Quick summary
- Article 70 Decree 37/2026/ND-CP specifically for goods traded on digital platforms serving electronic transactions: organizations, individuals selling and owner of an intermediary digital platform must comply with management requirements Article 34b of the Law on Product and Goods Quality (added at Clause 19, Article 1 of Law No. 78/2025/QH15) before circulating on the market.
- Article 70 does not copy the content of Article 34b — detailed obligations are in Article 34b of the Law. The seller must directly compare the Law document, not deduce it from the Decree.
- Article 69.1 requires that goods circulating on the market must meet the conditions in Article 34a of the Law (added in Clause 19, Article 1 of Law No. 78/2025/QH15); Article 69.2 lists five groups of obligations of organizations and individuals selling goods.
- Selling online is not an exempt area: Clause 9 Article 3 defines “circulation” as including sales on digital platforms — display, promotion, transportation, preservation, storage, purchase and sale.
- Article 41.5 requires sellers on e-commerce platforms publicly disclose all label content when posted for sale and ensure goods are delivered to the buyer with a label according to regulations.
- Article 41.6 require the platform owner to publicly display the label when listed for sale, share data with the National Database on Standards – Measurement – Quality and store for a minimum of 5 years.
- The seller must maintain quality records for at least 03 years (Article 69.2.d); Goods with a longer shelf life should be stored at least equal to the shelf life.
- Management agencies inspect indirectly through electronic data, traceability, codes and barcodes, certification of standard and regulation conformity (Article 69.3.b), so the act of “posting one thing for sale, delivering another” is easy to compare and detect.
- High-risk goods are subject to mandatory traceability (Article 22.1) and may be required to use a product digital passport or electronic label (Article 32) — this is the part that online sellers are most likely to miss.
1. Why does a decree on “goods quality” affect Shopee, Lazada, and TikTok Shop?
Decree 37/2026/ND-CP was issued to detail and guide implementation Law on Product and Goods Quality No. 05/2007/QH12, as amended and supplemented by Law No. 78/2025/QH15. Notable point: the Decree does not consider e-commerce a separate area, which pulls all sales activities on digital platforms into the scope of general regulation of product quality.
The basis for expanding the scope lies right in the definition stage. Clause 9 Article 3 defines circulation as “all activities of bringing products and goods to market, including buying and selling on digital platforms for electronic transactions, including displaying, promoting, transporting, preserving, storing, buying and selling products and goods”. In other words, from the stage put up for sale (display) to the stage of delivery and storage are all “circulated” in the legal sense — and are therefore subject to the Decree.
In parallel, Clause 1 Article 2 identifies applicable subjects including organizations and individuals production and business products, goods and organizations and individuals with activities related to the quality of products and goods, codes, barcodes, product labels, digital passports, and traceability. An online seller — even if it’s just an individual selling a few items — is still in the “goods business” group.
Practitioner’s note. Many sellers still think “I only sell on the platform, I’m not a manufacturing enterprise so I’m not eligible”. This understanding is wrong on two points: first, the Decree applies to all business individuals, not just legal entities; second, the seller’s obligations are regulated independently of the manufacturer’s obligations (Article 69), it is impossible to “push” responsibility to the manufacturer or platform owner.
Three axes of obligations that an online seller needs to understand before reading deeply:
| Pillar | Core question | Base |
|---|---|---|
| Goods in circulation | Do the products I sell meet quality conditions when released to the market? | Article 69.1 (referring to Article 34a of the Law), Article 69.2 |
| Digital platform channel | If I sell through the platform, what else do I need to do? | Article 70 (referring to Article 34b of the Law), Article 41.5, Article 41.6 |
| Labels and data | What does the label say, where is it published, and how long will it be kept? | Article 42, Article 41, Article 69.2.d, Article 41.6.c |
2. Article 69 — six obligations once the goods have entered the market
Article 69 titled “Ensuring the quality of goods circulating in the market”. This is the “backbone” of the seller’s obligations, which apply to all sales channels — both physical stores and stores on e-commerce platforms.
