Regulations and Procedures for Importing Japanese Cosmetics into Vietnam
Foreign Lawyer (Japan and Vietnam)
Kazuya Mori, Chief Advisor to the Firm (Japanese Law)
NEXORA Law Firm, Managing Partner
Vietnamese Attorney
Mediator, Bankruptcy Trustee, Outside Auditor
Table of Contents
01 - Relationship Diagram
02 - Import Procedures
03 - Preparation and Retention of the Product Information File (PIF)
04 - Cosmetics Labeling and Display Requirements
05 - Other Points to Note
Importing and selling Japanese cosmetics in Vietnam requires compliance with strict regulations and procedures. This article explains, step by step, the necessary procedures, including the cosmetics notification process, management of the Product Information File (PIF), and labeling requirements. It also touches on ingredient restrictions and the risks of importing through official versus unofficial channels, providing information to support efficient, law-compliant import and sales activity in the Vietnamese market.
Importing and selling Japanese cosmetics in Vietnam requires compliance with strict regulations and procedures. This article explains, step by step, the necessary procedures, including the cosmetics notification process, management of the Product Information File (PIF), and labeling requirements. It also touches on ingredient restrictions and the risks of importing through official versus unofficial channels, providing information to support efficient, law-compliant import and sales activity in the Vietnamese market.
01 - Relationship Diagram
02 - Import Procedures
To import cosmetics into Vietnam, the following procedures must be carried out.
Procedure / Items requiring action
Required documents, etc.
1. Cosmetics notification procedure
Cosmetics notification application form
A power of attorney from the Japanese manufacturer or exporter (consular legalization in Japan is required). Note: the power of attorney must contain certain mandatory items, so these should be confirmed in advance.
Points to note:
The party carrying out the procedure (the applicant) must be the importer/seller that is a locally incorporated entity in Vietnam. It cannot be carried out directly in the name of the Japanese manufacturer or exporter.
A separate application must be prepared and submitted for each product (SKU).
Because the Japanese manufacturer or exporter must disclose detailed product information (such as ingredient information) to the notifying party (applicant), a proper non-disclosure agreement, among other things, must be concluded.
Competent authority: the Drug Administration of Vietnam, Ministry of Health
Result of the procedure: a cosmetics notification receipt number issued by the Drug Administration of Vietnam
This cosmetics notification receipt number is valid for five years.
Because there are rules governing how ingredients must be stated in the application, these must be strictly followed. In addition, the ingredients stated in the notification and those stated on the label must match.
Ingredients contained in the cosmetic product must not fall within the list of prohibited ingredients or the list of restricted-ingredient standards for cosmetics established by the Drug Administration of Vietnam, Ministry of Health. Furthermore, even where an ingredient does not fall within these lists, approval may in some cases still be refused at the authority's discretion.
2. Customs clearance procedure
(No product inspection/visa procedure is required.)
Customs declaration
Sale and purchase agreement (or distribution agreement)
Invoice
Bill of lading (B/L)
Import price declaration for the imported goods
Certificate of ingredient disclosure
Packing list
Certificate of origin (C/O)
Other documents, etc.
03 - Preparation and Retention of the Product Information File (PIF)
A distributor of cosmetics must prepare and retain a Product Information File (PIF) for each individual product, consisting of the following items. If requested by an inspection body, the PIF documents must be submitted immediately.
Administrative documents relating to the product, and a product overview
Quality of raw materials
Quality of ingredients
Safety and efficacy of the product
04 - Cosmetics Labeling and Display Requirements
The cosmetics label must be affixed to the product and its commercial packaging in a position where the specified content can be confirmed without having to disassemble the product or its components. The label must include the following content.
Name and function of the cosmetic product
Directions for use
The names of all raw materials
Country of origin
The corporate or individual name of the domestic distributor
Volume or weight
Product lot number
Date of manufacture or expiration date
Precautions for use
The labeling language is to be English or Vietnamese; however, among the labeling items above, the "name of the domestic distributor (company or individual)" and "precautions for use" must be stated in Vietnamese.
05 - Other Points to Note
In recent years, there have also been many cases of selling cosmetics directly to Vietnamese consumers from Japanese e-commerce sites, without going through a locally incorporated entity in Vietnam. In such cases, there are two possible patterns: (i) importing through the official route, or (ii) importing through an unofficial route.
Where the value of the cosmetics is 2,000,000 VND or less, the import is treated as being for personal consumption purposes, and the cosmetics notification procedure is not required. On the other hand, where the value exceeds this amount, the import is deemed to be for trade purposes, and the goods cannot be imported unless a cosmetics notification receipt number has been obtained from the Drug Administration of Vietnam.
There are also many cases of importing through unofficial routes. The risk is that, should an investigation by the market management authority or a consumer complaint arise, the manufacturer's products circulating in the market may be subject to recall, and it may subsequently prove difficult to switch successfully to a pattern of formal import into Vietnam.