How Must Ingredients Be Listed According to Concentration Rules?
Under Circular 06/2011/TT-BYT, all ingredients contained in a cosmetic formula must be declared in descending order of concentration at the time they are added to the formulation. In practical terms, this means the ingredient with the highest percentage must appear first on the list, followed sequentially by ingredients with lower concentrations. This rule ensures transparency and allows both regulators and consumers to clearly identify the main components of the product.
However, the regulation also provides certain controlled flexibilities. Once the ingredient concentration falls below 1%, those ingredients may be listed in any order after all ingredients above 1% have been declared. This flexibility applies only to minor components and does not affect the overall descending structure of the primary formulation.
Fragrance ingredients are treated differently for practical and commercial reasons. Instead of listing every aromatic compound individually, manufacturers are permitted to group them under general terms such as “Perfume,” “Fragrance,” “Flavor,” or “Aroma.” This approach protects proprietary fragrance compositions while still complying with declaration requirements.
Similarly, colorants may be listed after all other ingredients and do not need to follow strict concentration order. They must be declared using their Colour Index (CI) numbers or the names specified in Annex IV of the ASEAN Cosmetic Directive. In the case of decorative cosmetics available in multiple shades, colorants may be grouped under a “May contain” or “+/-” statement to accommodate variations between different product colors.
When Is It Mandatory to Declare Ingredient Percentages?
Not all cosmetic ingredients require percentage disclosure. However, when an ingredient is subject to concentration limits under the Annexes of the ASEAN Cosmetic Directive, its exact percentage must be declared in accordance with regulatory requirements.
These limits typically apply to restricted substances that are permitted only within specific maximum concentrations. In such cases, the declared percentage serves as evidence that the product complies with safety thresholds established by ASEAN regulations and adopted under Circular 06/2011/TT-BYT. The disclosure may be required in the cosmetic product notification dossier and supporting technical documentation submitted to the competent authority.
In addition to substance limits, businesses must comply with Vietnamese formatting standards. Decimal values must be written using a comma (“,”) instead of a period. For example, the correct format is 0,3% rather than 0.3%. Although this may seem like a minor technical detail, it forms part of formal regulatory compliance.
Why Must Cosmetic Ingredients Be Written Using INCI Names?
Under Vietnamese cosmetic regulations, all ingredients must be declared using the International Nomenclature of Cosmetic Ingredients (INCI). This requirement is stipulated in Circular 06/2011/TT-BYT and aims to ensure international consistency, scientific accuracy, and regulatory transparency.
The INCI system provides standardized ingredient names that are recognized globally. These names are based on authoritative references such as the International Cosmetic Ingredient Dictionary, the British Pharmacopoeia, the United States Pharmacopoeia, the Chemical Abstracts Service, and the Japanese Cosmetic Ingredients Codex. By relying on these internationally accepted publications, ingredient declarations remain uniform across different markets and jurisdictions.
For plant-derived ingredients and botanical extracts, the scientific name must include the genus and species to avoid ambiguity. The genus name may be abbreviated where permitted, but the botanical identification must remain precise. Similarly, ingredients derived from animals must clearly state the exact scientific species to ensure traceability and regulatory clarity.
Ingredient names must appear in English or Latin according to INCI standards. While Vietnamese translations may be added to the label for consumer understanding, the original INCI names must not be altered or replaced. Maintaining the standardized INCI declaration ensures that the ingredient list remains legally compliant and internationally recognizable.
Which Substances Are Not Considered Cosmetic Ingredients?
Under Circular 06/2011/TT-BYT, not every substance involved in the manufacturing process is considered a cosmetic ingredient. The regulation clearly distinguishes between substances that form part of the finished cosmetic product and those that are merely incidental to production.
First, impurities that naturally occur within raw materials are not regarded as cosmetic ingredients. These trace elements are unavoidable and do not constitute intentional components of the formula.
Second, technical auxiliaries used during the manufacturing process—but not present in the final finished product—are also excluded from ingredient declaration. Since these substances do not remain in the product placed on the market, they are not subject to labeling requirements.
Finally, solvents or carriers used in strictly necessary quantities, particularly those employed to dissolve fragrance components, are not treated as independent cosmetic ingredients when their function is purely technical.