Clause 1 sets a prerequisite: goods circulating on the market must meet the conditions in Article 34a of the Law on Product and Goods Quality, added at Clause 19, Article 1 of Law No. 78/2025/QH15, before circulating on the market. The Decree references, but does not copy, the content of Article 34a — meaning that the seller is forced to look up the Law document to know the full conditions.
Clause 2 is the “hands-on” part that sellers need to know:
| # | Obligations (Article 69.2) | Practical interpretation | Consequences if ignored |
|---|---|---|---|
| a | Ensure product quality conforms to announced applicable standards and corresponding technical regulations | Only sell goods whose source you know and that have quality documents; do not sell “floating” goods of unknown standards | Goods are considered not to meet circulation conditions |
| b | Establish and operate an internal control system to maintain quality | There is a process of importing – exporting – checking goods, keeping traces of each batch | Unable to prove quality control |
| c | Provide records, documents and information when requested by competent authorities | Be ready to present certificates, invoices, labels, and publication documents | Treated as not cooperating/concealing |
| d | Keep records for a minimum of 3 years from the time the goods are released into circulation (goods with a longer shelf life will be kept equal to the shelf life) | Set a storage schedule in batches, do not delete documents after the end of the selling season | There was no evidence during post-examination |
| đ | Coordinate with quality control agencies and market management agencies in inspection, retrieval and handling of violations | Dispatch contacts, provide data quickly when requested | Assessed for non-compliance, increased inspection frequency |
Clause 3 specifies how to check. Worth noting is point b clause 2 (now expressed in the structure of Article 69.3) allows authorities to check indirectly through “electronic data system, traceability information, codes, barcodes, standard conformity certification, regulation conformity certification”. For online sellers, this is a big change in approach: the agency does not necessarily have to go to the warehouse, but can compare data displayed on the booth with national data and manufacturer’s certification.
Practitioner’s note. The obligation to “retain for 03 years” (Article 69.2.d) is a fatal point for small sellers: after the end of the season, many shops delete all import invoices to “clean up their machines”. When the agency post-inspected a batch sold two years ago, there were no documents, meaning it could not prove origin and quality — even though the goods were in fact good. Consider quality records as legal assets, not administrative documents.
3. Article 70 — digital platforms and the question “so what does Article 34b include?”
The full text of Article 70 is brief but has great comprehensiveness:
> “Organizations and individuals selling goods and owners of intermediary digital platforms serving electronic transactions are responsible for implementing the management requirements specified in Article 34b of the Law on Product and Goods Quality, supplemented in Clause 19, Article 1 of Law No. 78/2025/QH15 before circulating on the market.”
There are four things to “peel” from this one sentence:
1. Object: consists of two groups — Sales organizations and individuals and owners/managers of an intermediary digital platform serving electronic transactions. According to common understanding, Shopee, Lazada, TikTok Shop (as an intermediary) belong to the second group; Sellers on these platforms belong to the first group. Both groups have obligations, and are not mutually exclusive.
2. Content: obligation is to “implement the management requirements specified in Article 34b of the Law“.
3. Time: “before being circulated on the market” — that is, obligations arise before goods are put up for sale, not after being inspected.
4. Limitations of the Decree: the Decree only refers to it and does not redefine Article 34b.
This is the most important point of the whole article, and is also where many articles online get it wrong. Article 70 does not list the specific content of Article 34b. If you want to know exactly what sellers and platform owners should do, you must read Article 34b of the Law on Product and Goods Quality (consolidated version after Law No. 78/2025/QH15). Anyone — including this article — who “invents” a list of obligations under Article 34b without citing the Law text is not trustworthy.
Therefore, the correct way to use Article 70 in practice is:
- Determine which group you belong to (seller / platform owner).
- Open the Law document and read it Article 34b and the articles referenced by the Decree.
- Compare with Article 41 (label obligations of sellers and floor owners — Decree regulates directly), Article 69 (duty for goods in circulation) and Chapter IV on labels to create your own checklist.
