Imported vitamin products in capsules, tablets, gummies, powder sachets or liquid drops are often misclassified between health supplements, supplemented foods, pure vitamin raw materials or medicinal products. A wrong HS code, wrong product registration route, missing CFS (Certificate of Free Sale)/Health Certificate, missing GMP evidence or inconsistent labeling may lead to document requests, customs inspection, denial of preferential C/O treatment and unexpected DEM/DET charges. This guide provides an E2E (End-to-End) review map before ETA (Estimated Time of Arrival).

QUICK FACT

Item	Review direction for imported vitamin supplements
Main scope	Finished vitamin products used as health supplements/supplemented foods: capsules, tablets, gummies, powders, granules or small-dose liquid supplements.
Main reference HS	2106.90.72 – Other food supplements. Not automatically applicable to pure vitamin raw materials, vitamin drugs or ready-to-drink beverages.
Import duty	Reference MFN: 15%; reference ordinary duty: 22.5%; FTA/C/O may reduce duty to 0% or a lower rate depending on origin and agreement.
VAT	Standard VAT is generally reviewed at 10%; during the VAT reduction period under Decree 174/2025/ND-CP, 8% may apply if the product is eligible and not excluded.
Specialized policy	Imported health supplements are generally subject to product registration declaration and state food safety inspection upon import.
High-risk points	Disease-treatment claims, insufficient scientific evidence, missing GMP, invalid CFS/Health Certificate, and discrepancies between original label, Vietnamese supplementary label and registration dossier.

Legal note: This article applies only to finished vitamin products positioned as health supplements/supplemented foods. The actual dossier must be reviewed against specification, ingredient list, label, CFS/Health Certificate, declared claims and import purpose.

SCOPE OF APPLICATION

This guide applies to vitamin products imported for commercial distribution in Vietnam as health supplements or supplemented foods, such as vitamin C gummies, multivitamin capsules, vitamin D3 drops, powdered vitamins or vitamin-mineral combinations.

Applicable

Finished products in retail or wholesale packaging with dosage, instructions, vitamin ingredients and health-supporting claims.

Not automatically applicable

Pure vitamin raw materials under Chapter 29, vitamin medicines under Chapter 30, medical nutrition, infant formula, ready-to-drink vitamin beverages or disease-treatment products.

Variants requiring separate review

Gelatin gummies, capsules, enzyme/probiotic powder, children’s products, and products containing collagen, minerals, herbs, caffeine or new active ingredients.

Samples/projects

Samples, trial goods, exhibition goods or non-commercial shipments may require different handling and supporting documents.

CLASSIFICATION & TECHNICAL IDENTIFICATION

Vitamin products should not be identified by trade name alone. Importers should cross-check ingredient list, nutrition/supplement facts, specification, COA (Certificate of Analysis), original label, packaging images and manufacturer’s claims.

TECHNICAL IDENTIFICATION CRITERIA

Criteria	Documents to check	Risk if described incorrectly	Suggested goods description
Dosage form	Label, specification, catalogue	Confusion between supplement, medicine or beverage	“Vitamin supplement, capsule/tablet/gummy/powder form, for health support, not a medicine”
Active ingredients	Ingredient list, COA, test report	Mismatch of vitamin content and registration basis	State key vitamins and content per serving where shown on documents
Claims	Label, leaflet, manufacturer website	Treatment claims may trigger drug review	Avoid “treat”, “cure” or “prevent disease” in food dossiers
Target users	Label, instructions	Children/pregnancy products may face closer review	Use the same target-user wording as the registered label
Manufacturer and origin	C/O, CFS/Health Certificate, GMP	Mismatch between registration and import documents	Manufacturer and country of manufacture must be consistent

HS CODE – DUTY – C/O

Finished vitamin supplements are usually reviewed under heading 2106 for food preparations not elsewhere specified. However, pure vitamin raw materials, vitamin drugs, ready-to-drink products or micronutrient premixes may fall under different HS headings.

HS – DUTY – DOSSIER CROSS-CHECK TABLE

Reference HS	Conditions	Ordinary duty	MFN duty	Reference VAT	Documents to check
2106.90.72	Finished vitamin supplement in capsule/tablet/gummy/powder/liquid form, not medicine and not ready-to-drink beverage	22.5%	15%	10%; 8% may apply during VAT reduction if eligible	Ingredient list, label, supplement facts, registration dossier, CFS/Health Certificate
2106.90.73	Micronutrient premixes used to fortify foods	22.5%	15%	10%/8% subject to VAT policy	COA, specification, import purpose and end-use
2936.xx	Pure vitamins or vitamin derivatives not mixed	Often 5%	Often 0%	Review by actual nature and VAT policy	COA, MSDS/SDS, purity, intended food/pharma/additive use
2202.99.50	Non-carbonated ready-to-drink vitamin beverage not requiring dilution	45%	30%	10%; 8% may apply if eligible	Label, formula, instructions, volume, ready-to-drink status
3004.xx	Products determined as medicines with therapeutic/preventive indication	Review by pharmaceutical HS	Review by pharmaceutical HS	Review by drug category	Drug registration, pharmaceutical dossier, instructions and treatment claims

