Most sellers importing from 1688 focus on product cost, freight, and platform fees. The Vietnamese secondary label requirement rarely makes the list until an enforcement visit or a buyer complaint makes it impossible to ignore. Missing it is not a minor oversight: it can mean confiscated stock, administrative fines, and a suspended listing.
What a secondary label is and why it exists
When goods arrive from China, they carry the original label: typically in Chinese or English, occasionally both. Vietnamese law requires that imported consumer goods sold on the domestic market carry a secondary label in Vietnamese with the key product information a buyer needs to use the product safely and make an informed purchase.
The legal basis is Decree 43/2017/ND-CP on goods labeling, along with subsequent amendments. The obligation falls on the importer or the seller, not the Chinese factory. If you import and sell, you are the responsible party. The secondary label does not replace the original; it supplements it.
Which product categories need a secondary label
The general rule is: if you sell it retail to end consumers in Vietnam, it needs a Vietnamese secondary label. A few categories to know specifically:
- Food and beverages. Snacks, seasonings, functional foods, packaged drinks imported from China all require secondary labels. This group is the most strictly enforced because of food safety concerns.
- Cosmetics and personal care. Skincare, facial cleansers, lip products, shampoo imported from 1688 all need labels. Beyond the standard fields, cosmetics must list the full ingredient list under international nomenclature (INCI names).
- Household goods and small appliances. Cookware, kitchen gadgets, portable electronics, small electrical devices sold at retail all fall under the requirement.
- Children's toys. Toys need the standard label fields plus a clear age-suitability notation and safety warnings where relevant. Many toy categories also require a conformity mark (CR mark) under national technical standards before they can be sold legally.
- Phone accessories and electronics. Cables, earphones, cases with circuitry, power banks all need labels under the regulation.
- Apparel and footwear. Fabric composition, country of origin, and care instructions must appear in Vietnamese.
Raw materials, industrial inputs, and goods not sold directly to end consumers typically fall outside the retail labeling requirement. If you sell through TikTok Shop, Shopee, or Lazada to individual buyers, assume the requirement applies.
What the label must contain
The minimum required fields under the general regulation:
- Product name. In Vietnamese, specific enough for a buyer to understand what the item is.
- Country of origin. For goods from China this is "Made in China" or the Vietnamese equivalent. This field cannot be left blank.
- Name and address of the responsible organization or individual. This is typically your business name and address as the importer and distributor, not the factory.
- Quantity. Weight, volume, or unit count depending on the product type.
- Ingredients or main components. Required for food, cosmetics, and certain other categories.
- Expiry date or best-before date. Mandatory for food, cosmetics, and any product that has a use-by period.
- Instructions for use and storage. The information a buyer needs to use and store the product correctly.
- Warnings. Required for toys, electrical products, and cosmetics with special ingredients.
Category-specific rules add to this base. Cosmetics must list all ingredients in INCI format as a minimum. Food products must include nutritional information in the format required by food safety authorities. Toys subject to national technical standards (QCVN) must carry the CR conformity mark before they can be sold.
The label must be legible and durable enough to stay attached through normal handling. It must be in place before the product reaches the buyer, not applied after an order comes in.
Where and how to get labels applied
Three practical approaches are common among sellers importing from 1688.
Ask the factory to apply labels before shipment. This works if your order volume is large enough to justify the request and you can provide a print-ready label file. The upside is convenience. The downside is that you are relying on the factory to apply the right label to every unit consistently. Order a sample run and check before you commit to a large batch.
Use a China consolidation warehouse that offers labeling services. Many freight agents and consolidation warehouses in China add this as a paid service. The cost typically runs a few thousand to a few tens of thousands of Vietnamese dong per unit depending on volume and label complexity. This is a reasonable option if you import across many SKUs from multiple factories and cannot manage per-factory labeling.
Apply labels yourself when stock arrives in Vietnam. This gives you the most control over label quality and content, but adds labor and requires a clear process so no unit ships without a label. For smaller operations with a physical warehouse, this is how many sellers handle it.
Whichever approach you use, keep a record that your stock was labeled before it reached buyers. A photo of labeled stock before packing is a simple habit that protects you if a dispute arises later.
Real consequences of selling without a label
The risks are practical, not just theoretical. Three enforcement channels matter.
Market surveillance inspections at warehouses or retail points. Inspectors can pull any product for a spot check. If it lacks a valid secondary label, the entire lot can be temporarily seized or confiscated. Administrative fines for labeling violations can range from a few million to tens of millions of VND depending on the scale of the violation and the product category.
Buyer complaints through the platform. On TikTok Shop and Shopee, buyers can report listings for missing Vietnamese product information. The platform may suspend the listing, require a correction before reactivating it, or for repeated violations, flag the seller account. This is a real operational risk during high-volume periods when any listing suspension is costly.
Tax and customs audit context. Sellers operating under formal import channels with invoices are subject to review. Selling goods that do not meet circulation requirements can affect your compliance record when auditors examine invoices and inventory.
The three highest-risk categories from an enforcement standpoint are food, cosmetics, and children's toys. These are the categories regulators prioritize and the ones where buyers are most likely to notice and flag missing information.
Common labeling mistakes to avoid
Knowing you need a label and doing it correctly are two different things. These are the errors that come up most often.
- Incomplete information on the label. Many sellers include the product name and country of origin but leave off the expiry date, ingredients, or the responsible party's details. A partial label is still a violation.
- Covering important original-label information. The secondary label can go on top of the original, but it must not obscure critical information from the original label such as the expiry date or safety symbols.
- Font too small or contrast too low to read. The regulation requires the label to be clearly legible under normal lighting. Small-print labels that cannot be read without effort do not meet this standard.
- Not updating labels when you switch suppliers. If you move to a different factory, the origin or ingredient details may change. Old labels printed for the previous factory cannot simply be applied to new stock without a review.
- Printing large batches of labels far in advance. If regulations change or your product specifications shift, a large stock of pre-printed labels becomes unusable. Printing in quantities tied to your import batches is safer.
Bottom line
Secondary label compliance is a real cost and takes real effort to set up. But shops that get it right from the start avoid stock seizures, do not lose listings over buyer complaints, and have one less compliance variable to manage when enforcement activity increases. Build the label cost into your landed cost calculation from the beginning, treating it the same way you treat freight or platform fees. It is a fixed input, not a surprise.