A container clears customs, reaches the warehouse, and then stops moving, because nobody agreed who was printing the Vietnamese stickers or what had to be on them. The law that decides both changed at the start of 2026. The highest-authority English guidance on page one is still written on Decree 43/2017/ND-CP, which no longer governs anything. Newer English pages on the replacement decree exist, but they summarise it.
Decree 37/2026/ND-CP, dated 23 January 2026, detailing the Law on Product and Goods Quality, replaced Decree 43/2017/ND-CP and Decree 111/2021/ND-CP on goods labelling. We rechecked currency on 15 September 2026 and found no amendment to 37/2026; the most recent customs guidance applying it is Official Letter 20807/CHQ-GSQL of 22 August 2026.
💬 Shipping your first SKU into Vietnam and unsure who applies the Vietnamese label? Sunsho Trade is a Japanese-managed trading company in Ho Chi Minh City that imports, registers and distributes for foreign brands — see market entry support or tell us what you are shipping.
Which imported goods need a supplementary label
Any imported goods whose own label does not show the mandatory content in Vietnamese, or does not show all of it, must carry a supplementary label — and the original label must be kept intact.
That is Article 39(3) (khoản 3 Điều 39 in the Vietnamese text, if you are searching it) of Decree 37/2026/ND-CP. The Vietnamese term is nhãn phụ: a second layer of information in Vietnamese travelling alongside the manufacturer’s original label, not a replacement for it. A label printed for Japan, Korea or Europe will not normally carry the mandatory content in Vietnamese, so the test is met on arrival rather than by exception.
There is an exemption list, at Article 40(4), and its shape matters: it is written by purpose of use, not by product name. It covers replacement parts supplied under warranty; raw materials, food additives and processing aids imported for production; samples imported for testing, certification or research; and goods for display at trade fairs. The common thread is goods not sold on the Vietnamese market as they stand.
The same item can be exempt in one consignment and not the next, because the purpose changed. And exemption from the label is not exemption from the dossier: material imported for production still needs the lot’s quality documents.
The field-by-field checklist
Article 42 sets the master list of mandatory label content and refers to Appendix I of the decree for content specific to each group of goods, with Articles 43 to 50 defining what goes in each field.
A row you cannot fill is a row to resolve before the sticker is printed.
| Field | What goes in the Vietnamese box | Article | Where it goes wrong |
|---|---|---|---|
| Name of goods | The name it is sold under | Article 43 | A marketing name that does not say what it is |
| Entity responsible for the goods | The Vietnamese importing organisation, with address | Article 44 | The foreign brand owner printed instead of the importer |
| Quantity | Net content, in the appropriate unit | Article 45 | Quantity left readable only on the original label |
| Date of manufacture and expiry | Both dates, in the decree’s form | Article 46 | A sticker that omits the dates and covers the originals |
| Origin of goods | ”Sản xuất tại” / “Made in” / “Product of” plus the country | Article 47 | A country that does not match the customs declaration |
| Composition and quantitative composition | Ingredients, with quantities where required | Article 48 | A shortened list that no longer corresponds |
| Technical specifications and warnings | Specifications and warning content | Article 49 | Dropping a warning from the original label |
| Instructions for use and storage | How to use and store it | Article 50 | A translation that changes the storage condition |
| Group-specific mandatory content | What Appendix I adds for your group of goods | Article 42 and Appendix I | Filling the eight rows above and stopping there |
Checked against the published text on 15 September 2026.
Article 40(3) defines the sticker’s own content: the Vietnamese translation of the mandatory content on the original label, plus any mandatory items the original is missing. The test customs applies is correspondence: in Official Letter 20807/CHQ-GSQL of 22 August 2026, on the language of cosmetic labels, the Customs Department read Article 39(3) as requiring the Vietnamese content to correspond to the content on the original label. You may lay the sticker out compactly; you may not drop a field or soften a claim in translation.
