Cosmetics are among the easiest goods to source on 1688 from a logistics standpoint, but they sit in one of the highest legal-risk categories for sellers who skip the declaration step. This covers the declaration and certification process under Vietnamese regulations, the costs that belong in your landed-cost calculation, and when the process actually applies to a given product.
What imported cosmetics require before you can sell legally
Under current Vietnamese regulations, cosmetics fall under the category of goods that require a product declaration before they can be sold on the market. This is not a pre-market approval in the censorship sense. It is the obligation of the importer or the party bringing the product to market to self-declare to the regulator that the product meets safety standards.
The receiving authority is the Drug Administration of Vietnam (Ministry of Health) for imported cosmetics circulating nationally. After submitting a complete file and having it accepted, the company receives a declaration receipt number (so tiep nhan phieu cong bo). The product may only be sold once this number exists. Worth noting: this is a receipt number, not an approval number. The state records that you declared, it does not pre-screen the product.
Legal responsibility for product safety rests with the declaring party, not with the regulator. If the product causes harm after it is sold, the importer bears direct liability.
Who must declare: the importer or the reseller
This is a common source of confusion. The declaration obligation belongs to the organization or individual responsible for bringing the product to market. In practice, a few scenarios apply:
- You import formally and sell yourself: you are the one who must declare.
- You source through an order agent, goods arrive informally or without proper invoices: you have no import documentation and cannot complete a proper declaration. The product is in a legally exposed position.
- You buy from a domestic distributor who already imported: that distributor must hold the declaration number. If you resell, check that they have declared and ask for a copy of the receipt number.
Selling 1688 cosmetics sourced through informal channels without a declaration means the product is, legally, not authorized for sale. TikTok Shop and Shopee are tightening enforcement on this. A reported listing getting pulled is the mild outcome. Administrative fines and stock confiscation are at the heavier end.
What the declaration file contains
A cosmetics declaration file for an imported product typically includes the components below. The specific document list can change based on current guidance from the Drug Administration, so verify against the latest official instructions before preparing.
- Product declaration form (on the prescribed template, with full ingredient list, claimed uses, and manufacturer information).
- Commercial invoice from the Chinese supplier, correctly showing product name, quantity, and value.
- Ingredient formula list (INCI list), usually requested directly from the manufacturer on 1688.
- Original product label and a Vietnamese secondary label (translated and designed to meet mandatory content requirements).
- Certificate of Free Sale from the competent authority in the country of origin, usually requiring notarization and consular legalization.
- Import license (if applicable, for certain product subcategories).
The hardest step with 1688-sourced goods is obtaining the INCI list and Certificate of Free Sale from the factory. Many smaller 1688 suppliers do not have these or cannot issue them because they have never exported through formal channels. If the supplier cannot provide these documents, the declaration cannot be completed regardless of how legitimate the product is.
Submission process and processing time
Files are submitted online through the national public service portal or the Ministry of Health portal (specifically the Drug Administration receiving system). After submission of a complete and valid file, the typical processing time for a receipt number is around 7 to 15 working days if there are no errors. If the file is sent back for additional documents, that timeline extends.
Some businesses hire a specialized cosmetics regulatory consultant to prepare and submit the file on their behalf, because the process has friction the first time through. Service fees vary considerably by firm, typically running from a few million to several tens of millions of VND per product depending on the level of support. If you have multiple cosmetics SKUs to declare at once, outsourcing to one firm that handles the batch tends to save time.
Which costs belong in your landed cost
This is the part many sellers miss, which leads to mispriced margins. For 1688 cosmetics sold legally, several compliance costs need to be added to landed cost before setting the selling price:
- Declaration submission fee: typically a few hundred thousand to under one million VND per product under state regulations. Small, but real.
- Consultant or agent service fee: if outsourced, allocate it per SKU and spread it across the expected units sold from that batch.
- Vietnamese secondary label design and printing: the secondary label must meet mandatory content requirements (product name, ingredients, claimed uses, manufacturer, importer, expiry date, and more). Print cost per unit depends on volume. For small batches of a few hundred units, the per-unit cost can be significant.
- Lab testing cost (if chosen): some importers elect to run quality testing at an accredited laboratory to build a paper trail for their own protection. This is not mandatory for every product, but it is a sensible precaution for items applied to the face or used by children. Cost per test parameter ranges from a few hundred thousand to a few million VND depending on the test and the lab.
- Waiting time: an invisible but real cost. Stock in the warehouse without a declaration number cannot be sold. If you import first and then start the paperwork, your capital sits idle for additional weeks. The cost of that tied-up capital is a real number even if it never appears on an invoice.
A simple way to avoid missing these: total all compliance costs for the batch, then divide by the number of units you expect to sell. That per-unit number tends to be small if the batch is large enough, but for batches under a few hundred units it can meaningfully eat into margin.
Product categories that need extra attention
Not every cosmetics product carries the same complexity at declaration time. A few groups require closer attention:
- Sunscreens: contain UV filters, which require more detailed documentation and, in some cases, SPF index testing.
- Products for children: stricter safety standards apply, and the supplier must have the corresponding documentation.
- Products requiring cold storage: more complex logistics, with cold-chain costs to factor in.
- Products with restricted active ingredients (acids, mercury, hydroquinone, and others): some ingredients are banned or concentration-capped. If the INCI list contains these above the allowed threshold, the product cannot be declared regardless of what the factory claims.
A practical rule of thumb: simple products (body lotion, shower gel, plain lip balm) generally have fewer complications than high-function products (dark-spot treatments, high-concentration serums, whitening formulas). First-time cosmetics importers are better off starting with the simpler category to learn the process before moving to the complex ones.
Build the process knowledge before importing at scale
The cosmetics declaration process is not especially difficult once you have done it once, but the first time tends to take longer and more errors creep in. The practical approach: pick one simple SKU, complete the declaration for that product, then import a small batch after the receipt number is confirmed. Once the process is familiar, add more SKUs.
Do not import a large batch and then start the paperwork. The risk is stock sitting in the warehouse while capital is locked up, and if the file runs into a problem that cannot be fixed (the supplier cannot produce the required documents, for instance), that batch becomes dead stock.
Bottom line
1688 cosmetics can be sold legally and profitably, but the compliance cost and lead time are part of the landed cost, not optional extras. Build the full declaration and labeling cost into every unit, complete the paperwork before bringing in a large batch, and qualify your supplier's ability to provide the required documents at the sourcing stage. Those three steps eliminate most of the legal and capital risk in this category.