
Imported goods labeling is an essential compliance requirement for businesses bringing products into the Vietnamese market. Even a small detail on a product label, such as the use of the ® symbol, may lead to customs-related issues if the applicable regulations are not fully understood. This article explains the latest guidance issued by Vietnam Customs and highlights the key considerations businesses should keep in mind to reduce compliance risks and ensure a smoother import process.
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ToggleFor many businesses, imported goods labeling is more than simply translating product information into Vietnamese. It also involves ensuring that every element displayed on the product label complies with Vietnamese regulations before the goods are released to the market. One of the issues that frequently raises compliance concerns is the use of the ® symbol on imported products, particularly when the trademark has been registered overseas but has not yet obtained trademark protection in Vietnam.
This situation is common across a wide range of imported products, including cosmetics, food products, medical devices, household goods, and other consumer products. While the ® symbol generally indicates that a trademark has been legally registered in another country or jurisdiction, that protection does not automatically extend to Vietnam. As a result, businesses importing products into Vietnam should not assume that the trademark enjoys the same legal status in the Vietnamese market.
To provide a consistent approach for handling these cases, Vietnam Customs issued Official Letter No. 19365/CHQ-GSQL dated July 24, 2026, offering guidance on the use of the ® symbol on imported goods and explaining how the trademark’s protection status should be determined in Vietnam. The guidance also clarifies the labeling requirements for imported goods when a trademark displayed with the ® symbol has not yet been protected in Vietnam.
Understanding these requirements is essential for businesses seeking customs clearance for imported goods without unnecessary delays. By verifying the trademark’s legal status in advance and ensuring that product labels comply with Vietnam import labeling regulations, businesses can reduce compliance risks, avoid misunderstandings during customs procedures, and prepare the appropriate documentation before their products are placed on the Vietnamese market.
One of the key points clarified in Official Letter No. 19365/CHQ-GSQL concerns imported products that display the ® symbol even though the trademark has not yet been protected in Vietnam.
Many businesses assume that the ® symbol must be removed or covered before customs clearance can be completed. According to the latest guidance from Vietnam Customs, however, this is not a mandatory requirement. Instead, businesses are required to complete two important steps.
First, they must attach a supplementary label that truthfully reflects the trademark’s protection status in Vietnam. In other words, the supplementary label should clearly indicate that the trademark has not yet been protected in Vietnam, preventing consumers and regulatory authorities from mistakenly assuming that the ® symbol means the trademark is already registered and protected within the country.
Second, the customs declarant must submit a written commitment to Vietnam Customs confirming that the supplementary label will be affixed before the products are circulated in the Vietnamese market.
Once these requirements have been fulfilled and the shipment is free from any other regulatory violations, Vietnam Customs may proceed with customs clearance in accordance with applicable regulations.
Simply put, the new guidance does not prohibit businesses from importing products bearing the ® symbol. Instead, it requires businesses to provide accurate information regarding the trademark’s protection status in Vietnam so that consumers and authorities are not misled and the labeling remains compliant with Vietnamese regulations.
In addition to clarifying the use of the ® symbol, Official Letter No. 19365/CHQ-GSQL also emphasizes that businesses are responsible for ensuring their imported goods labeling complies with Vietnamese regulations before products are placed on the market.
Under the current requirements, imported goods must be accompanied by the applicable product standard declaration and bear labels that comply with Vietnam’s labeling regulations before they can be legally distributed.
Label information may be presented in different formats, including physical labels, electronic labels, or digital product passports. Depending on the applicable regulations, labels must also include information relating to barcodes, product identification, and traceability.
Businesses should pay particular attention to supplementary labels, which play an important role when the original label does not fully satisfy Vietnam’s mandatory labeling requirements.
A supplementary label must accurately translate the information shown on the original label and include any mandatory information required under Vietnamese law that is missing from the original packaging. However, the supplementary label must not alter, distort, or create a different meaning from the original label.
By preparing compliant labels before customs clearance and market distribution, businesses can significantly reduce the risk of additional documentation requests, labeling corrections, or administrative issues during the import process.
For trademarks registered internationally under the Madrid Agreement or the Madrid Protocol, businesses should verify whether trademark protection has been granted in Vietnam before relying on the ® symbol on imported products.
According to Vietnam Customs, the trademark’s protection status in Vietnam should be determined based on one of the following official sources.
The first is the Trademark Registration Certificate or other protection documents issued by the Intellectual Property Office of Vietnam (IP Viet Nam).
The second is the official online trademark database maintained by IP Viet Nam, which allows businesses to search and verify the current protection status of a trademark.
Checking these official sources before importing products enables businesses to determine whether a trademark has been protected in Vietnam and helps them choose the appropriate labeling approach, thereby minimizing unnecessary delays during customs clearance.
In practice, many businesses only discover that a trademark has not yet been protected in Vietnam after their shipment has already arrived at the port or while customs procedures are underway. This often results in additional documentation, supplementary labeling requirements, longer customs processing times, and increased compliance costs.
To avoid these situations, businesses are advised to verify the trademark’s protection status with the Intellectual Property Office of Vietnam before signing an import contract or arranging international shipment.
If the original product label displays the ® symbol but the trademark has not yet been protected in Vietnam, the business should prepare a written commitment to Vietnam Customs confirming that a supplementary label will be added before the products are released to the Vietnamese market. The supplementary label should truthfully indicate the trademark’s protection status in Vietnam in accordance with the Customs guidance.
Preparing the required documents in advance and ensuring labeling compliance from the beginning will help businesses shorten customs processing time, reduce legal risks, and facilitate a smoother import process.
It is also important to note that imported goods labeling is only one aspect of import compliance. Depending on the type of product, businesses may also be required to complete additional regulatory procedures. For example, cosmetics must generally undergo product notification before being marketed in Vietnam, food products may require self-declaration or product registration depending on the applicable regulations, while medical devices are subject to separate classification, declaration, or licensing requirements. Understanding both labeling obligations and sector-specific regulations will help businesses avoid unnecessary delays and maintain full compliance throughout the import process.
Vietnam’s regulations on imported goods labeling and intellectual property continue to evolve to meet changing regulatory and market requirements. Businesses should therefore review product labels regularly and ensure that all mandatory information is complete and accurate before products enter the Vietnamese market.
With extensive experience in import compliance and regulatory consulting, Green NRJ assists businesses in reviewing import documentation, advising on labeling requirements, preparing supplementary labels, and resolving issues that may arise during customs procedures.
Whether your business imports cosmetics, food products, medical devices, or other regulated goods, our team provides practical guidance to help ensure compliance while minimizing unnecessary delays and operational risks.
Imported goods labeling is an essential part of regulatory compliance for businesses importing products into Vietnam. Understanding the latest Customs guidance on the use of the ® symbol, supplementary labeling requirements, and trademark protection status can help businesses reduce legal risks, avoid customs delays, and ensure products are legally placed on the market.
If your business needs professional support with imported goods labeling, supplementary labels, customs procedures, or other import compliance matters, Green NRJ is ready to provide reliable guidance tailored to your business needs.