Transparent product information through global identification systems is becoming an inevitable trend for goods seeking access to modern distribution channels or participation in export activities. The presence of a standardized identification system helps strengthen an enterprise’s market position and enhance its reputation in the marketplace. The following article by VO & Associates provides enterprises with comprehensive guidance on legal regulations, dossier requirements, and procedures for barcode registration under the current legal framework.

1. What Are Barcodes and Their Role in Goods Management?

Pursuant to Article 3 of Circular No. 10/2020/TT-BKHCN, the concepts are technically https://gs1vn.org.vn/?utm_source=chatgpt.comand legally defined as follows:

• Barcode Number (Product Code): A sequence of numbers or characters structured according to common standards and used to uniquely identify products, services, locations, organizations, or individuals.
• Barcode: A method of representing, storing, and transmitting barcode number information through visual symbols readable by scanners, including traditional linear barcodes (1D barcodes), multidimensional geometric patterns (such as Data Matrix, QR Code, PDF417, and other 2D barcode structures), or radio-frequency identification chips (RFID) and equivalent identification technologies.

From a practical perspective, barcodes function as a unique electronic identification tool for goods throughout the circulation process. It should be noted that barcodes serve only identification and traceability purposes and do not directly reflect the technical specifications or intrinsic quality standards of products.

International Standards

Under the regulations of the global GS1 Organization, goods originating from Vietnam are internationally recognized through the country prefix beginning with “893.” Each product variation in packaging specifications, weight, color, or characteristics must be assigned a separate barcode number for supply chain management purposes.

Practical Example from VO & Associates Experts

A bottle of chili sauce manufactured in Vietnam typically uses the global EAN-13 barcode standard consisting of 13 digits, for example: 8931234567897. The structure of this barcode includes four mandatory components:

• 893: Country code assigned to Vietnam under the international GS1 system.
• 12345: Enterprise prefix assigned by the National Barcode Center under the Directorate for Standards, Metrology and Quality.
• 6789: Product item code structured and assigned by the enterprise to distinguish the chili sauce product from other product lines such as ketchup or soy sauce.
• 7: Final check digit automatically calculated based on the preceding 12 digits according to the Modulo 10 algorithm to ensure scanning accuracy.

2. Regulations on Registration of Barcode Usage Rights

As a fundamental principle, current law does not require all manufactured goods to bear barcodes. However, if an enterprise voluntarily chooses to use barcodes on product labels or packaging, it must carry out barcode registration procedures with the competent authority in accordance with regulations.

Obtaining lawful barcode usage rights from the competent authority provides several strategic advantages for business operations:

• Access to modern distribution channels:
  Although not legally mandatory, in practice barcode systems are almost an operational and logistics management requirement for major supermarket chains (such as Co.opmart, WinMart, Aeon, and Lotte) and e-commerce platforms when establishing official stores.
• Enhanced traceability:
  Barcodes support state authorities in market supervision while allowing consumers to scan products using mobile applications to verify official information, thereby protecting brands against counterfeit and imitation goods.
• Integration into global supply chains:
  Applying the international GS1 standards gives products a “common identification language,” facilitating customs clearance and export procedures in foreign markets.

3. Dossier Requirements for Barcode Registration

Pursuant to Decree No. 13/2022/ND-CP of the Government (amending and supplementing several provisions of Decree No. 132/2008/ND-CP and Decree No. 74/2018/ND-CP guiding the Law on Product and Goods Quality), enterprises are required to prepare one complete legal dossier consisting of:

1. An application for barcode usage registration (prepared in accordance with the prescribed form issued together with Decree No. 13/2022/ND-CP).
2. A certified true copy of one of the following documents: Enterprise Registration Certificate; Investment Registration Certificate; or Establishment Decision of the organization.

4. Latest Procedures for Barcode Registration

(Pursuant to Decree No. 13/2022/ND-CP)

Step 1: Submit the Dossier and Pay Fees to the Standing Agency

Enterprises shall submit the above-mentioned legal dossier and fulfill fee payment obligations to the specialized authority, namely the National Barcode Center (GS1 Vietnam), through one of the following methods:

• Online submission: Declaring information and uploading digitized dossiers via the online public service portal to optimize processing time.
• Direct submission or postal submission.

