that the goods are subject to Vietnamese supplementary labeling requirements, the location and method of affixing the supplementary label must also comply with the regulations.

The supplementary label must be affixed to the goods or their commercial packaging. At the same time, the supplementary label must not obscure any mandatory information on the original label as required by Vietnamese law.

Although this requirement may appear straightforward, issues can arise in practice if a business chooses an unsuitable location for the supplementary label. For example, if the supplementary label is too large or is placed directly over an area containing mandatory information on the original label, consumers or regulatory authorities may no longer be able to fully inspect the original product information.

Therefore, when preparing a supplementary label, businesses need to consider both its content and placement. The supplementary label must provide the necessary information while still allowing the mandatory information on the original label to remain visible and verifiable.

What Should Be Checked on a Supplementary Label Before Circulation?

Adding Vietnamese information should not be understood simply as translating the content shown on the foreign-language label.

Depending on the type of goods, the supplementary label may need to contain mandatory information under general regulations as well as applicable sector-specific requirements. Businesses should therefore accurately identify the product category before finalizing the label content.

The information on the supplementary label must also be accurate and truthful and consistent with the information on the original label and the product documentation. Any translation or additional information must not alter the nature of the product or cause consumers to misunderstand the goods.

For imported goods, information such as the product name, origin, the organization or individual responsible for the goods, and other mandatory information should be reviewed consistently. If there is any discrepancy between the label, the documentation, and the actual goods, the business should resolve the issue before placing the products on the market.

This is also why businesses should not use a single standard supplementary label for multiple products without first checking the specific labeling requirements applicable to each product.

What Should Businesses Check Before Placing Imported Goods on the Market?

Before placing products into circulation, businesses should review the entire labeling process, from the original label to the supplementary label, rather than checking only individual pieces of information.

First, the actual original label of the product should be reviewed to determine whether the product name, origin, and information about the overseas manufacturer or the organization or individual responsible for the goods have been fully provided.

Next, the information on the label should be compared against the import documentation and the actual goods. In particular, origin should be checked carefully to avoid inconsistencies between the information shown on the product and the supporting documents.

Businesses should then determine which information must be added in Vietnamese based on the nature of the product. Not all goods are subject to the same labeling requirements, so both general regulations and, where applicable, sector-specific requirements should be considered.

Finally, the actual placement of the supplementary label on the goods or commercial packaging should be checked. The supplementary label must be properly affixed and must not obscure any mandatory information on the original label.

Customs Clearance and Circulation Are Two Different Stages to Keep in Mind

One point that importers need to pay particular attention to is that labeling requirements at the time of customs clearance should not be treated as identical to the requirements applicable when goods are placed on the market.

At the customs clearance stage, imported goods are inspected based on the requirements applicable at the time customs procedures are carried out. Meanwhile, before the products are placed into circulation in Vietnam, businesses must complete the required Vietnamese information in accordance with the regulations.

This distinction has practical implications for how businesses organize their import process. A shipment may successfully complete customs clearance but still not be ready to be placed on the market if the importer has not added the required Vietnamese labeling.

For this reason, the labeling review process should be carried out throughout the entire import process, starting before importation, continuing during customs procedures, and ending only when the products are ready to be distributed on the market.

What Does Official Letter No. 20238/CHQ-GSQL Add to the Guidance on Goods Labeling?

In addition to the requirements under Decree No. 37/2026/ND-CP, businesses should also take note of Official Letter No. 20238/CHQ-GSQL dated August 12, 2026, issued by the Customs Department regarding issues related to goods labeling.

The contents of the Official Letter do not establish separate requirements to replace Decree No. 37/2026/ND-CP. Instead, it provides a reference for businesses when comparing their specific circumstances with the current requirements concerning original labels, supplementary labels, and imported goods bearing labels in foreign languages.

Where businesses still encounter difficulties in applying Decree No. 37/2026/ND-CP, the Customs Department has instructed them to submit written requests to the Ministry of Science and Technology, the agency responsible for drafting the Decree, for guidance within its authority.

Accordingly, businesses should regard Official Letter No. 20238/CHQ-GSQL as an update that helps clarify how the requirements may be applied in practice. The primary legal basis for goods labeling remains the provisions of Decree No. 37/2026/ND-CP and relevant sector-specific regulations.

Why Should Importers Review Product Labels Before the Goods Arrive in Vietnam?

For imported goods, dealing with labeling only after the goods have arrived in Vietnam can often result in additional time and costs. In many cases, even a single inaccurate piece of information or an unsuitable label placement may require the business to make adjustments before the products can be placed on the market.

A safer approach is therefore to review the product label at the preparation stage, before importation. Businesses can compare the original label with the product documentation, identify the information that needs to be added in Vietnamese, and prepare the supplementary labeling method in advance.

For product categories subject to sector-specific labeling requirements, such as food, cosmetics, medical devices, or other products subject to specific regulatory conditions, the review should be carried out even more carefully. In addition to the general requirements on goods labeling, additional sector-specific requirements may also apply.

Taking action from the outset not only helps businesses minimize risks when the goods arrive in Vietnam but also makes the process of bringing products to market more efficient.

Conclusion

Goods labeling for imported products must be properly completed, from the original label and supplementary label to the required Vietnamese information before circulation. Green NRJ supports businesses in reviewing and completing labeling requirements in accordance with applicable regulations.