IMPORT PROCEDURE GUIDE FOR MINERAL SUPPLEMENTS
Mineral supplements imported as tablets, capsules, powder, sachets or dosage-form products may be regulated as health supplements / supplemented foods. Wrong HS classification, missing product declaration registration, inconsistency between label – specification – COA, or late food-safety inspection may cause customs channel escalation, dossier supplementation, delayed clearance and DEM/DET costs.
This guide provides an E2E (End-to-End) map for enterprises to review before ETA (Estimated Time of Arrival), covering product scope, technical identification, HS Code, duties, C/O (Certificate of Origin), food-safety policy, customs dossier, clearance decision points and pre-ETA risk controls.
QUICK FACT
| Item | Review content | Operational note |
|---|---|---|
| Product | Finished mineral supplement / health supplement. | Separate it from mineral raw materials, micronutrient premix, medicine, mineral water and ready-to-drink mineral beverages. |
| Reference HS | 2106.90.72 – Other food supplements. | Reference only; final HS depends on ingredients, dosage form and declared use. |
| Reference taxes | MFN 15%; ordinary duty 22.5%; VAT may be 8% during the VAT-reduction period if eligible, otherwise review the standard 10% rate. | Valid C/O may support special preferential duty under the applicable FTA. |
| Specialized policy | Product declaration registration, imported food-safety inspection, Vietnamese supplementary labeling. | Do not wait until cargo arrival to start declaration/inspection files. |
| Processing authority / portal | Ministry of Health / Vietnam Food Administration; online public service or National Single Window depending on the procedure. | Check the electronic workflow at the filing date. |
SCOPE OF APPLICATION
This guide applies to finished mineral supplement products used for nutritional supplementation or health support, commonly presented as tablets, capsules, chewables, powder, granules, sachets, dosage liquids or similar forms.
Core application
- Calcium, magnesium, zinc, iron, selenium, iodine or multi-mineral finished products.
- Retail-packed products with dosage, target users, instructions for use and health-support claims.
- Imports for commercial distribution, retail chains, e-commerce or pharmacy channels.
Not automatically covered
- Vitamins, collagen drinks, probiotics, gummies, or other capsule/powder supplements where minerals are not the key ingredient.
- Mineral raw materials, micronutrient premix, mineral water, ready-to-drink mineral beverages.
- Products with therapeutic or disease-prevention claims that may fall under drug regulations.
PRODUCT CLASSIFICATION & IDENTIFICATION
The commercial name “Minerals” or “Supplement” is insufficient. Invoice, Packing List, B/L/AWB, original label, product declaration and customs declaration should consistently describe the main minerals, dosage form, packaging, content, serving size and intended use.
Technical identification
- Check main minerals: calcium, magnesium, zinc, iron, selenium, iodine, potassium, etc.
- Confirm product form: tablet, capsule, powder, granules, sachet or dosage liquid.
- Match mineral content per serving size with label and specification.
- Check whether vitamins, herbs, probiotics, amino acids or bioactive substances are combined.
Risk of generic description
- Wrong HS between 2106.90.72, 2106.90.73, 2202.99.50 or pharmaceutical headings.
- Wrong food-safety policy, declaration dossier or import inspection requirement.
- Supplementary label inconsistent with claims, ingredients or target users.
- C/O description mismatch, causing loss of tariff preference.
| Technical criterion | Documents to compare | Risk if wrongly described | Suggested goods description |
|---|---|---|---|
| Main minerals | Specification, formula, COA, original label | Cannot prove product nature; HS/policy risk | Health supplement containing [main mineral], [tablet/powder/sachet], [packing]. |
| Dosage form / packing | Catalogue, label, product images, packing list | Confusion with raw materials, premix or ready-to-drink products | Mineral supplement tablets/capsules/powder sachets – finished product, retail pack. |
| Content and serving size | Label, specification, test report | Mismatch with declaration dossier and inspection questions | State key mineral content if it is shown on label/dossier. |
| Claims and use | Label, declaration dossier, scientific evidence | Therapeutic claims may trigger drug-policy review | Use support claims only, not disease treatment/prevention. |
| Origin and manufacturer | C/O, CFS, GMP, invoice, original label | Origin/manufacturer/C/O inconsistency | Keep country of origin, manufacturer, brand owner and importer consistent. |
HS CODE – DUTIES – C/O
Finished mineral health supplements are commonly reviewed under heading 2106 – food preparations not elsewhere specified or included. The final HS must be determined by ingredients, product form, retail packing and actual use, not by brand name.
