Regulations on Cosmetic Product Formula in Vietnam (2025 Guide)

Introduction

Vietnam cosmetic product formula regulations are a critical requirement for any company planning to import, distribute, or manufacture cosmetics in Vietnam. Are you certain your ingredient list complies with Circular 06 and ASEAN standards? Do you know how INCI naming, ingredient percentages, and restricted substances affect your cosmetic notification dossier?

In 2025, regulatory authorities apply strict scrutiny to every cosmetic product formula submitted to the Drug Administration of Vietnam. This article explains the legal basis, mandatory content, compliance principles, and common mistakes to help your cosmetic notification process proceed smoothly and lawfully.

What Is a Cosmetic Product Formula Under Vietnamese Law?

A cosmetic product formula is the complete and official declaration of all ingredients contained in a cosmetic product at the time of formulation. It forms an essential part of the cosmetic notification dossier submitted to the Drug Administration of Vietnam.

Unlike marketing ingredient highlights displayed on packaging, the formula submitted for notification must reflect the full composition, including active ingredients, excipients, preservatives, colorants, and fragrance components.

This requirement is grounded in the ASEAN Cosmetic Directive, which harmonizes cosmetic safety standards across ASEAN member states. Vietnam adopts and enforces these standards through Circular 06/2011/TT-BYT and its amendments, including Circular 32/2019/TT-BYT.

Submitting an accurate cosmetic product formula is therefore not optional—it is a mandatory legal condition for market entry.

Legal Framework Governing Vietnam Cosmetic Product Formula Compliance

To ensure your Vietnam cosmetic product formula compliance, it is necessary to understand how national and regional regulations interact.

The ASEAN Cosmetic Directive establishes unified rules on prohibited substances (Annex II), restricted substances (Annex III), permitted colorants (Annex IV), preservatives (Annex VI), and UV filters (Annex VII). Vietnam incorporates these annexes into its domestic regulatory system.

Circular 06 further clarifies documentation standards, ingredient declaration structure, and procedural requirements for cosmetic product notification in Vietnam. Circular 32 updates technical documentation obligations and strengthens regulatory oversight.

Together, these regulations ensure that every cosmetic formula submitted in 2025 meets safety, traceability, and transparency standards.

How to Prepare a Compliant Cosmetic Ingredient List

A compliant cosmetic ingredient list must follow strict formatting and scientific conventions. The first principle concerns INCI naming.

All ingredients must be declared using the International Nomenclature of Cosmetic Ingredients (INCI). Trade names, supplier codes, or marketing labels are not accepted. Botanical ingredients must include their Latin genus and species, while animal-derived substances require clear scientific identification to ensure traceability.

Equally important is ingredient order. Substances must be arranged in descending order of concentration at the time of formulation. Ingredients present at concentrations below 1% may appear after those above 1% in flexible order, but the total composition must always equal exactly 100%.

For regulated substances listed under ASEAN annexes, precise concentration percentages must be stated. These values are crucial for evaluating compliance with maximum permitted limits, especially for preservatives and restricted ingredients.

By respecting INCI standards, concentration order rules, and ASEAN annex limitations, businesses can significantly reduce the risk of cosmetic notification rejection.

Which Substances Are Excluded from the Official Formula?

Not every material used during manufacturing is considered part of the final cosmetic product formula.

Trace impurities naturally present in raw materials, processing aids removed during production, and volatile carriers that evaporate completely are generally excluded from declaration. This distinction allows regulators to focus on substances that remain in the finished product and may impact consumer safety.

Understanding this boundary prevents both under-declaration and unnecessary over-disclosure, two common causes of regulatory clarification requests.

Common Mistakes in Cosmetic Notification Dossiers

Regulatory delays often stem from avoidable documentation errors. One frequent issue is the use of non-INCI ingredient names, which automatically triggers correction requests.

Another serious problem involves restricted or banned substances under Annex II and Annex III of the ASEAN Cosmetic Directive. Even minor deviations from permitted concentration thresholds can result in dossier rejection.

Inconsistent formulas—where the total percentage does not equal 100%—also raise red flags during evaluation. Additionally, submitting outdated formulas that do not reflect current 2025 regulatory updates may invalidate the entire application.

Ensuring internal regulatory review before submission is therefore essential to maintaining smooth import procedures.

Why Accurate Cosmetic Product Formula Submission Matters

A properly prepared Vietnam cosmetic product formula supports faster cosmetic notification approval, reduces compliance risks, and builds regulatory credibility. It also protects businesses from administrative penalties under Vietnamese law, including fines, suspension, or product recall.

More importantly, accurate formula declaration safeguards consumer safety and aligns your product with ASEAN cosmetic standards, strengthening your brand’s position in the Vietnamese market.

Conclusion

Vietnam cosmetic product formula compliance is the foundation of successful cosmetic product notification in 2025. From INCI ingredient listing and concentration order to ASEAN annex restrictions and scientific naming standards, every detail must be legally accurate and technically precise.

If you are preparing a cosmetic notification dossier or reviewing your cosmetic ingredient list, expert guidance can prevent costly delays. Contact Green NRJ today to ensure your cosmetic product formula meets all Vietnamese and ASEAN requirements before market launch.