How to Determine if Your Product is a Cosmetic in Vietnam (2025 Guide)

Vietnam’s cosmetic market is rapidly growing, driven by increasing beauty awareness and demand for skincare, makeup, and personal care products. However, not all beauty-related products are cosmetics under Vietnamese law. Understanding the classification criteria ensures compliance, avoids penalties, and speeds up the approval process. This guide explains how to determine if your product is a cosmetic, outlines the step-by-step evaluation process, lists recognized categories, and highlights excluded items.

Definition of Cosmetics in Vietnam

According to Circular No. 06/2011/TT-BYT (Vietnam Ministry of Health), a cosmetic product is:

“Any substance or preparation intended to be placed in contact with the external parts of the human body (epidermis, hair system, nails, lips, and external genital organs) or with the teeth and the mucous membranes of the oral cavity, with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition, or correcting body odours.”

This definition aligns with the ASEAN Cosmetic Directive.
Key points to note:

• The product must be applied to the external parts of the body.

• The primary purpose is cosmetic (appearance, hygiene, protection) — not therapeutic or medicinal.

• Claims must not suggest medical treatment or disease prevention.

Recognized Cosmetic Categories in Vietnam

According to the ASEAN Cosmetic Directive, cosmetics are grouped into 21 categories, including:

1. Hair care products (shampoos, conditioners)

2. Hair styling products (gels, sprays)

3. Hair dyes and bleaches

4. Hair waving/straightening products

5. Skin care products (creams, lotions)

6. Face masks

7. Makeup removers

8. Skin lightening products

9. Anti-wrinkle products

10. Body care products

11. Deodorants and antiperspirants

12. Bath and shower preparations

13. Oral and dental care products

14. Shaving products

15. Makeup products (foundation, powders)

16. Eye makeup (eyeshadow, eyeliner, mascara)

17. Lip products (lipstick, gloss)

18. Nail care and polish products

19. Sun protection products

20. Self-tanning products

21. Skin whitening and brightening products

Steps to Determine if Your Product is a Cosmetic in Vietnam

Step 1 – Check Intended Use

• Review the product’s main purpose: Is it for cleaning, beautifying, altering appearance, or protecting body surfaces without changing body functions?

• If the product claims to prevent, treat, or cure a medical condition, it is not a cosmetic.

Step 2 – Identify Body Application Area

• Confirm that the product is used on external body parts, including skin, hair, nails, lips, and oral cavity.

• Products for internal use (such as dietary supplements) are excluded from the cosmetic category.

Step 3 – Verify Product Form and Composition

• Check the physical form: cream, lotion, gel, spray, powder, liquid, etc.

• Review ingredient lists: All ingredients must comply with the ASEAN Cosmetic Ingredient Listings (prohibited substances, restricted substances, allowed colorants, preservatives, UV filters).

Step 4 – Match with Recognized Cosmetic Categories

• Compare your product with the 21 ASEAN cosmetic categories above.

• If it falls clearly within one or more categories, it is likely a cosmetic.

Step 5 – Review Product Claims

• Advertising claims should be consistent with cosmetic functions.

• Avoid medical or therapeutic claims (e.g., “cures eczema”, “treats fungal infection”) which may reclassify the product.

Step 6 – Seek Expert Verification (if uncertain)

• For borderline products (e.g., medicated toothpaste, anti-dandruff shampoo, skin-lightening cream), seek confirmation from the Ministry of Health or a qualified regulatory consultant before proceeding with cosmetic notification.

Why Correct Classification Matters

Correct classification ensures:

• Regulatory compliance with the Ministry of Health’s cosmetic notification procedures.

• Avoiding penalties for mislabeling or misclassification.

• Faster market entry by preventing unnecessary delays due to incorrect product category registration.

Conclusion

Determining whether your product qualifies as a cosmetic in Vietnam is the first critical step before market entry.
By following the official definition, checking the application area, matching it with the 21 recognized ASEAN cosmetic categories, and reviewing product claims, you can avoid costly misclassifications.
If in doubt, professional advice from a regulatory expert like Green NRJ can help you achieve a smooth and compliant product launch.

Need expert support for cosmetic classification and registration in Vietnam?
📩 Contact Green NRJ today for a fast and compliant solution.