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IMPORT PROCEDURE GUIDE FOR ACIDITY REGULATORS
Acidity regulators are high-risk for customs classification because the same pH-control function may cover citric acid, citrates, lactic acid, tartaric acid, gluconates, phosphates, carbonates/bicarbonates or additive premixes. If the goods are described generically as “food additive” or “acid regulator”, enterprises may misapply HS Code, confuse self-declaration with product declaration registration, lack food safety import documents, omit INS/E-number, prepare inconsistent Vietnamese labels or fail to prove food grade. Common consequences include customs channel escalation, additional COA/MSDS/test report requests, loss of C/O preferential duty, DEM/DET and production delays. This guide provides an E2E review map before ETA, covering HS code, duty, specialized policy, dossier set, customs workflow and pre-arrival risks.
QUICK FACTS
Product
Food-grade acidity regulators, e.g. citric acid, citrates, lactic acid, tartaric acid/salts, gluconates, phosphates/carbonates for pH adjustment
Key HS
Depends on active substance: 2918.14.00 citric acid; 2918.15.10/90 citrates; 2918.11.00 lactic acid; 2918.12.00/13 tartaric acid/salts; 2918.16.00 gluconic acid; 2809.20.xx phosphoric acid; 2836.xx carbonate/bicarbonate
Reference duty
Many organic acid codes show MFN 0–5%, ordinary 5–7.5%, VAT 10%; citric acid/citrate lines commonly show MFN 5%, ordinary 7.5%, VAT 10%
Key policy
Self-declaration or product declaration registration depending on additive type/blend/use; import food safety inspection; labeling; review Circulars 24/2019 and 17/2023
Technical file
COA, specification, MSDS/SDS, INS/E-number, purity, food grade, permitted food categories, maximum level/GMP and original label
Caution
Do not classify all acidity regulators under one HS code; review each CAS/INS, composition, single/blended form and actual use
Legal note: This article applies only to food-grade acidity regulators within the group of sweeteners, preservatives, colorants, acidity regulators and anti-caking agents. It does not automatically apply to industrial chemicals, pharmaceutical ingredients, feed additives, multi-component additive premixes, additives outside the permitted list or additives used for inappropriate food categories. COA, specification, MSDS/SDS, CAS, INS/E-number, purity, food grade and actual import purpose must be reviewed.
SCOPE OF APPLICATION
This guide covers food additives used to adjust acidity/alkalinity or stabilize pH, commonly shown as acidity regulator, acidulant, pH regulator, buffer or buffering agent. Products may be single substances or salts of organic/inorganic acids, in powder, granule, crystal, liquid, solution, bag, drum, can, IBC or retail packaging.
- Not automatically applicable to industrial-grade acidity regulators used for water treatment, textiles, detergents, batteries, plating or chemical manufacturing.
- Not automatically applicable to multi-component premixes or blended additives; such goods require separate review.
- If an additive is outside the permitted list, has a new intended use or does not match the permitted food category, it must not be treated as ordinary food additive import.
- Samples, R&D goods, factory/EPE/FDI imports, internal processing goods or commercial goods may require different declarations and dossiers.
CLASSIFICATION & TECHNICAL IDENTIFICATION
Identification must start from the chemical name, CAS number, INS/E-number, chemical formula, purity, food-grade standard, intended food use and single/blended form. One trade name may hide different active substances, while one active substance may appear under multiple names. Merely writing “acid regulator” on invoice can cause HS, food safety and labeling errors.
| Checkpoint | Documents to review | Risk if described incorrectly | Suggested goods description |
|---|---|---|---|
| Main active substance | COA, specification, CAS, MSDS/SDS | All acidity regulators classified under one HS code | Food additive – acidity regulator: citric acid/sodium citrate/lactic acid…, INS…, CAS… |
| Single or blended product | Formula, ingredient list, technical sheet | Premix may require different declaration or HS | Single food additive / blended additive, with component ratio if any |
| Food-grade status | COA, certificate, test report, supplier declaration | Goods may be treated as industrial chemicals | Food-grade acidity regulator, purity…, batch… |
| INS/E-number and food category | Circular 24/2019, Circular 17/2023, specification, label | Additive not permitted, wrong food category or excess level | INS/E-number…, intended food categories…, max level/GMP… |
| Physical form and packing | Packing list, photos, original label | Wrong unit, storage or chemical identification risk | Powder/crystal/liquid, net weight…, packed in bag/drum/can/IBC… |
| Import purpose | PO, contract, purpose letter, use plan | Food use declared as industrial use or vice versa | Imported for use as food additive/acidity regulator in food manufacturing |
| Goods condition | Invoice, batch/lot, COA, actual photos | Sample/expired/near-expiry or COA mismatch risk | New 100%, batch…, MFG/EXP…, remaining shelf-life… |
HS CODE – DUTY – C/O
HS classification is based on the chemical nature and actual product form, not on the generic acidity-regulating function. Organic acids are usually in Chapter 29; inorganic acids and inorganic salts are usually in Chapter 28; blended preparations may require Chapter 21, 38 or another heading depending on composition.
