Gummies used as chewable vitamin/mineral/health-supplement products are easy to mishandle if they are described merely as “candy” in commercial documents. The key risks usually relate to incorrect HS classification, confusion between ordinary confectionery and health supplements, or missing product declaration files before arrival.

If the catalogue, original label, ingredients, claims and test report do not match, the shipment may be routed for document inspection, additional submission, C/O preference rejection, or DEM/DET charges due to port/container delays.

This article provides an E2E (End-to-End) review map before ETA: HS code, duties, food-safety policy, product declaration, commercial documents, labeling and pre-arrival risk controls.

QUICK FACT

Item	Review direction	Operational note
Product	Vitamin/mineral/functional gummies for oral use.	Applies only to gummies, not automatically to vitamins, minerals, collagen drinks, probiotics or capsule/powder supplements.
Main reference HS	2106.90.72 – other health supplements.	Applicable where the product is a health supplement/supplement gummies; review ingredients, claims, use instructions and label.
HS to further review	2106.90.73, 1704.90.xx or another code depending on product nature.	Do not use “candy” if the label shows nutrient/health supplement claims.
MFN import duty	Reference 15% for 2106.90.72.	Verify the tariff schedule on the customs declaration date.
Ordinary import duty	Reference 22.5% if MFN/FTA conditions are not met and no lower/specific ordinary rate applies.	Based on the 150% of MFN principle for ordinary duty.
VAT	Review 8% during the VAT-reduction period if not excluded; 10% is the standard/fallback rate.	Check VAT policy on the declaration date.
Food safety	May require product declaration registration if classified as a health supplement.	Declaration files must match label, ingredients and testing indicators.
Labeling	Original label and Vietnamese supplementary label must contain mandatory information.	Pay attention to product name, ingredients, quantity, manufacturing/expiry dates, origin, responsible party, directions/warnings.

Legal note
Legal note: Gummies may be treated as health supplements or ordinary food depending on ingredients, dosage, declared use and labeling. Do not determine policy from the commercial name alone; review catalogue, specification, original label, COA/test report, product declaration and actual import purpose.

SCOPE OF APPLICATION

This article applies to gummies used to supplement vitamins, minerals, collagen, probiotics or other nutrients, imported for commercial distribution in Viet Nam. It does not automatically apply to medicinal gummies, edible cosmetics, ordinary confectionery without health claims, R&D samples or products with specially controlled ingredients.

Determine whether the product is a health supplement, food supplement or ordinary confectionery.
New goods, samples, gifts, trial goods or project goods may require different handling.
Products containing animal-origin gelatin, probiotics, high-dose vitamins or special claims require additional technical review.
Review catalogue, specification, original label, test report, SKU and actual import purpose.

CLASSIFICATION & PRODUCT IDENTIFICATION

Main function

Usually described as gummy supplement/health supplement gummies for oral supplementation of vitamins, minerals, collagen, probiotics or other nutrients.

Product form

Soft chewable gummies packed in bottles, jars, pouches or cartons; may vary by SKU, flavor, active dosage and packing size.

Technical files

Specification, ingredient list, nutrition facts, label artwork, COA/test report, GMP/HACCP/ISO if any, declaration dossier and directions for use.

Identification risk

Generic descriptions such as “gummies/candy” may lead to wrong HS, wrong food-safety policy and declaration questions.

Criterion to check	Document to compare	Risk if misdescribed	Suggested goods description
Product nature	Original label, specification, ingredient list, claims.	Confusion with ordinary confectionery or another supplement group.	Vitamin/mineral supplement gummies, chewable form, for oral use, brand new.
Ingredients and dosage	COA/test report, nutrition facts, declaration formula.	Wrong food-safety policy, declaration mismatch or testing request.	State key actives if needed: vitamin C, zinc, collagen, probiotic…
Claims	Catalogue, label, advertising content, declaration file.	May be treated as health supplement if supplement/functional claims are shown.	Avoid disease-treatment claims; keep wording neutral and dossier-consistent.
Packing specification	Invoice, Packing List, label, goods photos.	Mismatch in quantity/weight during inspection.	Example: 60 gummies/bottle, 120g/bottle, 24 bottles/carton.
Manufacturing/expiry dates	Original label, COA, batch/lot list.	Shelf-life questions or circulation risk.	State batch/lot/expiry if required by documents or specialized files.

