Labelling Imported Supplements and Cosmetics in Vietnam (Decree 37/2026)

Every imported supplement or cosmetic sold in Vietnam needs label information in Vietnamese. Since 23 January 2026, the rules are set by Decree 37/2026/ND-CP, which replaced Decree 43/2017/ND-CP and Decree 111/2021/ND-CP. This guide explains what the original label must show at import, what the Vietnamese sub-label must contain, when e-labels can be used and how the transition works. It reflects our practice as an importer; it is not legal advice.

What the original label must show at import

For imported goods, the original label must be a physical label. At customs clearance it must show, in a foreign language or in Vietnamese:

• the product name;
• the origin (or the place where the final step was completed if origin cannot be determined);
• the name and address of the foreign manufacturer or responsible company, in full or abbreviated.

If the full name and address are not on the label, they must appear in the documents that accompany the goods.

Mandatory content in Vietnamese

All goods must show the product name, the name and address of the responsible organisation, and the origin, plus the items required for their product group:

Cosmetic labelling must also follow Circular 06/2011/TT-BYT, as amended by Circular 34/2025/TT-BYT, including the ingredient-listing rules.

The Vietnamese sub-label

• Who: the importer is responsible for adding the Vietnamese sub-label.
• When: before the goods are put into circulation in Vietnam. It is not required before customs clearance.
• Where: on the product or its retail packaging, without covering mandatory content on the original label.
• What: a Vietnamese translation of the mandatory content on the original label, plus any mandatory items that are missing for the product group. The content must not misrepresent the original label or the origin.

Samples for testing, research or trade fairs and raw materials not sold on the market are exempt from sub-labels.

Electronic labels

Decree 37/2026 allows electronic labels (for example QR codes) as an option. For medium- and high-risk goods, four items must always stay on the physical label: the product name, the responsible company and its address, the origin, and warnings. For imports, the original label must remain physical; a sub-label may be electronic only if the original label is kept intact and consumers are clearly told where to find it. In practice, we recommend a physical Vietnamese sub-label for supplements and cosmetics.

Origin wording

Origin is shown with wording such as “Sản xuất tại”, “Xuất xứ” or “Made in”. If origin cannot be determined, wording such as “Đóng gói tại” or “Finished in” is used.

Transition rules

• Goods produced, imported or circulated before 23 January 2026 with labels that met the old rules can be sold until their expiry date.
• Labels and packaging printed before 23 January 2026 can be used for up to two years, until 23 January 2028.

Common mistakes

• Using the disclaimer wording from an advertisement on the label (the label wording uses a comma: “…không phải là thuốc, không có tác dụng…”).
• Covering the original ingredient list or batch number with the sub-label.
• Translating claims that go beyond the functions in the product declaration.
• Missing the expiry date on cosmetics with stability under 30 months.

How Hoang Bao Minh Vietnam can help

As an importer of record for supplements and cosmetics, we review your labels before production, draft the Vietnamese sub-label, apply it in Vietnam and keep the documents on file. Send us your product list for a first review, or read more about our import and distribution services.

Frequently asked questions

Must the sub-label be applied before customs clearance?

No. Under Decree 37/2026 the importer must add the Vietnamese sub-label before the goods are put into circulation in Vietnam. At clearance, the original label must show the product name, origin and manufacturer details.

Can we use a QR code instead of a sub-label?

Only partly. The original label must stay physical, and for medium- and high-risk goods the name, responsible company, origin and warnings must always appear physically. Most importers of supplements and cosmetics still use a printed sub-label.

Can we keep using our old labels?

Labels and packaging printed before 23 January 2026 can be used until 23 January 2028, and goods already in circulation can be sold until expiry.

Related guides: registering food supplements and cosmetic notification.

Last reviewed: November 2026. This article is general information, not legal advice.