Blended additive is a high-compliance-risk product group because classification depends on the composition, technological function, intended food category and regulatory status of each additive. A wrong HS code, missing product registration, inconsistent label or unclear formulation may lead to document queries, customs inspection, delayed clearance and DEM/DET charges. This guide provides an E2E (End-to-End) roadmap for reviewing HS code, duties, C/O, food-safety policy, product announcement dossier, labeling and pre-ETA risks.

QUICK FACTS

Field	Details
Product	Blended additive – mixed food additive preparation for use in food processing
Reference HS	2106.90.91 if it is a mixture of chemicals with foodstuffs or nutritive substances for food processing; it may shift to 2106.90.98, 2106.90.99, 3302.xx, 3824.xx or chemical-specific codes depending on the actual nature
Reference duties	MFN 15% for 2106.90.91; ordinary duty 22.5%; VAT generally reviewed at 10% or 8% if eligible under the temporary VAT reduction policy
Key policy	Product registration may apply to blended additives with new technological functions, additives outside the permitted list, or additives used for non-permitted food categories
Authority/portal	Vietnam Food Administration – Ministry of Health; public service portal/NSW where applicable
Core warning	Do not conclude marketability before checking each additive, INS/E-number, maximum use level, permitted food category and technical dossier

Illustration for Import Procedure Guide for Blended Additive — Illustration of the product group and document review before customs clearance.

LEGAL NOTE

LEGAL NOTE: A blended additive should not be treated as an ordinary food ingredient. If the product has a new technological function, contains an additive outside the permitted list, or is intended for a non-permitted food category, the importer should prepare the product registration dossier before importation or circulation. Review must be based on specification, COA, MSDS, ingredient list, label and actual import purpose.

SCOPE OF APPLICATION

This article applies only to blended additive imported as a mixed food additive preparation for food manufacturing or processing. It does not automatically apply to stand-alone flavourings, processing aids, enzymes, pure chemicals, micronutrient premixes, food supplements, pharmaceutical excipients or cosmetic ingredients. Samples, R&D goods, FDI/EPE factory imports, internal-use goods, re-export goods and commercial imports may trigger different compliance handling. The actual catalogue, datasheet, formulation and import purpose must be reviewed.

CLASSIFICATION & PRODUCT IDENTIFICATION

Product nature

Determine whether the product is a blended food additive, a chemical, a flavouring, a processing aid or a micronutrient premix.

Quantitative composition

Obtain ingredient list showing each additive, carrier, solvent, anti-caking agent, stabilizer and ratio where required.

Technological function

Clarify whether it works as stabilizer, emulsifier, gelling agent, acidity regulator, antioxidant, preservative, colour, sweetener or humectant.

Permitted use

Check permitted food category, maximum level, GMP or ML under food additive regulations.

TECHNICAL IDENTIFICATION CRITERIA

Criteria to check	Documents to compare	Risk if misdescribed	Suggested goods description
Trade and technical name	Specification, label, catalogue, COA	Generic wording “food additive” may create HS/policy uncertainty	Blended food additive preparation for food processing, main components…, powder/liquid form, used in…
INS/E-number of each additive	Ingredient list, manufacturer declaration	An additive outside the permitted list or wrong food category may require product registration	State INS/E-number list where available
Mixing ratio/carrier	Formula summary, COA, MSDS	Missing ratios may cause queries during registration or customs explanation	Blended food additive with carrier…, not a finished consumer food
Form and packaging	Packing list, label photos, technical sheet	Retail packs may be interpreted differently from industrial raw materials	Powder/liquid in bags/drums/cans for food manufacturing
Import purpose	PO/contract, factory dossier, production process	Trading, R&D, internal use or re-export may require different handling	Raw additive material used in production at…

HS CODE – DUTY – C/O

HS classification for blended additive depends on composition and function. A mixed additive preparation used in food processing may be reviewed under Chapter 21, especially 2106, but flavourings, pure chemicals, enzymes or non-food-additive products must not be forced into 2106 without technical grounds.

