Circular 34/2025/TT-BYT: Amendments to cosmetic management and importer compliance notes

Legal document | Ministry of Health | Imported cosmetics

CIRCULAR 34/2025/TT-BYT: AMENDMENTS TO COSMETIC MANAGEMENT AND OPERATIONAL NOTES FOR IMPORTERS

Circular 34/2025/TT-BYT amends several provisions of Circular 06/2011/TT-BYT on cosmetic management. For importers, the key control point is the consistency between the cosmetic product notification dossier, formula, label, responsible entity, e-filing data and customs documents. This article places the regulation in the practical context of import-export operations, clarifying its scope, affected parties, and the checks required before it is relied on for a shipment dossier. Before implementation, businesses should verify the effective date, amendments, and relevant official guidance applicable to the transaction, while retaining the source and document version used for later explanation or audit.

DOCUMENT INFORMATION

Field Details
Document Circular 34/2025/TT-BYT amending and supplementing Circular 06/2011/TT-BYT on cosmetic management.
Issuing authority Ministry of Health
Issue date 03 July 2025
Effective date 18 August 2025
Signer Do Xuan Tuyen
Scope Product notification form, e-submission, additional dossier handling, import orders for cosmetics used for research/testing, market responsible entity obligations and replacement of Appendix 14-MP.
Translation note This English version is for operational reference only and is not an official legal translation.
Illustration of the regulation and compliance context for Circular 34/2025/TT-BYT: Amendments to cosmetic management and importer compliance notes
Illustration of the legal document and affected subjects in import-export operations.

KEY POINTS TO NOTE

1. Cosmetic product notification dossier

The amended rule distinguishes 01 electronic copy for online submission and 02 paper copies for direct/postal submission.

2. Product notification form

Enterprises should review Appendices 01-MP and 02-MP, e-signature/digital signature requirements, company seal, page-sealing and formula declaration rules.

3. Dossier supplementation

If the dossier is not compliant, the receiving authority notifies the applicant within 05 working days; a compliant supplemented dossier is processed for issuance of receipt number within 05 working days.

4. Cosmetics for research/testing

Import orders for cosmetics used for research/testing are submitted to the provincial health authority where the entity is headquartered. Maximum quantity: 10 samples per product.

Operational note: before closing documents and before ETA, importers should check the notification receipt, formula, label, commercial invoice, packing list, B/L/AWB, COO where applicable and manufacturer documents.

AFFECTED BUSINESSES / PRODUCTS

Group Impact Documents to review Risk trigger
Importers / distributors Imported cosmetics for commercial circulation in Vietnam. Notification receipt, invoice, packing list, B/L/AWB, contract, COO where applicable, original label and Vietnamese sub-label. Mismatch in product name, formula, manufacturer, owner or responsible entity.
Brand owners Entities responsible for putting cosmetic products on the Vietnamese market. Notification dossier, power of attorney, formula, label, safety/quality data. Incorrect legal entity, representative, distribution right or dossier inconsistency.
Research/testing samples Cosmetics imported for research or testing only. Import order under Appendix 14-MP, product information and intended use. Over 10 samples/product, wrong use purpose or market circulation.
Logistics / compliance teams Document control, customs declaration and shipment coordination. Commercial documents, product dossier, label photos and authority approval if applicable. Commercial documents inconsistent with specialized dossier.

IMPACT ON IMPORT / LOGISTICS OPERATIONS

Operation stage Practical impact Pre-ETA checklist
Before import Classify whether the shipment is for commercial circulation or research/testing. Product name, formula, manufacturer, owner, responsible person/entity and import purpose.
Customs declaration Specialized dossier must match invoice, packing list, transport document and label data. HS code reference, description, quantity, origin, original label, notification receipt or approved import order.
E-filing Online submission and digital signature are relevant control points. Account, digital signature, authorized signer and document format.
Port/warehouse delivery Dossier mismatch may cause storage, delay or additional document requests. Lock specialized documents before ETA.
Post-clearance The market responsible entity is accountable for data accuracy, safety and product quality. Archive dossier by shipment, product notification, label and import documents.