The table below is a “reference map” between the Decree and the Law, helping to avoid citing the wrong article:
| Article of Decree 37/2026/ND-CP | Reference to the Law on Product and Goods Quality | Notes |
|---|---|---|
| Article 66.1 (manufacturer obligations) | Article 28 of the Law (amended and supplemented at Clause 17 Article 1 Law No. 78/2025/QH15) | Requirements for product quality management in production |
| Article 68 (importer’s obligations) | Article 34 of the Law (amended and supplemented in Clause 19, Article 1 of Law No. 78/2025/QH15) | Requirements for quality management of imported goods |
| Article 69.1 (goods circulating on the market) | Article 34a Law (added in Clause 19, Article 1 of Law No. 78/2025/QH15) | Conditions of goods before circulation |
| Article 70 (goods traded on digital platforms) | Article 34b Law (added in Clause 19, Article 1 of Law No. 78/2025/QH15) | Obligations of sellers and digital platform owners |
Practitioner’s note. Because of Article 69.1 reference Article 34a, and Article 70 references Article 34b (also supplemented by Clause 19, Article 1 of Law No. 78/2025/QH15), do not confuse these two articles. Article 34a is associated with general obligations of goods in circulation; Article 34b pertains to goods traded on digital platforms. When making an explanation, citing the wrong thing will lose credibility and easily lead to errors.
4. When selling online, the label must be disclosed — Article 41.5 and Article 41.6
If Article 70 is the “doorway” to the Law text, then Article 41 is the part of the Decree that stipulates directly the label obligations for e-commerce. Article 41.5 is for seller, Article 41.6 for platform owner.
Article 41.5 — Obligations of organizations and individuals trading goods on e-commerce platforms:
- a) Publicly disclose all contents of product labels and electronic labels (if any) on the platform, except information that is specific to each product such as: year/month/date of manufacture, expiry date, production batch number, frame number, engine number. That is: what is the stable label content (name of goods, responsible organization, origin, ingredients, technical specifications, warnings…) must be public; and the time stamp and serial number may not need to be displayed.
- b) Declare and update exactly goods information on the sales system according to legal regulations on e-commerce and consumer protection.
- c) Ensure that goods delivered to consumers have labels according to regulations. This is a point many shops miss: the listing has a nice description, but the goods delivered are unlabeled goods, the label does not have enough content, or the goods are imported and do not yet have Vietnamese sub-labels attached.
Article 41.6 — obligations of e-commerce platform owners:
- a) Ensure that goods traded on the platform have full labeling information declared, publicly display product labels and electronic labels (if any) when posted for sale.
- b) Providing and sharing minimal data to connect with National database on standards, measurement and quality, including: information about organizations and individuals doing business on the platform; data on product labels; Information reported from consumers related to product labels and product quality.
- c) Archive complete, safe, confidential data on product labels and related information (seller information, electronic contracts, documents, invoices, documents proving the legality of labels, quality declaration and certification documents, transaction data) Minimum 5 years.
Points to highlight: Articles 41.5 and 41.6 differ in terms of storage period (seller 03 years according to Article 69.2.d; platform owner 05 years according to Article 41.6.c). This is a detail that compliance policy makers can easily confuse.
The table below summarizes What must be done for each role in the online sales chain:
| Role | The main thing to do | Base |
|---|---|---|
| Individual seller (small shop, used goods, handmade goods) | Publicize label content when posting for sale; Accurately declare information; Ensure delivered goods have labels; keep records for 03 years; cooperate when tested | Article 41.5; Article 69.2.c, d, e |
| Professional seller (many SKUs, warehouse, staff) | All five groups of obligations Article 69.2; establish internal control system; traceability if selling high-risk products | Article 69.2.a–đ; Article 22.1; Article 23 |
| Owner of e-commerce platform | Publicly display the label when listing for sale; share data with national database; Store for at least 5 years; coordinate with management agencies | Article 41.6.a–c; Article 70 |
| Manufacturer – importer (source) | Declaration of conformity with medium/high-risk goods; correct labeling Appendix I; perform import inspection; Create a digital passport if applicable | Article 66; Article 68; Article 41; Article 42; Articles 82–86; Article 32 |
Two groups of regulations are easily overlooked when listing for sale
First, the cases are not subject to labeling (Article 35.2). The Decree lists types of goods that do not require labeling, including: real estate; goods temporarily imported for re-export, in transit, transshipment, transit, imported goods sent to bonded warehouses for export to third countries; luggage of people entering and exiting the country, movable property; Goods brought with people entering the country for personal consumption, gifts and presents within tax-free limits; Confiscated goods sold at auction; fresh, raw food, processed food without packaging sold directly to consumers; fuel, raw materials, scrap, unpackaged construction materials sold directly; used goods; radioactive substances, electrical energy, emergency goods, railway, waterway and air transport vehicles. For shops selling used goods, agricultural products or liquidated goods, this is a point to understand – but must not be construed as “exemption from all obligations”: The obligation to ensure the quality of goods in circulation (Article 69) and the responsibility to handle and recall non-conforming goods (Article 90) still apply.
