

Table of Contents
ToggleErrors in cosmetic product formula declarations in Vietnam are causing many cosmetics notification applications to be rejected. So, is your ingredient list truly compliant with current regulations? From naming conventions and ingredient order to exact proportions, even small details can lead to issues if not carefully reviewed. This article highlights common mistakes through real-world examples and explains how to properly check your formula to minimize risks during submission.
A common issue is treating the ingredient list like a promotional tool. Instead of presenting the full composition, some businesses highlight only the “hero” ingredients and leave out the rest.
For example, a skincare product may contain a full base system—water, emollients, preservatives, fragrance—yet the dossier only mentions actives like Niacinamide or Hyaluronic Acid. This makes the formula incomplete and no longer representative of the actual product. During review, such gaps are easy to spot and typically lead to requests for correction.
The key point is simple: a notification dossier is not for marketing purposes. It is a legal document, and it must present the formula in a complete and accurate manner.
If the ingredient list is the content, then the names are the language by which regulatory agencies understand your product. Using the wrong language renders all the information that follows worthless.
In reality, many applications still use familiar names like “Vitamin C” or the trade names given by the supplier. For example, an ingredient might be sold under the name “Nano HA Complex,” but the application should use the standard name as required by regulations. When the naming convention is inconsistent, the regulatory agency will have no basis to compare it with the regulated list.
This may seem like a minor error, but it’s the reason many applications require multiple revisions. Using the correct names from the start not only saves time but also demonstrates the professionalism of the business.
A formula not only needs to have all the ingredients but also the correct order. The order of arrangement reflects the proportions and is the basis for evaluating the reliability of the entire application.
Imagine a product where water makes up the majority, followed by moisturizers and active ingredients. If the active ingredient is listed at the top of the list in the application, this immediately creates a contradiction. Even without in-depth analysis, the reviewer can see that the formula is problematic.
It’s worth noting that this error doesn’t stem from a lack of knowledge, but is often due to subjective presentation. However, in the context of increasingly stringent controls, such details become a decisive factor in whether an application is accepted or not.
Besides the names and order, the proportion of ingredients is an indispensable factor. Many businesses focus only on listing ingredients, forgetting that the overall formula must be absolutely accurate.
In some cases, the total proportion only reaches 98% or 99%, with the remainder unexplained. There are also cases where the concentration of substances requiring control is not specified. These discrepancies prevent the regulatory agency from fully assessing the product’s safety.
In reality, even a small error is enough to warrant a request for additional documentation. And when corrections are needed, the processing time will be much longer than if everything were done correctly from the start.
A less obvious, yet quite common issue is relying on an outdated formula. Cosmetic regulations are not static; they evolve over time as safety standards are updated.
For instance, an ingredient that was previously allowed at a certain concentration may later be subject to stricter limits. If the formula is not reviewed against the latest requirements, it may no longer be compliant, even if it was acceptable before.
This highlights an important point: compliance is not a one-time task. It requires ongoing review and updates to stay aligned with current regulations. That is why many businesses choose to work with regulatory specialists to reduce unnecessary risks.
Not every substance involved in the production process needs to be included in the final formula. However, determining which components need to be declared is not always clear.
In some cases, businesses include substances that have completely evaporated in the formula, making the list redundant. Conversely, there are also cases where seemingly “insignificant” components are omitted but still present in the product.
Both approaches distort the nature of the formula. In such cases, the documentation may not only require revisions but also further explanations, prolonging the entire process.
Errors in cosmetic product formula in Vietnam often stem not from complexity, but from incorrect understanding and presentation. When every small detail is carefully controlled, the documentation becomes clearer, more transparent, and more easily accepted. Green NRJ will partner with businesses in reviewing and standardizing ingredient lists and ensuring formulas fully meet legal requirements, helping the registration process to proceed quickly and efficiently.