Reference HS	Application condition	Reference duty/VAT	Risk if wrongly applied	Documents to compare
2106.90.91	Other mixtures of chemicals with foodstuffs or nutritive substances for food processing	Reference MFN 15%; ordinary duty 22.5%; VAT 10% or 8% if eligible	Composition, processing purpose and nutritive carrier may be queried	Specification, COA, ingredient list, MSDS, label
2106.90.98	Other flavouring preparations for food use	Reference MFN 8%; ordinary duty 12%; VAT by import time	Wrong if the product has additive technological functions beyond flavouring	Catalogue, formula summary, function declaration
2106.90.99	Other edible preparations not elsewhere specified	Reference MFN 15%; ordinary duty 22.5%; VAT by import time	High risk if used as a fallback code without technical evidence	Catalogue, composition, use purpose
3302.xx / 3824.xx / chemical-specific codes	When the product is a flavour mixture, chemical preparation or pure chemical additive not fitting 2106	Rates vary by actual code	Wrong HS may lead to duty and specialized policy errors	MSDS, CAS, purity, food-grade/technical-grade data

C/O & FTA REVIEW TABLE

Origin/source	Possible C/O form	Duty implication	Key risk
China	Form E or RCEP if conditions are met	Preferential rate may apply depending on HS and rule of origin	Mismatch in HS/description/origin criterion/transit documents
ASEAN	Form D or RCEP	Review PSR and direct consignment	Generic description may be challenged
Korea/Japan	Form AK/VK, AJ/VJ or RCEP	Choose the agreement based on duty rate and available origin evidence	Third-party invoicing and mixing-origin issues require control
EU/UK	EVFTA/UKVFTA	Review proof of origin/REX or relevant origin statement	Inconsistent documents may lead to C/O rejection

APPLICABLE SPECIALIZED POLICIES

Goods scenario	Possible policy	Dossier to check	Authority/portal	Recommended timing	Risk note
Standard blended additive within permitted list and proper food category	Review self-declaration/registration requirements under Decree 15 and current additive regulations	Ingredient list, INS/E-number, ML/GMP, COA, label	Food safety authority; public portal where applicable	Before shipment	Wrong function or target food category may shift it to product registration
Blended additive with new technological function	Product registration with MOH/VFA under Decree 15 and Circular 24/VBHN 09	Registration dossier, scientific evidence, quantitative composition	Vietnam Food Administration – MOH	Before ETA	May not be circulated/used without acceptance
Additive outside permitted list or wrong target use	Product registration and circulation only after acceptance	Specification, COA, safety data if required, proposed use category	VFA/MOH	Before commercial import	High rejection and storage-cost risk
Samples/R&D goods	Still review food safety policy, purpose and non-commercial restrictions	Invoice, packing list, purpose letter, research dossier	Customs and sectoral agency	Before shipping	“Sample” does not automatically waive specialized dossiers
FDI/EPE factory imports	Review internal use, export processing, domestic sale and food safety requirements	Contract, BOM, production process, factory dossier	Customs and food safety agency	Before import planning	Domestic sale may trigger full announcement/label requirements