HS CODE – DUTIES – C/O

For gummies classified as health supplements/food supplements, HS classification is generally reviewed under Chapter 21 – miscellaneous edible preparations. The final HS code still depends on product nature, ingredients, dosage, claims, use and declaration file.

Reference HS code	Applicable condition	Risk if wrongly applied	Documents to compare
2106.90.72	Gummies are other health supplements with nutrient/health supplement claims for oral use.	Declaring as ordinary candy may cause wrong duty and missing declaration policy.	Original label, specification, ingredient list, product declaration, COA/test report.
2106.90.73	For micronutrient mixtures added to food; only when the goods are premix rather than finished retail gummies.	Wrong if the product is finished gummies for direct consumption.	Catalogue, use purpose, retail/non-retail packing.
1704.90.xx	Only for ordinary confectionery without supplement/health claims.	May miss food-safety declaration if actual goods are supplements.	Label, claims, active ingredients, marketing files.

Tax item	Reference rate	Applicable condition	Control note
MFN import duty	15% for 2106.90.72	When MFN conditions are met and HS is correctly declared.	Verify tariff schedule on declaration date.
Ordinary import duty	Reference 22.5%	When MFN/special preference is not available and no separate ordinary rate applies.	Based on 150% of MFN under Decision 15/2023/QD-TTg.
VAT	8% or 10% depending on period/policy	Review VAT reduction validity and exclusion lists.	Do not fix the rate without checking on declaration date.
Special preferential duty by C/O	May be lower than MFN, depending on FTA	Valid C/O, correct form, origin criterion, description and HS.	Check FTA, C/O form, direct transport and third-party invoicing.

Checklist C/O

C/O description must match invoice, packing list and declaration dossier.
HS on C/O should be consistent or acceptable under the applicable FTA.
Origin criterion must satisfy product-specific rules, not merely the exporting country.
For third-party invoice, back-to-back C/O or transit, prepare transport and explanatory documents.

APPLICABLE SPECIALIZED POLICY

Goods situation	Possible policy	Files to check	Authority/portal if identified	Recommended timing	Risk note
Health supplement gummies	Product declaration registration; imported food-safety inspection.	Declaration, COA/test report, label, specification, company files.	Ministry of Health/Viet Nam Food Administration; food-safety e-portal.	Before arrival/before distribution.	Late filing after ETA can delay clearance/circulation.
Ordinary food gummies	Self-declaration and import food-safety inspection depending on file.	Self-declaration, testing sheet, label, ingredients.	Local food-safety authority/NSW if inspection arises.	Before distribution.	Do not apply this if health claims appear on label.
Probiotic, gelatin or animal-origin ingredients	Additional review of ingredients, storage, safety or quarantine documents may arise.	COA, health certificate/free sale, ingredient-origin files.	Food-safety/quarantine authority based on file.	Before purchase and before ETA.	Insufficient ingredient data often triggers explanation requests.
Samples/R&D goods	May differ from commercial goods; purpose must be clear.	Non-payment invoice, packing list, purpose letter, technical files.	Customs and specialized authority if any.	Before declaration.	Do not assume exemption if goods will be sold.
EPE/FDI/factory import	Review import type, use purpose, storage and domestic distribution.	Contract, PO, business license, use/distribution plan.	Managing customs office.	Before ETA.	Wrong declaration type can affect tax and post-clearance audit.
Vietnamese supplementary label	Import labeling before market circulation.	Original label, supplementary label, label photos.	Importer responsibility; market surveillance/customs may check.	Before circulation.	Label errors may trigger penalties or correction.

