EXTENDMAX – Updated on May 7, 2026 – On January 23, 2026, the Government of Vietnam issued Decree No. 37/2026/ND-CP guiding the implementation of the Law on Product and Goods Quality. The Decree introduces important updates regarding goods labeling requirements, languages displayed on labels, mandatory label contents, electronic labels, and digital product passports.
We frequently receive questions from manufacturers and importers such as: Is a Vietnamese label mandatory before goods are imported into Vietnam? Are English labels acceptable? What information must be included on a product label, and where can each item of information be displayed? Must conformity marks (ICT Mark, CR Mark, Energy Label) be affixed to the original label (factory label)?
Everything you need to know about product labeling requirements for electrical and electronic products imported into Vietnam, as well as products manufactured domestically, will be explained and guided in this article by legal expert Tran Thanh Phuong.
Basic Concepts of Goods Labels
What Is Goods Labeling Under Vietnamese Law?
Clause 1, Article 3 of Decree No. 37/2016/ND-CP provides:
“Goods labeling means presenting essential and necessary information about goods on their labels so that consumers can identify them and use such information as a basis for selection and use; so that manufacturers and traders can provide information and promote their goods; and so that competent authorities can conduct inspection and supervision.”
Definition of Goods Labels and Types of Goods Labels
Clause 2, Article 3 of Decree No. 37/2016/ND-CP defines goods labels and their forms as follows:
“2. A goods label means written text, printed matter, drawings, photographs of words, drawings, images, or data carriers that are affixed, printed, attached, molded, embossed, engraved, mounted, or directly displayed on goods, the commercial packaging of goods, or on other means attached to the goods or their commercial packaging.
3. A physical label means a goods label in physical form, including written text, printed matter, drawings, photographs of words, drawings, or images, which are affixed, printed, attached, molded, embossed, engraved, or directly displayed on goods, their commercial packaging, or on other materials attached to the goods or their commercial packaging.
4. An electronic label means a goods label in electronic form that is presented through a data carrier affixed, printed, attached, molded, embossed, engraved, mounted, or directly displayed on goods or their commercial packaging.
5. A data carrier means a medium used to encode information or encode a link to product or goods data (including barcodes, QR codes, DataMatrix codes, RFID, NFC, and other appropriate methods).
6. An original label of goods means the label first displayed on the goods or their commercial packaging.
7. A supplementary label means a label presenting mandatory information translated from the original foreign-language label into Vietnamese and adding any mandatory information required under Vietnamese law that is not included on the original label.”
Lean more: Importer of Record IOR and Exporter of Record EOR services in Vietnam
Are There Any Products That Are Not Required to Bear Goods Labels?
As reflected in the title of Chapter V and throughout the provisions of Decree No. 37/2016/ND-CP, the regulation applies specifically to “goods labels.” This means that products which are not considered goods do not fall within the scope of this Decree.
The Law on Product and Goods Quality No. 78/2025/QH15 defines:
“Goods means products that are placed on the market for consumption, use, or commercial purposes.”
Accordingly, products imported in the following circumstances may be considered not to be goods and therefore fall outside the scope of Decree No. 37/2016/ND-CP:
a) Samples imported for testing, research, or product development purposes under non-commercial import procedures.
b) Other products that are not placed on the market.
This interpretation applies not only to electrical and electronic products but also to all other categories of products.
In addition, certain types of goods are exempt from labeling requirements under Clause 2, Article 35 of Decree No. 37/2016/ND-CP, including:
“2. The following goods are not subject to goods labeling requirements under this Decree:
a) Real estate;
b) Goods temporarily imported for re-export; goods in transit; transshipped goods; goods transferred through Vietnam; imported goods stored in bonded warehouses for export to a third country;
c) Luggage of persons entering or leaving the country; relocated personal property;
d) Goods carried by incoming passengers for personal use; gifts and presents within duty-free allowances; imported goods entitled to diplomatic privileges and immunities under international treaties to which Vietnam is a member;
dd) Confiscated goods sold by auction;
e) Fresh food, live food, and processed food sold directly to consumers without packaging;
g) Fuels, raw materials (agricultural products, aquatic products, minerals), scrap materials (used in production and business activities), and construction materials sold directly to consumers without packaging;
h) Used goods;
i) Radioactive substances, electrical energy, goods used in emergency situations for disaster recovery or epidemic control, and railway, waterway, and aircraft transportation vehicles.”
