Decree No. 37/2026/ND-CP updates Vietnam's goods labeling regulations by strengthening requirements on mandatory label information and introducing clearer provisions on electronic labeling. It also maintains transitional measures, allowing previously compliant products to remain in circulation for a limited period.

 

1. Decree Replaced and Effective Date

Decree No. 37/2026/ND-CP was issued by the Government of Vietnam on 23 January 2026 and took effect on the same date.

This Decree replaces and supersedes previous regulations on goods labeling, including:

• Decree No. 43/2017/ND-CP on goods labeling; and
• Decree No. 111/2021/ND-CP, which amended and supplemented several provisions of Decree No. 43/2017/ND-CP.

 

2. Key Highlights on Labeling Requirements

2.1. Mandatory Label Information

Labels must ensure visibility, readability, and completeness of mandatory information:

• Product name
  • Must be placed in the most visible position
  • Must have the largest font size on the label
• Name and Address of the Responsible Organization/Individual
  • The full name and address of the entity responsible for the product must be clearly indicated
• Country of origin
  • Acceptable expressions include: "Made in", "Product of", or "Origin"
  • If origin cannot be determined: processing statements such as "Assembled in" or "Finished in" may be used
  • Country names must follow abbreviations under TCVN 7217-1
• Date of manufacture and expiry date
  • Format: day – month – year
  • Abbreviations allowed: MFG / EXP
  • Recommended wording: "Best before..."
• Font size & presentation
  • Must be clear, legible, and contrast with the background
  • Minimum font height: ≥ 0.9 mm
  • Smaller font sizes may be acceptable for small packaging, provided that the information remains clearly readable
• Placement principles
  • Must be readable without disassembling the product
  • Applied consistently across:
    • Outer packaging
    • Inner units (if sold separately)

 

2.2. Additional Mandatory Information for Medical Devices

In addition to the general labeling requirements above, medical device labels must include the following specific information:

• Circulation or import license number
  The marketing authorization number or import license number of the medical device must be indicated.
• Batch or serial number
  A batch number or serial number must be provided for traceability.
• Manufacturing date and expiry date
  • For sterile, single-use devices, reagents, calibrators, control materials, and chemicals:
    → The expiry date is mandatory
  • For other cases:
    → Either the manufacturing date or the expiry date must be indicated
  • For machinery and equipment:
    → The year of manufacture, or the month and year of manufacture, must be indicated
• Warnings, instructions, and after-sales information
  The label must include or provide access to:
  • Warning information
  • Instructions for use
  • Storage instructions
  • Warranty or servicing information

These contents may be:

• Presented directly on the label; or
• Referenced on the label with clear instructions on how to access them

 

2.3. Notes on Secondary Labels (Vietnamese Labels)

Secondary labels are required when the original label does not contain Vietnamese language.

Key principles:

• Must not obscure or alter the original label
• Must include all mandatory information in Vietnamese
• Must ensure consistency with the original label and product documentation

For multi-layer packaging:

• If goods are sold individually → labeling is required on each unit
• If only outer packaging is sold → labeling on the outer packaging is sufficient

 

2.4. Electronic Labeling

Decree No. 37/2026/ND-CP introduces clearer and more specific provisions on electronic labeling, which were not fully guided in previous decrees such as Decree No. 43/2017/ND-CP and Decree No. 111/2021/ND-CP.

It permits the use of electronic labeling (e.g., QR codes, barcodes) as a supplementary method to provide additional information, while maintaining the requirement that mandatory information must still be displayed on the physical label and remain directly accessible to consumers.

Key Requirements for Electronic Labeling

• Accessibility
  • Electronic labeling must be easily accessible at all times
  • The format, interface, and data structure of electronic labels must comply with ISO/IEC 18975 or other accepted equivalent national or international standards
• Complementary Role
  • Electronic labels may only supplement physical labels and must not replace mandatory information. They must be visibly affixed to the product or packaging and remain secure under normal distribution conditions.
  • Clear instructions must be provided to enable consumers to access the electronic label information
• Data Retention
  • Full electronic label content must be retained for at least 12 months after the product’s expiry date
  • For products without an expiry date, the retention period shall be determined by the responsible organization or individual
• System Integrity
  • Organizations must ensure traceability of any changes
  • Data must be available for inspection upon request
  • All information must remain accurate and up to date
• Legal Responsibility
  • Organizations are liable if the system is inaccessible
  • Organizations are also responsible for any inaccurate or non-compliant information

 

3. Important notes on transitional provisions

1. Goods labeled in compliance with Decree No. 43/2017/ND-CP and Decree No. 111/2021/ND-CP that were manufactured, imported, circulated, or used before the effective date of Decree No. 37/2026/ND-CP may continue to be used until their expiry date.
2. Goods with labels compliant with Decree No. 43/2017/ND-CP and Decree No. 111/2021/ND-CP that were manufactured or printed before the effective date of Decree No. 37/2026/ND-CP may continue to be used for up to 2 years from its effective date.
3. In cases where the address of the responsible organization or individual changes due to such adjustments (without changing the responsible entity), goods bearing labels printed with the former address prior to such change may continue to be used for up to 2 years from the effective date of the administrative boundary adjustment decision, provided that no confusion is caused and traceability is ensured.

Note: In Vietnam, administrative boundary adjustments took effect from 1 July 2025. Therefore, all product labels must be updated to reflect the new administrative addresses from 1 July 2027.

 

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Reference

Decree No. 37/2026/ND-CP of the Government: Detailing a number of articles and measures for the implementation of the Law on Product and Goods Quality