| Reference HS code | Application condition | Ordinary duty | MFN duty | VAT | FTA preferential duty with valid C/O | Risk if incorrect | Documents to review |
|---|---|---|---|---|---|---|---|
| 2918.14.00 | Citric acid, single substance, food grade where used as acidity regulator | 7.5% | 5% | 10% | Certain FTAs may reduce to 0–2% or staged rates if C/O is valid | Confusing citric acid with citrate or premix distorts HS and C/O | COA, CAS 77-92-9, specification, label, C/O |
| 2918.15.10 / 2918.15.90 | Salts and esters of citric acid, e.g. calcium citrate or other citrates | 7.5% | 5% | 10% | FTA preference subject to valid C/O | Declaring citrate as citric acid may misdescribe goods | COA, CAS, salt/ester composition, specification, label |
| 2918.11.00 | Lactic acid, its salts and esters | 5% | 0% | 10% | Often 0% under many FTAs if eligible | May be confused with lactic culture or lactate blends | COA, CAS, purity, food-grade certificate |
| 2918.12.00 / 2918.13.00 | Tartaric acid or its salts/esters | 5% | 0% | 10% | FTA may be 0% if origin rules are met | Acid and salts/esters may be mixed up | COA, CAS, INS, specification |
| 2918.16.00 | Gluconic acid, its salts and esters | 5% | 0% | 10% | FTA by valid C/O | Industrial gluconates may not qualify as food additives | COA, CAS, use, label, test report |
| 2809.20.xx / 2836.xx / 2835.xx | Phosphoric acid, carbonate/bicarbonate, phosphate or inorganic salts used as pH buffers | Commonly 4.5–7.5% ordinary or by final code | Commonly 0–5% MFN or by final code | 10% | By each FTA if C/O is valid | Organic acid codes cannot be used for inorganic salts or industrial chemicals | COA, formula, CAS, purity, food grade, intended use |
| 2106 / 3824 / other codes | Only for blended preparations/premixes rather than separate chemically defined substances | As per final HS | As per final HS | As per final HS | By FTA if eligible | Declaring a premix as a single substance may be wrong | Formula, component ratio, intended use, label, declaration dossier |
Duty and C/O note: Rates are references for common codes. Tariffs may change by amendments and FTAs. C/O discrepancies in form, origin criteria, description, HS code or direct transport evidence may lead to denial of preferential duty.
APPLICABLE SPECIALIZED POLICY
| Goods scenario | Possible policy | Documents to check | Authority / processing channel if identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Single acidity regulator in permitted additive list and correct food category | Product self-declaration; state food safety inspection on import; Vietnamese supplementary label; traceability | Self-declaration, COA/test report, specification, original label, supplementary label, INS/E-number | Food safety authority; Customs; NSW if applicable | Before ETA and before circulation | COA alone is insufficient; permitted food category and level must be proven |
| Blended additive or multi-component premix | May require product declaration registration if new function or scope is not aligned; review Decree 15/2018 | Formula, ratio, intended use, label, test report | Competent food safety authority | Before purchase contract | Do not apply single-additive conclusion to premixes |
| Additive outside list, no INS/E-number or wrong food category | May not be eligible for import/circulation as food additive or may require special regulatory review | Specification, legal evidence, safety data, function | Competent food safety authority | Before purchase | High risk: may not be permitted in Vietnam |
| Food-grade chemical with industrial-use risk | Review import purpose, label, standard, use commitment and food safety inspection if used as food additive | COA, MSDS/SDS, food-grade certificate, PO, use-purpose letter | Customs; food safety authority | Before ETA | Industrial-grade documents may undermine food-use compliance |
| Samples/R&D/testing goods | Different customs regime and purpose evidence may apply | Purpose letter, PO, quantity, label, COA | Customs and specialized authority if requested | Before declaration | Do not use sample route for commercial import |
| Factory/EPE/FDI import for food production | Review customs regime, BOM/norms, storage records and food safety use | Contract, BOM, production plan, COA, declaration dossier | Customs managing EPE/FDI; food safety authority for domestic release | Before ETA | Domestic sale/use in domestic products may require tax and food safety review |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document name/number | Issuing authority | Effective timing | Role in procedure | Key points | Review note |
|---|---|---|---|---|---|---|
| Law | Law on Food Safety No. 55/2010/QH12 | National Assembly | Effective from 01 Jul 2011 | Core basis for foods and food additives | Responsibilities of food business operators | Check amendments if any |
| Food safety decree | Decree 15/2018/ND-CP | Government | Effective from 02 Feb 2018 | Self-declaration, product declaration registration, import food safety inspection, labeling, advertising | Articles 4, 6 and 13 are key for additives/import inspection | Distinguish permitted single additives from blends/new uses |
