Boxes used for containing, storing or packaging food may look simple, but they can create customs and compliance risks if the product name is too generic, the HS code is selected by assumption, material evidence is missing, or food-contact safety requirements have not been reviewed. Any mismatch among the Invoice, Packing List, catalogue, original label and test documents may trigger document review, inspection channel, additional evidence, loss of C/O duty preference, DEM/DET or delivery delay. This article provides an E2E (End-to-End) map for pre-ETA review: HS code, duties, C/O, specialized policy, documents, customs decision points and risk controls before cargo arrival.

QUICK FACT SUMMARY

Item	What to review	Operational note
Applicable product	Food-contact boxes: plastic boxes, paper/paperboard boxes, metal boxes, glass/ceramic boxes, boxes with food-contact lids or gaskets.	Do not automatically apply this article to bottles, films, trays, spoons, forks, knives or other containers.
Policy focus	Food safety for direct food-contact materials, import labeling, HS classification by material and function.	Review against catalogue, datasheet, model/SKU and actual import purpose.
Reference HS codes	3923.10.90 for plastic boxes; 4819.10.00/4819.20.00 for paper/paperboard boxes; 7310/7612 for metal boxes; 7010.90.99 for glass containers.	The final HS code depends on material, design, capacity, closing mechanism and intended use.
Reference duties	Common MFN references: plastic 10%, paper/paperboard 15%, glass 20%; metal must be checked by the final 8-digit code. VAT may be 10% or 8% if eligible for reduction.	Do not use duty rates as final figures without checking the tariff at declaration date.
Key documents	Invoice, Packing List, B/L or AWB, C/O if any, catalogue/datasheet, product photos, original labels and test/QCVN evidence if applicable.	Product name, material, specification, quantity and origin must align across commercial, technical and labeling documents.

Illustration for Import Procedure Guide for Food-Contact Boxes — Illustration of the product group and document review before customs clearance.

Legal note: This English version is for operational reference and is not an official legal translation. It applies only to the product “box” in the direct food-contact packaging/materials group. If the actual product includes mixed materials, coating, printing ink, silicone/rubber gasket, metal lid, accessories or special use, each component must be reviewed against the technical file and applicable QCVN.

SCOPE OF APPLICATION

This article applies to imported boxes used to contain, store or package food where the product may directly contact food during circulation, storage, retail or end use.

Covered variants include PP/PE/PET/PS plastic boxes, paper/paperboard boxes, carton boxes, metal boxes, glass/ceramic boxes, and boxes with food-contact lids or gaskets.
External transport packaging that does not contact food, or household articles whose principal function is not commercial food packaging, must be reviewed separately.
New goods, samples, display goods, warranty goods, FDI/EPE factory imports and project cargo may trigger different declaration types and document requirements.
Used/refurbished goods should not be processed under the same assumptions as new commercial goods.
Review must be based on catalogue, datasheet, model/SKU and actual import purpose.

CLASSIFICATION & PRODUCT IDENTIFICATION

Material identification

Identify the main material: plastic, paper/paperboard, metal, glass, ceramic, multilayer material, or food-contact lid/gasket.

Functional identification

Distinguish boxes for transport/packaging, retail food storage, single-use, reusable or accessory-combined products.

File-based identification

Cross-check catalogue, datasheet, product photos, original label, packaging specification, capacity, size, model/SKU and import purpose.

Technical criterion	Documents to compare	Risk if described incorrectly	Suggested product description
Food-contact material	Catalogue, datasheet, material certificate, test report	Wrong QCVN or insufficient basis for safety declaration/testing	Plastic PP food box, new 100%, model…, capacity…
Principal function	Product description, photos, PO/contract, technical data	Wrong classification between packaging and household goods	Box for packaging/containing food, without electronic function
Lid/gasket/coating structure	BOM, gasket/lid datasheet, coating certificate if any	Missing rubber/silicone, metal or coating requirement	Plastic box with PP lid and silicone food-contact gasket
Goods condition	Invoice, Packing List, contract, actual photos	Samples/used goods treated as new commercial cargo	New 100%, food-contact packaging box
Original label	Label photos, artwork, draft Vietnamese sub-label	Labeling risk during circulation and customs explanation	State product name, material, origin, manufacturer and use warnings if any

Generic names such as “box”, “container” or “food box” without material, function and condition may lead to wrong HS code, wrong specialized policy, wrong QCVN/TCVN, wrong testing/declaration file and labeling non-compliance.

HS CODE – DUTIES – C/O

For food-contact boxes, the HS code must not be determined merely by the word “box”. The key basis is material composition, principal function, packaging/container design, capacity, closing mechanism and import purpose.