Article 37 sets a minimum character height of 0.9 mm, and the field list grows while the sticker does not, so print one proof at full size on the real box first. And where origin genuinely cannot be determined, Article 47(3) provides for stating where the last operation to complete the goods was performed — a defined fallback, not a licence to leave the field blank.
The original label carries its own obligation, and it is the exporter’s. Under Article 42(2) it must show the name of the goods, the origin, and the name and address of the foreign manufacturer or foreign responsible entity, with point (c) accepting a full or abbreviated name. A supplementary label cannot rescue an original that never carried them, so they belong in the packaging specification and in the quotation that prices it. Who absorbs relabelling cost depends on where the delivery term hands over.
💬 Want the Vietnamese field list checked against your artwork before it goes to the printer? Send us the draft — we apply these labels in Vietnam as part of import and distribution work.
Which Appendix I group your product sits in
Where goods have characteristics falling in more than one Appendix I group and no other legal instrument decides the point, Article 42 lets the organisation responsible for the goods determine the group itself, from the main use of the product.
This is the row artwork stalls on. The eight fields above are the same for every product; Appendix I is where a food, a cosmetic, a supplement or an electrical product picks up extra content, and a real product often sits in two groups at once. Article 42 does not send you to an authority for a ruling: the responsible entity classifies by the main use of the product and writes the content for that group.
So the choice is yours to make and yours to defend — record the reasoning with the artwork. The main-use test applies only where no other instrument covers the category; where one does, it decides. Cosmetics are the clearest case: in Official Letter 20807/CHQ-GSQL the Customs Department sent the cosmetic label question back to Circular 06/2011/TT-BYT of the Ministry of Health.
Four ways a supplementary label fails
Four failures recur, and each traces to a specific clause.
1. The original label is removed or replaced. Peeling off the Japanese label and applying a Vietnamese one in its place breaches Article 39(3) directly: that clause requires the original to be kept. The supplementary label is additive by design.
2. The sticker obscures mandatory content. The largest flat area on a pack is usually the ingredients panel, the expiry date or the lot code, which is why stickers land there. Article 40 does not permit covering mandatory content of the original, and covering the lot code also destroys your own batch traceability. The related error is labelling the outer carton only, so the retail unit reaches the shelf with no Vietnamese label.
3. The Vietnamese text does not correspond to the original. This is the test stated in Official Letter 20807/CHQ-GSQL, and it cuts both ways: a translation that drops a warning fails it, and so does one that adds a use the original never claimed. Translate first, then add the mandatory items that are missing, so every Vietnamese line has a source.
4. A Decree 43/2017 template is reused unchanged. Decree 37/2026/ND-CP replaced that decree on 23 January 2026, so a template drafted against it has to be reviewed against the current text rather than assumed to carry over.
Who is responsible, and by when
For imported goods the labelling obligation sits with the importing organisation or individual in Vietnam, and the Vietnamese label must be in place before the goods are put into circulation on the Vietnamese market, not before customs clearance.
Article 41 governs labelling responsibility: labelling must be truthful, clear and accurate and reflect the true nature of the goods, and for imports the importer carries it. Article 41 also requires label content to be disclosed for goods sold on e-commerce platforms, which catches brands selling through a marketplace who never see the physical pack.
On timing, Official Letter 11816/CHQ-GSQL of 12 February 2026 from the Customs Department, guiding Decree 37/2026/ND-CP, states that imported goods must have the Vietnamese label added before being put into circulation on the Vietnamese market. Several commercial pages assert instead that it must go on before customs clearance. That is not what the guidance says, and the difference is a working sequence rather than a deadline: draft the content while the goods are in transit, and sticker in the warehouse between clearance and the first distribution delivery.
Origin is the one field read against another document. Official Letter 17552/CHQ-GSQL of 16 June 2026 directs customs units to compare the origin shown on the goods and on the packaging against the customs declaration, and singles out goods manufactured abroad but marked as made in Vietnam.
