Short answer: Vietnam's draft cosmetics decree, notified on 2 October 2026 and proposed to take effect on 1 January 2027, would replace the current framework with a full lifecycle regime — but it is still a draft, so the right work now is tightening the document chain you already rely on.
Vietnam's cosmetics rulebook has been stable for a decade, built on a decree from 2016 and a circular from 2011. On 2 October 2026 the country notified a replacement to the World Trade Organization and opened a comment window that closes on 1 November 2026. The proposal is a full rewrite: ten chapters, sixty articles, covering manufacturing licences, notification, import control, product information files, labelling, testing, post-market surveillance and recall.
That is a significant piece of news for any brand selling or planning to sell in Vietnam. It is also, precisely, a draft — and the most useful thing a brand can do right now is understand where the line sits between what is proposed and what is already binding.
What has actually happened
The sequence matters more than the headline, because it tells you how much time you have.
- 2 October 2026 — the draft decree on cosmetics management was notified to the WTO, developed by Vietnam's drug administration under the Ministry of Health.
- Until 1 November 2026 — a public comment period is open. Comments go through the notified channel, which in practice means through a trade association or a local regulatory consultant rather than from a brand directly.
- 1 January 2027 — the proposed date of effect, if the draft proceeds as notified.
- On effect — the draft would supersede the 2016 decree and the 2011 circular.
A notified draft is a proposal that has cleared internal drafting and entered international transparency. It can still change, and the comment window exists precisely because it may. Nothing in it is an obligation today.
Why a draft is not a compliance requirement
The costliest mistake brands make during a rule change is to start building to text that has not been adopted. Two things happen: the draft is amended, and the work has to be redone; or the draft does not move as fast as assumed, and a brand has paid for compliance with a rule that does not yet exist while neglecting duties that are live.
The disciplined position is to separate the two stacks:
- What is binding today — the existing notification, authorisation and import requirements, and the documents that support them. This is the work that ships goods this quarter.
- Direction of travel — what the draft indicates about where the framework is heading, used to make decisions that are hard to reverse, such as who holds the notification, where the product information file lives, and how the labelling artwork is structured.
Decisions with a two-year horizon can be made once. Decisions with a one-quarter horizon should be made against the law as it stands. A draft is planning input, not a specification.
The document chain that already decides your project
Independent of the draft, Vietnam's current regime turns on a small set of documents, and the projects that go wrong are almost always missing one of them rather than failing a technical test:
- A product notification filed with the competent authority before the product is placed on the market. The notification number carries a validity period, and its expiry is a commercial event, not a clerical one.
- A power of attorney authorising the local entity that places the product on the market, where the brand owner is outside Vietnam.
- A certificate of free sale for imported cosmetics, showing that the product is freely sold in the country of manufacture — with the exemptions and specific applications judged case by case against the current rules.
- A product information file, assembled to the ASEAN guidelines, with the safety assessment report that the guidelines require.
- Labelling that follows the ASEAN Cosmetic Directive's mandatory content alongside Vietnam's general goods-labelling law — two layers, not one.
- The supporting batch documentation that makes the file auditable: analysis, stability and microbiological records against the specification actually produced.
Two of these deserve more attention than they usually get. The certificate of free sale has to match the product, the manufacturer and the market it is issued for; a certificate covering a different entity or a differently named product is a finding waiting to happen. And the product information file is not a launch document — it has to stay current, because post-notification review and market surveillance both reach into it.
Who holds the notification — the quiet commercial risk
The most expensive question in a Vietnam launch is not a technical one. It is this: when the project ends, who keeps the regulatory asset?
In the current framework, the notification, the power of attorney and often the product information file sit with the local partner or distributor that places the product on the market. If the brand has not agreed what happens to those assets on termination, replacing a distributor can mean losing the notification with them — and with it the ability to sell the product, and the sales history that supports the next one.
The draft makes the same point sharper rather than softer. It proposes administrative handling of notification numbers and a defined status for those numbers, which means the number is explicitly a managed asset rather than an incidental filing. Whether or not the draft arrives in its current form, the drafting advice is the same: put the notification amendment and transfer mechanics in the distribution agreement, name who owns the product information file, and write down what happens to both on termination.
