Who Is Authorized to Sign the LOA for Cosmetic Product Notification? (2026)

Who is authorized to sign the Letter of Authorization (LOA) for cosmetic product notification is one of the most common questions businesses face when preparing a cosmetic product notification dossier in Vietnam. In practice, many applications contain complete information on the product, labeling, and technical documentation but are still required to be amended because the Letter of Authorization does not meet the applicable requirements.

This demonstrates that the LOA is not merely a mandatory document in the notification dossier. It also serves as the legal basis for the competent authority to verify the validity of the authorization relationship between the parties. So, how do the current regulations determine who is authorized to sign a Letter of Authorization? What should businesses understand and apply to avoid unnecessary complications during the cosmetic product notification process? Green NRJ provides a detailed analysis below.

What Is a Letter of Authorization (LOA), and Why Is It a Mandatory Document in the Cosmetic Product Notification Dossier?

For imported cosmetics, the Letter of Authorization (LOA) is one of the mandatory documents required for product notification in Vietnam. It is a written authorization issued by the party holding the rights to the product, authorizing an organization or individual in Vietnam to act on its behalf in carrying out the product notification procedure and assuming responsibility for placing the product on the Vietnamese market. Including the LOA in the dossier is not simply a procedural requirement.

It also enables the competent authority to verify that the entity named in the notification dossier has been duly authorized by the overseas party to undertake the procedures related to placing the cosmetic product on the Vietnamese market. In addition, the LOA helps clarify the responsibilities of each party throughout the product’s circulation in the market.

In practice, many notification dossiers are requested to be amended or supplemented not because the Letter of Authorization is missing, but because its content does not comply with the applicable regulations or because the information contained in the LOA is inconsistent with other documents in the dossier. Therefore, businesses should carefully review the Letter of Authorization during the dossier preparation stage to ensure that it is properly drafted and fully consistent with the remaining application documents.

One of the issues businesses are most concerned about when preparing a Letter of Authorization is determining who is legally entitled to issue and sign it. In practice, some LOAs are signed by the manufacturer, while others are signed by the product owner or the brand owner. So, what do the current regulations actually require? This issue is examined in detail below.

What Do the Regulations Say About the Entity Authorized to Sign a Letter of Authorization?

When learning about the Letter of Authorization required for cosmetic product notification, many businesses ask the same question: must the LOA be signed by the manufacturer or by the product owner?

This is one of the most common questions raised by companies carrying out notification procedures for imported cosmetics. The issue becomes particularly relevant for products manufactured under contract manufacturing arrangements or marketed under another company’s brand, where determining the appropriate signatory for the Letter of Authorization can be confusing.

According to Article 6 of Circular No. 06/2011/TT-BYT issued by the Ministry of Health, as consolidated in Consolidated Document No. 09/VBHN-BYT of 2025, the organization or individual responsible for placing the product on the market must obtain written authorization from either the manufacturer or the product owner. Accordingly, Vietnamese regulations recognize that both the manufacturer and the product owner may legally issue and sign the Letter of Authorization. The law does not restrict this authority to only one specific party.

However, the current regulations do not specify the circumstances in which the LOA must be signed by the manufacturer or when it must be signed by the product owner. This means that businesses cannot determine the appropriate signatory solely based on the name of the manufacturing facility or the entity that owns the brand.

In practice, there are cases where the manufacturer directly issues the Letter of Authorization to the Vietnamese company. In other cases, the Letter of Authorization is issued by the product owner. Both approaches may comply with the regulations, provided that the issuing party has the legal authority to grant the authorization in relation to the product concerned.

Rather than searching for a universal answer applicable to every situation, businesses should focus on identifying which scenario applies to their specific business relationship. Before requesting the issuance of a Letter of Authorization, companies should communicate with their overseas partner to determine which entity has the authority to authorize the product for notification in Vietnam. Identifying the correct party from the outset helps ensure consistency throughout the dossier and minimizes the risk of issues arising during the review process.

It is therefore clear that the question, “Should the manufacturer or the product owner sign the Letter of Authorization?” does not have a single answer applicable to every cosmetic product. Under the current legal framework, either party may sign the LOA, provided that doing so is consistent with the legal status of the issuing entity and its rights over the product in each specific case.

How Can Businesses Determine the Correct Entity to Issue the Letter of Authorization?

Since the law does not specify when the manufacturer should issue the Letter of Authorization and when the product owner should do so, businesses should proactively verify this information with their overseas partner before preparing the cosmetic product notification dossier.

During discussions with the partner, businesses should clearly confirm which entity has the legal authority to issue the Letter of Authorization for the relevant product. If the partner confirms that the manufacturer is responsible for granting the authorization, then the manufacturer should issue the LOA. Conversely, if this authority belongs to the product owner, then the product owner should be the party issuing the Letter of Authorization in accordance with the regulations.

Businesses should also ensure that all information contained in the Letter of Authorization is fully consistent with the other documents included in the notification dossier. If there are discrepancies relating to the manufacturer, the product owner, or other product information, these issues should be clarified with the overseas partner before submission to avoid requests for amendment or supplementation.

In practice, each business operates under a different manufacturing and commercial model. Some companies act as both the manufacturer and the product owner, while others perform only one of these roles. For this reason, businesses should avoid applying a one-size-fits-all interpretation and instead assess each case based on the actual legal documents and commercial arrangements associated with the product.

If there is any uncertainty regarding the appropriate entity to issue the Letter of Authorization, businesses are strongly advised to seek guidance from an experienced regulatory consulting firm before requesting the document from their overseas partner. Conducting a thorough review at the outset helps ensure a consistent dossier, reduces the likelihood of amendments during the notification process, and shortens the time required to bring the product to the Vietnamese market.

Conclusion

Determining who is authorized to sign the Letter of Authorization (LOA) for cosmetic product notification is an important step that businesses should address at the very beginning of the dossier preparation process. Correctly identifying the appropriate issuing entity and understanding the applicable legal requirements can help avoid unnecessary complications, reduce delays, and facilitate a smoother product notification process before placing cosmetics on the Vietnamese market.

If your business needs advice on Letters of Authorization or cosmetic product notification procedures in Vietnam, Green NRJ is ready to support you by preparing a compliant dossier tailored to the applicable legal requirements.