Learn how to legally update cosmetic product notification in Vietnam. Discover what changes require re-notification or just an update, with a step-by-step guide and legal insights.

Table of Contents

1. Introduction
2. Legal Basis for Updating Cosmetic Notification
3. Types of Changes: Re-Notification vs. Update
4. Required Documents and Procedures
5. Common Questions (FAQs)
6. Key Notes on Cosmetic Notification Updates in Vietnam
7. Why Choose Green NRJ

1. Introduction

Cosmetic products in Vietnam must be notified to the Drug Administration of Vietnam (DAV) before they are allowed to be circulated on the market. Once your product has received the official Notification Receipt from DAV, it may legally enter the market.

However, in the dynamic cosmetic industry, changes to product details are inevitable. You might update your packaging design, change your company’s address, or reformulate your product for better performance. In any of these cases, it is crucial to determine whether the change you are making requires a new product notification (re-notification) or just a supplementary update to the existing Notification Receipt.

This guide will walk you through the relevant legal regulations, help you classify the types of changes, and explain step-by-step how to handle each situation. Whether you are a foreign investor, local distributor, or brand owner, this article will help you ensure full compliance with Vietnamese cosmetic regulations.

2. Legal Basis for Updating Cosmetic Notification

The legal foundation for managing cosmetic product notifications in Vietnam lies in Circular No. 06/2011/TT-BYT, which regulates the management of cosmetic products. Under this circular, Appendix 05-MP clearly outlines two groups of changes:

• Group A: Changes that require a completely new notification. These changes are deemed significant enough that the product is no longer considered the same as originally notified.
• Group B: Changes that allow for a supplementary update. These are relatively minor modifications that do not fundamentally alter the nature of the product but still require official approval from DAV before being implemented in the market.

Understanding which category your change falls into is essential, as incorrect procedures could lead to administrative penalties, product recalls, or delays in distribution.

3. Types of Changes: Re-Notification vs. Update

To simplify this classification, we have organized the most common changes in the table below, along with the required action:

Important: No matter the type of change, DAV must issue an official approval for any update before the new version of the product can be circulated. Never distribute a product with modified details before receiving this written confirmation.

4. Required Documents and Procedures

Depending on whether your change is classified as a re-notification or a supplementary update, the documents and steps involved will differ.

A. For Supplementary Updates

These are less complex and faster to process, but they still require a formal submission:

Required Documents:

• A request letter detailing the nature of the update, signed and stamped by the legal representative of the company.
• Supporting documentation such as updated product labels, business registration certificate, or power of attorney if a third party is applying on your behalf.
• A copy of the original Notification Receipt.

Procedure:

1. Prepare all necessary documents.
2. Submit the dossier to DAV.
3. Wait for confirmation and approval in writing.

Estimated Processing Time: 5 – 7 working days from the date of valid submission. 

Note: The change shall only take effect upon written approval by the competent state authority.

B. For Re-Notification (New Notification)

This process mirrors the initial cosmetic notification process.

Required Documents:

• New notification dossier, fully updated.
• Documentation proving the change (e.g., new formula specs, updated GMP certificates).
• Online submission through DAV portal and fee payment.

Estimated Processing Time: 30 – 45 working days.

Failure to follow these procedures can result in suspension of product circulation, administrative fines (ranging from VND 5 million to 30 million), or revocation of the Notification Receipt.

5. Common Questions (FAQs)

Q1: I updated my company address but the business license remains unchanged. Do I need to submit a new notification?
A: No. You only need to submit a supplementary update with supporting documents such as the updated business license or office lease contract.

Q2: What if I redesign the label but the ingredients and claims stay the same?
A: If the new label still matches the contents of the Notification Receipt and complies with cosmetic labeling regulations, you can submit it as an update.

Q3: Can I launch my revised product before DAV’s approval?
A: Absolutely not. Doing so may result in fines, product recall, or license suspension. Always wait for written confirmation from DAV.

Q4: I want to change from a tube to a jar packaging. Do I need to re-notify?
A: If the product content remains the same and packaging was not a defining factor in the original CPN, a supplementary update is sufficient.

6. Key Notes on Cosmetic Notification Updates in Vietnam

• Classify the change correctly
• Never distribute without approval
• Use DAV’s portal for submission
• Keep clear records
• Stay updated on regulations

7. Why Choose Green NRJ

At Green NRJ, we understand that managing cosmetic notifications can be time-consuming, especially when rules seem unclear or frequently updated.

Our experienced team offers:

• A precise review of your intended changes to determine the correct procedure.
• Preparation of complete and compliant documentation.
• Direct online submission through DAV’s system.
• Ongoing communication with regulatory officers to ensure timely processing.

We work with both local and foreign clients and maintain strict confidentiality for all submissions. Whether you’re updating one detail or re-notifying multiple products, we’re here to make the process smooth and stress-free.

📞 Contact us today for a consultation and let us help you stay compliant while focusing on growing your brand in Vietnam’s fast-growing cosmetics market.

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