What the draft proposes to change
The proposal is broad, so it helps to read it as a shift from "notify and place" to a full-lifecycle regime with risk classification running through it.
| Area | Current framework | What the draft proposes |
|---|---|---|
| Manufacturing oversight | Manufacturing eligibility under existing requirements | Cosmetic GMP requirements with competence, dossier and certificate lifecycle, including suspension and revocation, and inspection by risk group using on-site, remote or data-based assessment |
| Raw materials and bulk | Control of origin and quality as part of manufacturing practice | Explicit control of origin, source, quality and legality of raw materials and bulk products |
| Notification | Product notification before placing on the market | Notification plus post-notification amendment procedures, followed by dossier review and surveillance |
| Imports | Notification prior to customs clearance, with exemptions | Retained, with the exempted cases set out, plus certificates of free sale for locally manufactured goods intended for export |
| Product information file | PIF assembled to ASEAN guidelines | PIF including the safety assessment report, with electronic labelling, digital product passports and traceability provisions |
| Market control | Inspection and post-market checks | Risk-based inspection and surveillance including the online environment, plus sampling and testing rules and third-party conformity assessment results |
| Recall | Recall and enforcement provisions | Recall forms and scope, withdrawal of notification numbers, and measures for establishments on a key control list |
| Cosmetovigilance | Safety monitoring obligations | A defined cosmetovigilance regime linked to quality management |
Read the table as a direction rather than a checklist. The consistent theme is documentation: what it must contain, how long it must remain accurate, and how a regulator reaches into it after the product is already on the market. That theme is already true across the region — the notification route itself is covered in our ASEAN notification guide, and the destination-specific registration and labelling requirements are set out on our Southeast Asia market pages.
A practical sequence for the next ninety days
- Inventory the documents you hold for each product and each market entity: notification, power of attorney, certificate of free sale, product information file, label artwork.
- Check the validity dates, especially the notification number, and diarise renewal ahead of the expiry rather than behind it.
- Confirm the entity chain — brand owner, manufacturer, local market authorisation holder — and that the certificate of free sale names the right one.
- Review the product information file for currency, including the safety assessment and the batch documentation behind it.
- Read the draft against your own roadmap and note the two or three items that would change your label artwork or your file structure. Those are worth pre-empting; everything else can wait for the final text.
- If you have a genuine comment, route it through an association or a local consultant before 1 November 2026. Comment windows are short and the channel is not direct.
Our own documentation approach is built for this: each order ships with a certificate of analysis, a stability summary and a microbiological report, and documentation prepared for the destinations we serve — the detail is in our batch documents guide. Those files are the raw material of a product information file, and a brand that already holds them answers a rule change with assembly rather than investigation.
FAQ
Q: Is Vietnam's new cosmetics decree in force? A: No. It is a draft, notified to the World Trade Organization on 2 October 2026 with a public comment period closing on 1 November 2026 and a proposed date of effect of 1 January 2027. The current framework remains binding until any new text is adopted and takes effect.
Q: What documents do I need to sell cosmetics in Vietnam now? A: A product notification filed before the product goes on the market, a power of attorney for the local entity placing it on the market where the brand owner is outside Vietnam, a certificate of free sale for imported products, a product information file assembled to the ASEAN guidelines including the safety assessment report, and labelling that satisfies both the ASEAN Cosmetic Directive and Vietnam's goods-labelling law.
Q: How long is a Vietnam product notification valid? A: The notification number carries a validity period rather than being open-ended. Treat the expiry date as a commercial deadline: it has to be diarised and renewed ahead of time, and it is worth confirming the current position with a local regulatory consultant because the framework is under revision.
Q: Should I wait for the new decree before launching in Vietnam? A: No. The work that makes a launch possible — a current notification, a matching certificate of free sale, an up-to-date product information file and compliant labelling — is required under the framework in force today. Read the draft for the decisions that are expensive to reverse, such as who holds the notification, and keep producing to the rules that are actually binding.