REFERENCE HS CODE TABLE

Reference HS code	Applicable condition	Risk if misapplied	Documents to compare
3923.10.90	Boxes, cases, crates and similar plastic articles used for transport or packing.	Misclassified as 3924 household/kitchenware or wrong material if coating/accessory exists.	Catalogue, plastic material, photos, packaging/food use purpose
4819.10.00	Cartons, boxes and cases of corrugated paper or paperboard.	Wrong distinction between corrugated and non-corrugated paperboard.	Sample, paper structure, basis weight, photos
4819.20.00	Folding cartons, boxes and cases of non-corrugated paper or paperboard.	Misclassified into other 4819 packaging lines.	Catalogue, folding design, material evidence
7310.29.99 / 7612.90.90	Iron/steel or aluminium boxes depending on material, capacity and function.	Wrong metal group or wrong treatment as kitchenware.	Material certificate, capacity, design, intended use
7010.90.99	Glass containers for conveyance or packing; capacity and description must be checked.	Confused with glassware for household/decorative use.	Catalogue, capacity, photos, material and food-container use

REFERENCE DUTY TABLE TO BE CHECKED BEFORE ETA

Code/product group	Ordinary import duty	MFN duty	VAT	Special preferential duty with valid C/O
3923.10.90 – plastic box	15% reference if MFN is 10%	10% reference	10% or 8% if eligible for VAT reduction	Possibly 0%-5% depending on FTA and origin
4819.10.00 / 4819.20.00 – paper box	22.5% reference if MFN is 15%	15% reference	10% or 8% if eligible	Possibly 0%-5% depending on FTA and C/O
7310/7612 – metal box	Must be finalized by 8-digit code and current tariff	Usually to be reviewed within 10%-20% depending on code	10% or 8% if eligible	May be reduced if origin rules are met
7010.90.99 – glass container	30% reference if MFN is 20%	20% reference	10% or 8% if eligible	May be 0%-5% or other FTA rate

C/O note: C/O is only useful when the form, origin criterion, product description, HS code and transport route are compliant. A generic or inconsistent “box/container” description may result in customs verification or rejection of preference.

APPLICABLE SPECIALIZED POLICIES

Goods scenario	Potential policy	Documents to check	Authority/portal if identifiable	Recommended timing	Risk note
Plastic food-contact box	Review QCVN 12-1:2011/BYT; testing/self-declaration may be required under Decree 15/2018/ND-CP if circulated as food-contact packaging.	Catalogue, test report, material composition, label, declaration file if any	Food safety authority/testing body; customs	Before ETA, ideally before shipment	Do not assume exemption without actual use and circulation status.
Paper/paperboard food-contact box	Review material safety, coating/ink migration and evidence of suitability for food contact.	Material certificate, migration test if any, coating photos, label	Food safety authority/testing body; customs	Before PO finalization and ETA	Internal PE/PLA layer or coating may change the required file.
Metal food-contact box	Review QCVN 12-3:2011/BYT and coating/lacquer if any.	Metal material, coating, test report, datasheet, label	Food safety authority/testing body; customs	Before ETA	Wrong material may cause wrong HS and wrong QCVN.
Glass/ceramic/enamelled box	Review QCVN 12-4:2015/BYT and migration limits if applicable.	Test report, photos, datasheet, enamel/coating specification	Food safety authority/testing body; customs	Before ETA or before circulation	Do not combine with decorative/household glass goods without review.
Box with rubber/silicone gasket	Additionally review QCVN 12-2:2011/BYT for rubber/silicone parts in direct contact with food.	BOM, gasket datasheet, contact-part test report	Food safety authority/testing body; customs	Before mass purchase	A small gasket may trigger additional testing criteria.
Samples/testing/display goods	Customs process may differ from commercial goods; material and purpose must still be clear.	Sample invoice, packing list, purpose letter, photos	Customs; specialized authority if any	Before ETA	Do not automatically apply bulk commercial procedure.
EPE/FDI/factory import	Review declaration type, internal use/production/export purpose, inventory control and post-clearance file.	Contract, PO, usage plan, logistics documents	Supervising customs authority and border customs	Before declaration	Wrong customs type may affect duty and audit risk.

Control principle: Do not state that no permit or specialized inspection is required until model, material, function, label, test report and import purpose have been reviewed.