RELATED LEGAL DOCUMENTS TO REVIEW

Type Document Authority Role Notes
Base circular Circular 06/2011/TT-BYT Ministry of Health Base regulation on cosmetic management and product notification. Review together with Circular 34/2025/TT-BYT and consolidated versions.
Amending circular Circular 34/2025/TT-BYT Ministry of Health Amends notification dossier, e-filing and import order for research/testing samples. Effective from 18 Aug 2025.
Decrees 45/2020/ND-CP, 42/2022/ND-CP, 68/2024/ND-CP, 69/2024/ND-CP, 118/2025/ND-CP Government Administrative e-procedures, online public services, digital signatures, e-identification and single-window mechanism. Review when filing dossiers online.
Administrative procedure decision Decision 2393/QD-BYT dated 22 July 2025 Ministry of Health Announces 03 administrative procedures amended under Circular 34/2025/TT-BYT, including the procedure for receiving cosmetic product notification numbers for imported cosmetics. Review when preparing dossiers for the Drug Administration of Vietnam or provincial health authority.
Specialized HS circular Circular 09/2024/TT-BYT Ministry of Health Provides lists of medicines, medicinal ingredients and cosmetics for import/export with determined commodity codes, including List 14 for cosmetics. Use as a specialized HS reference; final HS still depends on actual goods, Vietnam import/export nomenclature and tax schedule at declaration date.
ASEAN framework ASEAN Cosmetic Agreement and Annexes ASEAN / competent authorities Ingredient restrictions, safety and quality framework. Check INCI, restricted ingredients, colorants and fragrances.

VIEW / DOWNLOAD ORIGINAL DOCUMENT

FULL TEXT OF THE LEGAL DOCUMENT

The following text is an unofficial English translation prepared for operational reference. The Vietnamese version and the official PDF remain the controlling source for legal application.

MINISTRY OF HEALTH
No.: 34/2025/TT-BYT
SOCIALIST REPUBLIC OF VIET NAM
Independence – Freedom – Happiness
Ha Noi, 03 July 2025
CIRCULAR
Amending and supplementing a number of articles of Circular No. 06/2011/TT-BYT dated 25 January 2011 of the Minister of Health on cosmetic management

Pursuant to Decree No. 45/2020/ND-CP dated 08 April 2020 of the Government on implementation of administrative procedures in the electronic environment;

Pursuant to Decree No. 69/2024/ND-CP dated 25 June 2024 of the Government on electronic identification and authentication;

Pursuant to Decree No. 42/2022/ND-CP dated 24 June 2022 of the Government on provision of information and online public services by state agencies in the network environment;

Pursuant to Decree No. 42/2025/ND-CP dated 27 February 2025 of the Government prescribing the functions, tasks, powers and organizational structure of the Ministry of Health;

At the proposal of the Director of the Drug Administration of Viet Nam;

The Minister of Health promulgates this Circular amending and supplementing a number of articles of Circular No. 06/2011/TT-BYT dated 25 January 2011 of the Minister of Health on cosmetic management.

Article 1. Amendments and supplements to a number of articles of Circular No. 06/2011/TT-BYT dated 25 January 2011 of the Minister of Health on cosmetic management (hereinafter referred to as Circular No. 06/2011/TT-BYT)

1. Clause 1 Article 4 is amended and supplemented as follows:

“1. Cosmetic product proclamation form: 01 electronic copy for online submission of cosmetic product proclamation dossiers; 02 paper copies for submission in person or by postal service.”.

2. Article 5 is amended and supplemented as follows:

“Article 5. Preparation of the cosmetic product proclamation form

1. The cosmetic product proclamation form shall comply with Appendix No. 01-MP enclosed with this Circular. Instructions for completing the contents of the cosmetic product proclamation form shall comply with Appendix No. 02-MP enclosed with this Circular.

For online submission of cosmetic product proclamation dossiers: the proclamation form must be signed by the legal representative or a person authorized by the legal representative, with full name and seal affixed (electronic signature or digital signature is accepted). Where the organization or individual responsible for placing the product on the market is a household business, the seal of such household business is not mandatory on the proclamation form.

For submission in person or by postal service: the proclamation form must be signed by the legal representative or a person authorized by the legal representative, with full name and seal affixed (stamp-signature is not permitted), and must bear a seal across adjoining pages where the proclamation form consists of 02 pages or more. Where the responsible organization or individual is a household business, the seal of the household business is not mandatory, but the household business owner must sign all pages containing information of the proclamation form.

