Customs clearance does not automatically mean that imported goods may be sold immediately. For products whose original labels are in a foreign language, the critical control point sits between two milestones: the physical original label must contain the minimum data required at customs clearance, while the Vietnamese-language information must be completed before the goods are placed into circulation in the Vietnamese market. If the warehouse, sales team and transport provider fail to distinguish these stages, goods may leave quarantine before the supplementary label is approved, may be labelled only partially, or may carry information inconsistent with the registered product dossier. This article explains the current legal milestone, the data that must be reconciled, the responsibility of each function, and the release controls required from customs clearance to commercial distribution.

TGIMEX operational guidance · Legal update: 20 July 2026

QUICK FACTS

Core legal milestone

The Vietnamese supplementary label must be completed before the goods are placed into circulation in Vietnam.

Clearance is not final release

At customs clearance, the physical original label must carry the minimum required data. Vietnamese information should be completed after clearance only within the statutory non-circulation exception: transport from the border checkpoint to the first storage warehouse and storage at that warehouse, unless sector-specific law requires an earlier milestone.

Warehouse quarantine is essential

Pending goods must be quarantined at the first storage warehouse. Before transfer to a second warehouse, another 3PL or a commercial channel, the supplementary label should be completed unless a specific legal basis permits otherwise.

Application matters, not only artwork

The approved label must be correctly attached to the goods or commercial packaging without obscuring mandatory original-label information.

Operational conclusion: The supplementary label may be completed after customs clearance at the first storage warehouse, but it must be approved and fully applied before any subsequent step constitutes circulation. Use three separate statuses: customs cleared, quarantined at first warehouse and released for circulation.

Illustration for When must a supplementary label for imported goods be completed? — Illustration of the logistics topic, document or operation discussed in the article.

SCOPE OF APPLICATION

This article applies to imported goods bearing a foreign-language original label and intended for circulation in Vietnam. It focuses on post-clearance labelling at the first storage warehouse, inter-warehouse transfer and commercial release. Temporary imports for re-export, transit, merchanting, transshipment, goods placed in a bonded warehouse for export to a third country and other excluded or sector-regulated cases require separate review.

Legal note: Decree 37/2026/ND-CP took effect on 23 January 2026; Decree 43/2017/ND-CP and Decree 111/2021/ND-CP ceased to have effect on the same date. Article 98, however, contains transitional rules for goods produced, imported, circulated or used, and for labels or commercial packaging printed, before 23 January 2026. Food, cosmetics, medicines, medical devices, veterinary drugs, chemicals and other sector-regulated goods must also be reviewed against the applicable sector rules.

KEY TERMS

Term	Meaning	Operational role
Original label	The label first applied to the goods or their commercial packaging.	It is checked for minimum mandatory data at customs clearance.
Supplementary label	A label providing Vietnamese translations of mandatory original-label content and adding mandatory information that is missing.	It enables lawful circulation in Vietnam while preserving the original label.
Customs clearance	Completion of customs procedures subject to the conditions applicable to the shipment.	It does not replace the labelling obligation before circulation.
Release for circulation	All activities that place goods on the market, including display, promotion, transport, preservation, storage and sale. The specific exclusion covers only transport from the border checkpoint to the first storage warehouse and storage at that warehouse.	The label-completion gate; it must not be reduced to the moment of sale or customer delivery alone.
Label quarantine	An internal warehouse status for goods whose supplementary labels have not been approved or applied.	It prevents accidental release before legal and QA requirements are met.

OPERATING PRINCIPLE

Decree 37/2026/ND-CP creates two different data gates: original-label data at customs clearance and Vietnamese information before the goods enter circulation. The correct process is therefore neither “supplementary labels are always required before filing the declaration” nor “cleared goods may be moved anywhere and labelled later”.

Article 3(9) defines circulation to include transport, preservation and storage, while excluding only transport of imported goods from the border checkpoint to the first storage warehouse and storage at that warehouse. If goods are to be moved from the first warehouse to a second warehouse or another 3PL for labelling, that movement must be assessed in advance and, as a rule, the supplementary label should be completed before transfer unless a sector rule or specific approval provides otherwise.

Minimum original-label data at customs clearance

Name of the goods
Origin of the goods; where origin cannot be determined, the place of the final completion stage must be stated as prescribed
Full or abbreviated name and address of the foreign manufacturer or foreign entity responsible for the goods; where full details are not on the original label, they must appear in accompanying documents or shipment documents

Control point: A supplementary label cannot cure the absence of the product name or origin on the original label at customs clearance, nor legitimise inaccurate or misleading original information. For the foreign producer or responsible entity, Article 42(2)(c) expressly allows the full name and address to appear in accompanying documents or shipment records when not fully shown on the original label.

