COSMETIC PRODUCT NOTIFICATION FORM AND KEY NOTES ACCORDING TO THE LATEST 2025 REGULATIONS

Currently, the cosmetics market is rapidly expanding, and the control and management of cosmetic products circulating in Vietnam are becoming increasingly stringent to safeguard consumer health and ensure transparency and legal compliance among businesses operating in this sector. One mandatory procedure before launching a cosmetic product on the market is the Cosmetic Product Notification (CPN)—a necessary legal step to legitimize products in accordance with applicable laws.

With the issuance of Circular No. 34/2025/TT-BYT, amending and supplementing several key provisions of Circular No. 06/2011/TT-BYT, enterprises must stay up to date with the latest changes to fulfill their legal obligations properly and completely.

1. Regulations on the Cosmetic Product Notification Form

According to Article 5 as amended by Circular No. 34/2025/TT-BYT, the Cosmetic Product Notification Form must be completed using the template in Appendix No. 01-MP attached to the Circular. Depending on the method of submission (online, in person, or via postal service), the requirements for signatures and seals on the Notification Form are specifically defined as follows:

  • Online submission:
    The form must be signed by the legal representative or an authorized person, using a valid electronic or digital signature. Household businesses are not required to affix a seal.

  • Direct submission or via postal service:
    The form must be signed and stamped by the legal representative or an authorized person. If the form consists of more than one page, all pages must be affixed with a page-stitching seal. Household businesses are still not required to use a seal, but the business owner must sign on all pages.

2. Quantity and Scope of Product Notification

Each Cosmetic Product Notification Form applies to only one individual cosmetic product. In cases where a product is fully manufactured across multiple companies, each company’s name, address, and corresponding production stage must be clearly specified.

However, one Notification Form may cover multiple products if the following conditions are met:

  • The products are packaged under the same common name and sold as a product set;

  • Products share the same name, line, and similar formulation but differ only in color or fragrance (excluding hair dyes and perfumes);

  • Other special cases as approved by the Drug Administration of Vietnam based on ASEAN Cosmetic Committee decisions.

3. Guidelines for Declaring Product Ingredients

Enterprises must strictly adhere to the following ingredient declaration requirements on the Notification Form:

  • Ingredients must be listed in descending order by concentration;

  • Ingredients under 1% may be listed in any order following higher-concentration components;

  • Fragrance ingredients can be listed generally as “fragrance,” “perfume,” or “flavour”;

  • Colorants must be listed using CI numbers or names as per Appendix IV of the ASEAN Cosmetic Directive, and the terms “may contain” or “+/-“ may be used;

  • All ingredient names must follow INCI (International Nomenclature of Cosmetic Ingredients) standards or be sourced from recognized references such as the British Pharmacopoeia (BP), United States Pharmacopeia (USP), or Japanese Standards.

For ingredients subject to concentration limits, the exact percentage must be declared, using a comma (“,”) to separate decimal values.

The following must not be listed:

  • Unintentional impurities in raw materials;

  • Technical materials not present in the final product;

  • Solvents or carriers used solely for fragrance ingredients.

4. Language and Mandatory Information

The Notification Form must be presented in Vietnamese or English. However, certain fields are mandatory in Vietnamese, or in both Vietnamese and English, including:

  • Intended use;

  • Responsible business entity information;

  • Legal representative details;

  • Importing company information.

5. Dossier Submission and Processing Procedure

As amended in Article 7, the Cosmetic Product Notification dossier can be submitted via:

  • The National Public Service Portal under the one-stop mechanism, or

  • Directly at the One-Stop Service Department.

Within 5 working days from the date of receipt, if the dossier is incomplete, the receiving agency must notify the applicant of the required corrections. Upon proper supplementation, within the next 5 working days, the authority must issue a Notification Receipt Number. If the dossier still fails to meet the requirements, a written rejection notice will be issued.

 

6. Import of Cosmetics for Research and Testing Purposes

Organizations or individuals importing cosmetics for the purpose of research or testing must submit an Import Order Form using the template in Appendix No. 14-MP to the provincial Department of Health where the business is registered. Each product may be imported with no more than 10 samples and must not be distributed on the market.

Approval will be granted within 3 working days from the date of receipt of a valid application.

 

7. Legal Responsibilities of the Notifying Entity

Under the new provisions in Article 48, the organization or individual whose name appears on the Notification Form is fully liable under the law for:

  • The accuracy, legality, and truthfulness of all declared information;

  • The consistency between hard copies and electronically submitted files;

  • The safety, efficacy, and quality of the cosmetic product prior to circulation;

  • Compliance with the ASEAN Cosmetic Directive and related Appendices.

For consultation on medical devices, health supplements, cosmetics, or food registration, call our hotline at (+84) 98 546 1894.