| New decree / validity status | Decree 46/2026/ND-CP and Resolution 15/2026/NQ-CP | Government | Resolution 15 effective from 06 Apr 2026 suspends Decree 46 and Resolution 66.13/2026 | Monitor applicable food safety regime | Resolution 15 suspension rule | Do not apply Decree 46 as effective without rechecking |
| Food additive circular | Circular 24/2019/TT-BYT | Ministry of Health | Issued 30 Aug 2019, effective 16 Oct 2019 | Management and use of food additives, permitted list, food categories and maximum levels/GMP | Appendices on permitted additives and maximum levels | Core source for INS/E-number review |
| Amending circular | Circular 17/2023/TT-BYT | Ministry of Health | Effective from 09 Nov 2023 | Amends/supplements food safety regulations including Circular 24/2019 | Article 1 amends Circular 24/2019 | Check consolidated/latest text before applying |
| HS list for food safety inspection | Circular 15/2024/TT-BYT | Ministry of Health | Issued 19 Sep 2024, effective 02 Nov 2024; replaces Circular 28/2021/TT-BYT | HS-coded list of foods, food additives and direct food-contact packaging/materials subject to import food safety inspection under the Ministry of Health | Principles for HS-list application and intended use; items not listed are classified under customs law and reported to the Ministry of Health for coordination/update | Clarify if goods are not intended for food/additive use |
| Goods labeling | Decree 43/2017/ND-CP and Decree 111/2021/ND-CP | Government | 43 effective 01 Jun 2017; 111 effective 15 Feb 2022 | Original and Vietnamese supplementary labeling | Mandatory label contents for imported goods | Labels must match COA, declaration and documents |
| Nutrition labeling | Circular 29/2023/TT-BYT | Ministry of Health | Effective from 15 Feb 2024 | Nutrition labeling where applicable | Nutrition facts presentation | Not every single additive needs nutrition facts; review actual label |
| Tariff | Decree 26/2023/ND-CP; Decree 108/2025/ND-CP | Government | 26 effective 15 Jul 2023; 108 effective 19 May 2025 | MFN and ordinary tariff basis for Chapters 28/29 | Chapter 28/29 by active substance | Rates are references; check tariff at declaration date |
| VAT | VAT Law 48/2024/QH15; Decree 181/2025; Resolution 204/2025; Decree 174/2025 | National Assembly/Government | Effective from 01 Jul 2025 for key VAT documents | Standard VAT and possible 2% reduction if eligible | Check exclusions and validity period | Verify before declaring VAT |
VIEW / DOWNLOAD ORIGINAL LEGAL TEXTS
Decree 15/2018/ND-CPCircular 24/2019/TT-BYTCircular 17/2023/TT-BYTCircular 15/2024/TT-BYTChapter 29 tariff
Enterprises should additionally verify the texts on official legal document portals or issuing authority websites before applying them.
CUSTOMS CLEARANCE DOCUMENT SET
Commercial documents
- Commercial Invoice
- Packing List
- B/L or AWB
- Sales Contract/PO if any
- C/O if preferential duty is claimed
- Product photos, original label, batch/lot
Additive / food safety files
- Self-declaration or registration certificate if applicable
- COA/test report by batch
- Specification, MSDS/SDS
- INS/E-number, CAS, food-grade certificate
- Vietnamese supplementary label and use-purpose documents
Shipment control data
- Chemical name and formula
- Purity/active content
- MFG, EXP and remaining shelf-life
- Storage condition
- Permitted food categories and max level/GMP
| File group | Required documents | Used for | Usually prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO | Value, quantity, trade terms | Procurement/Docs/Importer | Generic “food additive”; missing CAS/INS; wrong unit | Match chemical name, CAS, batch and packing |
| Transport | B/L or AWB, arrival notice, pre-alert | D/O, manifest, declaration | Forwarder/Carrier/Docs | Wrong description or missing DG data if applicable | Check draft B/L/AWB and MSDS |
| HS–tax | COA, specification, CAS, composition, MSDS | HS, MFN duty, VAT and FTA review | Importer/Compliance/Broker | HS based on use instead of chemistry | Map active substance – CAS – HS before ETA |
| Food safety/additive | Declaration, test report, INS/E-number, Circular 24/2019 | Import food safety inspection and circulation | QA/Compliance/Importer | Food grade or permitted use not proven | Match INS, food category, max level and label |
| C/O | Eligible C/O form, invoice, transport documents | Special preferential duty | Exporter/Supplier/Docs | Wrong HS, chemical description or origin criterion | Check draft C/O before ETA |
| Labeling | Original label, supplementary label, artwork, storage warning | Post-clearance circulation | Importer/Marketing/Compliance | Missing additive name, function, INS, expiry, origin, storage warning | Review under Decrees 43/2017 and 111/2021 |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended handling |
|---|---|---|---|---|
