Vietnam recalls cosmetic batches over misleading medicinal claims

Vietnam’s Ministry of Health has mandated a nationwide recall and destruction of 13 cosmetic product batches distributed by Minh Khương due to misleading labelling that suggests pharmaceutical efficacy. The Drug Administration of Vietnam (DAV) says the move is part of a broader regulatory effort to protect consumers and ensure market compliance with cosmetic classification standards.

The recall targets products that present themselves as medicines in both formulation description and labelling, which violates Vietnam’s cosmetic labeling regulations.

Moreover, the Ministry of Health has proposed amendments to the country’s cosmetic management regulations to further improve cosmetic safety.

Violation by misrepresentation

Eight of the affected batches are facial cleansers and skin care products under the Image Skincare brand, distributed by Minh Khương and manufactured by US-based Image International Manufacturing.

The products allegedly contain primary label ingredient lists that do not match their registered dossiers.

An additional five batches, also from Minh Khương, were flagged for using language that could lead consumers to believe the cosmetics were medicinal in nature.

Under Vietnam’s Decree No. 117/2020, the possibility of misrepresentation violates advertising and product classification laws.

The DAV states that if the misleading elements on the five product batches cannot be physically removed, Minh Khương must destroy the products under current legal provisions.

Concerns mount over the trade of non-compliant cosmetic products.Removal and destruction

Minh Khương has been ordered to notify all distributors and users of the recall, accept and collect returned products, halt the circulation of all affected batches, and destroy non-compliant items where necessary.

The Ho Chi Minh City Department of Health has been assigned to oversee the recall and destruction of the five products labeled with drug-like claims. The department must report the results to the DVA by August 29, 2025.

Authorities have also directed provincial and municipal health departments to inform all relevant cosmetic businesses and end users of the recall.

In addition to the recall, the administration has instructed Minh Khương to review all imported batches of the affected product lines. If similar violations are discovered, the company must initiate further recalls and report the outcome of this review to the administration by July 29, 2025.

The DAV emphasizes that the company will be held fully accountable under the law for any dishonest or inaccurate reporting.

Regulatory landscape reform

This enforcement action follows Vietnam’s broader effort to modernize and tighten its cosmetic regulatory framework. Earlier this month, the Ministry of Health issued Circular No. 34/2025/TT-BYT, proposing amendments to the country’s cosmetic management regulations.

The proposed revisions include changes to the product notification process and the requirement that ingredients in product formulations be listed in descending order of concentration.The possibility of misrepresentation is a violation of Vietnam’s advertising and product classification laws.

Ingredient names must follow the International Nomenclature of Cosmetic Ingredients format as outlined in the latest edition of the International Cosmetic Ingredient Dictionary.

Scientific names, including genus and species, are required for plant-derived ingredients, while animal-derived ingredients must specify the exact species. The declaration form must be submitted in either Vietnamese or English.

These reforms come as concerns mount over the trade of non-compliant cosmetic products.

Last month, Personal Care Insights spoke with Dr. Shahriar Hossain of ESDO, who identified Vietnam as one of several countries linked to the illicit circulation of mercury-laced skin-lightening creams, underscoring the challenges of cross-border regulation and enforcement.