What Information Must Appear on Cosmetic Labels?
Under Vietnamese law, the cosmetic ingredient list must be clearly presented on the product label to ensure transparency and consumer access to information. The ingredient declaration may appear on the primary packaging, secondary packaging, or in accompanying documentation, provided that it is easily visible and accessible.
According to Decree 43/2017/ND-CP, the font size of mandatory labeling content must meet minimum readability requirements, with a letter height of at least 1.2 mm. This ensures that consumers can clearly read the ingredient information without difficulty.
For products circulated in Vietnam, labeling must include Vietnamese-language content as required by law. However, the cosmetic ingredient list itself must remain in its standardized INCI format. While a Vietnamese explanation may be added for consumer clarity, the original INCI names cannot be modified, translated, or reformatted in a way that changes their internationally recognized structure.
In addition to appearing on the label, the same ingredient list must be consistently declared in the cosmetic product notification dossier submitted to the Drug Administration of Vietnam in accordance with Circular 06/2011/TT-BYT. Any discrepancy between the dossier and the product label may result in requests for clarification, amendment, or regulatory review prior to market circulation.
Practical Example of How to Write Cosmetic Ingredient List
To better understand how to write cosmetic ingredient list 2026, consider a moisturizing cream formulated with water, humectants, emollients, active ingredients, preservatives, and fragrance components. When declared in accordance with INCI standards and descending concentration rules, the ingredient list would appear as follows:
Ingredients:
Water, Glycerin, Cetearyl Alcohol, Stearic Acid, Dimethicone, Niacinamide, Tocopheryl Acetate, Phenoxyethanol, Fragrance.
In this structure, Water is listed first because it represents the highest concentration in the formulation. It is followed by Glycerin, Cetearyl Alcohol, and Stearic Acid, which are present in lower but still significant amounts. Functional active ingredients such as Niacinamide and Tocopheryl Acetate appear afterward, reflecting their respective percentages in the formula. Finally, Phenoxyethanol (a preservative) and Fragrance are placed toward the end of the list, as these components are typically present at lower concentrations.
If the product is circulated in Vietnam, the label may include a Vietnamese translation to support consumer understanding:
Thành phần:
Nước, Glycerin, Cồn Cetearyl, Axit Stearic, Dimethicone, Niacinamide, Tocopheryl Acetate, Phenoxyethanol, Hương liệu.
However, it is important to emphasize that the legally recognized ingredient declaration remains the INCI version. Any Vietnamese translation is supplementary and must not replace or modify the standardized INCI names.
What Are the Risks of Incorrect Ingredient Declaration?
Incorrect cosmetic ingredient declaration can expose a business to significant regulatory and commercial risks. Errors such as omitting an ingredient, misspelling an INCI name, listing ingredients in the wrong order of concentration, or failing to disclose restricted substances in accordance with ASEAN limits are considered violations of Vietnamese cosmetic regulations.
Under Decree 117/2020/ND-CP, administrative sanctions may include monetary fines, mandatory product recall, suspension of circulation, or corrective labeling measures. The severity of the penalty depends on the nature and extent of the violation, particularly if consumer safety is affected.
In addition, inconsistencies between the ingredient list declared in the cosmetic product notification dossier and the information printed on the product label may result in regulatory review, requests for amendment, or delays in market circulation. Even minor discrepancies can trigger compliance checks, as regulatory authorities require absolute consistency between submitted documentation and actual product labeling.
For these reasons, accurate ingredient declaration is not merely a formal requirement—it is a critical compliance safeguard for both legal approval and brand credibility.
Conclusion:
Understanding how to write cosmetic ingredient list 2026 is essential for regulatory compliance, consumer transparency, and successful market circulation in Vietnam. Ingredient declaration is legally mandated under Decree 43/2017/ND-CP and Circular 06/2011/TT-BYT, and aligned with the ASEAN Cosmetic Directive.
A properly written ingredient list not only protects consumers but also safeguards your business from administrative penalties and notification rejection.
If your company requires expert consultation to review ingredient lists or prepare a compliant cosmetic product notification dossier, Green NRJ is ready to support you with professional regulatory services in 2026 and beyond.
