Vietnam Cosmetics Registration: What Japanese Cosmetics Manufacturers Need to Know

Japanese brands now represent the third-largest share of Vietnam’s imported cosmetics market, reflecting strong and growing demand for Japanese skincare, makeup, and personal care products. However, entering Vietnam — a market where foreign brands make up over 90% of the market — requires more than strong brand demand. While trade agreements offer meaningful advantages, market access ultimately depends on regulatory readiness, as Vietnam enforces a strict, documentation-driven compliance framework for foreign manufacturers.

Continue below for the key points Japanese companies need to know when entering Vietnam, or get in touch with Cisema for assistance with Vietnam cosmetics registration and market entry compliance.

Understanding Vietnam’s Cosmetics Regulatory Framework

Vietnam regulates cosmetics through a notification-based system administered by the Drug Administration of Vietnam under the Ministry of Health. Cosmetics are not subject to pre-market technical approval; instead, regulatory control is exercised through formal notification, inspections, and post-market enforcement.

A defining feature of this system is the requirement for a locally established responsible entity. This entity assumes legal responsibility for the product once it is placed on the Vietnamese market, enabling authorities to conduct post-market surveillance, investigate safety concerns, and require corrective action where necessary. For Japanese manufacturers, this means regulatory obligations extend beyond export and continue throughout the product’s lifecycle in Vietnam.

Vietnam’s Alignment With the ASEAN Cosmetic Directive

Vietnam’s cosmetics framework is aligned with the ASEAN Cosmetic Directive, which harmonizes safety, ingredient, and labeling requirements across ASEAN member states. Vietnam implements this framework through national regulations and administrative guidance that reflect local enforcement priorities.

What This Means for Japanese Manufacturers

As a result, Japanese manufacturers must evaluate compliance across multiple layers:

• ASEAN-wide cosmetic safety and labeling standards
• Vietnam-specific regulatory interpretations
• Product-level risk factors such as ingredients, claims, and intended users

Clarifying these layers early helps determine whether existing Japanese products can be introduced into Vietnam with minimal adjustment, or whether formulation, labeling, or positioning changes are required.

Once regulatory expectations are clear, attention should shift to product readiness before notification.

Determining Product Suitability for the Vietnamese Market

Before proceeding with notification, Japanese manufacturers must confirm that products are suitable for Vietnam’s regulatory environment. Ingredient compliance is often the most sensitive and time-intensive part of this assessment.

Cosmetic Ingredient Compliance in Vietnam

At the regional level, ingredients permitted for use in cosmetics in Vietnam are regulated under the ASEAN Cosmetic Directive (ACD). Detailed requirements are set out in the negative lists contained in ACD Annexes II to VII, which specify prohibited substances, restricted substances, and permitted preservatives, colorants, and ultraviolet (UV) filters.

In addition, Vietnam applies national controls under its Cosmetic Management Regulation. Article 14 of Chapter IV (Cosmetic Safety Requirements) publishes lists of prohibited cosmetic ingredients and restricted concentration limits established by the Drug Administration of Vietnam (DAV).

As a result, Japanese manufacturers should be aware that:

• Ingredients permitted in Japan may not be permitted in Vietnam
• Acceptable concentration limits may differ from Japanese standards
• Products with functional or borderline claims often face closer regulatory scrutiny

Importantly, even ingredients not listed in the ASEAN annexes may still be prohibited by the DAV. Conducting a thorough ingredient review early therefore helps avoid rejected notifications, reformulation, and delays to market entry.

Preparing Compliant Labels for the Vietnam Market

Labeling is the most visible element of compliance and one of the most frequently inspected. All cosmetics sold in Vietnam must bear labels that clearly and accurately communicate required information.

In accordance with the ASEAN Cosmetic Directive, labels must include:

• Product name and function
• Instructions for use
• Full ingredient list using INCI names
• Country of origin
• Domestic distributor or responsible party name
• Net content
• Batch or lot number
• Manufacturing or expiration date
• Precautions for use

While labels may be in English or Vietnamese, the domestic distributor’s name and precautions for use must appear in Vietnamese. In practice, Japanese manufacturers often rely on supplementary Vietnamese labels applied after import, making early coordination with local partners particularly important.

Once formulation and labeling are aligned, manufacturers can move forward with formal market notification.

Securing Market Access Through Cosmetic Notification

Before imported cosmetics may be sold on the Vietnamese market, a locally appointed third-party — such as a Local Authorized Representative — must complete the cosmetic notification procedure and obtain a Cosmetic Notification Number from the Drug Administration Department of the Ministry of Health. Through this process, the responsible party formally declares the product’s intended use, safety, efficacy, and quality.

Although a full technical dossier is not submitted at the notification stage, authorities may request supporting documentation during inspections or post-market reviews.

In practical terms, the key features of Vietnam’s cosmetic notification framework include:

• The typical notification timeline is approximately 2-3 months from the submission date
• Each Cosmetic Notification Number is valid for 5 years
• Renewal is mandatory prior to expiration to maintain uninterrupted market access
• Re-notification is required if there are changes to the formulation, labeling, product name, or intended use
• For a walkthrough of the procedure, timelines, and fees, see Cosmetic Product Registration and Notification in Vietnam

For Japanese manufacturers, this reinforces the need to clearly define regulatory roles, data ownership, and update responsibilities with local Vietnamese partners.

