Vietnam has notified the WTO of its Draft Decree on the Management of Cosmetics, proposing a broader and more risk-based framework for cosmetic manufacturing, product notification, import control, Product Information Files, labeling, advertising, market surveillance, recalls and suspension of notification dossiers. The draft is proposed for adoption on 1 August 2026 and entry into force on 31 December 2026, with comments open until 28 July 2026.

Key regulatory changes

The draft Decree would apply to domestic and foreign organizations involved in the manufacture, notification, trading, advertising, quality control, supply and use of cosmetic products in Vietnam.

The main changes include:

• Cosmetic products must be notified before being placed on the Vietnamese market.
• Imported cosmetics must have a valid product management number before import, except for specific non-commercial cases.
• Cosmetic manufacturing facilities must meet CGMP requirements.
• Product Information Files must be maintained in line with ASEAN cosmetic rules.
• Cosmetic products will be classified by risk level: Group A, Group B and Group C.
• Labeling must follow Vietnamese goods labeling rules and ASEAN cosmetic requirements.
• Advertising will no longer require prior content approval, but claims must remain consistent with the notified product function and supporting evidence.
• Authorities may conduct post-notification dossier review, remote PIF checks, on-site inspections and market sampling.
• Product recalls, withdrawal of product management numbers and suspension of new notification dossiers are introduced as enforcement measures.

Product notification and import control

The draft introduces a product management number as the key identifier for cosmetic products in Vietnam. Each product of a notifying entity would have one management number, and the number would not expire.

For imports, cosmetic products with a valid management number may be imported under customs procedures. Non-commercial imports, such as samples for research or testing, exhibition products, gifts, personal luggage within duty-free limits and diplomatic-use products, may be exempt from product notification but must still meet the relevant customs documentation requirements.

PIF, safety assessment and CAS information

The draft requires a Product Information File consisting of four parts: administrative documents and product summary, ingredient and raw material quality data, finished product quality and manufacturing process data, and safety assessment plus claims substantiation.

The updated notification template also introduces a structured ingredient list requiring the full ingredient name, CAS number, percentage and notes for base formulas and product variants. This is important for companies because CAS-level ingredient mapping will become more central in notification, PIF maintenance and post-market review.

Risk-based supervision

The draft introduces a risk classification system:

• Group A, high risk: products for children under three years, mucosal-contact products, sensitive-skin products, professional-use products, products with high levels of restricted ingredients, extreme pH, nanomaterials, enhanced penetration technology or inhalation exposure risk.
• Group B, medium risk: leave-on products, products for children aged three and above, products with moderate levels of restricted ingredients, and products such as sunscreen creams, emulsions or gels.
• Group C, low risk: rinse-off products, adult-use products with localized contact, products with lower exposure and products from compliant CGMP facilities.

This classification will guide inspection frequency, dossier review intensity and market surveillance priorities.

Implementation timeline

The draft provides several transition points:

• 31 December 2026: Decree enters into force.
• Until 31 December 2028: The Ministry of Health continues handling imported cosmetic notification dossiers, while provincial health authorities handle domestic products.
• From 1 January 2029: provincial health authorities handle notification procedures for all products based on the notifying entity’s headquarters.
• Before 1 January 2029: the Ministry of Health is expected to complete the national cosmetic database.
• From 1 January 2030: safety assessment and CGMP-related requirements apply according to the roadmap.
• Existing notification numbers remain valid until expiry, while existing labels and packaging may continue for a transitional period subject to the conditions in the draft.

Industry impact

The draft Decree would significantly reshape cosmetic compliance in Vietnam. Companies exporting or distributing cosmetics in Vietnam should prepare for stronger formula-level documentation, clearer CAS-based ingredient identification, local PIF readiness, digital product data management, and risk-based inspection.

Importers and local responsible persons should also review their authorization letters, CGMP evidence, CFS or alternative documents, label content, claims support, adverse event procedures and recall readiness before the new regime takes effect.