LEGAL DOCUMENTS TO REVIEW

Document group	Name/number	Issuing authority	Validity/application time	Role in procedure	Key article/appendix	Review note
Law	Law on Food Safety No. 55/2010/QH12	National Assembly	Effective 01 Jul 2011	Legal framework for food safety and food additives	Provisions on additives, labels and responsibilities	Apply with implementing decrees/circulars
Decree	Decree 15/2018/ND-CP	Government	Issued/effective 02 Feb 2018	Product self-declaration, product registration, import food safety inspection and labeling	Articles 6, 7, 8 and additive-related provisions	Current baseline while Decree 46/2026 is suspended
Resolution	Resolution 15/2026/NQ-CP	Government	Effective 06 Apr 2026	Suspends Decree 46/2026/ND-CP and Resolution 66.13/2026/NQ-CP	Full text	Monitor new replacement/restoration instruments
Circular/Consolidation	Circular 24/2019/TT-BYT; Consolidated Document 09/VBHN-BYT 2024	Ministry of Health	Circular effective 16 Oct 2019; consolidation issued 06 Sep 2024	Permitted additive list and management/use rules	Rules for new-function blended additives and non-listed/wrong-use additives	Check INS/E-number, food category and maximum level
Tariff	Decree 26/2023/ND-CP and amendments	Government	Effective 15 Jul 2023; check current version at declaration time	MFN basis for Chapter 21	Heading 2106.90	Do not finalize duty before HS confirmation
VAT	Decree 174/2025/ND-CP; Resolution 204/2025/QH15	Government/National Assembly	Applicable from 01 Jul 2025	Temporary VAT reduction policy	Exclusion appendices and conditions	Review 8%/10% at import time
Labeling	Decree 43/2017/ND-CP; Decree 111/2021/ND-CP	Government	Review validity at circulation time	Imported goods labeling and Vietnamese sub-label	Mandatory label information	Additive name, ingredients, instructions and warnings must be consistent

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises may search legal documents by number on official legal databases, the Government portal or the issuing authority website. Always re-check the official source before applying.

Decree 15/2018/ND-CP Consolidated Document 09/VBHN-BYT Resolution 15/2026/NQ-CP Decree 174/2025/ND-CP

CUSTOMS CLEARANCE DOCUMENT SET

The dossier should be divided into commercial documents and specialized regulatory documents. Product name, quantity, item code, batch/lot, origin, composition and function must match across commercial documents, regulatory dossier, label and customs declaration.

Commercial documents

Commercial Invoice with accurate product name, specification, item code and food-processing purpose.
Packing List showing packages, weight, packing form and batch/lot if available.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if available.
Certificate of Origin – C/O if preferential duty is claimed.
Specification/Catalogue, COA, MSDS, ingredient list, original label and product photos.

Specialized regulatory dossiers

Self-declaration or product registration dossier depending on the actual case.
Product registration acceptance for new-function blended additives, non-listed additives or wrong-use additives.
Quantitative composition for each additive; INS/E-number, function and maximum level information.
Test report/food-safety criteria where required.
Vietnamese sub-label and instructions/warnings where applicable.
Food-grade and quality standard evidence from the manufacturer.

OPERATIONAL DOCUMENT CHECKLIST

Dossier group	Required documents	Used for step	Typical preparer	Common error	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB, Contract/PO	Declaration, value and quantity check	Importer/Docs/Supplier	Generic product name	Compare with label, specification and COA before ETA
Technical	Specification, COA, MSDS, ingredient list	HS and food-safety policy determination	Supplier/QA/Compliance	Missing quantitative composition or INS/E-number	Request official technical documents
Food-safety announcement	Self-declaration/registration acceptance	Marketability/import compliance	Importer/Legal/Compliance	Filing after ETA, missing certified translation	Close regulatory status before shipment
Origin	C/O, invoice, packing, through B/L	Preferential duty claim	Supplier/Forwarder/Docs	Wrong HS, description or origin criterion	Check draft C/O before issuance
Labeling	Original label and Vietnamese sub-label	Clearance/circulation	Importer/QA	Missing instructions/warnings/ingredients	Compare label against dossier and regulations

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended handling
Is HS sufficiently supported?	Is it 2106.90.91 or flavouring/chemical/other preparation?	Specification, COA, MSDS, ingredient list	Wrong duty and policy	Prepare classification analysis before ETA
Is product registration required?	New function, non-listed additive or wrong target food use?	INS/E-number, Circular 24/VBHN 09, product dossier	Cannot circulate/use or dossier query	Review each additive and food category
Are names consistent?	Invoice, label and specification aligned?	Invoice, PL, label, catalogue	Document query and suspected misdeclaration	Lock product description before issuance
Is C/O eligible?	Correct form, origin criterion, HS and description?	Draft C/O, B/L, invoice	Loss of preferential duty	Check draft C/O pre-shipment
Is labeling compliant?	Vietnamese sub-label and warnings available?	Label artwork, original label, registration dossier	Supplement or post-clearance risk	Prepare sub-label by lot

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Confirm HS, food-safety policy, registration/self-declaration status, C/O, VAT, labels and sample/commercial status.

