On 07 September 2026, the National Committee for Standards, Metrology and Quality issued Official Letter No. 3506/TĐC-HCHQ to clarify the management principles applicable to pre-printed labels bearing brand and origin information.
The following are some notable points:
1. A standalone label is not yet the “goods label of a finished product”
Pre-printed labels imported as independent goods (not yet affixed to a product or its packaging) are not yet subject to the regulations on label content and the manner of labelling under Decree 37/2026/NĐ-CP.
The import of standalone labels is carried out under the general regulations on foreign trade management, customs and intellectual property; no separate import conditions on labelling are required.
2. Legal liability by type of import
Organizations and individuals responsible for labelling must ensure that the content is truthful, accurate and correctly reflects the nature of the goods.
Liability for the truthfulness of the origin and the trademark only fully arises when the label is affixed directly to the goods or to the commercial packaging.
For processing, export production, export processing and production-trading goods: Enterprises must use the labels for the registered purpose. After labelling, export products must comply with the labelling, origin and intellectual property regulations of the importing country.
For goods imported for business purposes (A11, A41): The enterprise importing and distributing the labels and the person who directly uses the labels to affix them to goods circulated in Vietnam bear full responsibility for the label content under Decree 37/2026/NĐ-CP.
3. Recommended customs control measures
- No dossiers beyond those prescribed: Customs control measures must comply with the correct authority, order and procedures, and must not give rise to dossier components or import conditions beyond those prescribed.
- Focus on consignments showing signs of violation: Customs will inspect on the basis of the actual risk indicators of the transaction rather than automatically classifying risk by type of import.
- Explanatory documents where doubts arise: Only where there are grounds to doubt the right to use the trademark or the origin will Customs request the presentation of documents such as the processing contract, purchase order, sale and purchase contract or the letter of authorization of the trademark owner.
(According to Official Letter No. 3506/TĐC-HCHQ dated 07 September 2026)
Related service: Customs clearance procedures
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