Selling imported goods with a foreign-language original label and no Vietnamese supplementary label falls under Article 31(1)(b) of Decree 119/2017/ND-CP, as amended by Decree 126/2021/ND-CP. It is tiered by the value of the infringing consignment and carries remedial measures as well as fines, including recall and correct relabelling before the goods may circulate. That decree is reportedly under amendment to align with 37/2026, so read the text in force rather than a figure from a blog.
Where a compliant Decree 37 label is still not enough
Food, health supplements, cosmetics and medical devices carry sector rules on top of Decree 37/2026/ND-CP, so a label satisfying the checklist above can still be non-compliant.
For food and health supplements the operative basis remains Decree 15/2018/ND-CP, because its intended replacement is suspended; that currency question is set out in the food and supplement declaration route. Under 15/2018 an imported food label must show both the manufacturer and the organisation responsible for the product declaration, and health supplement labels carry a mandatory warning that the product is not a medicine and does not replace medicine. For cosmetics, label content is governed by Circular 06/2011/TT-BYT, as amended by Circular 34/2025/TT-BYT.
The failure mode here is not a missing field. It is a sticker describing the product more broadly than the registered declaration does — a claim the dossier does not support is worse than a missing sticker, because it is evidence. The corporate documents behind that dossier usually need apostille or consular legalisation first.
Health supplements are foods, not medicines, and are not a substitute for medical treatment. No disease name and no treatment verb belongs on a Vietnamese label, whatever the original says in another market.
Decree 37/2026/ND-CP also provides for label content in electronic form, in Section 3 of Chapter IV, while the duty to keep the original label stands. Confirm the scope for imported goods against the current text before assuming a QR code discharges anything.
Labels you have already printed
Article 98 allows packaging and labels printed before the decree took effect to continue in use for not more than two years from that date.
This is a transition window, not an exemption: it buys time to run down printed stock, not permission to keep a Decree 43-era design. Put the new field list into the next packaging revision, and check the instrument in force on the day you print. A missing row is a problem you fix in the warehouse. A row citing a repealed decree is a problem that reaches the market.
💬 Would you rather print the Vietnamese content at the factory than hand-sticker every retail unit? Sunsho Trade handles import, product registration and distribution in Vietnam for foreign brands, and is the entity named on the label when we import. Start with market entry or send us your label draft.
Frequently asked questions
1. Does the original foreign label have to stay on the box?
Yes. Article 39(3) of Decree 37/2026/ND-CP requires the original to be kept intact, and Article 40 requires the supplementary label not to obscure its mandatory content. Removing it and sticking a Vietnamese label in its place breaches both.
2. Must the Vietnamese label be applied before customs clearance?
No. Official Letter 11816/CHQ-GSQL of 12 February 2026, guiding Decree 37/2026/ND-CP, states that the Vietnamese label must be added before the goods are put into circulation on the Vietnamese market. That leaves the warehouse window between clearance and the first distribution delivery.
3. My product could sit in two Appendix I groups. Who decides which one?
You do, unless another instrument has already decided it. Article 42 provides that where goods fall in more than one Appendix I group and no other legal document covers the point, the entity responsible determines the group from the product’s main use.
4. Is a supplementary label template drafted under Decree 43/2017 still usable?
It needs review. Decree 37/2026/ND-CP replaced Decree 43/2017/ND-CP and Decree 111/2021/ND-CP on 23 January 2026. Article 98 lets packaging and labels printed before that date continue in use for not more than two years — a transition window, not a permanent exemption.
5. Whose name goes on the label, the foreign brand owner’s or the importer’s?
For imported goods, Article 44 identifies the entity responsible as the Vietnamese importer, and that is the name and address on the supplementary label. Article 42(2) separately requires the original foreign label to show the foreign manufacturer or responsible entity, so both appear on the pack.