New Export Labeling Regulations 2026: What Businesses Need to Know

During the export process, many businesses still wonder: Do exported goods require Vietnamese labeling under export labeling regulations? If labeling is incorrect, could shipments be detained during customs clearance or pose legal risks in the market?

In particular, with numerous regulatory updates issued between 2025 and 2026, including new guidance from customs authorities, any misunderstanding or failure to fully comply with export product labeling requirements may result in customs clearance delays, administrative penalties, or even forced re-importation of goods.

So, what are the applicable regulations, and what should businesses do to ensure compliance? In this article, Green NRJ summarizes the key regulations on product labeling in Vietnam.

Language Rules for Export Product Labeling in Vietnam

One of the key points businesses must understand in export labeling is the distinction between goods for domestic consumption and those intended for export.

Pursuant to Clause 1, Article 7 of Decree No. 43/2017/ND-CP, as amended by Clause 3, Article 1 of Decree No. 111/2021/ND-CP, goods circulating in Vietnam are required to have label content in Vietnamese. However, for exported goods that are not consumed domestically, this requirement is more flexible.

Specifically, businesses are not required to label products in Vietnamese; instead, they may use the language of the importing country. This flexibility allows them to tailor labels effectively and access target markets, particularly those with stringent product requirements such as the EU, the United States, and Japan.

However, this “flexibility” does not mean that labeling can be applied freely. Product labels must still fully comply with the legal requirements of the importing country and ensure accuracy.

Label Placement: A Small Detail with a Big Impact

Label placement is also a critical requirement that must comply with applicable regulations. Businesses should take note of the following:

In terms of label placement, product labels must be affixed to the product or its packaging in a clearly visible location, ensuring that all mandatory information is fully presented without requiring disassembly. Where outer packaging cannot be opened for inspection, it must bear a label containing all required information.

In practice, many businesses overlook this requirement, placing labels in incorrect or hard-to-identify locations, which can trigger requests for correction, delay delivery schedules, and ultimately increase operational costs.

Who Is Responsible for Labeling Exported Goods?

Many businesses assume that outsourcing printing and labeling transfers legal responsibility to the service provider. However, this is a common misconception.

Pursuant to Article 9 of Decree No. 43/2017/ND-CP, as amended by Clause 4, Article 1 of Decree No. 111/2021/ND-CP, the exporting organization or individual bears ultimate legal responsibility for the content of product labels. Regardless of whether third parties are engaged for design, printing, or logistics, the exporter must ensure that all labeling information is accurate, truthful, and reflective of the product’s true nature.

Where goods intended for export are not exported or are returned and subsequently placed on the domestic market, the organization or individual responsible for placing them on the market must ensure that the goods are labeled in compliance with applicable regulations.

Product Origin Labeling: Freedom Comes with Responsibility

Businesses have the right to determine origin labeling for their goods; however, they must take full responsibility for its accuracy. Misdeclaration of origin may result in legal violations and affect eligibility for tariff preferences under agreements such as the EVFTA and the CPTPP.

In the context of increasingly stringent post-clearance inspections, businesses should prioritize rules of origin compliance and adherence to applicable international commitments.

In particular, where goods move between export, re-import, and domestic distribution, regulations on origin and labeling must be applied consistently and in parallel. For a clearer understanding of how to handle each scenario, businesses may refer to our article on import labeling regulations in 2026.

Supplementary Labels: Flexible in Use, Strict in Application

A supplementary label refers to a Vietnamese translation used to provide missing mandatory information where the original foreign-language label does not fully comply with Vietnamese regulations. The content of the supplementary label must be fully consistent with the original label and must not distort or misrepresent its meaning. It must also accurately reflect the nature and origin of the goods.

In practice, some businesses treat supplementary labels as a temporary workaround. However, this approach can create significant legal risks if the content is inaccurate or inconsistent with the original label.

Conclusion

Export product labeling is not merely a technical requirement but a critical legal obligation that directly impacts customs clearance and business reputation. Therefore, understanding and fully complying with labeling regulations from the outset will help businesses minimize risks and avoid unnecessary costs.

If your business is preparing for export and facing labeling challenges, Green NRJ is ready to provide expert consulting and tailored solutions for each market, helping ensure full compliance and minimize risks.