Step 2: Dossier Appraisal and Issuance Timeline

The dossier processing procedures at the National Barcode Center are carried out according to the following timelines:

Actual Dossier Status	Processing Time	Measures Taken by the Authority
Incomplete or invalid dossier	Within 05 working days from the date of receipt	The authority shall issue a written notice specifying the reasons and requesting amendments or supplements.
Complete and valid dossier with full fee payment	Within 20 days from the date of receipt	The competent authority shall issue the Certificate of Barcode Usage Rights to the enterprise.

Legal Note from VO & Associates

The validity period of the Certificate of Barcode Usage Rights is no more than 03 years from the date of issuance (pursuant to Article 19c of Decree No. 74/2018/ND-CP amending and supplementing Decree No. 132/2008/ND-CP). Enterprises should proactively monitor this timeline and carry out renewal procedures before expiration to avoid barcode interruptions that may directly affect business operations.

5. Legal and Operational Risks When Enterprises Handle the Procedures Themselves

From practical legal consulting experience, VO & Associates has observed that enterprises conducting barcode registration procedures independently without a proper understanding of the system’s technical requirements often encounter unintended issues.

5.1. Delays Due to Product Classification Errors

The online barcode registration portal requires a high degree of accuracy in product classification according to the standardized GS1 categories. Even a minor mistake in product description or incorrect classification may result in the dossier being returned. Due to strict amendment deadlines, lack of experience can significantly delay the appraisal process and affect product launch schedules.

5.2. Failure to Update Post-Registration Data Affecting Brand Reputation

Many enterprises mistakenly believe that the process is completed once they receive the hard-copy certificate. In practice, enterprises are required to assign specific barcodes to each product variation and update detailed product information onto the national GS1 Vietnam database.

If this step is neglected, when partners or consumers scan the barcode through traceability applications (such as iCheck or Barcode Việt), the system may display notifications such as “Product information has not been updated,” inadvertently creating doubts regarding product origin and authenticity.

5.3. Risk of Barcode Suspension and Administrative Penalties Due to Late Maintenance Fee Payment

Under current regulations, enterprises are required to pay annual barcode maintenance fees before June 30 each year. Due to the lack of dedicated personnel monitoring deadlines, many enterprises overlook this financial obligation, leading to undesirable consequences.

Pursuant to Article 32 of Decree No. 119/2017/ND-CP, as amended and supplemented by Decree No. 126/2021/ND-CP:

• The use of barcodes after the expiration of the Certificate shall be subject to a fine ranging from VND 2 million to VND 5 million for organizations (pursuant to Article 3 of Decree No. 119/2017/ND-CP).
• Failure to pay the maintenance fee in accordance with regulations shall result in a fine equivalent to between one and three times the barcode maintenance fee amount. The maximum fine is VND 50 million, together with remedial measures requiring full payment of the prescribed maintenance fee.

6. Comprehensive Barcode Registration Services at VO & Associates

To optimize time efficiency and minimize legal risks, VO & Associates provides comprehensive barcode registration services for enterprises, including:

• Consulting on product classification and standardized product code structures in accordance with the GS1 system.
• Representing enterprises in drafting legal dossiers in compliance with Decree No. 13/2022/ND-CP, submitting dossiers, and directly working with the National Barcode Center.
• Providing guidance on updating product information to the database system after barcode issuance and supporting enterprises in monitoring annual maintenance fee deadlines.

Let the legal experts at VO & Associates accompany your enterprise in building a solid foundation for your products. For further information, please contact us via the website vo-associates.vn.

Contact Information

 Hotline: +84 909 865 891 (Zalo, WhatsApp)

 Email: hello@vo-associates.vn

 Website: https://vo-associates.vn

 Room 105, 1st floor, Cityview Building, 12 Mac Dinh Chi Street, Sai Gon Ward, Ho Chi Minh City.

Best regards./.