Cosmetic launch imagery: beautiful and accurate.
The failed launch of a cosmetic line was not due to poor visuals, but because the wording crossed the boundaries of disclosure or the visuals were beautiful but no one remembered the brand.
The launch images for cosmetics need to evoke desire while adhering to the declared language framework: only describing beauty and care functions, without using treatment or healing language. Every description of features in images, videos, and influencer content (KOL) must match the registered product declaration. The primary image must be distinctive enough for viewers to remember the brand, accompanied by an adaptable guideline that allows the community and KOLs to create content while still recognizing it as a house brand.
- launching cosmetics needs to evoke desire and emotion but must be within the framework of legal announcements
- with a large KOL network or affiliate marketing: prioritize the toolkit that binds the text of the function from the start
- needs adaptive guidelines for the community to create compliant content, both in identity and announcement language
- using terms like treatment, targeted treatment, definitive treatment, or allowing KOLs to exaggerate the function, leading to regulatory violations
- the image is very beautiful but the brand identity is weak, viewers remember the effect but forget the brand
The cosmetics industry has a unique characteristic that few other industries face: images must be compelling enough to evoke desire while not exceeding what the product has declared to regulatory authorities. These two requirements are not contradictory. However, without proper preparation, a campaign can easily be beautiful yet incorrect, or correct yet bland.
The boundary of the announced language you need to understand beforehand
According to Circular 06/2011/TT-BYT (as amended) and Decree 342/2025/NĐ-CP detailing the Advertising Law (replacing Decree 181/2013/NĐ-CP from February 15, 2026), the content of cosmetic advertising must match the declared features. This content must not mislead consumers into thinking the product is a medicine. The ASEAN feature guidelines (ASEAN Cosmetic Harmonization Agreement) also state a similar direction: cosmetics should describe beauty and care functions, avoiding treatment or healing language. These documents may have been amended or replaced, so you need to compare with the current effective version before publication.
In practice, that boundary lies in the choice of each word:
- Typically found in the care and beauty category: acne reduction, acne prevention, dark spot fading, cleansing, moisturizing, improving skin texture.
- Often considered crossing the line: acne treatment, targeted treatment, definitive treatment, dark spot cure, therapy.
The specific list depends on each product declaration that the business has registered. Your legal team or product team is responsible for verifying the wording in images and videos before publication.
Beautiful imagery that no one remembers the brand is a failure.
The beauty industry has countless beautiful images. Smooth, radiant skin, warm golden light, close-up product textures, and glowing models. If you cover the logo, most brand images look similar.
Jenni Romaniuk in Building Distinctive Brand Assets (Oxford University Press, 2018) points out that the goal of brand imagery is not only to be beautiful but to create a memory link. Viewers must remember the brand correctly, not just the general feeling of the entire beauty sector.
Therefore, the primary image should have distinctive identity assets: colors, shapes, image materials, or characters. These elements must be specific enough for viewers to remember the brand correctly even when scrolling quickly on their phones.
When to choose an emotional story, when to choose to illustrate the function
Storytelling, emotional direction: Suitable when the campaign goal is to build the brand, create desire, or associate the brand with a specific emotion or lifestyle. Imagery leans towards experience, atmosphere, and characters. The wording describes feelings and expectations, not listing features.
Illustration of functions: Suitable when the goal is to persuade trial use, explain mechanisms, or compete directly on features. The wording is more specific, but must still fall within the declaration framework. Before-and-after images can be used if there is real evidence and accurate expression, without absolutizing.
Two directions can be combined in the same campaign, for example, a long emotional film, product articles on a sales channel focused on functionality. It is important that the wording in both directions aligns with the Disclosure Form.
The brief for KOLs and community content: constraints from the start
The most fragile point of a cosmetic campaign is the network of influencers (KOL) and user-generated content (UGC). Each person speaks differently, and if one person exaggerates the functions, the entire campaign is at risk.
The approach is to prepare adaptive guidelines before sending the brief to the KOL, instead of reviewing each post after it is published.
- A list of words to use and words to avoid when describing benefits.
- Sample sentences can be used immediately, having been checked by the legal team against the announcement framework.
- Guide on colors, logos, and image ratios to maintain consistent brand identity.
When the KOL network or affiliate marketing is large, this toolkit is more important than any main image. It controls what actually reaches the consumer.
Common mistakes when launching cosmetics
- Use terms like treatment, specialized treatment, or let KOLs exaggerate the benefits, leading to advertising regulation violations.
- An image may be very beautiful but lacks a unique identity asset; viewers remember the effect but forget the brand.
- Do not prepare an adaptable guideline for the community, as each channel describes the function differently.
- Exaggerating results in before-and-after images compared to the actual product, trading long-term trust for short-term attention.
- Putting all resources into the main image while neglecting to check if the text matches the announcement form before release.
Cosmetic advertising content must align with the declared features and not mislead consumers into thinking the product is a drug.
Decree 342/2025/NĐ-CP detailing the Advertising Law
The order to follow: permissible wording first, images later
You should confirm the list of features that can be declared first, and then create the primary image and brief. Doing the opposite can lead to many revisions at the final stage, when the images and videos have already been created.
The verification of whether the wording describing functions matches the product declaration belongs to the product or legal team of the business. This step needs to be approved before publication, and for any ambiguous points, you should consult a specialized lawyer.
Decision checklist
Topic: Cosmetics: product launch images and disclosure obligations. Sinh Vũ guide, sinhvu.com
Tick each item that applies or that you can already answer, then print or save as PDF to take with you.
If you have marked most of the signs above, this is the time to discuss in more detail. Sinh Vũ can help you review and propose a direction.
This article provides general information according to the documents in effect as of October 6, 2026. This is not legal advice and does not substitute for a lawyer's opinion for your specific case. Rights and obligations between Sinh Vũ and clients arise only according to the signed contract.
References
Circular 06/2011/TT-BYT from the Ministry of Health on cosmetic management; Decree 342/2025/NĐ-CP detailing the Advertising Law, Article 4 (cosmetic advertising); ASEAN Cosmetic Harmonization Agreement; Jenni Romaniuk, Building Distinctive Brand Assets (Oxford University Press, 2018).
Frequently asked questions
Can before and after images be used in a cosmetics launch campaign?
It can be used, but there must be real evidence and accurate expression, without absolutizing the results. Accompanying wording must still fall within the declaration framework: for example, 'skin looks brighter after a period of use' instead of 'definitively treats dark spots'. If evidence is exaggerated, legal risks and long-term loss of trust will increase.
If KOLs and the community post incorrect content about the product's use, will the brand be implicated?
There are risks, especially when the brand provides briefs or materials that KOLs use to exaggerate functions. The preventive measure is to prepare an adaptable guideline clearly stating words to use and words to avoid from the start of the campaign, before sending the brief externally. The specific level of liability is determined by current regulations and your lawyer.
Which words are prohibited, and which can be used when describing cosmetic features?
Words implying treatment or healing are often considered crossing the line: acne treatment, targeted treatment, definitive cure, melasma treatment. Words describing care and beauty typically fall within: acne reduction, acne prevention, melasma fading, cleansing, moisturizing. A complete list needs to be compared with the product declaration, ASEAN feature guidelines, and the currently effective documents; your legal team is the final verifier.
This article is for reference. The scope, pricing, and specific commitments of Sinh Vũ are detailed in the proposal and signed contract.