How to Update Cosmetic Product Notification in Vietnam: An Easy 2026 Guide

Update Cosmetic Product Notification in Vietnam is not something businesses can afford to overlook when there are any changes to a product that has already been issued a receipt number. Under current regulations, cosmetic products are only allowed to be placed on the market after completing the notification procedure with the Drug Administration of Vietnam.

In practice, however, changes are quite common during business operations. You may need to adjust certain product details from time to time. The key question is whether those changes require a new notification or can simply be handled through an amendment to the existing dossier. Getting this wrong can easily expose a business to legal risks.

Why should businesses pay attention to updating cosmetic product notifications?

In practice, many businesses tend to focus mainly on sales and overlook the fact that all product-related information has already been officially recorded in the original Product Notification Form. Once any changes occur, if they are not updated in time, the product circulating on the market will no longer match the registered dossier.

It is also quite common for companies to make internal updates without completing the required procedures with the regulatory authority. This is a typical mistake. If inspected, a business may face administrative fines ranging from VND 5 million to 30 million. In more serious cases, products may be subject to recall or suspension from circulation. Beyond financial penalties, such violations can also damage brand reputation, especially for businesses that are in the process of expanding their market.

Legal basis to understand before proceeding

The regulations on cosmetic product notification in Vietnam are set out in Circular No. 06/2011/TT-BYT. This is the primary legal document that businesses should refer to when handling related procedures.

In particular, Appendix 05-MP is important as it specifies different types of changes. The key point is that the law divides these changes into two main approaches: either a new cosmetic product notification is required, or the business can proceed with an amendment or supplementation to the existing notification.

While this may sound straightforward, in practice, each case needs to be carefully reviewed to ensure the correct approach is applied.

Understanding the two approaches: new notification vs. amendment

One of the most common questions businesses ask is: “Which category does my change fall into?”

In simple terms, if a change affects the nature of the product, it will almost certainly require a new notification. On the other hand, if the change is merely an update of information and does not impact the product itself, it can usually be handled through an amendment or supplementation to the existing notification.

The tricky part lies in how “the nature of the product” is interpreted. This is exactly where many businesses tend to get confused.

Changes that require a new cosmetic product notification

Some changes are considered fundamental, meaning that once they are made, the original notification dossier is no longer valid and must be re-submitted.

For example, changing the product name or brand name directly affects how the product is identified on the market. Similarly, a change in product form—such as from a cream to a gel—can alter how consumers use and perceive the product.

Changes related to product claims or formulation are even more critical, as they directly impact the product’s safety and effectiveness. In addition, switching the manufacturing site or the entity responsible for placing the product on the market also falls into this category.

In all of these cases, businesses are required to submit a new cosmetic product notification and obtain a new receipt number before continuing distribution.

Changes that can be handled through amendment or supplementation

Not every change requires starting from scratch. Some updates are more administrative in nature, such as changing the company’s address without altering its legal entity, or updating the legal representative. These do not affect the nature of the product and can be handled through an amendment or supplementation procedure. The same applies to updates in importer information or adjustments to packaging design, provided that the content remains consistent with the originally notified dossier. That said, an important point to keep in mind is that even for amendments, businesses must still submit the required documents and wait for approval from the competent authority before applying the changes.

How does the amendment procedure work?

In general, the amendment process is relatively straightforward, but it still needs to be done properly from the beginning. Businesses are required to prepare a written request clearly describing the proposed changes. This should be supported by relevant documents, such as updated product labels or an amended business registration certificate. A copy of the previously issued Product Notification Receipt must also be included. Once completed, the dossier is submitted to the Drug Administration of Vietnam for review. If everything is in order, the processing time typically takes around 30 to 40 working days.

What should be noted when submitting a new notification?

When a new notification is required, the process is essentially the same as registering a product for the first time, so careful preparation is essential. All documents must be submitted through the official online system in accordance with current regulations. The review process usually takes between 45 and 60 working days. Given this timeline, businesses are advised to plan ahead to avoid disruptions to their market activities.

When should businesses seek professional support?

For companies familiar with the process, handling the procedure internally can be manageable. However, when dealing with more complex or unclear changes, having professional support can significantly reduce risks. Green NRJ assists businesses in reviewing proposed changes, determining the appropriate approach, and preparing compliant dossiers. We also represent clients in working with the regulatory authorities to help ensure a smooth and timely process.

Conclusion

Update cosmetic product notification in Vietnam is not something businesses can afford to overlook when product-related changes occur. Misclassifying a change can lead to unnecessary delays, additional costs, or even legal exposure. If you are unsure about your specific case, it is always better to verify before taking action. Green NRJ is ready to support you with practical advice and end-to-end assistance, helping you stay compliant and confidently bring your products to market.