LEGAL DOCUMENTS TO REVIEW

Document group	Document name/number	Issuing authority	Effective/applicable timing	Role in procedure	Key provisions/appendix to note	Review note
Law	Law on Food Safety No. 55/2010/QH12	National Assembly	Review current effect	Legal foundation for food safety.	Rules on food-safety conditions, declaration and inspection.	Background legal basis.
Decree	Decree 15/2018/ND-CP	Government	Effective 02/02/2018	Product declaration, import food-safety inspection, labeling/advertising.	Articles 6–8 on product declaration; import inspection and labeling chapters.	Determine whether gummies are health supplements or ordinary food.
Circular	Circular 43/2014/TT-BYT	Ministry of Health	Effective from 01 Feb 2015	Regulates functional foods, including food supplements and health supplements.	Scope, labeling, instructions for use and warnings for functional foods.	Review when gummies carry supplement or health-function claims.
Circular	Circular 18/2019/TT-BYT	Ministry of Health	Effective from 17 Jul 2019	Guides GMP for manufacturing and trading health supplements.	GMP certificate or equivalent certificate for imported health supplement declaration files.	Important for preparing the product declaration registration dossier.
Decree	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	43 effective 01/06/2017; 111 effective 15/02/2022	Import labeling and Vietnamese supplementary label.	Mandatory contents, language and labeling responsibility.	Check for later amendments/replacements.
Tariff decree	Decree 26/2023/ND-CP	Government	From 15/07/2023	MFN tariff schedule.	Heading 21.06, code 2106.90.72.	Verify on declaration date.
Decision	Decision 15/2023/QD-TTg	Prime Minister	Effective 15/07/2023	Ordinary import duty.	150% MFN principle where no separate ordinary rate applies.	Use only where MFN/FTA preference is unavailable.
Decree	Decree 174/2025/ND-CP	Government	01/07/2025–31/12/2026	VAT reduction policy.	Exclusion lists and application period.	Check VAT on declaration date.
FTA/tariff	Special preferential tariff decrees by FTA	Government/Ministry of Finance	By FTA and period	Preferential duty with valid C/O.	PSR, C/O form, direct consignment.	Do not assume 0%; verify origin and form.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Businesses may search by document number on the legal document portal, the Government e-portal or the issuing authority website. Businesses should cross-check the legal document portal or the authority website before application.

View Decree 15/2018 View Circular 43/2014 View Circular 18/2019 Food declaration portal View Decree 43/2017 View Decree 111/2021 View Decree 174/2025

CUSTOMS CLEARANCE DOCUMENT SET

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
C/O if claiming preferential duty.
Catalogue/specification, original label, photos, batch/lot list if needed.

Specialized files if applicable

Product declaration registration or self-declaration file.
Testing sheet/COA/test report for declared criteria.
Vietnamese labeling file.
Ingredient, directions, warning and claim documents.
Imported food-safety inspection result if applicable.
Origin files for special ingredients if any.

File group	Required document	Used for	Usually prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB, contract/PO.	Declaration, cargo release and value check.	Importer, seller, forwarder.	Generic goods name; wrong quantity/unit.	Compare SKU, bottle/carton count, net/gross weight, Incoterms.
Technical	Specification, ingredient list, nutrition facts, label artwork.	HS classification and food-safety policy.	Importer/manufacturer.	No clear active dosage or claim.	Compare with original label and declaration file.
Declaration/food safety	Declaration, testing sheet, COA/test report, registration file.	Import/distribution eligibility.	Legal/Compliance/QA.	Name, ingredients or packing mismatch.	Freeze label and specification before shipment.
C/O	Proper C/O form, transport docs, third-party invoice if any.	Special preferential duty.	Shipper, importer, forwarder.	Wrong form, criterion, description/HS.	Review draft C/O before original issuance.
Label	Original label, Vietnamese supplementary label, label photos.	Clearance/circulation/post-audit.	Importer/brand owner.	Missing responsible party, origin, expiry, warning.	Check mandatory contents and declaration consistency.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended handling
Product nature	Health supplement or ordinary confectionery?	Label, specification, claim, declaration.	Wrong HS and food-safety policy.	Confirm product nature before quotation/declaration.
HS Code	Is 2106.90.72 well-supported?	Catalogue, ingredients, function, packing.	Consultation, duty adjustment, dossier revision.	Prepare HS classification memo before ETA.
Product declaration	Is declaration available for the correct SKU/pack?	Registration/self-declaration, test report.	No circulation eligibility, delayed clearance.	Complete files before arrival.
Label	Does label match declaration?	Artwork, photos, declaration file.	Correction/explanation request.	Freeze label artwork before production.
C/O	Is C/O valid for preference?	C/O, B/L/AWB, invoice, origin rules.	Preference rejected.	Check draft C/O under each FTA.
Goods status	New, sample, gift or commercial goods?	Invoice, PO, purpose letter.	Wrong declaration type/policy.	Define import purpose at the beginning.