TIMING AND RELEASE CONDITIONS

Stage	Required action	Acceptance condition	Risk	Control point
Before and at customs clearance	Review the physical original label and shipment documents.	Product name, origin and foreign responsible entity must meet the rule and match the dossier.	Minimum original-label or permitted supporting-document data are missing.	Do not proceed without resolving the data gap.
From the border to the first storage warehouse	Transport directly to the first warehouse and receive the goods into label quarantine.	Evidence identifies the location as the first storage warehouse; SKU, lot, quantity and commercial status are locked.	The first-warehouse status cannot be evidenced or pending goods are mixed with saleable stock.	HOLD/LABEL PENDING; no sales allocation or inter-warehouse dispatch.
Before leaving the first storage warehouse	Complete, apply and inspect the supplementary label before moving goods to a second warehouse, another 3PL or a distribution point.	Correct content and SKU, no obstruction of original data, and complete release records.	Subsequent transport or storage may constitute circulation while the goods remain improperly labelled.	Allow transfer only after LABEL RELEASED, unless a specific legal basis permits another flow.
Before circulation	Verify completion against the approved master.	Correct content and SKU; durable, legible application; original label remains visible.	Goods enter sales channels with missing or incorrect labels.	Release only after QA/Compliance approval.
After commercial release	Retain records and monitor changes.	Approved artwork, retained sample, lot list, labelling records and inspection evidence.	The label version cannot be traced during inspection or complaint handling.	Manage versions and link them to SKU and lot.

DOCUMENTS AND DATA TO VERIFY

Data field	Source	Control requirement	Owner
Product name	Original label, commercial invoice, registration/notification dossier	Same product nature and intended use; translation must not change the product category.	QA/Regulatory
Origin	Original label, certificate of origin if any, import dossier	Vietnamese wording must be clear; the packing location must not be presented as origin unless legally correct.	Import/Compliance
Responsible entities	Original label, invoice/shipment documents, importer registration	Distinguish foreign manufacturer, foreign responsible entity and Vietnamese responsible entity.	Legal/Regulatory
Quantity, ingredients, dates	Original label, specification, COA, sector dossier	Correct units, formats and category-specific mandatory scope.	QA/R&D/Regulatory
Instructions, storage, warnings	IFU, SDS, product dossier, sector rules	Translate fully; do not weaken warnings or change conditions of use.	QA/Safety
SKU, lot and barcode	Packing list, ERP/WMS, carton and unit labels	Match the correct variant, volume, model and lot.	Warehouse/IT/QA
Labelling completion status	Labelling record, sampling record, inspection photos	Evidence of labelled quantity and acceptance before release.	Warehouse/QA

RESPONSIBILITY MATRIX

Party	Responsibility	Decision or control gate
Importer	Organises Vietnamese labelling and prevents incompletely labelled goods from entering circulation.	Approves scope, budget and accountable owner.
Regulatory/Legal	Determines general and sector-specific mandatory information; reviews translation, claims and warnings.	Approves the master label and version.
Warehouse/3PL	Quarantines stock, identifies SKU and lot, performs labelling and reconciliation.	Must not dispatch stock until RELEASED.
QA/QC	Checks first-off samples, in-process quality and completion.	Signs release under the applicable sampling or 100% inspection plan.
Sales/Distribution	Accepts only commercially released stock.	Must not schedule delivery, display or promotion before release.
Customs broker/Forwarder	Supports original-label data checks at import within the authorised scope.	Does not replace the importer’s legal responsibility for market labelling.

IMPLEMENTATION PROCESS

Collect original-label and product documents

Gather images of every label panel, invoice, packing list, specification, sector approvals and translation source files.

Check the customs gate

Confirm that the physical original label contains the minimum data under Article 42(2), with valid supporting documents where permitted.

Prepare the supplementary-label master

Translate mandatory information, add missing items and lock product name, origin, responsible entities and sector-specific text.

Approve before mass printing

Regulatory, QA and the responsible entity approve the final artwork, text size, label position and non-obstruction of the original label.

Quarantine at the first storage warehouse

Assign LABEL PENDING status by SKU and lot at the first warehouse; block sales orders, inter-warehouse transfers and movement into saleable storage.

Apply labels and inspect

Follow the work instruction; inspect first-off, in-process samples and any mislabelling or damaged labels.

Confirm completion before circulation

Reconcile quantities, retained sample, labelling record and inspection result; sign RELEASED.

Retain records and control changes

Link label version to SKU and lot; reapprove when the original label, formula, claim, address or law changes.