Second, content permitted and prohibited on labels (Article 50). Clause 1, Article 50 allows the display of additional codes, barcodes, standard conformity marks, regulation conformity marks, traceability data carriers and other contents, provided that they are not illegal, truthful, accurate, do not obscure or falsify mandatory content. Clause 2 Article 50 prohibits images and content related to sovereignty disputes and other sensitive content affecting security, politics, economics, society, diplomatic relations and fine customs. Online sellers need to apply this rule to everyone product photos, listing descriptions, and livestream content when introducing products.
| Regulation group | Core content | Practical consequences for online sellers |
|---|---|---|
| Not required for labeling (Article 35.2) | List excluded goods (real estate, used goods, fresh food without packaging…) | Labeling is not required according to the Decree, but quality must still be guaranteed (Articles 69, 90) |
| Additional expressions are allowed (Article 50.1) | Codes, barcodes, standards/regulation conformity marks, traceable data carriers… | Posted with a certificate and QR for traceability on the store if truthful |
| Prohibited expression (Article 50.2) | Images, copyright disputed content and sensitive content | Review photos, descriptions and livestream content |
Practitioner’s note. Don’t confuse “labeling on display” with “labeled delivery”. Article 41.5 requires both. Many shops only pay attention to the description (item a) but forget that the goods are actually delivered Has a physical label according to regulations (section c). With imported goods, “labeled” means added Vietnamese sub-label according to Article 39.3 and Article 40 before delivery.
5. Traceability, barcodes, digital passports, electronic labels — parts that online sellers easily miss
Decree 37/2026/ND-CP promotes three digital tools: traceability, codes and barcodes and product digital passport/electronic label. Online sellers are beneficiaries (transparency to increase reputation) but are also responsible.
Traceability (Articles 22–23). According to Clause 1 Article 22, for products and goods with a high level of risk, traceability is required. Ministries managing sectors and fields issue a list and roadmap for mandatory application (Article 22.2). Article 23 stipulates that the traceability system must ensure connection, data sharing, use of trace codes and data carriers Compliant with TCVN 13274 and TCVN 13275; Traceable data includes information such as product name, image, name and address of production and business unit, origin, key events, batch/serial number, expiry date, applicable standards/regulations (Article 23.5). For goods not subject to mandatory traceability, the seller may choose to implement it (Article 22.5).
Codes and barcodes (Articles 28–31). Article 31.3 regulates the cases of revoke the right to use codes and barcodes, including the acts of granting, leasing and transferring codes to other organizations and individuals; attaching codes to products that are not within the scope of registration; misleading information in registration documents or product data. This is a direct warning to online sellers: using barcodes “borrowed” from others, or attaching your own codes to goods that are not properly registered, can all have your rights revoked.
Digital passport and electronic label (Articles 32–34). Clause 1 Article 32 sets out the minimum content of a digital passport, which includes: product name and global product identifier (GTIN); name, address, identification number of the organization or individual producing – importing – trading; origin information or the place of final processing; traceability information; Certificates of conformity to standards, regulations, and quality certificates (if any); date of manufacture, expiry date (if any); Safety warnings (if any). Clause 4 Article 32 allows using digital passports instead of electronic labels if the digital passport has all the required labeling content. Article 34 places responsibility on production, import and business organizations and individuals to establish, maintain and update digital passports and responsible before the law about published information.
