VI In the circulation of goods, product labels serve not only as tools for brand identification but also as critical legal grounds for quality control and the protection of consumer rights. Notably, effective from January 23, 2026, goods labeling regulations have undergone stricter adjustments to align with new standards for information transparency. Accurately determining the label’s position to ensure easy visibility, as well as strictly complying with mandatory content, is a prerequisite for all manufacturing and importing enterprises. Errors in presenting label content not only lead to risks of administrative penalties but may also result in the suspension of goods from market circulation. To promptly grasp the latest technical standards and legal regulations that have just come into effect, let’s join Pham Consult in exploring the regulations on mandatory positions and content on goods labels.
- Concept of Goods Labels
Goods label refers to any writing, print, drawing, photocopy of letters, figures, or images, or data-carrying devices that are pasted, printed, attached, molded, engraved, etched, affixed, or directly displayed on the goods, the commercial packaging of the goods, or via other methods attached to the goods or their commercial packaging.
Physical label is a goods label in physical form, including writing, prints, drawings, or photocopies of letters, figures, or images that are pasted, printed, attached, molded, engraved, or etched directly on the goods, their commercial packaging, or on other materials attached to the goods or their commercial packaging.
Electronic label is a goods label in electronic form displayed through data-carrying devices that are pasted, printed, attached, molded, engraved, etched, affixed, or directly displayed on the goods or their commercial packaging.
- Regulations on Goods Labeling Locations from January 23, 2026
From January 23, 2026, regulations on goods labeling locations are guided by Decree No. 37/2026/ND-CP of the Government, which details several articles and measures for the organization and implementation of the Law on Quality of Products and Goods. Accordingly, the location of goods labels is regulated under Article 36 of Decree 37/2026/ND-CP, specifically as follows:
– The goods label must be displayed on the goods or their commercial packaging in a position where all prescribed label contents can be easily and fully observed without having to disassemble the parts or components of the goods.
Mandatory contents do not necessarily need to be concentrated in one place on the label; they can be recorded in other positions on the goods, provided they remain easily and fully observable without disassembling parts of the goods. Such mandatory contents are considered an integral part of the goods label.
For specific goods such as paintings, statues, artistic ceramics, and sculptures where the label cannot be displayed in an easy-to-observe position on the goods or their commercial packaging, the label may be presented on a separate tag attached to the goods, or on the back or bottom of the item.
– For goods with both primary (internal) packaging and outer packaging, labeling is performed according to the following principles:
+ Goods on the market with outer packaging where small units with primary packaging are not sold separately must be labeled on the outer packaging.
+ Goods on the market with outer packaging where small units with primary packaging are also sold individually must have full labeling on both the outer and primary packaging.
In cases where the outer packaging cannot or may not be opened, the outer packaging must have a label, and the label must present all mandatory contents.
In cases where the outer packaging is transparent and the labeled content of the internal product can be observed, labeling for the outer packaging is not mandatory.
- Mandatory Content to be Displayed on Goods Labels
According to Article 42 of Decree 37/2026/ND-CP, the following contents must be displayed on goods labels:
a. For goods circulating in Vietnam:
Labels for goods circulating in Vietnam must display the following contents in Vietnamese:
(i) Name of the goods;
(ii) Name and address of the organization or individual responsible for the goods;
(iii) Origin of the goods;
(iv) Other mandatory contents based on the nature of each type of goods as specified in Appendix I issued with Decree 37/2026/ND-CP and relevant legal regulations.
In cases where goods fall into multiple groups specified in Appendix I and are not yet regulated by other relevant legal documents, the responsible organization or individual shall determine the group based on the primary utility of the goods to record the contents accordingly.
b. For goods imported into Vietnam:
The original label of goods imported into Vietnam must be a physical label displaying the following contents in a foreign language or Vietnamese during customs clearance:
(i) Name of the goods;
(ii) Origin of the goods;
If the origin cannot be determined, record the place where the final processing stage was performed to complete the goods as per Clause 3, Article 47 of Decree 37/2026/ND-CP.
The name of the country or territory of origin on the original label may be abbreviated according to TCVN 7217-1.
(iii) Full name or abbreviation and address of the manufacturing organization/individual or the entity responsible for the goods abroad.
If the original label does not yet show the full name and address of the manufacturer or responsible entity abroad, this information must be fully displayed in the documents accompanying the goods or in the shipment dossier.
For goods imported into Vietnam with original labels in a foreign language as per points (i), (ii), and (iii) above, the importer must supplement the label with a Vietnamese version as prescribed in Section (a) before circulating the goods in the Vietnamese market.
c. For goods exported abroad:
Labels for exported goods shall comply with the laws of the importing country, contracts, and international treaties to which Vietnam is a member, while also complying with Clause 2, Article 50 of Decree 37/2026/ND-CP.
In cases where exported goods cannot be exported or are returned but meet the conditions for circulation in the Vietnamese market, the manufacturer must label them as goods produced for domestic circulation or apply a supplementary label for imported goods as per Decree 37/2026/ND-CP before putting the goods into circulation.