Step 2: Lock documents and technical dossier

Match Invoice, Packing List, B/L/AWB with specification, COA, MSDS, ingredient list, label and batch/lot.

Step 3: Handle specialized dossiers if applicable

Prepare product registration if it is a new-function blended additive, non-listed additive or wrong-use additive.

Step 4: Customs declaration

Explain HS, customs value, product description, C/O and specialized dossier. Green channel is system-based clearance; Yellow checks documents; Red checks documents and goods.

Step 5: Clearance, delivery and post-clearance file

Deliver to warehouse, finalize sub-labels where applicable, retain registration/COA/C/O/declaration documents by lot.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA blocking action	Documents to check
Generic product name “food additive”	Insufficient HS/policy basis	Use full technical description	Invoice, specification, label
Missing quantitative composition	Cannot determine permitted use/registration requirement	Request formula summary/ingredient list before ETA	Ingredient list, COA, MSDS
No registration acceptance where mandatory	Cannot circulate/use; storage delay	File specialized dossier before arrival	Registration dossier, acceptance
C/O errors	Loss of preferential duty	Check draft C/O	C/O, B/L, Invoice
Label inconsistent with dossier	Sub-label/post-clearance risk	Review label artwork before import	Label, dossier, acceptance

FAQ – FREQUENT BUSINESS QUESTIONS

Does blended additive require a permit?

Do not conclude absolutely. Product registration may be required for new-function blended additives, non-listed additives or wrong-use additives.

What is the main HS code?

2106.90.91 is a common reference when the product is a mixture of chemicals with foodstuffs or nutritive substances for food processing. Actual HS depends on technical dossier.

Is a test report required?

It may be required for announcement/registration or when requested by authorities, depending on composition and standards.

Can C/O reduce import duty?

Yes, if valid and compliant with the applicable FTA rule of origin.

Is Vietnamese sub-label required?

Likely required for circulation in Viet Nam, and it must match the dossier, ingredients, instructions and warnings.

Are samples treated the same?

Samples still require food-safety policy review; “sample” does not automatically waive specialized requirements.

What if supplier refuses composition details?

The risk is high. At minimum obtain ingredient list, function, INS/E-number, COA/MSDS and food-grade evidence.

IMPLEMENTATION SOLUTIONS FROM TGIMEX

This article provides a working map of HS code, duty, dossier and specialized policy for blended additive. In actual shipments, enterprises still need to review specification, ingredient list, COA, MSDS, label, C/O, commercial documents, origin and import purpose.

TGIMEX maintains an agency network in more than 60 countries, is a member of WCA, WCA China Global, VLA and HNLA, and supports ocean, air, road/rail transport, customs clearance, C/O, permits, warehousing and inland delivery.

Pre-ETA review

HS, food-safety policy, C/O, VAT, labels, ingredient list and announcement dossier.

Compliance dossier control

Invoice, Packing List, B/L/AWB, C/O, COA, MSDS, specification, label and technical documents.

International logistics

Coordinate agents, carriers/airlines, ETA, pre-alert and transport documents.

Customs & post-clearance

Prepare customs dossier, handle Green/Yellow/Red channels, retain lot-based files and support explanations.

For shipments that may involve specialized inspection, permits, C/O or labeling requirements, enterprises should not wait until arrival to start document review. A small discrepancy among Invoice, Packing List, C/O, COA, MSDS, specification or labels may trigger document requests, delayed clearance or unplanned storage costs. TGIMEX supports E2E import planning: pre-ETA policy review, document checking, international transport coordination, customs declaration, clearance handling, inland delivery and post-clearance file retention.

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