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Confirm HS, duty, C/O, labeling, food-safety declaration and product nature.

Step 2: Lock commercial and technical files

Lock Invoice, Packing List, B/L/AWB, specification, ingredient list, label artwork and SKU list.

Step 3: Complete specialized files if applicable

Step 4: Customs declaration

Green lane may clear subject to system conditions; Yellow lane checks documents; Red lane checks documents and physical goods.

Step 5: Clearance and post-clearance control

Release cargo, apply supplementary labels, archive shipment files and prepare for post-clearance explanation.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Files to check
Described as “candy” despite health claims.	Wrong HS/policy and explanation request.	Standardize description as supplement gummies.	Label, specification, claim, declaration.
Declaration file mismatches label/ingredients.	No circulation eligibility or dossier revision.	Freeze label and formula before filing.	Declaration, test report, label.
C/O form or criterion error.	FTA preference rejected.	Review draft C/O.	C/O, invoice, B/L, origin rule.
Missing proper test report/COA.	Additional specialized filing.	Obtain testing documents before ETA.	COA, test report, product standard.
Packing mismatch.	Inspection and quantity issues.	Compare bottle/carton/gummy count/net weight.	Invoice, Packing List, label, photos.
VAT not reviewed on declaration date.	Cost estimate error.	Update VAT policy and exclusion list.	Tariff, VAT policy, final HS.

FAQ – COMMON BUSINESS QUESTIONS

Do gummies require an import license?

If they are health supplements, product declaration registration and food-safety procedures are usually required. Do not conclude without reviewing label, ingredients, claims and import purpose.

Which HS code applies to gummies?

2106.90.72 is a common reference for other health supplements, but final classification depends on ingredients, use, claims and packing.

Is import food-safety inspection required?

It may arise under Decree 15/2018/ND-CP depending on product group, declaration file, import history and inspection method.

Is a Vietnamese supplementary label required?

Yes, for goods circulated in Viet Nam where the original label does not contain all mandatory Vietnamese information.

Can C/O reduce duty?

Possibly, if C/O is valid under the relevant FTA and description, HS and origin criterion are acceptable.

Are sample gummies treated the same as commercial goods?

Not automatically. Review import purpose, quantity, value, post-import use and specialized requirements.

What if the label includes disease-treatment claims?

This is a high-risk point because food must not be presented as medicine. Review claims, declaration and advertising content before shipment.

What if SKU on invoice differs from label?

Ask the supplier to amend documents before arrival; otherwise prepare a SKU mapping table, label photos, packing list and explanation.

IMPLEMENTATION SUPPORT FROM TGIMEX

This article provides a review map for HS, duty, documents and specialized policy for gummies. In actual shipments, businesses still need to verify catalogue, specification, original label, ingredients, documents, origin and import purpose.

Pre-ETA review

HS, duty, C/O, food-safety policy and labeling.
Cross-check catalogue/specification/SKU before arrival.

Compliance document control

Invoice, Packing List, B/L/AWB, C/O, test report and label.
Consistency between declaration file and commercial documents.

International logistics & clearance

Coordinate agent/carrier, monitor ETA and pre-alert.
Prepare customs declaration, handle lanes and support explanations.

For gummies shipments with possible product declaration, food-safety inspection, C/O or labeling requirements, businesses should not wait until arrival to review files. TGIMEX supports an E2E import plan covering pre-ETA policy review, document checking, international logistics, customs declaration, clearance handling, domestic delivery and post-clearance file archiving.

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