Who Is Responsible for Goods Labeling and Label Content?
Article 41 of Decree No. 37/2016/ND-CP specifies the entities responsible for goods labeling as follows:
“For goods manufactured for circulation within the domestic market, the manufacturing organization or individual shall be responsible for goods labeling.”
“Organizations and individuals importing goods into Vietnam must label such goods in accordance with the mandatory labeling requirements applicable to imported goods under this Decree.”
This means that foreign manufacturers or overseas exporters are not legally responsible for complying with Vietnam’s goods labeling regulations. However, if the goods are not labeled in accordance with Vietnamese requirements, the importer will be deemed non-compliant and may be subject to penalties, shipment delays, and additional costs before the goods can reach consumers. Therefore, we provide the following guidance and recommendations.
Recommendations for Manufacturers or Brand Owners (Outside Vietnam)
Manufacturers and brand owners should affix the original label (applied at the factory or production facility) to the product before it is imported into Vietnam. The original label may be in a foreign language or in Vietnamese, but it must contain the mandatory information specified in Clause 2, Article 41 of Decree No. 37/2016/ND-CP as follows:
“2. The original label of goods imported into Vietnam must be presented in the form of a physical label and must contain the following information in a foreign language or in Vietnamese at the time of customs clearance:
a) Name of the goods;
b) Country of origin of the goods;
Where the origin cannot be determined, the label shall indicate the place where the final substantial processing operation was carried out to complete the goods in accordance with Clause 3, Article 47 of this Decree.
The country or territory of origin stated on the original label may be abbreviated in accordance with TCVN 7217-1.
c) Full name or abbreviated name and address of the manufacturer or the organization/individual responsible for the goods overseas.
Where the original label does not display the full name and address of the manufacturer or the organization/individual responsible for the goods overseas, such information must be fully provided in documents accompanying the goods or in the shipment documentation.
For imported goods bearing original labels in a foreign language that comply with Points a, b, and c of this Clause, the importing organization or individual must supplement the goods with a Vietnamese-language label in accordance with Clause 1 of this Article before placing the goods on the Vietnamese market.”
Responsibilities of Importers and Distributors in Vietnam
Importers are responsible for affixing a Vietnamese supplementary label to the goods after importation into Vietnam and before selling the goods to third parties or end users. (This also means that if the imported goods are intended solely for the importer’s own use, a Vietnamese supplementary label is not required.)
If the original label is not in Vietnamese, the importer must prepare a Vietnamese supplementary label in accordance with Clause 1, Article 41 of Decree No. 37/2016/ND-CP. For electrical and electronic products, the supplementary label must include the following information:
a) Name of the goods;
b) Name and address of the organization or individual responsible for the goods;
c) Country of origin of the goods;
d) Other mandatory information required for specific categories of goods as prescribed in Appendix I attached to the Decree, including:
- Year of manufacture;
- Technical specifications;
- Warning information;
- Instructions for use and storage;
- For refurbished information technology products, the label must clearly state in Vietnamese “sản phẩm tân trang làm mới” (refurbished product) or an equivalent statement in English.
>>> You need to know: Circular 18/2022/TT-BKHCN - Detailing regulations on some compulsory contents shown on goods labels of certain group of goods electronically
Conformity marks for electric and electronic goods (ICT Mark, CR Mark, Energy Efficiency)
There are three major kinds of conformity marks which is applicable for electric and electronic products
ICT Mark (regulated by Vietnam MIC)
Currently, the ICT conformity mark has been abolished under Circular No. 23/2024/TT-BTTTT. However, the Authority of Telecommunications (AOT) and the Telecommunications Quality Measurement Center (TQC) may still request enterprises to voluntarily register an ICT mark specimen. In such cases, enterprises may refer to the guidance below:
- ICT Mark is owned by importer and registered to VNTA by importer
- ICT Mark is understood to be related or bound to “importer”, not to the "goods" or “product” itself.
