In industry import cosmetics, functional foods and consumer goods, error wrong ingredient names on the actual label Even just one letter can cause the whole shipment to "freeze" at the border gate. This is exactly the situation in which the team Logistics power has successfully handled hundreds of businesses each year. An “o” instead of “ou”, a missing hyphen, or the INCI name is reversed - all of which can turn into a customs clearance "nightmare"..

This article by Logistics power will give detailed instructions from A-Z on how to identify, analyze and fix errors wrong ingredient names on the actual label compared to published records. The content is built based on practical experience and current legal regulations, Help your business avoid losing tens of millions of dong in storage costs and administrative fines.

Opening: Wrong one drink, take a shipment

Imagine: shipment 5.000 A box of skin cream worth 300 million VND has arrived at Cat Lai port. Customs checked and discovered that the actual label said "Flavor" while the documents announced it was "Flavour". Or “Gluten free” is missing a hyphen from the profile. In just 30 minutes, The declaration was "whistle-blowing", Goods must be transferred to a bonded warehouse.

Why was a small error discovered?? Customs authorities and Food Safety Department (or the Drug Administration of Vietnam) Use automatic comparison software. Just 1 wrong character, The system reports "no match". This is not a random error but a mandatory requirement for absolute accuracy between the actual label and the published record.

Common practical consequences for businesses:

• Delay in customs clearance 7–30 days
• Storage costs: 2–5 million VND/day/lot
• Risk of administrative fines ranging from 20–50 million VND
• Risk of revocation of published numbers, must be announced again from the beginning
• Loss of credibility with foreign partners

Legal Basis and Sanction Regulations

To handle it legally, Businesses need to clearly understand the following documents (Updated to 2025):

• Decree 15/2018/ND-CP (and additional modifications): Detailed regulations on food safety. Articles 10 and 15 require labels to be “correct, enough, clear” and fully consistent with self-declared or published records.
• Circular 06/2011/TT-BYT (and Circular 06/2021/TT-BYT as amended): Regulations on cosmetic management. Annex II requires that the component name must match the international INCI name (International Nomenclature of Cosmetic Ingredients). Wrong name INCI is considered “component error”.
• Decree 43/2017/ND-CP (Amended by Decree 111/2021/ND-CP): Regulations on product labels. Article 10 clearly stipulates: “The content on the label must be consistent with the published records”. Wrong ingredient name belongs to the group "label not in accordance with regulations".
• Decree 115/2018/ND-CP (Amended by Decree 117/2020/ND-CP): Penalties for administrative violations in the field of health and food safety.
  • Small error penalty (spelling): 10–20 million VND
  • Serious error (Completely wrong substance name): 40–60 million VND + product recall + import suspension for 3–6 months.

III. Analyze the nature of errors (Assessment)

Before deciding on a solution, Businesses must accurately classify errors wrong ingredient names on the actual label Which group do you belong to?:

1. Pure spelling error (Mild – accounts for 65% of cases) For example: “Gluten free” vs “Gluten-free”, “Vitamin C” vs “Vitamine C”, “Flavor” vs “Flavour”. Does not change the nature of the ingredients → has a chance of successful explanation.
2. Identification error (INCI name/Chemical name) (Severe – accounts for 25%) For example: The label says “Sodium Lauryl Sulfate” while the profile says “Sodium Laureth Sulfate” (two completely different substances). Or different CAS names → high risk, may be considered “wrong ingredient names on the actual label”.
3. Formula update error (Very heavy – accounts for 10%) The manufacturer changed the formula but the business has not yet had time to file a new announcement. → Must cancel the old announcement number and re-announce it all.

Quick tips from Cuong Quoc Logistics: Take a photo of the actual label + scan the publication file → immediately send it to our team for free classification within 15 minutes.

4-step process to fix label discrepancies

Logistics power Apply the standard 4-step process, has helped 98% of shipments successfully clear customs without penalty.

Step 1: Temporarily suspend customs clearance - Store in storage

• Contact Customs immediately to transfer goods to our bonded warehouse or CFS warehouse Logistics power (Save 30–40% of costs compared to port warehouses).
• Time: 24–48 hours to avoid high storage fees.

Step 2: Compare CAS codes and International Standards

• Look up the code now CAS (Chemical Abstracts Service) on PubChem or INCI database.
• If the CAS code on the actual label and records is completely coincide (For example: CAS 9004-32-4 cho Carboxymethyl Cellulose), Enterprises have a solid basis to explain "typographical errors".

Step 3: Choose a treatment plan

• Option A – Secondary labeling (Recommended for minor errors) Based on Article 15 of Decree 43/2017/ND-CP: Attach additional labels to correct ingredient names according to the published dossier. Secondary label right:
  • There is a clear word "Secondary label".
  • Do not obscure other required information
  • Fixedly glued, no peeling
• Option B – Refresh the announcement (Required for fatal errors) Cancel the old announcement number → submit a new announcement dossier that matches 100% with the actual label. Time 7–15 working days.

Step 4: Work with authorities

• Submit a written explanation + technical evidence.
• Logistics power Business representatives submit documents at the Food Safety Department or Customs Branch, Reduce approval waiting time by 70%..

1. How to draft a "persuasive" Explanation Letter

A professional dispatch is the "golden key". Below is the standard 4-part structure Logistics power Successfully used for more than 150 customers:

1. Introduction Dear: Food Safety Department / Customs Branch... Business name: …Declaration number: … Product name: … Number of votes announced: …
2. Misleading content “At ingredient number 3 on the label it actually says ‘Flavour’, while the release records say ‘Flavor’. This is the only difference, does not affect the nature of the product.”
3. Expert argument
   • Quote MSDS/COA from manufacturer (attached).
   • Confirm: “The two names refer to the same substance with CAS code 123-45-6”.
   • Citing international INCI standards (Cosmetic Ingredient Database).
   • “This is just a spelling error due to differences between British English and American English, do not change the formula".
4. Commitments and Proposals “We commit to taking full legal responsibility. Proposal to allow additional labeling according to Decree 43/2017/ND-CP for immediate customs clearance.”

Conclude

Error wrong ingredient names on the actual label It is not the "death" of the shipment if you act correctly and quickly. With a 4-step process + professional dispatch, 98% of cases are approved for additional labeling or customs clearance after editing documents.

Cuong Quoc Freight Forwarding Company Limited

Office: 7th floor, Parami Building, 140 Bach Dang, Tan Son Hoa Ward, Ho Chi Minh City

Hotline: 0972 66 71 66

Email: info@cql.com.vn

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