Free Sale Certificate Exemption for Japanese Cosmetics Under CPTPP

While a Free Sale Certificate is normally required for cosmetic notification, an important exception applies to Japanese manufacturers. Because Japan and Vietnam are both parties to the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), cosmetic products manufactured and lawfully sold in Japan are exempt from this requirement when submitting a cosmetic notification.

This exemption reduces administrative burden, but it does not eliminate the obligation to demonstrate full compliance if requested by authorities.

With notification secured, products can move on to importation.

Importing Cosmetics Into Vietnam: Customs and Cost Considerations

Once cosmetic notification is secured, focus shifts to execution — specifically customs clearance and total landed cost. Smooth coordination at this stage is essential to avoid delays and cost overruns.

Customs Procedures and Required Import Documents

Under Circular 38/2015/TT-BTC, cosmetic imports must be formally declared through Vietnam’s customs system using a customs declaration supported by the required documentation. Customs clearance is only permitted when a valid Cosmetic Notification Number is in place..

For Japanese manufacturers, this notification is held by a locally established entity, most often a Local Authorized Representative or Vietnamese partner. Where the notification holder is not the importer of record, the notification holder must provide written authorization. Any changes to importer information must be updated in the notification before shipment, as customs authorities verify notification data against import documents.

The importer is generally required to submit the following:

• Customs declaration form (two originals)
• Sales contract (one copy)
• Commercial invoice (original and one copy)
• Bill of lading (original and one copy)
• Cosmetic Notification Number issued by the Ministry of Health
• List of goods, where products are diverse or separately packaged (one copy)
• Certificate of Origin (C/O)
• Other documents required under applicable laws (original and one copy)

Customs delays most often arise from inconsistencies between notification data and shipping documentation. For Japanese manufacturers, early document alignment with Vietnamese partners helps avoid disruptions.

Import Duties, Preferential Tariffs, and VAT for Japanese Companies

Import duties and taxes directly affect pricing and margin planning. Most cosmetics are classified under Harmonized System (HS) codes 3304–3307 and are subject to Most-Favored-Nation (MFN) duty rates of 6–22%, depending on product classification.

Japanese manufacturers may reduce duties through applicable trade agreements:

• ASEAN–Japan Comprehensive Economic Partnership Agreement (AJCEP)
• Japan–Vietnam Economic Partnership Agreement (JVEPA)
• Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP)

Under the CPTPP, eligible cosmetics imported from Japan may qualify for a 0% import duty rate, provided CPTPP rules of origin are met and a valid CPTPP Certificate of Origin is submitted.

In addition to import duties, Vietnam applies a 10% Value Added Tax (VAT), calculated on the import contract price plus applicable duties. Accounting for both duties and VAT early supports accurate pricing, margin control, and clearer distributor negotiations.

Key Compliance Tips for Japanese Cosmetic Manufacturers

With Vietnam’s regulatory framework and Japan’s trade position in mind, Japanese manufacturers can reduce risk and improve predictability by focusing on three practical priorities.

Tip 1: Leverage Japan’s Trade Benefits With Documentation Discipline

Japanese manufacturers benefit from Vietnam–Japan trade arrangements, including exemptions and preferential tariffs under the CPTPP. These advantages can reduce both documentation burden and landed cost, but only when products are clearly manufactured and lawfully sold in Japan and supporting records remain consistent across regulatory and customs filings.

Tip 2: Validate Products Against Vietnam Rules, Not Japanese Standards

Compliance with Japanese cosmetic standards does not automatically satisfy ASEAN or Vietnam requirements. Products must be reassessed for ingredient eligibility, concentration limits, and labeling rules, as reliance on Japanese approvals alone can be a cause of notification delays and post-market issues..

Tip 3: Separate Regulatory Control From Commercial Distribution

Beyond product compliance, structural decisions also shape long-term outcomes. Vietnam places ongoing legal responsibility for cosmetic compliance on the locally established notification holder, even when formulation and product decisions remain in Japan. This makes the choice of notification holder a strategic governance decision.

If a commercial importer or distributor holds the notification, regulatory control is tied to the commercial relationship. That party controls renewals, amendments, and importer authorizations, creating compliance and supply risk if priorities change or partnerships end. By contrast, appointing an independent regulatory partner — such as Cisema — as the notification holder decouples compliance from distribution, allowing Japanese manufacturers to change importers or distributors without re-registering products.

From Japan to Vietnam: Building Long-Term Market Access

Vietnam offers a clear opportunity for Japanese cosmetic brands, but success depends on navigating a demanding regulatory environment with care. Treating Vietnam cosmetics registration as an ongoing responsibility rather than a one-time task helps Japanese cosmetics brands and manufacturers keep products on the market and expansion plans on track.

Cisema supports Japanese cosmetic brands and manufacturers throughout the Vietnam cosmetics registration process, from ingredient and labeling review to notification submission, customs coordination, and post-market compliance. With Japanese-, English-, and Vietnamese-speaking professionals, Cisema bridges communication between teams in Japan and stakeholders in Vietnam, helping cosmetics brands and manufacturers enter the market with clarity and confidence.

For support with Vietnam cosmetics registration and market entry planning, get in touch with Cisema to discuss your products and timelines.

Further Information

• Explore Cisema’s services for Vietnam cosmetics registration
• Read our comprehensive guide to Vietnam cosmetics registration

References

• ASEAN Cosmetic Directive
• Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP):
  • Official agreement text
  • Agreement background and history
• Japan–Vietnam Economic Partnership Agreement
• ASEAN–Japan Comprehensive Economic Partnership Agreement
• Circular 38/2015/TT-BTC issued by the Ministry of Finance (Vietnamese)