| Reference HS | Applicable condition | Risk if misapplied | Documents to review |
|---|---|---|---|
| 2106.90.72 | Finished mineral health supplement / other food supplement, retail packed or dosage-based. | Wrong duty, policy, re-classification or tax reassessment. | Specification, formula, label, product declaration, CFS/GMP, COA. |
| 2106.90.73 | Micronutrient premix / fortificant mixture used as food ingredient. | Raw material confused with finished product. | Material-use contract, manufacturing purpose, factory documents. |
| 2202.99.50 | Ready-to-drink mineral beverage not requiring dilution. | Wrong classification if the product is a tablet/powder supplement. | Label, beverage composition, bottle/can packing, use instructions. |
| Pharmaceutical headings if applicable | Products with active ingredients or therapeutic claims. | Food import approach may be unacceptable. | Claims, active ingredients, drug registration or medical documents. |
| Tax item | Reference rate | Basis / condition | Control note |
|---|---|---|---|
| MFN import duty | 15% for reference HS 2106.90.72 | Applicable where MFN treatment is available and HS is correct. | Check the tariff schedule at customs declaration date. |
| Ordinary import duty | 22.5% reference | May be 150% of MFN if no preference applies and no separate ordinary rate exists. | Check Decision 15/2023/QD-TTg. |
| VAT | 8% if eligible under the VAT reduction period; otherwise review 10%. | Subject to Decree 174/2025/ND-CP and exclusion appendices. | Do not fix the rate without reviewing current policy. |
| Special preferential duty | May be 0% or another FTA rate. | Requires valid C/O, correct origin criterion, route, invoice and goods description. | C/O errors may result in denial or post-clearance verification. |
SPECIALIZED POLICY MATRIX
| Goods scenario | Potential policy | Documents to check | Authority / portal | When to do | Risk note |
|---|---|---|---|---|---|
| Finished health supplement | Product declaration registration. | Declaration, test report, CFS, GMP/equivalent, label, scientific evidence. | MOH/VFA; relevant online public service. | Before cargo arrival, ideally before booking. | Missing declaration may delay clearance/circulation. |
| Imported food subject to inspection | State food-safety inspection for imports. | Inspection registration, declaration, invoice, packing list, B/L/AWB, label. | National Single Window / assigned authority. | Before ETA or once documents are stable. | Late filing may cause storage and DEM/DET costs. |
| Mineral + vitamins/bioactives | Review RNI thresholds, maximum levels and claim evidence. | Formula, specification, scientific evidence, label. | MOH/VFA. | Before label and declaration finalization. | Over-claiming may require dossier amendment. |
| Vietnamese labeling | Product label and supplementary label requirements. | Original label, Vietnamese sub-label mockup, ingredients, warnings, expiry date. | Customs / market surveillance / food safety authority. | Before clearance and circulation. | Incorrect label may cause hold, relabeling or sanctions. |
| Samples / R&D / gifts | Purpose and quantity-based review. | Sample letter, proforma invoice, technical documents. | Customs and specialized authority if applicable. | Before shipment. | Unclear purpose may be treated as commercial import. |
| EPE/FDI/factory import | Purpose, domestic sale, storage, disposal and post-clearance obligations. | Business license, contract, warehouse records, use purpose. | Managing customs branch. | Before declaration. | Wrong purpose may affect duty and compliance. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document number/name | Issuer | Effective date / timing | Role in procedure | Article / appendix to note | Review note |
|---|---|---|---|---|---|---|
| Law | Law on Food Safety No. 55/2010/QH12 | National Assembly | Effective from 01/07/2011 | Legal foundation for food safety obligations. | Business obligations for food trading/importing. | Review with current implementing documents. |
| Decree | Decree 15/2018/ND-CP | Government | Effective from 02/02/2018 | Product declaration, import food-safety inspection, labeling, advertising and health supplement conditions. | Articles 6–8; Article 29 on GMP. | Check amendments/suspension updates. |
| Policy update | Resolution 15/2026/NQ-CP | Government | Effective from 06/04/2026 per published information | Suspends Decree 46/2026/ND-CP and Resolution 66.13/2026/NQ-CP pending revised Food Safety Law guidance. | Article 1 on suspension. | Recheck official sources before application. |
| Circular | Circular 43/2014/TT-BYT | Ministry of Health | Effective from 01/02/2015 | Management of functional foods, supplemented foods, health supplements, labeling and claims. | Articles 10–11; RNI appendices. | Match mineral content and claims. |
| Circular | Circular 28/2021/TT-BYT | Ministry of Health | Effective from 02/02/2022 | HS-based list for imported food safety inspection. | Appendix and application principles. | Check if replaced or amended. |
| Labeling | Decree 43/2017/ND-CP and Decree 111/2021/ND-CP | Government | 01/06/2017 and 15/02/2022 | Goods labeling, supplementary labels, origin and mandatory information. | Imported goods labeling provisions. | Review before ETA. |
| Tax/VAT | Decision 15/2023/QD-TTg; Decree 174/2025/ND-CP; current tariff schedule | Prime Minister / Government / customs authority | 15/07/2023; 01/07/2025 | Ordinary duty, VAT reduction and current tariff review. | Ordinary duty principle; VAT reduction. | Review by HS, origin, C/O and declaration date. |
VIEW / DOWNLOAD ORIGINAL DOCUMENTS
Enterprises should cross-check the documents on official legal databases or issuing authority websites before application.
