VIETNAM · COSMETICS

Vietnam Cosmetic Notification Documents: Responsible Entity, Letter of Authorisation and CFS

When preparing documents for Vietnam — often called “registration” — first confirm the named local entity responsible for placing the product on the market, then prepare the notification form, the letter of authorisation from the manufacturer or product owner, and the CFS or proof supporting an exemption. Qualifying for a CFS exemption does not remove the need for a Vietnamese product notification. Imported products must be notified under the applicable procedure before import; another country’s notification is not a Vietnamese receipt number. (Source: Vietnam National Public Service Portal)

What is commonly called “registration” is in fact a cosmetic notification and receipt number; it should not be promoted as government approval of the product’s efficacy.

How do the brand, the responsible entity and the actual importer relate?

The responsible entity is the party named in the notification that is accountable for the product on the market and must be entitled to trade cosmetics in Vietnam. The brand owner, manufacturer, responsible entity and actual importer should be declared according to the real transaction, not according to who is most convenient to sign. (Source: Cosmetics regulation, Articles 2–3)

When choosing a structure, an overseas brand should ask: who notifies, who imports, who holds and provides the PIF, and who receives channel complaints? The form has an importer field, but entering a company name there does not mean that company meets all business and customs conditions.

Write the division of responsibilities into the cooperation agreement, and keep handover arrangements in case the brand changes channels.

What should the letter of authorisation from the manufacturer or product owner state?

The letter may be in Vietnamese, English or both. Under Article 6, key points include the names and addresses of the grantor and manufacturer, the name and address of the authorised party, the brands or products covered, the scope of authorisation to notify and distribute in Vietnam, the validity period, a commitment to provide the full PIF, and the name, title and signature of the authorised representative. (Source: Authorisation requirements, Article 6)

Where the product owner grants authorisation, do not omit the actual manufacturer. A group company or distributor forwarding documents does not automatically have the authorising status the rules require.

In practice, check the coverage of the authorisation product by product before signing and legalisation, to avoid finding out after legalisation that a brand, factory or authorised activity is missing.

When is a CFS required, and when may an exemption apply?

The National Public Service Portal sets out the following routes:

For the CPTPP routes, confirm that the agreement is in force for the countries concerned. “Made in ASEAN” is not the same as “already notified in an ASEAN member state”. Where a CFS shows no validity period, it must generally have been issued within the last 24 months; specific proof and legalisation conditions still need to be checked item by item. (Source: Official document list and exemptions)

How can legalisation, signatures and document consistency be handled in one pass?

For imported products, the letter of authorisation generally requires notarisation and consular legalisation unless a treaty exemption applies. The CFS and exemption proofs each have their own legalisation or confirmation rules, so assess them separately; an exception for one document does not extend to all. (Source: Formal requirements for authorisation, Article 4)

Build an entity name table that standardises legal company names, addresses, manufacturers, brands and product names. Then compare the letter of authorisation, CFS or alternative proof, notification form and artwork side by side. Where abbreviations, address versions or multi-site manufacturing differ, explain them first rather than altering issued documents.

Filing under the 2025 amendment: key points on forms and queries

Circular 34/2025/TT-BYT updated the electronic and paper notification forms, signature methods and completion requirements. Online filing needs one electronic copy; filing in person or by post needs two paper copies. The signatory must be the legal representative or an authorised person, and electronic or digital signatures are accepted online.

In principle, each product is declared on one form. Eligible kits, or shade and fragrance variants in the same line, may be combined under the rules, but hair dyes and perfumes must be declared separately for each shade or scent. Multi-manufacturer cases should be assessed according to the actual division of production. (Source: Circular 34/2025, Article 1)

When a query is received, submit an explanation and corrected documents, and check whether other documents are affected. The authority’s processing time does not include the time needed to obtain originals, legalise, translate and correct documents, so it should not be treated as the launch date.

Note also that Vietnam’s new decree on cosmetics management is still in draft; once adopted, the receiving authority and procedures may change.

For organising the full PIF, see How to Prepare an ASEAN Cosmetic PIF; for receipt expiry, changes and updates on the draft decree, see Vietnam Cosmetic Notification Validity and Changes.