On October 2, 2026, Vietnam notified the World Trade Organization (WTO) of the Draft Decree on Cosmetics Management (G/TBT/N/VNM/453), drafted by the Drug Administration of Vietnam under the Ministry of Health. The public comment period closes on November 1, 2026. The draft is slated to enter into force on January 1, 2027 and will supersede the existing Decree No. 93/2016/NĐ-CP and Circular No. 06/2011/TT-BYT.
Overall Framework of the Draft Decree
The draft decree consists of 10 chapters and 60 articles, establishing a whole-chain regulatory system for cosmetics:
- Chapter I: General Provisions, covering terminology, technical requirements, risk classification and Management Number status management;
- Chapter II: Production, ingredients and quality control of production establishments;
- Chapter III: Product notification and post-notification changes;
- Chapter IV: Imported product management and issuance of Certificates of Free Sale (CFS);
- Chapter V: Product Information File (PIF), labeling and advertising;
- Chapter VI: National quality management, testing requirements and cosmetovigilance;
- Chapter VII: Inspection, supervision and post-market control (including online sales inspection);
- Chapter VIII: Product recall, Management Number withdrawal and Key Control List measures;
- Chapters IX and X: Organizational implementation responsibilities and implementation roadmap, transitional provisions and effective date.
Within this framework, the Management Number system and risk classification, product notification procedure, import control requirements and transitional arrangements are among the aspects cosmetics companies should review. The key points are summarized below.
Management Number System and Risk Classification
Products must be notified to the competent authority before being placed on the market, and a Management Number will be issued within three working days after the dossier is accepted, remaining valid until withdrawn. Imported products will clear customs through online verification of the Management Number status, and customs will no longer request notification dossiers or PIFs.
Products are classified into three risk groups: A (high), B (medium) and C (low). The Ministry of Health will publish the catalogs of Group A and B products, and products not listed will fall into Group C. Group A products are also subject to requirements such as batch data retention, batch-level traceability and enhanced pre-market testing.
Key Changes to the Product Notification Procedure
Compared with the current notification regime, import notifications require two additional documents: the Certificate of Free Sale (CFS) from the exporting country (exemptible or replaceable under certain conditions) and the GMP evidence of the overseas manufacturing facility (e.g., CGMP-ASEAN, ISO 22716).
In principle, foreign documents must undergo consular legalization or Apostille, unless verifiable online. Import notifications will be accepted by the Ministry of Health until the end of 2027 and delegated to the provincial level thereafter. Regarding change management, changes such as to the formula only require an update in the system, while changes to the product name, type, intended use, notifier or production site require re-notification. The notifier must be a trader with cosmetics business functions in Vietnam and is responsible for product safety and claims; the product owner must authorize the notification by letter of authorization and provide PIF data.
Production, Labeling and Distribution Requirements
Manufacturers must comply with CGMP and obtain the electronic Certificate of Eligibility for Cosmetics Production issued by provincial authorities (valid long-term, subject to periodic re-review); importing cosmetic ingredients and semi-finished products requires no permit from the Ministry of Health.
Labels must be made in accordance with the ASEAN Cosmetic Directive, with directions for use, warnings and notifier information in Vietnamese, and imported products may carry additional Vietnamese stickers after customs clearance.
Advertising may only be conducted while the Management Number remains valid, and e-commerce sellers must display the Management Number and a verification QR code on sales pages. The Management Number will be withdrawn from products that are seriously non-compliant, repeatedly subject to mandatory recalls, or supported by falsified application materials, and the companies involved may be placed on the Key Control List (mandatory pre-market testing and more frequent inspections).
Transitional Arrangements
Previously issued notification receipt numbers and Certificates of Eligibility for Cosmetics Production may be used until the end of 2028, with notification numbers converted free of charge; labels and packaging materials printed before the effective date may be used for up to 36 more months.
Main Impacts on Cosmetics Companies
(1) Prepare CFS and GMP documents in advance: check CFS exemption scenarios, confirm the validity period of GMP certificates with overseas manufacturers, and allow sufficient time for document legalization.
(2) Assess the cost of risk classification: evaluate product classification against the Group A and B catalogs to be published by the Ministry of Health, and arrange testing and traceability capabilities in advance.
(3) Make good use of transition and feedback channels: existing notification numbers will convert free of charge until the end of 2028; companies may submit comments on the draft through the WTO or directly to the Drug Administration of Viet Nam (nnanhdhn@gmail.com) before November 1, 2026.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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