Introduction
Vietnam initially intended to develop a Cosmetics Law to establish a more comprehensive legal framework for cosmetics management. However, for various reasons, a Draft Cosmetic Decree was developed instead. The draft is still under development and revision, incorporating feedback from ministries, industry associations, and enterprises. The latest available version is dated 2 February 2026.
This guide provides a summary of the key provisions and compliance implications of the Draft Decree on Cosmetics Management for cosmetics companies operating or planning to enter the Vietnamese market.
Key Amendments Proposed in Vietnam's Draft Cosmetic Decree
Product Safety and Quality Requirements
The draft provides clearer and more detailed requirements, including:
Compliance with ASEAN limits on heavy metals, microbiological contamination, and trace impurities.
Ingredients must comply with the Annexes of the ASEAN Cosmetic Agreement (latest updated version issued by the ASEAN Cosmetic Committee).
Mandatory safety assessment in accordance with the ASEAN Cosmetic Safety Assessment Guidelines.
Requirement to establish and publish internal product quality standards developed by the manufacturer.
Cosmetic Product Notification
The draft introduces a new cosmetic notification mechanism based on the principle of:
“Enterprise self-responsibility first – Authority inspection afterward” (i.e., a complete shift from pre-market control to post-market control), in accordance with the ASEAN Cosmetic Agreement.
Before a product is placed on the market, the notifying entity publicly disclose the product information on the centralized electronic cosmetic management system.
However, the public disclosure only confirms that the dossier has been submitted into the system; it does not constitute approval of the dossier content. After the product is declared and marketed, the competent authority will conduct a dossier review. If the dossier is found non-compliant, the authority may revoke the notification receipt number, conduct ad hoc inspections, recall the product, and impose administrative sanctions.
The notification dossier must include the “Product Quality Standard”, which serves as the basis for controlling product safety and quality and for post-declaration inspection and quality testing.
Cosmetic Manufacturing in Vietnam
Harmonization and revision of regulations on cGMP certification, manufacturing site assessment, and withdrawal of manufacturing eligibility certificates.
New Provisions Added in the Draft Decree on Management of Cosmetics
Post-Market Safety and Quality Inspection
Post-market Inspection of cosmetic product safety and quality shall be conducted based on a risk-based management principle, under which:
Detailed provisions are set out for post-market dossier inspection for two groups:
Cosmetics prioritized for dossier inspection: The notifying entity must provide certain documents within the Product Information File (PIF) - i.e., documents that must be readily available at the notifier’s premises upon request by the competent authority in accordance with the ACD - no later than 30 days from the date of the inspection request.
The receiving authority must complete the review of the notification dossier and the requested PIF documents within 45 days from the date of the inspection request.
Other cosmetics: The receiving authority must complete the review of the cosmetic product notification dossier within 3 months from the date the product information is publicly disclosed/notified.
Specialized Inspections: The inspection scope includes compliance with notification requirements, manufacturing conditions, the PIF, labeling, advertising, complaint handling, and product recall. Products that have already undergone post-declaration dossier review and been found compliant shall not be re-inspected.
Quality control: The order of priority for quality inspection is determined based on the risk level of the cosmetic product. The draft also specifies the authorities responsible for sampling and testing cosmetic products for quality control purposes.
Product Recall and Suspension Measures
The draft supplements provisions allowing authorities to:
Recall products that violate quality, ingredient, or labeling requirements.
Require the violating party to bear testing costs.
Temporarily suspend acceptance of new notification dossiers for repeat offenders or entities intentionally providing false information.
Responsibilities of Relevant Parties
Clear allocation of responsibilities among:
Notifying entity: with enhanced obligations.
Manufacturer
Importer
Distributor
Enhanced Obligations for Notifying Entity
Particularly for high-risk products (e.g., skin-whitening products, talcum powder, sunscreens, products labeled for pregnant women or children):
Within 30 days of market placement, the notifier must submit product samples to an independent laboratory certified under GLP or ISO/IEC 17025 for quality testing, unless the manufacturer’s laboratory has:
Performed full quality testing, and
Is certified under GLP, ISO/IEC 17025, or GMP.
If products fail quality testing:
The notifier must compensate consumers under consumer protection laws.
The Ministry of Health and the provincial authority must be notified within 24 hours.
Administrative Procedure Simplification under the Draft Decree
Removal of 4 Advertising Confirmation Procedures
The draft removes procedures related to advertisement content approval, including:
New issuance of advertisement content confirmation
Re-issuance due to loss/damage
Re-issuance upon expiry
Re-issuance due to administrative information changes
This reduces administrative burden in the cosmetics sector.
Introduction of Renewal Procedure
A new administrative procedure is introduced: Renewal of cosmetic product notification validity.
Instead of re-submitting a full notification after expiry, enterprises may:
Apply for a 5-year renewal,
Follow a simplified dossier and procedure compared to initial notification.
Conclusion
Vietnam’s Draft Cosmetic Decree marks a major shift from pre-market control to post-market, risk-based regulation, emphasizing product safety, quality, and streamlined administrative procedures.
Cosmetics companies entering Vietnam must strengthen internal quality standards, maintain comprehensive Product Information Files (PIFs), and ensure compliance across all stakeholders to succeed under this new post-market oversight framework.
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