2. Each cosmetic product shall be proclaimed in one proclamation form.

A cosmetic product completely manufactured at different manufacturing companies shall be proclaimed separately. Where two or more companies participate in manufacturing stages to produce a finished product, they shall be included in one proclamation form and the full name, address and manufacturing stage of each participating company must be clearly stated.

Products of the same product owner falling into one of the following cases may be proclaimed in one proclamation form:

a) Products packaged under a common name and sold as a set;

b) Products bearing the same name and belonging to the same product line with similar formulas but different colors or scents, except hair dye products and perfumes, which shall be proclaimed separately for each color or scent;

c) Other forms as decided by the Drug Administration of Viet Nam – Ministry of Health based on decisions of the ASEAN Cosmetic Committee.

3. Declaration of formula ingredients in cosmetic products:

a) Ingredients in the product formula must be fully listed in descending order of content. Perfume, fragrance, flavour and aroma ingredients and their raw materials may be stated as “perfume, fragrance, flavour, aroma”. Ingredients with a content of less than 1% may be listed in any order after ingredients with a content greater than 1%. Colorants may be listed in any order after other ingredients according to the Color Index (CI) or their names as set out in Annex IV of the ASEAN Cosmetic Agreement. Cosmetic products used for make-up in different colors may list all colorants under “may contain” or “+/-”;

b) The percentage of ingredients subject to concentration or content limits under the Annexes of the ASEAN Cosmetic Agreement must be fully stated. A comma (“,”) shall be used between the integer part and decimal part;

c) Ingredient names must be stated according to the International Nomenclature of Cosmetic Ingredients (INCI) as provided in the latest publications: International Cosmetic Ingredient Dictionary, British Pharmacopoeia, United States Pharmacopoeia, Chemical Abstract Services, Japanese Standard Cosmetic Ingredient, and Japanese Cosmetic Ingredients Codex. Names of plants and plant extracts must be written by scientific name including genus and species (the genus name may be abbreviated). Ingredients of animal origin must state the exact scientific name of the animal species;

d) The following substances shall not be regarded as cosmetic ingredients:

– Impurities in the raw materials used;

– Subsidiary materials used for technical purposes but not present in the finished product;

– Materials used in necessary quantities as solvents or carriers for fragrance ingredients.

4. The language used in the proclamation form shall be Vietnamese or English. The contents stated in item 3 (Intended use), item 8 (Information on the organization or individual responsible for placing the product on the market), item 9 (Information on the legal representative of the company), and item 10 (Information on the importing company) in the proclamation form must be written in Vietnamese or in Vietnamese and English.”.

3. The introductory sentence of Clause 1 and Point b Clause 2 Article 7 are amended and supplemented as follows:

a) The introductory sentence of Clause 1 Article 7 is amended and supplemented as follows:

“1. An establishment shall submit 01 set of cosmetic product proclamation dossier to the competent state management agency in accordance with Article 15 of Decree No. 118/2025/ND-CP dated 09 June 2025 of the Government on implementation of administrative procedures under the single-window and inter-agency single-window mechanism at the Single-Window Section and the National Public Service Portal.

Where the dossier is submitted on the National Public Service Portal, the establishment shall comply with Decree No. 45/2020/ND-CP dated 08 April 2020 on implementation of administrative procedures in the electronic environment, as amended and supplemented in 2022 and 2025, Decree No. 68/2024/ND-CP dated 25 June 2024 on specialized digital signatures for public service, and Decree No. 69/2024/ND-CP dated 25 June 2024 on electronic identification and authentication:”;

b) Point b Clause 2 Article 7 is amended and supplemented as follows:

“b) Where the proclamation dossier does not satisfy the requirements of this Circular, within 05 working days from the date of receipt of the dossier, the receiving agency shall notify the declaring organization or individual in writing of the non-compliant contents for amendment and supplementation, clearly specifying such contents.

Within 05 working days from the date of receipt of a supplemental dossier satisfying the requirements of this Circular, the competent state management agency shall issue the receipt number of the cosmetic product proclamation form.

Where the amended or supplemented dossier does not satisfy the requirements of this Circular, within 05 working days from the date of receipt of the supplemental dossier, the receiving agency shall notify in writing that the receipt number of the cosmetic product proclamation form shall not be issued for such product.

The establishment’s supplemental dossier includes:

– A written explanation on the amendments and supplements made by the organization or individual named in the proclamation;

– The cosmetic product proclamation form together with other amended or supplemented documents.”.