CUSTOMS CLEARANCE DOSSIER
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, COA, product images, original label, packing details.
Specialized documents if applicable
- Product declaration registration receipt.
- Valid food-safety test report.
- CFS / Free Sale Certificate, GMP or equivalent certificate if required.
- Imported food-safety inspection registration/result.
- Vietnamese supplementary label dossier and scientific evidence for claims.
| Dossier group | Required documents | Used for | Usually prepared by | Common errors | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, B/L/AWB, Contract/PO | Declaration, valuation, transport | Importer, shipper, forwarder | Generic goods name, quantity/packing mismatch | Line-by-line check against label, C/O and product declaration. |
| Technical | Specification, formula, COA, catalogue, label images | HS and policy review | Manufacturer / brand owner / importer | No mineral content per serving size | Freeze final specification before documents are issued. |
| Declaration / food safety | Product declaration, test report, GMP/CFS, inspection registration | Specialized compliance | Importer / compliance team | Declaration missing, test report expired | Check issue date, product name, manufacturer and packing. |
| Origin | C/O forms if any | Preferential duty | Exporter / importer | Wrong form, criterion, HS, third-party invoice issue | Review C/O draft before issuance. |
| Labeling | Original label, Vietnamese supplementary label | Clearance/circulation/post-check | Importer / brand owner | Missing non-drug warning or target users | Compare with declaration and labeling regulations. |
CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended handling |
|---|---|---|---|---|
| HS Code | Is it a finished health supplement, premix, beverage or medicine? | Specification, formula, label | Wrong duty/policy or reclassification | Finalize HS before booking. |
| Product declaration | Is there a valid declaration receipt matching the product? | Declaration receipt, test report | Insufficient specialized basis | Complete/check before ETA. |
| Food-safety inspection | Is the shipment subject to imported food inspection? | Applicable list, inspection registration | Delayed clearance | File early through the relevant portal. |
| Supplementary label | Does the label contain all mandatory contents and warnings? | Original/sub-label, declaration | Relabeling, hold, penalty | Approve label mockup before shipment. |
| C/O | Is C/O form/criterion/description/route correct? | C/O, B/L, invoice | Loss of preferential duty | Check draft C/O. |
| Claims | Do claims move into disease treatment/prevention? | Label, scientific evidence | Drug-policy or advertising risk | Use support claims consistent with dossier. |
PRACTICAL E2E WORKFLOW
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA control | Documents to check |
|---|---|---|---|
| No product declaration receipt | Delayed clearance/circulation | Check declaration status before booking | Declaration receipt, test report, GMP/CFS. |
| Wrong HS | Duty reassessment and policy mismatch | Classify by ingredients/form/use | Specification, formula, label. |
| Label mismatch | Relabeling or penalty | Approve label before shipment | Original label, sub-label, declaration. |
| C/O error | Loss of preference | Check draft C/O | C/O, invoice, B/L, route. |
| Expired test report | Dossier supplement request | Check 12-month validity and required indicators | Test report, standard, specification. |
| Therapeutic claim | Drug-policy/advertising risk | Review all claims and warnings | Label, scientific evidence. |
FAQ
1. Does importing mineral supplements require a license?
Do not conclude generally. For health supplements, the key requirements are often product declaration registration, food-safety import inspection and labeling. Special ingredients/claims require further review.
2. Is imported food-safety inspection required?
Possibly, if the HS/product falls under the applicable list and management scope. Check HS, declaration and import purpose.
3. Is HS 2106.90.72 fixed for all mineral products?
No. It is a reference for finished health supplements. Premix, beverage, raw material or medicine may require another HS.
4. Can C/O reduce duty?
Yes, if the C/O is valid and matches origin criterion, description, HS, invoice and route under the relevant FTA.
5. Is Vietnamese supplementary labeling required?
Imported goods circulated in Vietnam generally need compliant labeling. Health supplements also need product-group wording and non-drug warning.
6. Are samples handled like commercial goods?
Not automatically. Purpose, quantity, value and use must be proven; if circulated/sold, specialized requirements may apply.
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