A shipment of imported confectionery, milk or beverages cannot go on supermarket shelves with only its original English, Korean or Chinese label. Vietnamese law requires imported goods to carry a Vietnamese sub-label before circulation, and food is the category regulators examine most closely because it directly affects consumer health. This article explains when a sub-label is mandatory, what it must contain, and the risks of getting it wrong.
1. What a sub-label is and when it is required
Goods imported for circulation in Vietnam must be labelled under Decree 43/2017/ND-CP on goods labelling, as amended and supplemented by Decree 111/2021/ND-CP. The foreign manufacturer’s original label is usually not in Vietnamese, so the importing organisation or individual must add a Vietnamese sub-label.
The sub-label must be attached before the goods enter circulation. Critically, it must not obscure the mandatory contents shown on the original label, and the lettering must be clear, legible and durable. Where the original label already displays all mandatory contents in Vietnamese, no additional sub-label is needed.
2. Mandatory contents of a food sub-label
For imported food, the Vietnamese sub-label must show the following mandatory items:
- Product name; name and address of the organisation or individual responsible for the goods (normally the importer); country of origin.
- Quantity; date of manufacture and expiry date; ingredients and quantitative ingredient declarations.
- Instructions for use and storage; warnings where applicable; nutrition information for food groups subject to mandatory declaration.
The sub-label must faithfully reflect the mandatory contents of the original label, translated accurately, without added information that misrepresents the nature of the goods. Measurement units follow the metric system. Businesses should verify every item before mass printing, because a single error in the expiry date or ingredient list is enough to put an entire consignment in trouble.
3. Risks of missing or incorrect sub-labels
Imported goods without a Vietnamese sub-label may be treated as goods of unidentified origin during inspections. Market surveillance authorities may impose administrative penalties, order the goods recalled, and require compliant labelling; serious violations can lead to confiscation or destruction of the goods.
Liability does not stop with the importer. Distributors and retailers circulating inadequately labelled goods may also face enforcement action. In practice, plenty of consignments are held up at post-clearance inspection simply because sub-labels omit the expiry date or misstate ingredients compared with the original label — mistakes entirely avoidable with a label review before the goods arrive.
Conclusion
The Vietnamese sub-label is not a formality; it is a condition for imported food to circulate lawfully. Importers should standardise label checks from the ordering stage with foreign partners, rather than patching problems after the goods reach the port.
Frequently asked questions
1. Do imported goods whose original packaging already has a Vietnamese label need a sub-label?
No. If the original label already shows all mandatory contents in Vietnamese, no extra sub-label is required. The sub-label obligation only arises when the original label lacks the required Vietnamese contents.
2. Who is responsible for affixing the Vietnamese sub-label?
The importing organisation or individual must ensure the goods carry a compliant sub-label before circulation. Many importers delegate the physical work to a logistics provider or warehouse, but ultimate legal responsibility remains with the importer.
3. May the sub-label be pasted over information on the original label?
No. A sub-label must not cover up mandatory contents of the original label. Its placement must keep both layers legible, with durable lettering.
4. Does food imported for online sale need a sub-label?
Yes. The labelling obligation applies when goods circulate, regardless of whether the retail channel is physical or e-commerce. Goods delivered to consumers without a Vietnamese sub-label are still violations.
5. How is a sub-label with a wrong expiry date handled?
This is a serious violation because it directly affects consumer safety. Authorities may order a recall of the whole batch, impose administrative penalties, and require correction with accurate labels before the goods may circulate again.
This article has been quality-reviewed by the FLAW AI Legal Council.
