Every cosmetic product must be notified before circulating on the Vietnamese market — the state authority issues a receipt number for the Cosmetic Product Notification Dossier. To be clear from the start: this is a “notification” procedure, not a “circulation license”; the authority does not appraise product quality, and the enterprise bears full responsibility for the notified contents. This article details the dossier, timelines and validity for notifying imported cosmetics under Circular 06/2011/TT-BYT (amended by Circular 29/2020/TT-BYT and Circular 34/2025/TT-BYT, effective 18/8/2025).
1. Nature of the procedure: notification, not licensing
Cosmetic notification is a declaration procedure: the enterprise fully declares product information in the notification dossier, and the state authority receives it and issues a receipt number. There is no quality appraisal and no “cosmetic circulation license”. The enterprise is legally liable for the truthfulness of the notified contents and the quality of marketed products.
2. Competent authority: imports vs domestic manufacture differ
- Imported cosmetics: submit to the Drug Administration of Vietnam, Ministry of Health;
- Domestically manufactured cosmetics: submit to the provincial health specialized agency under the provincial People’s Committee where the manufacturing facility is located.
Note: do not submit imported-cosmetic dossiers to local Departments of Health — a common mistake leading to returned dossiers.
3. Dossier for imported cosmetics (Article 4, amended by Circular 29/2020/TT-BYT)
- (a) Cosmetic Product Notification Dossier: 01 electronic copy (for online submission) or 02 hard copies;
- (b) Letter of authorization from the manufacturer or product owner to the organization/individual responsible for placing the product on the market — requiring signature authentication and consular legalization (except where exempted under international treaties);
- (c) Certificate of Free Sale (CFS) meeting all three conditions: still valid; if the CFS states no validity period, it must have been issued within the last 24 months as of the submission date; consular legalization (except where exempted); and containing at minimum the information required by the Law on Foreign Trade Management.
The three CFS conditions (validity / 24 months / consular legalization) are the most common reason dossiers are returned.
4. Processing time (Decision 2393/QD-BYT of 2025)
- 3 working days from receipt of a complete, valid dossier plus fees → the authority issues the notification receipt number;
- Non-compliant dossiers → the authority notifies supplementation within 5 working days;
- Compliant supplemented dossiers → receipt number issued within 5 working days;
- Failure to supplement within 3 months of the notice → the dossier lapses; a fresh submission with new fees is required.
5. Validity: 5 years — re-notify before expiry
The notification receipt number is valid for 5 years from the date of issuance (Article 10 of Circular 06/2011/TT-BYT). After 5 years, to continue marketing the product, the enterprise must re-notify before expiry — there is no extension procedure. Letting it lapse before re-notifying means the product circulates without a valid receipt number during the gap.
6. What’s new in Circular 34/2025/TT-BYT (from 18/8/2025)
- Acceptance of online dossiers with electronic/digital signatures;
- Business households are not required to stamp dossiers;
- Standardized ingredient listing per INCI nomenclature, in descending order of concentration;
- Each product notified in a separate dossier — a finished product manufactured by different companies must be notified separately.
7. Product Information File (PIF) — Article 11
Enterprises must compile and keep the Product Information File (PIF) at the address of the organization/individual responsible for placing the product on the market. Authorities may inspect the PIF during post-market surveillance; lacking or failing to present the PIF is an independent violation, sanctioned separately from notification violations.
FAQs
Q: Is there such a thing as a “cosmetic circulation license”?
A: No. The law only provides for notification and issuance of a notification receipt number — “cosmetic circulation license” is not a legal term.
Q: Can I use an expired CFS, or one issued more than 24 months ago?
A: No. The CFS must be valid; if it states no validity period, it must have been issued within 24 months and be consularly legalized (except where treaty-exempted).
Q: What if I don’t supplement the dossier within 3 months?
A: The dossier lapses — you must re-submit from scratch with new fees.
Legal basis: Circular 06/2011/TT-BYT (25/01/2011, implementing the ASEAN Cosmetics Agreement), amended by Circular 29/2020/TT-BYT (effective 15/02/2021) and Circular 34/2025/TT-BYT (effective 18/8/2025) — in force; Decree 93/2016/ND-CP (amended by Decree 155/2018/ND-CP); Decision 2393/QD-BYT of 2025; Circular 41/2023/TT-BTC (fees). Checked on 14/10/2026.
This article is for general reference only and does not constitute legal advice for any specific case. The content has been reviewed by the QA Council.
Transparency note: This article was drafted with AI assistance and quality-checked by FLAT’s AI Legal Council; it has not been reviewed by a human lawyer.
See also: Contact FLAT Law Firm