| HS by active substance | Is it citric acid, citrate, lactate, tartrate, phosphate, carbonate or premix? | COA, CAS, specification, MSDS | HS query, duty correction, C/O error | Finalize active substance and CAS before booking |
| Additive status | Is it permitted for the intended food category and level? | Circular 24/2019, Circular 17/2023, INS/E-number | Circulation not accepted or food safety explanation required | Review INS, food category and max level/GMP |
| Declaration route | Self-declaration or registration? Premix/new use? | Decree 15/2018, formula, label, use purpose | Wrong dossier route and delays | Classify dossier route before ETA |
| Food grade | Do documents prove food grade and safety criteria? | COA, test report, supplier certificate | Goods may be treated as industrial chemicals | Request batch-specific COA and food-grade certificate |
| Supplementary label | Does the label show additive name, function, INS, quantity, origin, expiry? | Original and Vietnamese labels | Market circulation risk | Approve Vietnamese label before warehouse delivery |
| C/O | Does C/O match HS, chemical description, origin and direct transport? | Draft C/O, invoice, B/L | FTA preference denied | Check draft C/O before ETA |
PRACTICAL E2E WORKFLOW
Pre-ETA review.
Finalize active substance, CAS/INS, HS, duty, VAT, C/O, declaration route, food safety inspection, labeling and actual use.
Lock documents and technical files.
Finalize Invoice, Packing List, B/L/AWB, COA, specification, MSDS/SDS, original label, batch/lot, purity and food-grade certificate if any.
Register/update specialized dossier if applicable.
For permitted single additives, prepare self-declaration/food safety dossier. For premixes, new uses or additives outside the list, review registration or special handling before ETA.
Lodge customs declaration.
Green: system clearance subject to conditions. Yellow: document check. Red: document and physical inspection. Common queries: value, HS, chemical name, CAS, food grade, C/O, COA, MSDS and food safety policy.
Clear, deliver and archive post-clearance records.
Deliver to warehouse, check Vietnamese label, archive declaration, COA, test report, C/O and transport documents for post-clearance review.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA prevention | Documents to check |
|---|---|---|---|
| Generic name “acid regulator/food additive” | Wrong HS and weak food additive evidence | State chemical name, CAS, INS and function | Invoice, COA, specification |
| Food grade not proven | Industrial chemical suspicion and additional dossier request | Request COA/test report, food-grade certificate and correct labels | COA, test report, supplier declaration |
| Circulars 24/2019 and 17/2023 not reviewed | Additive may be wrong category or level | Map INS/E-number with food category and max level/GMP | Circular 24/2019, Circular 17/2023, specification |
| Single substance confused with premix | Wrong declaration route, HS and food safety policy | Obtain formula and component ratio before declaration | Formula, ingredient list, label |
| Wrong C/O HS or description | FTA duty denied | Check draft C/O against confirmed HS and invoice/B/L | C/O, invoice, B/L |
| MSDS shows hazard/DG but transport not declared properly | Carrier refusal or additional transport documents | Check MSDS, UN number/class before booking | MSDS/SDS, booking note, DG declaration if any |
FAQ
| Question | Short answer |
|---|---|
| Does importing acidity regulators require a permit? | Do not treat it as a generic permit. Review whether the additive is permitted for food use, food category and level, and prepare self-declaration or registration if applicable. |
| Is import food safety inspection required? | It may be required if the goods are imported for use as food additives and fall under managed HS/use. Review HS, intended use and actual dossier. |
| Which HS code is commonly used? | There is no single code. Citric acid: 2918.14.00; citrates: 2918.15.xx; lactic acid: 2918.11.00; tartaric acid: 2918.12/13; phosphoric acid: 2809.20.xx; carbonate/bicarbonate: 2836.xx. |
| Is Vietnamese supplementary labeling required? | Yes, if circulated in Vietnam. The label should show additive name, function, components/INS where relevant, quantity, expiry, origin, responsible entity and warnings if any. |
| Can C/O reduce duty? | Potentially, if C/O form, HS, chemical description, origin criteria and direct transport comply with the relevant FTA. |
| Are R&D samples handled like commercial goods? | Not always. Import purpose, quantity, value, food-use or non-circulation status must be reviewed. |
| Can industrial-grade COA be used for food additive import? | It should not be treated as food additive if food grade and safety criteria are not proven. Request documents matching food-use purpose. |
| If the product is citrate + phosphate blend, which HS applies? | Review formula, component ratio, principal character and HS rules. Do not automatically use citric acid or any single component code. |
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.
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