Goods imported for sale into Vietnam must bear a Vietnamese sub-label — an obligation with no exception for the e-commerce channel. Decree 43/2017/ND-CP, amended by Decree 111/2021/ND-CP, requires imported goods to keep their original label and add a Vietnamese sub-label with the mandatory contents before the goods enter circulation, and the responsible subject is the importing organisation or individual — not the carrier.
What mandatory Vietnamese content must the sub-label carry?
A goods label must show the basic mandatory contents: the goods’ name; the name and address of the organisation or individual responsible for the goods; and the goods’ origin. Depending on each goods group’s nature, the label must additionally carry quantity, production date, expiry date, ingredients, technical parameters, warning information and instructions for use and storage under sector rules. For imported goods, the foreign-language original label is kept, and the Vietnamese sub-label carries the mandatory contents missing or unclear on the original label.
The sub-label must be attached to the goods or commercial packaging before the goods enter circulation in Vietnam, in an easily observable position that does not obscure the original label’s mandatory contents. In the cross-border model with a Vietnamese warehouse, sub-labelling happens at the warehouse before delivery; in the direct-shipping model from abroad to the consumer, the obligation still exists and the sales chain must organise lawful labelling — one of the operational reasons organised cross-border selling almost always needs an in-country touchpoint.
Must goods bought from abroad via platforms bear Vietnamese labels?
Yes, when the goods enter circulation on the Vietnamese market. The labelling duty attaches to the act of placing goods on the market, not to the sales channel: selling via a platform, via livestream or in a store is all circulation of goods. Some special goods groups follow their own sector labelling rules, and goods such as gifts, non-commercial samples or personal luggage follow narrow exceptions of labelling law — but a commercial order sold to a Vietnamese consumer is not among those exceptions.
What individual buyers should know: the Vietnamese sub-label is not mere procedure — it is the basis for identifying the subject responsible for the goods in Vietnam when a quality incident occurs, and a condition for the goods to be warranted and exchanged domestically. A product with no Vietnamese information at all and no identifiable importer is a product for which the buyer has almost no legal fulcrum in a dispute.
How is a missing sub-label handled?
Imported goods circulating on the market without labels or with non-compliant labels face administrative sanctions in the commercial field under Decree 98/2020/ND-CP, with fines by value and violation nature, plus remedial measures such as compulsory supplementary labelling, removal of infringing label elements, or re-export and destruction for irremediable goods. At the import stage, goods without a sub-label may be allowed into the importer’s warehouse to complete labelling under supervision rather than being refused outright — but placing them into circulation before completion is a certain violation.
Beyond fines, operational consequences are usually heavier: the consignment is suspended from circulation until remedied, the platform shop is handled for selling goods unfit for circulation, and in a quality dispute the missing label weakens both seller and importer in proving origin and product responsibility. Labelling is therefore among the cheapest compliance costs in cross-border trade, while the risk of skipping it is among the highest.
Who is responsible for labelling: seller, importer or carrier?
The law places labelling responsibility on producing organisations and individuals and on organisations and individuals importing the goods. In a cross-border sales chain, the subject importing goods into Vietnam — which may be the seller’s subsidiary, a distributor, or an entrusted import unit named on the declaration — is responsible for organising sub-labelling and bears handling when labels are wrong. The foreign seller bears this responsibility indirectly through its contract with the importer and through its own duty as the subject placing goods on the market.
A pure carrier — an express company, a delivery logistics firm — is not the subject responsible for goods labels, because it decides neither the goods’ content nor their placing on the market; it becomes a related subject only if it simultaneously acts as the importer on the declaration or is hired to perform the labelling service — in which case responsibility arises from the import role or the service contract, not from transport activity. Parties should state this allocation clearly in the logistics contract to avoid disputes when a consignment is handled over labels.
Frequently asked questions
Must goods bought from abroad bear Vietnamese labels?
Yes. Imported goods placed into circulation in Vietnam — including sales via e-commerce platforms or livestream — must carry the original label and a Vietnamese sub-label showing the mandatory contents under Decree 43/2017/ND-CP and Decree 111/2021/ND-CP, before the goods reach the consumer. Labelling law exceptions cover only narrow cases such as non-commercial samples, gifts or personal luggage; a commercial order sold to a Vietnamese customer is not an exception.
Is there a penalty for missing Vietnamese sub-labels?
Yes. Goods circulating without a Vietnamese sub-label or with non-compliant labels face administrative sanctions under Decree 98/2020/ND-CP in the commercial field, with fines by consignment value and violation nature, plus remedies: compulsory correct supplementary labelling, removal of infringing elements, or re-export and destruction if irremediable. The consignment is also suspended from circulation until labelling is completed, and a shop selling goods unfit for circulation may be handled by the platform.
Who is responsible for labeling: the seller or the carrier?
The organisation or individual importing the goods bears primary labelling responsibility — in a cross-border chain, that is the subject named as importer into Vietnam (the seller’s subsidiary, a distributor or an entrusted import unit), and the foreign seller bears responsibility through its contractual relationship with the importer. A pure carrier bears no label responsibility, unless it is simultaneously the importer on the declaration or is hired to perform the labelling service — in which case responsibility comes from that import role or service contract.
This article has been quality-reviewed by the FLAW AI Legal Council