Comparison table of three forms of displaying commodity information:
| Criteria | Physical label | Electronic label | Product digital passport |
|---|---|---|---|
| Nature | Labels stuck/printed directly on goods and packaging | Label goods in electronic form via data carrier | Electronic data set associated with a unique product identifier |
| Base | Article 42, Article 39, Article 41 | Article 32.3; Articles 52–55 | Articles 32.1, 32.2, 32.4; Article 34 |
| Is there a replacement for physical labels? | Is the original standard | Cannot replace physical labels in cases prescribed by law | Can replace the electronic label if it has all required content (Article 32.4) |
| What online sellers use it for | Delivery of goods with correct labels (Article 41.5.c) | Publicity on the booth (Article 41.5.a) | Look up and authenticate origin and certification |
Practitioner’s note. A digital passport is not a mandatory obligation for all products. Clause 3 Article 32 says production and business organizations and individuals have the right to decide on electronic labeling; Clause 1 Article 33 says businesses are encouraged to use digital passports, the application roadmap is approved by the Prime Minister according to the proposal of the Ministry of Science and Technology. Don’t make incentives mandatory when consulting, and don’t ignore them because they’re “not mandatory” — the trend is to gradually tighten them along the way.
6. When the management agency checks: Articles 88–90 and how online sellers are “scanned”
Online sellers need to understand that checking the quality of goods circulating on the market (Article 88) does not exclude goods sold through platforms. Article 88.1 List the inspection grounds, with emphasis Existing data on risk level, traceability information, codes, barcodes, standard conformity certificates, regulation conformity certificates and Data from the quality management system connected to state agencies. This is the basis for the authorities Compare digital data instead of just checking directly.
Article 88.2 regulates the content of inspection: (a) check the compliance with legal requirements on quality; (b) if there are signs of quality failure, then sampling and testing at an independent and objective conformity assessment organization; (c) with high-risk goods, sampling planning periodically or unexpectedly to enhance testing.
Article 89 stipulates the order: announcing the inspection decision → collecting, reviewing, evaluating information, records, documents, data → making inspection records, records of administrative violations (if any) and handling according to law.
Article 90 imposes obligations on production and business organizations and individuals: products in circulation must not pose a risk; When detecting that the goods do not comply with standards/regulations or are likely to cause risks, it must be processed and recalled and comply with the requirements of competent state agencies. For online sellers, this is the basis for making a request Remove the listing, recall the delivered goods, and notify the buyer.
With imported goods (popular in hand-carried shops, consignment imports), need to know Article 82: goods of medium risk do not require quality inspection when imported, but require a declaration of conformity; goods of high risk must register for quality inspection (Article 83). Article 86 stipulates the cases exemption or reduction of inspection and reduced inspection regime (conditions of 03 consecutive imports passed, application period of 02 years…). Sellers who import goods through intermediaries need to check whether the source of goods has fulfilled this obligation, because when the goods go to market, responsibility for quality belongs to the business operator.
Practitioner’s note. For imported goods sold online, three common errors when inspected are: (1) missing Vietnamese sub-label; (2) no certificate of conformity of the shipment; (3) the labels displayed on the store do not match with physical labels delivered to customers. All three can be handled according to regulations on quality inspection of goods circulating on the market.
