Vietnam's 2026 Export-Import Goods Labeling Template: New Rules, Sample Label and Penalty Framework

1. Why Vietnam's export-import labeling rules changed in 2026

Nghị định 37/2026/NĐ-CP was issued by the Government on 23 January 2026 and took effect the same day, detailing certain articles and organizational measures for implementing the Law on Product and Goods Quality. It simultaneously replaces Nghị định 43/2017/NĐ-CP and Nghị định 111/2021/NĐ-CP on goods labeling, and adds an entirely new legal structure for electronic labels and digital traceability. Vietnam Customs issued implementation guidance in Công văn 11816/CHQ-GSQL dated 12 February 2026.

The scope covers three groups: goods manufactured and traded within Vietnam; imported goods entering the Vietnamese market; and exported goods governed by the requirements of the importing country, a contract, or a relevant international treaty.

2. The most important changes versus Nghị định 43/2017 and 111/2021

Minimum font size of 0.9mm. Under Clause 4, Article 37 of Nghị định 37/2026/NĐ-CP, the font and number size for the main content on a label must be at least 0.9mm so it can be read with the naked eye — previously there was no hard threshold. For extremely small goods (micro electronic components, small gemstone accessories, narrow-gauge cable or tubing), businesses may present the mandatory content on an accompanying supplementary label under Clause 2, Article 42.

Electronic labels now formally recognized. Section 3, Chapter IV permits label information to be delivered via QR code or electronic chip, subject to three conditions: consumers must be able to access it for free without paid software; the displayed content must be fully consistent with the information already declared to the competent authority; and the physical label must clearly indicate that an electronic label exists and how to access it.

Origin abbreviations using ISO codes. Point b, Clause 2, Article 42 allows the country or territory of origin to be abbreviated using standardized ISO codes (USA, UK, EU, etc.), provided the abbreviation does not create confusion about the goods' true origin.

Standardized English origin phrases. Article 47 lists the accepted phrases: Made in, Product of, Origin of, and Produced by — allowing a foreign original label to be accepted by customs without requiring a Vietnamese supplementary label solely to translate these terms.

Manufacturer address may be supplemented via accompanying documents. Under Point c, Clause 2, Article 42, if the original label lacks a complete address for the foreign manufacturer or responsible party, the importer may supplement it using technical documentation, the commercial invoice, the bill of lading, or a certificate of origin.

Transitional provision. Under Article 98, goods that were already manufactured or had already completed labeling procedures before Nghị định 37/2026/NĐ-CP took effect may continue to be circulated normally until their expiry date, without being forced to be recalled for relabeling.

3. Mandatory content on the original label

Every export-import shipment must, at minimum, display the following on its original label (in Vietnamese for goods circulating domestically; imported goods must carry a Vietnamese supplementary label if the original label does not already provide the mandatory content in Vietnamese):

Labels on exported goods follow the law of the importing country, the underlying contract, or an international treaty to which Vietnam is a party, and may not display content related to sovereignty disputes or other sensitive matters.

• The name of the goods, placed in a clearly visible, easily readable position.
• The full name and address of the organization or individual responsible for the goods (the manufacturer, the importer).
• The origin of the goods, in compliance with origin-marking rules and any relevant trade agreements.
• Net quantity (net weight, volume, or count).
• Manufacturing date and expiry date (where applicable).
• Technical specifications, ingredients, usage and storage instructions, and safety warnings (depending on the type of goods).

4. Reference label templates for businesses

Because export labels and import labels are governed by two different sets of rules (see Sections 2–3), this article provides two separate reference diagrams. These are illustrative references based on the provisions described in Sections 2–3; businesses should cross-check against the specific requirements for their product category (food, cosmetics, chemicals, medical devices, etc.), as these sectors may carry additional specialized requirements.

Template 1 — Label for goods exported from Vietnam: language and format follow the importing country's requirements, no Vietnamese supplementary label is required, and the origin is always marked "Made in Vietnam" or equivalent.

Template 2 — Label for goods imported into Vietnam: consists of the foreign original label plus the mandatory Vietnamese supplementary label, applicable to goods from any country of origin.

5. Penalty framework for labeling violations

From 1 July 2026, administrative penalties in the customs field — including violations related to export-import goods labeling — are governed by Nghị định 169/2026/NĐ-CP (issued 15 May 2026), which replaces Nghị định 128/2020/NĐ-CP. The general principle at Point a, Clause 3, Article 6 states: the monetary fine levels prescribed in Chapter II of the decree apply to organizations; an individual committing the same violation is fined half the organizational amount (with certain exceptions specified in the decree).

Table 1 — Confirmed penalty levels under Nghị định 169/2026/NĐ-CP

Beyond the monetary fine, the false-origin-marking violation under Article 18 also carries an additional penalty of confiscation of the material evidence, along with remedial measures including forced destruction of harmful goods and forced disgorgement of an amount equal to the value of evidence that was disposed of, sold, or destroyed in violation of the rules.

Regarding the general fine schedule for missing or incorrect mandatory label content (cases not involving false origin marking): before 1 July 2026, this schedule was set out in Article 22 of Nghị định 128/2020/NĐ-CP, tiered by shipment value, ranging from VND 500,000 (minor errors, low-value goods) up to VND 60,000,000 (goods with no original label at all, value VND 100 million or more). That schedule expired on 1 July 2026. The corresponding article in Nghị định 169/2026/NĐ-CP (referenced by some secondary sources as Article 22 or Article 23) was not available, at the time this article was written, as a publicly searchable electronic text — the signed PDF on the Government's web portal is a scanned image without extractable text. Businesses should verify the exact figures directly against Nghị định 169/2026/NĐ-CP or consult their local customs sub-department before making risk decisions based on this schedule.

Common remedial measures (applicable generally to labeling violations under Chapter II of Nghị định 169/2026/NĐ-CP): forced removal of unlawfully altered packaging or labels; forced removal of the goods from Vietnamese territory if the label content cannot be remedied; and forced disgorgement of an amount equal to the value of evidence if it was disposed of, sold, or destroyed before a penalty decision was issued.

6. Compliance recommendations for businesses

• Review all existing label templates against the 0.9mm minimum font size and the mandatory content in Articles 37 and 42 of Nghị định 37/2026/NĐ-CP before ordering a new print run of labels.
• If using an electronic label (QR/chip), ensure the displayed content matches 100% of the information already declared to the regulator — any discrepancy between the electronic label and the declared dossier may be treated as providing false information.
• For inventory manufactured or imported before 23 January 2026, take advantage of the transitional provision in Article 98 to continue circulating the goods until their expiry date rather than recalling them for relabeling.
• Cross-check the label against the customs dossier (declaration, invoice, bill of lading, certificate of origin) before clearance to avoid the shipment being flagged for a full physical inspection.
• For shipments with any uncertainty about origin or label content, proactively consult the local customs sub-department or an import-export legal advisor before declaring, since the fine under Article 18 of Nghị định 169/2026/NĐ-CP can reach VND 100,000,000 plus confiscation of the goods.