RISKS AND COMMON ERRORS

Error	Cause	Impact	Control
Treating clearance as permission to sell	ERP makes stock saleable immediately after receipt.	Goods may circulate without Vietnamese labels.	Separate customs-cleared status from commercial-release status.
Labelling without warehouse quarantine	Pending goods are stored with released goods.	Accidental dispatch and uncontrolled partial labelling.	Use a physical HOLD area, WMS block and dual count.
Transfer to a second warehouse or 3PL before labelling	Assuming that every internal or outsourced warehouse remains outside circulation.	The next transport or storage step may occur while the goods lack the required Vietnamese label.	Block warehouse transfer; complete labelling at the first warehouse or obtain a clear legal/sector basis before movement.
Accurate translation from the wrong source	Text is copied from an old email or catalogue.	Conflict with the original label, registration, licence or origin documents.	Define the authoritative source for each data field and control versions.
Obscuring original data or traceability codes	Label position is not tested on actual packaging.	Mandatory information, lot/date or barcode becomes unreadable.	Approve a mock-up on the actual pack.
One master for multiple variants	Similar names but different model, volume or ingredients.	Wrong-SKU labelling.	Control the master by SKU and scan the barcode before application.
Ignoring sector-specific law	The review relies only on Decree 37.	Registration number, warning, directions or other special content may be missing.	Use a regulatory matrix by product category.

LEGAL BASIS AND OFFICIAL SOURCES

Source	Authority	Status	Purpose
Law 78/2025/QH15	National Assembly	Effective 1 January 2026	Amends the Law on Product and Goods Quality and underpins the new framework.
Decree 37/2026/ND-CP	Government	Effective 23 January 2026	Article 3(9) defines circulation; Articles 39–40 govern language and supplementary labels; Article 42(2) governs original-label data at clearance and Vietnamese labelling before circulation; Articles 97–98 govern effect and transition.
Q&A: Original labels of imported goods	Ministry of Science and Technology / National Standards Authority	Updated 22 June 2026	Confirms Vietnamese labelling before goods are placed into circulation.
Guidance on labelling under Decree 37	Ministry of Science and Technology	Updated 10 March 2026	Clarifies supplementary labels, translation and origin wording before circulation.
Q&A on the responsible entity stated on labels	Ministry of Science and Technology	Updated 2026	Guides how the name and address of the organisation or individual responsible for the goods should appear on the label.

View Decree 37/2026/ND-CP Read official Ministry guidance

FREQUENTLY ASKED QUESTIONS

Must the supplementary label be attached before the customs declaration is filed?

Not in every case. At customs clearance, the physical original label must contain the minimum data prescribed by Article 42(2). Vietnamese information must be completed before circulation, unless sector-specific law or a particular procedure requires an earlier milestone.

Are customs-cleared goods stored in a warehouse already “in circulation”?

Under Article 3(9), transport from the border checkpoint to the first storage warehouse and storage at that warehouse are excluded from circulation. Outside that limited exclusion, transport, preservation and storage fall within circulation; the mere fact that goods are “still in a warehouse” is therefore not decisive.

Can a 3PL warehouse apply the labels?

Yes, if that 3PL is the first storage warehouse receiving the goods directly from the border and the importer maintains appropriate quarantine, records and controls. If goods must move from the first warehouse to another 3PL for labelling, complete the label before transfer or establish a specific legal basis for that flow.

Is approved artwork alone sufficient?

No. The label must be correctly attached to the goods or commercial packaging, must not obscure mandatory original-label data and must pass release verification.

Can a supplementary label be electronic?

Decree 37 permits electronic supplementary labels subject to Chapter IV, but this does not mean every mandatory item may be electronic. The imported original label must still physically show the minimum customs-clearance data; medium- and high-risk goods and sector rules may also require mandatory information on a physical label.

Can an incorrect origin statement on the original label be corrected by a supplementary label?

A supplementary label should not be used to legitimise incorrect or misleading original-label information. Origin is mandatory at customs clearance; an error must be handled based on the shipment facts and competent-authority guidance.

Must goods or packaging existing before 23 January 2026 be relabelled immediately?

Not in every case. Article 98 allows goods produced, imported, circulated or used before Decree 37 took effect to continue in circulation until their stated expiry; labels and commercial packaging lawfully printed under the former rules before that date may continue to be used, but for no more than two years from 23 January 2026. Keep evidence of the production, import or printing date.

APPLICATION NOTE: The core milestone is “before the goods enter circulation”, but the warehouse exception is limited to transport from the border checkpoint to the first storage warehouse and storage there. The safer model is to label at the first warehouse, block all sale and transfer orders, and release the goods only after content, quantity and inspection evidence have been verified.

TGIMEX IMPLEMENTATION SUPPORT

TGIMEX helps businesses turn the article into a shipment-ready checklist, covering input-data review, dossier preparation, milestone control, and coordination with the relevant parties.

Convert guidance into checks

Assign an owner and deadline to every operational control point.

Reconcile shipment data

Compare booking, transport, commercial, customs, and delivery evidence.

Manage operational risk

Record discrepancies, actions, and decision evidence to prevent recurrence.

Discuss your shipment dossier

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