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Export compliance | Vietnam revises cosmetics management circular letter, promote electronic declaration

On February 10, 2025, the Vietnam Drug Administration (DAV) issued a draft circular to amend and supplement certain provisions and appendices of Circular No. 06/2011/TT-BYT, which concerns cosmetic management. The main adjustments and additions include:

### Articles and Amendments

#### Article 1: Amendments and Supplements

##### Cosmetic Product Declaration Method (Article 4)
- Declaration documents can be submitted online, in paper form, or via postal service.

##### Declaration Document Requirements (Article 4, Clause 1)
- Online submission: Requires one copy of the cosmetic product declaration form.
- Paper or postal submission: Requires two copies of the cosmetic product declaration form.

##### Filling and Signing Requirements for Declaration Forms (Article 5)
- Online submission: Must use an electronic signature and company seal, complying with Decree No. 130/2018/NĐ-CP.
- Paper submission: Must be signed by the legal representative, stamped with the company seal, and include a cross-page seal.

##### Responsibilities of the Declaring Company (Article 5, Clause 2)
- The declaring company must ensure the authenticity, legality, and accuracy of all submitted information and bear full legal responsibility.

##### Submission Methods (Article 7, Clause 1)
Declaration documents can be submitted via:
1. Online submission (National Public Service Portal, Provincial/Ministerial Public Service Portals).
2. Paper submission to the national regulatory agency.
3. Postal submission.

##### Import of Cosmetics for Research and Testing (Article 35)
- Research institutions or enterprises must submit a Cosmetic Import Application for Research and Testing (Appendix 14-MP) to the Provincial Department of Health for approval.
- A maximum of 10 samples per cosmetic product (based on the smallest commercial packaging unit).
- Limited to one import per year.

##### Submission Methods for Research Cosmetic Imports (Article 35)
- Online submission (Provincial Public Service Portal): one set of documents.
- Paper or postal submission: three sets of documents.
- Upon approval, two copies will be archived at the Department of Health, and one copy will be returned to the enterprise with a “Company Archive” stamp for customs review.

##### Appendix Modification (Appendix 14-MP)
- Adjustments to the Cosmetic Import Application Form for Research and Testing.

#### Article 2: Effective Date
- This circular will come into effect on July 1, 2025.

#### Article 3: Reference Clauses
- If any referenced regulations in this circular are amended or revised, the latest version shall apply.

#### Article 4: Implementation Responsibility
- Relevant agencies and individuals (including the Ministry of Health, provincial health departments, enterprises, and research institutions) must strictly comply with this circular.
- Any difficulties or issues should be reported to the Vietnam Ministry of Health (Drug Administration) for further review and resolution.

### Appendix 14-MP: Cosmetic Import Application for Research and Testing

| Item | Content Requirements |
|------|----------------------|
| Applicant | Name of enterprise or research institution |
| Submission Entity | Provincial Department of Health |
| Cosmetic Information | Product name, specifications, ingredients, quantity, manufacturer, country of origin, etc. |
| Usage Restrictions | Imported cosmetics are strictly for research and testing purposes and may not be sold on the market. |
| Application Validity | Only applicable for a one-time import, not for repeated use. |
| Approval Process | Approved by the Provincial Department of Health, with a “Company Archive” stamp for customs review. |
| Compliance Obligation | The applicant must strictly adhere to the provisions of this circular. |

### Summary

The primary aim of these amendments is to simplify administrative procedures, promote electronic submissions, and enhance transparency and compliance in cosmetic regulations.

This circular will officially take effect on July 1, 2025, and all relevant enterprises and institutions must prepare in advance to ensure compliance.