Is It Mandatory for Product Labels to Include Illustrative Images on the Packaging?

On the product labels of our company, there are actual photographs of the product and accompanying ingredients. However, when printing the labels, we adjusted the colors of the photographs to make the product more appealing to consumers but did not note "Images on packaging are for illustrative purposes only" on the package labels. Therefore, are our product labels compliant with the regulations?

Article 10 of Decree 43/2017/ND-CP stipulates:

Mandatory Contents to be Displayed on Goods Labels

  1. Goods labels must display the following contents:

    a) Name of the goods;

    b) Name and address of the organization or individual responsible for the goods;

    c) Origin of the goods;

    d) Other contents depending on the type of goods as specified in Appendix I of this Decree and relevant legal documents.

  2. In cases where the goods fall under multiple categories in Appendix I or are not specified in legal documents, the organization or individual responsible for the goods will determine the category based on the primary use of the goods to record the contents specified in point d, clause 1 of this Article.

  3. In cases where the size of the goods is insufficient to display all mandatory contents on the label, the contents specified in points a, b, and c, clause 1 of this Article must be displayed on the label, while the contents specified in point d, clause 1 of this Article should be included in the accompanying documents, and the label must indicate where these contents are recorded.

For goods that are medical devices, the implementation of the contents specified in point d, clause 1 of this Article should follow the provisions in Appendix I of this Decree.

Additionally:

- The colors of letters, numbers, drawings, images, signs, and symbols on the goods label must be clear. For mandatory contents, the letters and numbers must have a color that contrasts with the background color of the goods label (Article 6).

- Other contents displayed on the goods label (Article 18):

+ Organizations or individuals responsible for the goods are allowed to display codes, barcodes, conformity marks, conformity marks, and other contents (if any). The additional contents must not conflict with the law and must ensure truthfulness, accuracy, reflect the true nature of the goods, and must not obscure or distort the mandatory contents on the label.

+ The goods label must not display images or contents related to sovereignty disputes and other sensitive contents that may affect security, politics, economy, society, diplomatic relations, and traditional customs of Vietnam.

Therefore, there is currently no mandatory requirement to note "The images on the packaging are for illustrative purposes only" on the label packaging. However, the displayed contents must ensure truthfulness, accuracy, and reflect the true nature of the goods.

Respectfully!

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