7. Seven common mistakes and their consequences
The table below summarizes common mistakes made by online sellers when applying Decree 37/2026/ND-CP, with grounds and solutions:
| # | Mistake | Why is it wrong (base) | Consequences / solutions |
|---|---|---|---|
| 1 | Thinking that “selling on the floor is not subject to quality control” | Clause 9, Article 3 defines circulation as including buying and selling on digital platforms; Article 70 clearly states the obligations of sellers and floor owners | Considered non-compliant; need to review all SKUs and obligations |
| 2 | Extract “Article 34b obligations” as a list available in the Decree | Article 70 only reference Article 34b; The Decree does not copy the content | Wrong basis when explaining; must read the Law text directly |
| 3 | Confusion of Article 34a (Article 69.1) with Article 34b (Article 70) | Two different articles, supplemented by Clause 19, Article 1 of Law 78/2025/QH15 | Citing the wrong thing; Loss of credibility when working with authorities |
| 4 | Only a nice description is published on the store, the goods are delivered without labels | Article 41.5.c obliges the goods to be delivered to the consumer must have a label | Risk of being dealt with; overcome by label checking process before delivery |
| 5 | Imported goods have not been labeled in Vietnamese | Article 39.3 and Article 40 require the addition of Vietnamese secondary labels; Article 42.2 requires the original label to have enough content upon customs clearance | Detained goods/failed import inspection; Additional labels are added before circulation |
| 6 | Not keeping quality records for up to 03 years (seller) | Article 69.2.d requires retention for at least 03 years; goods with a longer shelf life are stored according to the shelf life | Unable to prove origin upon post-inspection; Build a digital storage process |
| 7 | Using/transferring barcodes not within the scope of registration | Article 31.3.d stipulates revocation of rights when granting, leasing, or transferring code; attaching codes to goods outside the registered scope | Revoked the right to use the code; Must re-register and review labels |
The checklist below is for use before clicking “post for sale” for a new SKU:
| # | Things to check | Pass when | Grounds/notes |
|---|---|---|---|
| 1 | Identify product groups and required content on the label | Know clearly which group the SKU belongs to and what else needs to be written | Article 42.1.d + Appendix I |
| 2 | Check three common label contents | There is the name of the goods, name – address of the responsible organization, and origin | Article 42.1.a–c; Articles 43, 44, 47 |
| 3 | Check the content separately according to the nature of the goods | There are dosages, timelines, ingredients, warnings… according to SKU | Article 42.1.d; Appendix I |
| 4 | Check the correct time stamp | Correct “day/month/year”, “month/year” or “year” in groups | Article 46 |
| 5 | Check the label language | Mandatory content in Vietnamese; Imported goods have additional labels | Article 39; Article 40 |
| 6 | Check the public content on the store | Label content has been made public (except for product-specific information) | Article 41.5.a |
| 7 | Check the floor owner’s obligations (if you are the floor owner) | Has label display, data sharing, 5-year storage | Article 41.6 |
| 8 | Check traceability if goods are high-risk | There is a traceable code and standard-compliant data carrier | Article 22.1; Article 23 |
| 9 | Check quality records and retention periods | Have documents; saved for 03 years (seller) | Article 69.2.d |
| 10 | Check before delivery | Delivered goods have proper labels | Article 41.5.c |
This checklist does not replace reading Article 34b of the Law; it is a practical layer based on the regulations directly recorded in the Decree (Articles 41, 42, 46, 69) and references (Article 70). When Article 34b has specific content, businesses need to add corresponding items to the checklist.
8. Read next in the series of articles about Decree 37/2026/ND-CP
- Decree 37/2026/ND-CP: overview of 8 chapters, 99 articles, 7 appendices and 16 forms — “backbone” article to grasp the full text map before going into each article.
- Appendix I of Decree 37/2026/ND-CP: lookup table of 69 groups of goods and the mandatory content on labels — lookup tool to see what each SKU must include on the label.
- Appointing a conformity assessment organization under Decree 37/2026/ND-CP: conditions, documents and procedures — for businesses that need to understand who is issued a certificate of conformity for goods.
- What must e-commerce platform owners do to avoid being held responsible? — lawyer’s corner on platform owners’ obligations under Article 70 and Article 41.6.
- Live selling: legal risks and the compliance checklist under Decree 37/2026/ND-CP — Livestream sellers must also fulfill the obligations in Article 69 and Article 70, with a 12-point checklist before – during – after the live session.
The article was prepared according to Decree 37/2026/ND-CP provided by the enterprise; Code number, date of issuance and validity apply according to the official announcement document. The content is for technical reference only and does not replace legal advice for each specific case.
Conclusion
Selling on Shopee, Lazada, TikTok Shop or any other digital platform does not create an “exemption zone” regarding product quality. Article 69 of Decree 37/2026/ND-CP places on the seller five very specific groups of obligations: ensuring goods conform to announced applicable standards and corresponding technical regulations; maintain an internal control system; provide documents when requested by competent authorities; keep records for a minimum of 03 years; and coordinate in inspection, retrieval, and handling of violations. These are obligations that can be checked through paperwork, regardless of whether the goods are sold in stores or on an online store.
