By Tam Nguyen | CEO, GOL Solution | 24+ years in international trade & cross-border logistics

Last Updated: October 2026

To send beauty device samples to influencers across Southeast Asia, first check whether each country classifies the device as a medical device. Under Ministry of Health rules, beauty devices with LED count as medical devices in Vietnam, so the brand in this case study could not simply ship them in bulk without waiting for medical device licenses. It staged the launch instead: it held stock in Singapore, sent single parcels to creators as gifts, and left licensing for the point when sales showed which products deserved the investment.

Since 2025 the brand has shipped more than 700 orders to Vietnam this way, covering creator gifts. No parcel was held. A few parcels arrived damaged and went back to Singapore.

This article explains why Vietnam is the sticking point, what Singapore’s rules allow, the legal basis for the creator gifts, where the model reaches its limits, and the checklist we use with brands planning a similar campaign.

How do you send beauty device samples to influencers when one market treats the device as a medical device?

You split the launch into stages. Stage one holds stock in a country where the device is not regulated as a medical device. Stage two sends single parcels to creators in the regulated country, on a legal basis that fits each parcel, such as a gift to an individual. Stage three invests in the licence for the products that marketing data show are worth it.

Staging decides what to license and when. It does not remove the licence from the plan.

Why is Vietnam the sticking point for beauty devices with LED?

In Vietnam, Ministry of Health rules count beauty devices with LED as medical devices. Decree 98/2021/ND-CP defines a medical device by its medical purpose and sorts devices into four risk classes, A to D. Under Article 22, a device needs a circulation number or an import licence before it is placed on the market, except in the cases carved out in Article 3, clause 8 and Article 24. For Class A and B the circulation number is the number of a published declaration of applicable standards. For Class C and D it is a registration certificate.

The Decree has been amended several times. The consolidated text, 08/VBHN-BYT of 6 March 2026, includes amendments through Decree 342/2025/ND-CP of 26 December 2025.

That matters for a creator campaign. A brand does not know which SKUs will resonate until creators and audiences react. Licensing every LED SKU first means paying for the ones that never take off.

What do Singapore’s rules allow for holding the stock there?

Singapore’s Health Sciences Authority (HSA) regulates by intended use. Its June 2018 guideline on devices for modification of appearance or anatomy says that a device intended by the product owner for both medical use and modification of appearance is classified as a medical device. For devices intended solely for modification of appearance, HSA subjects only a positive list of high-risk devices to medical device controls. That list, Annex A, covers implants, injectable dermal and mucous membrane fillers, and equipment that removes or degrades fat by invasive means.

Other solely aesthetic devices are not regulated as medical devices. On that basis, the brand’s stock was held in Singapore on the cosmetics side of HSA’s rules, not as a registered medical device. The stock came into Singapore through a local partner. For how an importer of record works in Singapore, see our case study on importer of record in Singapore. More on the Singapore side is in our Singapore market entry guide and in Shopee cross-border cosmetics in Singapore.

Two cautions: The guideline does not discuss LED devices, so the brand’s claims matter: a device marketed with medical claims is a different case. The guideline also notes a separate regime, under which the National Environment Agency licenses the handling of non-ionizing radiation emitting equipment, so check whether it touches your device. HSA’s Medical Devices Branch is the place to confirm the classification of a specific product.

What is the legal basis for sending gift parcels to creators in Vietnam?

Article 3, clause 8(b) of Decree 98/2021 says the rules on classification, circulation numbers and declaration of sale conditions do not apply to medical devices traded as ordinary goods and imported as gifts to individuals or to organizations that are not medical facilities. A Vietnamese creator is an individual, not a medical facility. A sample sent with no payment from the creator is a gift. The brand sent each sample as a single parcel from Singapore.

Gifts to medical facilities follow a different rule. The Ministry of Health’s letter 6099/BYT-TB-CT of 27 October 2022 says that devices without a circulation number, imported as gifts to medical facilities, need an import licence. A gift basis that works for a creator does not carry over to a clinic or spa that counts as a medical facility.

The paper trail should show a gift: no payment, one parcel per recipient, and the recipient named.

What did more than 700 orders show?

More than 700 orders have shipped to Vietnam since 2025, covering creator gifts. No parcel was held. Some parcels arrived damaged, and each of those had to go back to Singapore through an export-back procedure.

When should the brand move to licensing?

When demand grows and the brand has marketing data on which products perform best. At that point it applies for licences for those SKUs so it can import stock in bulk into Vietnam. The data decides which SKUs to license first, so the licensing budget goes to products with proven demand.

The trigger is steady demand plus a clear list of best-performing SKUs, not a fixed number of orders.

How do you set up a staged sample program? A checklist

Work through these seven checks in order before the first parcel ships.

1. Classify every SKU in every campaign market. Is it a medical device there, and in which class?
2. Find the legal basis for each parcel type in each regulated market. For gifts to individuals in Vietnam, that is Article 3, clause 8(b) of Decree 98/2021.
3. Pick a hold point where the device is not regulated as a medical device, and confirm it with the regulator. For Singapore, that is HSA’s Medical Devices Branch.
4. Keep the gift paper trail: no payment, one parcel per recipient, the recipient named.
5. Plan returns. Damaged parcels need an export-back route.
6. Check the advertising rules before creator content goes live. Decree 98 covers information and advertising of medical devices (Article 1, clause 1).
7. Set the licensing trigger and the order of SKUs from marketing data.

When does this approach not apply?

A staged sample program fits a narrow set of cases.

• The device carries medical claims. HSA classifies a device intended for both medical use and modification of appearance as a medical device, so the Singapore hold point no longer works.
• You sell in commercial quantities in Vietnam. Normal trade needs a circulation number or an import licence (Article 22, clause 1(a)).
• The recipient is a clinic, spa or other medical facility. Gifts to medical facilities need an import licence if the device has no circulation number.
• You plan to rely on paid personal-consumption orders at scale.
• Other markets classify differently. Check each country in the campaign. This case covers Vietnam as the one market where the classification created the problem.
• The rules change. Decree 98 has been amended repeatedly, most recently by Decree 342/2025 in the consolidated text. Check the current text before each new campaign.

Frequently asked questions

Sources

• Decree 98/2021/ND-CP on medical device management (Vietnamese text, Article 3 clause 8, Article 22)
• Thu Vien Phap Luat: Decree 98/2021/ND-CP (Article 24, Article 22)
• Thu Vien Phap Luat: Decree 98/2021/ND-CP, classification of medical devices (English)
• Consolidated text 08/VBHN-BYT (6 March 2026), Decree on medical device management
• Ministry of Health letter 6099/BYT-TB-CT (27 October 2022)
• HSA: Aesthetic-Related Guidelines (June 2018)
• HSA: Regulatory Guidelines for Devices for Modification of Appearance or Anatomy (announcement, 1 June 2018)