- NAME usually will be registered as importer’s company name, but it can be also brand name, company short name or anything in words
- CODE is not type approval certificate number but a management code granted by VNTA to importer
- This ICT mark is not required to be put on original label, it can be put on sub-label by importer
- Factory can put ICT Mark on original label but it will be a problem if there are several importers (using different ICT Mark) importing the product at the same time.
- Electronic label is not allowed for ICT Mark yet
Lean more: In-depth guidance on ICT Mark
CR Mark (regulated by Vietnam MOST and other Ministries)
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CR Mark
- Not like ICT Mark, CR Mark is for “product”. It is neither for importer nor to certification body.
- Certification body will issue CR Mark together with their brand name or certificate number. But pursuant to MOST regulation at Circular 28/2012/TT-BKHCN, just the bare CR mark (above image) is sufficient
- Because CR mark is not related to importer but related to product only, factory can put it on original label without any problems
Energy Efficiency label marking (regulated by Vietnam MOIT)
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- It is importer’s responsibility to put on EE label.
- EE label is allowed to be put on product only after completing EE Declaration of Conformity process (applied under name of importer).
- Energy Efficiency label can be put on product by importer after importing to Vietnam, before selling to third parties or end-user.
- There is no information of importer required on "Energy Efficiency recognition label" (triangle label), so manufacturer or brand owner can consider putting it on original label from factory.
- "Energy Efficiency comparative label" (rectangle label) comes with information of importer so manufacturer should leave it for importer to put on EE comparative label, especially in case there are more than 1 importer.
- EE label is allowed to be presented in electronic form.
Learn more: In-depth guidance on Energy Efficiency label
Label and Marking contents and corresponding locations
| No. | Mandatory Content | Mandatory Location for Label Placement | Lưu ý | ||
|
|
| Main Label (affixed to the product) | User Manual (included in the same package) | Packaging box |
|
| I. | General Labeling Requirements Applicable to All Types of Goods | ||||
| 1 | Product name / trade name of the product | Required | Not mandatory | Not mandatory |
|
| 2 | Country of origin or place where the final processing operation was completed | Required | Not mandatory | Not mandatory | Made in…, Assembled in…, bottled in…, packed in… |
| 3 | Full name (or abbreviated name or trademark(1)) of the organization responsible for product quality (manufacturer or brand owner) | Required | Not mandatory | Not mandatory | (1) If the full name of the organization responsible for product quality is not stated on the main label, this information must be provided in the user manual or on the product packaging. |
| 4 | Model number / model name / identification code | Optional – may appear in any one of the three locations |
| ||
| 5 | Address of the organization responsible for product quality (manufacturer or brand owner) | Optional – may appear in any one of the three locations |
| ||
| 6 | Quantity of products contained in the commercial package | Not mandatory | Not mandatory | Required |
|
| 7 | Name and address of the importer or distributor | Optional – may appear in any one of the three locations |
| ||
| II. | Labeling Requirements Specifically Applicable to Electronic Products | ||||
| 8 | Year of manufacture | Optional – may appear in any one of the three locations |
| ||
| 9 | Basic technical specifications | Optional – may appear in any one of the three locations |
| ||
| 10 | Warning information (if any) | Optional – may appear in any one of the three locations |
| ||
| 11 | Instructions for use and storage | Optional – may appear in any one of the three locations |
| ||
| 12 | Barcode | Optional – may appear in any one of the three locations |
| ||
| III. | Dấu hợp chuẩn hợp quy, nhãn năng lượng | ||||
| 13 | Dấu hợp quy ICT (tem ICT) | Optional – may be displayed either on the main label or on the commercial packaging | Not mandatory | Optional – may be displayed either on the main label or on the commercial packaging |
|
| 14 | Dấu hợp quy CR | Optional – may appear in any one of the three locations |
| ||
| 15 | Nhãn năng lượng VNEEP | Required | Not mandatory | Not mandatory | Electronic labeling may be used. |
Notes:
- Conformity marks may be affixed to the product after customs clearance but before the product is sold to consumers.
- The name and address of the importer or distributor may be affixed to the product after customs clearance but before the product is sold to consumers.