The most notable new points lie in Articles 41 and 70. Businesses on e-commerce platforms must publicly disclose the entire content of goods labels and electronic labels (if any) when posting for sale, declare and accurately update goods information on the sales system, and ensure that goods delivered to consumers have the correct labels. Platform owners have their own obligations: ensuring goods are fully declared with labeling information, sharing minimum data with the National Database on standards, measurement, quality and storing related data. In other words, the data on the booth becomes a quality record, and the management agency can check indirectly via electronic data before checking directly.
Experience reviewing records for online sellers shows that the most serious error is not the lack of a document, but the discrepancy between three layers of information: the actual label on the goods, the public information on the store, and the internal quality records. When these three layers match – the label is in accordance with Appendix I, the store posts the correct label content, the dossier has a declaration of conformity, the certificate is valid and saved for 3 years – then the explanation to the inspection agency is just a matter of presentation, not proof. That is also the reason why records should be digitized right from the selling stage, instead of gathering them when requested.
Regarding timing, two milestones to remember are the effective date of Decree 37/2026/ND-CP and July 1, 2026 – the date when the old regulations on goods labels (Decree 43/2017/ND-CP and Decree 111/2021/ND-CP) expire. As for the reference in Article 70 (management requirements in Article 34b of the Law on Product and Goods Quality), the seller should directly compare the Law document to fully update the obligations, because the Decree does not copy the content of this law.
References
The text below is the basis of the article; Readers should look up the official version on the Government Electronic Information Portal (vanban.chinhphu.vn) and the Electronic Information Portal of the Ministry of Science and Technology (most.gov.vn).
- Decree No. 37/2026/ND-CP dated January 23, 2026 of the Government detailing a number of articles and measures to organize and guide the implementation of the Law on Product and Goods Quality — Article 2 (subjects of application); Article 3 (explanation of terms: physical labels, electronic labels, data carriers, secondary labels, commercial packaging); Articles 22–23 (traceability); Articles 30–32 (product number passport, electronic label); Article 35 (scope of application and cases where labeling is not required); Article 41 (responsibility for labeling goods, in which clauses 5 and 6 stipulate the obligations of traders on e-commerce platforms and of platform owners); Articles 42–50 (mandatory contents on labels, permitted and prohibited contents); Articles 66–70 (ensuring quality in production, import, circulation and on digital platforms, in which Article 69 regulates the obligations of organizations and individuals selling goods); Articles 82–86 (quality inspection of imported goods); Articles 88–93 (inspecting the quality of goods circulating on the market, quality surveys, application of digital technology and electronic data for management).
- Law on Product and Goods Quality No. 05/2007/QH12, amended and supplemented by Law No. 78/2025/QH15 — Article 34 (ensuring the quality of imported goods), Article 34a (conditions for goods circulating on the market), Article 34b (ensuring the quality of goods traded on digital platforms for electronic transactions), supplemented in Clause 19, Article 1.
- Decree No. 43/2017/ND-CP and Decree No. 111/2021/ND-CP on goods labels — expire according to Article 97 of Decree 37/2026/ND-CP; The use of printed labels and packaging shall comply with the transitional regulations in Article 98 of Decree 37/2026/ND-CP.
- Related articles on ticforall.com: Decree 37/2026/ND-CP: overview of 8 chapters, 99 articles, 7 appendices and 16 forms; Appendix I of Decree 37/2026/ND-CP: lookup table of 69 groups of goods; Appointing a conformity assessment organization under Decree 37/2026/ND-CP.
Discuss with us
This article is our interpretation to disseminate legal knowledge about the quality of products and goods traded on digital platforms, not legal documents. The content is restated according to Decree 37/2026/ND-CP that we have at the time of writing; Legal documents may be amended, supplemented, replaced or abolished after the time the article is published. As for the management requirements in Article 34b of the Law on Product and Goods Quality (added in Clause 19, Article 1 of Law No. 78/2025/QH15) that Article 70 of the Decree references, readers need to look up the Law text directly to get the full content. Determining specific obligations depends on the type of goods, the business’s role in the supply chain and the disclosure records of each product; Before applying to a specific case, readers need to look up the current document on official information portals and consult with competent authorities. The content of the article is for reference only and does not replace legal advice.