4. Point a Clause 2 Article 35 is amended and supplemented as follows:

“a) Organizations and individuals importing cosmetics for research or testing shall submit an order for import of cosmetics for research and testing according to Appendix No. 14-MP enclosed with this Circular to the specialized health agency under the provincial People’s Committee where the establishment’s head office is located. The maximum quantity for each product is 10 samples.

For online submission: 01 electronic copy of the order signed by the legal representative or a person authorized by the legal representative, with full name and seal affixed (electronic signature or digital signature is accepted). Where the organization or individual is a household business, the seal of the household business is not mandatory on the order.

For submission in person or by postal service: 02 paper copies of the order signed by the legal representative or a person authorized by the legal representative, with full name and seal affixed (stamp-signature is not permitted), and bearing a seal across adjoining pages where the order consists of two pages or more. Where the organization or individual is a household business, the seal of the household business is not mandatory, but the household business owner must sign all pages containing information of the order. After approval, 01 copy shall be kept by the specialized health agency under the provincial People’s Committee and 01 copy shall be sent to the establishment. The copy sent to the establishment shall bear the stamp “Copy sent to establishment” for presentation to the customs authority when carrying out customs clearance procedures.

Within 03 working days from the date of receipt of the order for import of cosmetics for research and testing, the specialized health agency under the provincial People’s Committee shall approve the order. In case of refusal, it must notify in writing and clearly state the reason.

Cosmetic products imported for research and testing must be used for the correct purpose and must not be placed on the market.”.

5. Clause 1 Article 48 is amended and supplemented as follows:

“1. The organization or individual responsible for placing a cosmetic product on the market shall be fully responsible before law for the accuracy, legality and truthfulness of the contents declared in the cosmetic product proclamation form and documents in the cosmetic product proclamation dossier; shall be responsible for the conformity and consistency of information on the cosmetic product proclamation form prescribed in Clause 1 Article 5 of this Circular with information in documents in the cosmetic product proclamation dossier submitted to the receiving agency; and shall be fully responsible for the safety, efficacy and quality of the product, ensuring that the product placed on the market satisfies all requirements of the ASEAN Cosmetic Agreement and its Annexes.”.

6. Appendix No. 14-MP is replaced by the Appendix enclosed with this Circular.

Article 2. Replacement of a number of phrases in Circular No. 06/2011/TT-BYT

1. The phrase “Department of Health” is replaced with “specialized health agency under the provincial People’s Committee” at Point b Clause 1 Article 7.

2. The phrase “Ha Noi Department of Health” is replaced with “specialized health agency under the Ha Noi People’s Committee” in Article 8 and Appendix No. 11-MP enclosed with Circular No. 06/2011/TT-BYT.

3. Relevant phrases referring to provincial Departments of Health in Clause 4 Article 33, Point b Clause 1 Article 41, Point b Clause 2 Article 45, Point b Clause 2 Article 46, Points a and b Clause 1 Article 41, Clauses 2 and 3 Article 50, Clause 4 Article 50, and Appendices No. 10-MP, 11-MP, 15-MP, 16-MP and 17-MP enclosed with Circular No. 06/2011/TT-BYT are replaced with “specialized health agency under the provincial People’s Committee”.

4. The phrase “by post” is replaced with “by postal service” in Clause 1 Article 38.

5. The phrase “Directors of Departments of Health of provinces and centrally-run cities” is replaced with “Heads of specialized health agencies under provincial People’s Committees” in Clause 3 Article 53.

6. The phrase “(PROVINCIAL / MUNICIPAL) HEALTH SERVICE” is replaced with “PROVINCIAL HEALTH SERVICE” in Appendix No. 12-MP enclosed with Circular No. 06/2011/TT-BYT.

Article 3. Effect

This Circular takes effect from 18 August 2025.

Article 4. Transitional provisions

Dossiers submitted before the effective date of this Circular may continue to be processed in accordance with the regulations applicable at the time of submission, or may apply the provisions of this Circular from its effective date in a manner that facilitates and simplifies administrative procedures for enterprises, organizations and individuals.

Article 5. Reference clause

Where legal normative documents and provisions referred to in this Circular are amended, supplemented or replaced, the new legal normative documents shall apply.