LEGAL DOCUMENTS TO BE REVIEWED

Document group	Document name/number	Issuer	Effective/applicable date	Role in procedure	Key points to note	Review note
Law	Law on Food Safety No. 55/2010/QH12	National Assembly	Effective from 01/07/2011	Foundation for food safety and food-contact material management.	Relevant food safety obligations.	Use as legal basis for compliance duties.
Decree	Decree 15/2018/ND-CP	Government	Effective from 02/02/2018	Detailed implementation of the Law on Food Safety; relevant to self-declaration and food safety control.	Review provisions applicable to food containers/packaging materials.	Do not assume exemption without actual file.
Decree	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	01/06/2017 and 15/02/2022	Goods labeling and amendments.	Original label, Vietnamese sub-label, origin, responsible entity.	Important for goods circulated in Vietnam.
Circular/QCVN	Circular 34/2011/TT-BYT; QCVN 12-1, 12-2, 12-3	Ministry of Health	Issued in 2011; effectiveness to be checked	Technical regulations for plastic, rubber and metal food-contact packaging/tools.	Material-specific criteria.	Apply according to actual contact material.
Circular/QCVN	Circular 35/2015/TT-BYT; QCVN 12-4:2015/BYT	Ministry of Health	Issued in 2015; effectiveness to be checked	Technical regulation for glass, ceramic, porcelain and enamelled food-contact packaging/tools.	Safety/migration criteria if applicable.	Only for relevant materials.
Decree	Decree 69/2018/ND-CP	Government	Issued 15/05/2018	Foreign trade management; review import restrictions/conditions if any.	Appendices and specialized lists if applicable.	Do not make absolute conclusions for special materials.
Tariff	Decree 26/2023/ND-CP; Decision 15/2023/QD-TTg	Government/Prime Minister	Decree 26 effective 15/07/2023	MFN tariff and ordinary duty principle.	8-digit HS code tariff lines.	Check amendments at declaration date.
VAT	Resolution 204/2025/QH15; Decree 174/2025/ND-CP	National Assembly/Government	Effective from 01/07/2025	Basis for VAT reduction review.	Excluded groups and applicable goods.	VAT must be checked by HS, nature and declaration timing.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises may search by document number on the official legal document portal, the Government portal or the issuing authority’s website.

Decree 15/2018/ND-CP Decree 43/2017/ND-CP Decree 26/2023/ND-CP Decree 174/2025/ND-CP

Enterprises should cross-check on the official legal document portal or the issuing authority’s website before applying.

CUSTOMS CLEARANCE DOCUMENT SET

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
Certificate of Origin – C/O if preferential duty is claimed.
Catalogue/Datasheet, product photos, original label, model/SKU list if needed.

Specialized documents if applicable

Material-specific food-contact test report.
Self-declaration/QCVN conformity evidence if applicable.
Labeling file and Vietnamese sub-label.
Technical data for material, coating, gasket, lid and printing ink if any.

Document group	Required document	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO	Value, quantity, sales term	Exporter/Importer/Docs	Generic product name or missing material	Check product name, material, quantity, price, Incoterms
Transport	B/L or AWB, Arrival Notice, Pre-alert	Cargo release and declaration	Forwarder/Carrier/Docs	Wrong consignee or missing pre-alert	Compare with commercial documents and delivery plan
Origin	C/O if preferential duty is claimed	Special preferential duty	Exporter/Importer	Wrong form, HS, description or origin criterion	Check draft C/O before issue
Technical	Catalogue, datasheet, photos, model/SKU, material composition	HS and policy finalization	Manufacturer/Importer/Compliance	Cannot prove food-contact material	Compare with declaration name and original label
Specialized	Test report, QCVN evidence, self-declaration, Vietnamese sub-label	Food safety, circulation and customs explanation	Importer/QA/Compliance	Wrong test scope or wrong model	Lock file before ETA

Document lock rule: Product name, quantity, model/SKU, material, origin and technical specifications must match 100% across commercial documents, catalogue, label, specialized file and customs declaration.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended action
Is the HS code sufficiently justified?	Is the box plastic, paper, metal, glass or mixed material?	Catalogue, datasheet, photos, sample	Reclassification and duty risk	Finalize HS by material and function before ETA
Do model/SKU references match?	Do Invoice, Packing List, label and catalogue show the same code?	Invoice, PL, label, model list	Inspection and additional explanation	Review draft documents before shipment
Is it food-contact material?	Does the box directly contact food during use/circulation?	Use purpose, test report, QCVN, label	Specialized file delay	Determine QCVN by material and purpose
Is C/O acceptable?	Are form, criterion, description and HS consistent?	Draft C/O, invoice, transport route	Loss of preferential duty	Check C/O before official issuance
Is labeling compliant?	Do original label and sub-label contain required information?	Label photo, artwork, sub-label	Circulation restriction or document request	Prepare sub-label before arrival
Do accessories change policy?	Do lid, gasket, coating or ink contact food?	BOM, datasheet, test report	Missing testing scope	Review every food-contact component

PRACTICAL E2E OPERATING PROCESS

Step 1: Pre-ETA review

Finalize HS, food-contact policy, duties, C/O, labeling and whether specialized documents are required.

