Warning: Nearly 300 Cosmetic Products Recalled Due to Updated List of Prohibited Substances

Nearly 300 cosmetic products have been recalled following an industry-wide review.

Do businesses assume that once their products have been officially approved, they remain “safe” throughout their entire lifecycle? If regulations change, will those products still be compliant? In light of widespread recalls involving cosmetics containing prohibited substances, the issue is no longer just about compliance, but about how quickly businesses can adapt to regulatory changes. 

Nearly 300 cosmetic products recalled in Vietnam have raised serious concerns among businesses following recent updates to the list of prohibited substances.

In March 2026, the Drug Administration of Vietnam (under the Ministry of Health) issued Decision No. 126/QD-QLD on the revocation of product registration numbers for cosmetic products, suspension of circulation, and recall of cosmetic products.  This development attracted significant attention as the regulatory agency reviewed products currently circulating in the market, particularly for businesses involved in importing cosmetics into Vietnam. According to this decision, 291 cosmetic products had their registration numbers revoked and were ordered to be recalled nationwide.

This is not just a routine inspection. It indicates that management is shifting to a stricter control phase, especially regarding ingredient content and cosmetic ingredient compliance in Vietnam. As safety standards are updated, products that no longer meet the requirements will be forced to cease circulation, regardless of whether they were previously registered and approved. This also requires manufacturing and distribution businesses to proactively review their product catalogs to ensure compliance with current regulations.

Updating the List of Prohibited Substances in Cosmetics According to ASEAN Standards

Cosmetics management in Southeast Asian countries is coordinated based on a common set of standards developed by the ASEAN Cosmetics Council. This set of standards clearly defines the groups of ingredients that are permitted, restricted, or prohibited in cosmetic products to ensure a consistent level of safety throughout the region. This is not an internal regulation of Vietnam, but a synchronized mechanism across the region.

According to the conclusions of the ASEAN Cosmetics Council at its 42nd meeting on November 20-21, 2025, member countries need to quickly adjust their domestic management systems to ensure consistency in controlling products circulating in the market. This mechanism helps minimize risks related to chemicals while raising safety standards for the cosmetics industry.

It’s important to note that these updates are not a “long-term adaptation” approach. As soon as an active ingredient is added to the banned list, all products containing that ingredient are no longer legally eligible for sale.

In the recent update, Cyclotetrasiloxane and Octamethylcyclotetrasiloxane were added to the list of ingredients not permitted for use in cosmetics , including products that had previously completed cosmetic product registration in Vietnam. Products that previously used these substances legally are now required to review everything, from their formulations to their cosmetic notification dossier requirements in Vietnam.

Process of Handling and Recalling Violating Products

After the new regulations were implemented, the regulatory agency reviewed the published cosmetic product data and identified products that no longer met legal requirements. The inspection revealed that 291 cosmetic products from various brands contained Cyclotetrasiloxane and Octamethylcyclotetrasiloxane.

These 291 products had their cosmetic product notification numbers revoked and were required to be recalled from the distribution system. The relevant businesses are responsible for notifying their distribution channels, recalling the products from the market, and reporting the results of the handling to the authorities as required.

The real problem lies not in the product, but in the control system.

In reality, upon review, the issue is often not whether the product contains banned substances, but rather the lack of timely re-inspection during distribution. Relying solely on the initial notification documents easily leads to a reactive situation. By the time inspections occur, the risks have already materialized. Conversely, businesses that proactively review their products periodically have more room to make adjustments sooner.

Changes in the list of banned substances in cosmetics show that the industry’s legal environment is constantly being updated to align with international safety standards. This transforms cosmetic management from a mere formality into a continuous control process.

Reviewing product formulas, cosmetic notification documents, and raw materials, if done correctly, will help businesses mitigate legal risks and adjust products promptly before regulations change.

In the context of increasingly stringent regulations, businesses need to build an internal control system that is flexible enough to adapt, rather than simply reacting when problems arise.

Green NRJ and a Systematic Compliance Approach

Looking at the practical implementation, many cosmetics businesses don’t struggle with “not knowing the law,” but rather with integrating regulations into their daily operations. Therefore, Green NRJ doesn’t stop at processing individual dossiers. A more appropriate approach is to review the entire product—from raw materials and cosmetic product formulation in Vietnam to legal document and how the product reaches the market—to identify the root cause of the problem. By following this approach, businesses can address immediate issues while gradually establishing a more stable control mechanism, allowing them to adapt when regulations change. In the current context, this is no longer an “optional” option, but something that needs to be considered from the outset.

Conclusion

The recall of cosmetics due to the presence of banned substances is no longer uncommon. With increasingly strict regulations, such cases are almost inevitable. The problem is that a product that was previously licensed is not guaranteed to be “safe” at the present time. Regulations change constantly, and without self-review, it’s easy to run into risks without being able to react in time. In reality, the difference often lies in whether businesses closely follow regulations and have good internal controls, especially for businesses navigating cosmetic compliance in Vietnam. If a product catalog review or compliance check is needed, Green NRJ can provide support to mitigate risks from the outset.