Article 6. Implementation responsibility

1. Provincial and centrally-run municipal People’s Committees shall direct specialized health agencies under provincial People’s Committees to implement the settlement of administrative procedures for issuance of cosmetic product proclamation receipt numbers for domestically manufactured cosmetics and approval of orders for import of cosmetics for research and testing under this Circular in online form.

2. The Chief of the Ministry Office, the Director of the Drug Administration of Viet Nam, heads of units under and affiliated to the Ministry of Health, heads of specialized health agencies under provincial People’s Committees, and relevant agencies, organizations and individuals shall be responsible for implementing this Circular.

If difficulties or problems arise during implementation, agencies, organizations and individuals are requested to report them to the Ministry of Health (Drug Administration of Viet Nam) for consideration and resolution./.

FOR THE MINISTER
DEPUTY MINISTER

Do Xuan Tuyen

APPENDIX
Enclosed with Circular No. 34/2025/TT-BYT dated 03 July 2025 of the Minister of Health

Appendix No. 14-MP: Form of order for import of cosmetics for research and testing

NAME OF ESTABLISHMENT
No.: …

SOCIALIST REPUBLIC OF VIET NAM
Independence – Freedom – Happiness
…, date … month … year …

ORDER
FOR IMPORT OF COSMETICS FOR RESEARCH AND TESTING

To: Specialized health agency under the provincial People’s Committee(1)

(Name of establishment) … requests the specialized health agency under the provincial People’s Committee(1)… to approve import of the following cosmetics for research and testing:

No. Name of cosmetic, dosage form, packaging specification Product form Formula ingredients Unit Quantity(2) Manufacturer and country Notes
1
2
3

The specialized health agency under the provincial People’s Committee(1)… approves the import order consisting of … pages … items attached to Official Letter No. …………. dated … month … year … of the specialized health agency under the provincial People’s Committee(1).

The order for import of cosmetics for research and testing is valid for one time only./.

HEAD OF AGENCY
(Signature, seal and full name of signer)
DIRECTOR OF ESTABLISHMENT
(Signature, seal and full name of signer)

(1) Specialized health agency under the provincial People’s Committee where the establishment’s head office is located.

(2) The maximum quantity for each product is 10 samples.

FAQ

1. When does Circular 34/2025/TT-BYT take effect?

It takes effect on 18 August 2025.

2. Does it affect imported cosmetics?

Yes. It affects notification dossiers, product data consistency and import orders for research/testing samples.

3. What about research/testing samples?

An import order under Appendix 14-MP is required where applicable; maximum quantity is 10 samples per product and products must not be circulated on the market.

4. Does it change HS code or tax?

No direct tariff change is made by this Circular; HS and tax must be reviewed separately based on the final product dossier, current tariff and Circular 09/2024/TT-BYT where relevant.

5. Can dossiers be filed online?

The Circular supports e-dossier and digital signature/e-signature requirements where applicable.

6. What should be checked before ETA?

Notification receipt, label, formula, invoice, packing list, B/L/AWB, origin data and manufacturer documents.

TGIMEX SOLUTIONS

For cosmetics, the key risk is usually data inconsistency between notification dossier, label, formula, manufacturer, responsible entity and import documents. The following controls are operational references and do not replace authority decisions.

Capability Control scope Operational value
Legal review Review original legal text, effective date, amended clauses, Appendix 14-MP and dossier-specific conditions. Identify the correct treatment: commercial goods, research/testing samples or other scenarios.
Document control Cross-check invoice, packing list, B/L/AWB, contract, label, formula, notification receipt and POA. Reduce mismatch risks in product name, form, origin, manufacturer and responsible entity.
Operational coordination Pre-ETA timeline, customs coordination, international transport, port/warehouse handling and document supplementation plan. Limit storage, delay and late dossier requests.
Post-clearance control Archive shipment dossiers, label data, product notification and manufacturer documents. Improve post-clearance and market circulation readiness.

Recommendation: review Circular 34/2025/TT-BYT before document lock and before ETA.

QUICK CONSULTATION

NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?

Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.

CALL NOW
Zalo
HOTLINE 0963 856 664 / 0982 135 393
EMAIL info@tgimex.com
SUITABLE FOR International shipping · Customs procedures · Import licenses · B2B logistics

Leave a Reply

Discover more from TGIMEX VIETNAM JSC

Subscribe now to keep reading and get access to the full archive.

Continue reading