Step 2: Lock commercial and technical documents

Finalize Invoice, Packing List, B/L/AWB, catalogue/datasheet and model/SKU list; check material, quantity, origin and specification.

Step 3: Prepare specialized file if applicable

For food-contact material requiring QCVN/test/self-declaration documents, prepare before ETA to avoid storage cost.

Step 4: Open customs declaration

Green channel: system-based clearance under conditions. Yellow: document review. Red: document and physical inspection. Key questions: value, HS, product name, material, C/O and policy.

Step 5: Clearance, delivery and post-clearance file

Release cargo, deliver to warehouse, apply sub-label if required, supplement results if any and keep lot-based file.

Step 6: Post-import circulation control

For retail/circulation goods, keep labeling, declaration/test report if any, import documents and lot traceability file.

PRE-ETA RISK CONTROL CHECKLIST

Risk	Consequence	Pre-ETA control	Document to check
HS chosen by name “box” only	Wrong duty/policy and reclassification	Confirm material, function and structure before booking	Catalogue, datasheet, photos, sample
Missing QCVN/test file where required	Specialized delay and circulation risk	Determine applicable QCVN and testing early	Test report, certificate, declaration file if any
Mismatch among Invoice, PL, C/O and label	C/O rejection or inspection	Approve draft documents before shipment	Invoice, PL, C/O draft, label artwork
Vietnamese sub-label not controlled	Circulation non-compliance	Prepare sub-label under labeling decrees before ETA	Original label and sub-label
Food-contact accessory omitted	Wrong testing/QCVN scope	Review BOM for every contact part	Gasket/lid/coating datasheet and test report
Wrong C/O form or origin criterion	Loss of special preferential duty	Check form, criterion, HS and route	Draft C/O, B/L, invoice, PL

FAQ – COMMON BUSINESS QUESTIONS

Question	Short answer
Does an imported box require an import permit?	Do not conclude absolutely. For standard new goods, key issues are HS, duty, labeling and food-contact safety file if circulated. Review the actual file.
Is quality inspection/conformity certification required?	Testing, self-declaration or QCVN evidence may be required depending on material, import purpose and circulation method.
Is Vietnamese sub-label required?	If the goods are circulated in Vietnam, original label and Vietnamese sub-label should be reviewed under Decree 43/2017 and Decree 111/2021.
Can C/O reduce duty?	Yes, if the C/O is valid, correct form, correct origin, correct HS and product description.
Do samples/warranty goods follow the same procedure?	Not automatically. Purpose, value, quantity, customs policy and specialized files must be reviewed.
What if the model on Invoice differs from catalogue?	Request correction or prepare clear explanation before declaration; do not wait until customs channeling.
What if a plastic box has silicone gasket?	Review both plastic and silicone/rubber contact parts; different QCVN may apply.
Is VAT always 8%?	No. VAT must be checked at declaration date and by excluded groups; otherwise 10% may apply.

IMPLEMENTATION SOLUTIONS FROM TGIMEX

This article provides a map of HS code, duties, documents and specialized policy for food-contact boxes. In actual shipments, enterprises still need to review catalogue, datasheet, model/SKU, material, documents, origin and import purpose.

Capability signals

Agent network in more than 60 countries.
Member of WCA, WCA China Global, VLA and HNLA.
Sea, air, road and rail freight capability.
Customs clearance, C/O, import permit, warehousing and domestic delivery capability.

Operational support

Pre-ETA review: HS, policy, C/O, duties, label, catalogue/datasheet/model.
Compliance file control.
Coordination with overseas agents, carriers/airlines, ETA tracking, pre-alert and transport documents.
Customs declaration, Green/Yellow/Red channel handling and explanation support.

Post-clearance control

Lot-based file archiving.
Review of sub-label, self-declaration/test report if applicable.
Preparation for post-clearance audit explanations.

For shipments that may involve specialized inspection, permits, C/O or labeling requirements, enterprises should not wait until cargo arrival to review the file. A small discrepancy among Invoice, Packing List, catalogue, datasheet, C/O or label may lead to additional document requests, clearance delay or unplanned storage costs.

TGIMEX supports enterprises in establishing an E2E import plan: pre-ETA policy review, document checking, international freight coordination, customs declaration, clearance handling, domestic delivery and post-clearance file archiving. This approach helps control timeline, cost and compliance risk from the preparation stage.

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