A brand printed ‘100% organic’ on a cream imported from Korea, assuming the origin country’s certification was enough. When inspectors asked for the basis of that claim in the Vietnamese market, the brand could produce nothing beyond the manufacturer’s catalogue.
1. Current legal basis
Vietnamese law currently has no dedicated state ‘organic’ standard for cosmetics: products are governed by the general framework of Decree 93/2016/ND-CP (as amended by Decree 155/2018/ND-CP) and the ASEAN Cosmetic Directive — product announcement, ingredient safety and labelling under Decree 43/2017/ND-CP (as amended by Decree 111/2021/ND-CP). Certifications such as COSMOS or ECOCERT are private international schemes issued by foreign certifiers; they evidence a claim but are neither licences nor Vietnamese state certifications.
2. How this applies in practice
The legal issue is the claim, not the formula: printing ‘natural’ or ‘organic’ is a commercial assertion, and the seller must substantiate it when regulators ask. A product with a small natural-ingredient share marketed as wholly organic is the classic misleading pattern addressed by the Law on Protection of Consumers’ Rights 19/2023/QH15 and advertising law.
For imports, a foreign organic certificate is only one piece of evidence; the Vietnamese sub-label and local advertising must match its scope — certification of an ingredient is not certification of the finished product, and that mismatch is where brands are most often caught.
3. Steps to take
1. Audit every claim on labels and ads: remove or reword any claim lacking supporting documents such as certificates or ingredient test reports.
2. Distinguish ingredient certification from finished-product certification; use certification logos only within the certifier’s permitted scope.
3. Keep valid certificates from international certifiers, with translations, ready for inspection.
4. For domestically made products, consider certifying under an international private scheme from the start instead of making unsupported claims.
4. Risks and post-checks
Uncertified organic advertising can draw misleading-advertising penalties, forced corrections and marketplace delisting; the larger loss is brand trust when media name the product — over a claim that never had documents behind it.
This article has been quality-reviewed by the FLAW AI Legal Council