C/O and FTA treatment

Origin	Common C/O form	Possible benefit	Risk to prevent
ASEAN	Form D	Potentially 0% if origin rules are met	Description, origin criterion or invoice number mismatch
China	Form E/RCEP if applicable	May be lower than MFN, often 0% for eligible cases	Third-party invoice, transit and unclear RVC/CTH criteria
Korea/Japan/EU/UK	AK/VJ/AJ/EUR.1/REX or equivalent proof	Depends on agreement and final HS	C/O HS different from declaration or lack of direct transport proof
United States or non-FTA sources	Non-preferential C/O where needed	MFN may apply if conditions are met	No special preferential duty; duty cost should be planned

APPLICABLE SPECIALIZED POLICIES

SPECIALIZED POLICY MATRIX

Goods scenario	Potential policy	Documents to check	Authority/portal	Recommended timing	Risk note
Finished vitamin health supplement	Product registration declaration; state food safety inspection on import	Declaration, CFS/Health Certificate, test report, GMP, scientific evidence	Vietnam Food Administration – Ministry of Health; online public service/NSW where applicable	Before import and before circulation	Missing or wrong registration may block clearance/circulation
Vitamin with disease-treatment claims	May be reviewed as medicine or drug advertising	Label, leaflet, website, marketing materials	Ministry of Health/Drug Administration if classified as drug	Before contract signing	Avoid treatment claims in health supplement dossiers
Gummies/capsules with gelatin, dairy, honey or animal extracts	May trigger quarantine/food-safety review by ingredient	Ingredient list, COA, origin certificate, formula	Veterinary/food safety authority depending on ingredient nature	Before ETA	Do not conclude no quarantine without full formula
Goods imported for EPE/FDI/factory	Customs procedure, use purpose, warehousing and domestic distribution	Contract, PO, end-use, registration if circulated	Customs branch of declaration	Before customs declaration	Internal/manufacturing use differs from commercial retail import
Samples or trial goods	Different handling may apply, but purpose must be proven	Sample invoice, packing list, purpose letter, technical documents	Customs/food safety authority as applicable	Before arrival	Not automatically treated like commercial goods

LEGAL DOCUMENTS TO REVIEW

LEGAL DOCUMENT CHECK TABLE

Group	Document	Issuing body	Effective timing	Role	Key points	Review note
Law	Law on Food Safety No. 55/2010/QH12	National Assembly	Effective from 01 Jul 2011	Legal framework for food safety	Importer responsibility and food import provisions	Use as baseline for compliance responsibility
Decree	Decree 15/2018/ND-CP	Government	Effective from 02 Feb 2018; continues to be applied while Decree 46/2026 is suspended	Product registration, import food safety inspection, labeling and advertising	Articles 6, 7, 8; Articles 13–22	Main document for imported health supplements
New/suspended framework	Decree 46/2026/ND-CP and Resolution 15/2026/NQ-CP	Government	Resolution 15/2026 suspends Decree 46/2026 from 06 Apr 2026 until a new framework applies	Determines old/new applicability	Article 1 of Resolution 15/2026/NQ-CP	Recheck at filing or declaration date
Circular	Circular 43/2014/TT-BYT	Ministry of Health	Effective from 01 Feb 2015	Management of functional foods and health supplements	Classification, labeling, warnings and management	Review based on product type and claims
Labeling	Decree 43/2017/ND-CP; Decree 111/2021/ND-CP	Government	01 Jun 2017; amendment effective 15 Feb 2022	Original label, Vietnamese supplementary label, origin, quantity and mandatory information	Article 10, Article 12 and imported-goods labeling provisions	Supplementary label must match registration dossier
Tariff	Decree 26/2023/ND-CP and amendments	Government	Effective from 15 Jul 2023	MFN import tariff schedule	Headings 2106, 2936, 2202 depending on product nature	Recheck at customs declaration date
VAT	VAT Law 48/2024/QH15; Decrees 181/2025, 359/2025 and 174/2025	National Assembly/Government	Law and implementing decree from 01 Jul 2025; Decree 174 applies until 31 Dec 2026	Determines 10% or reduced 8% VAT	Exclusion appendices under Decree 174/2025/ND-CP	Do not assume 8% without checking exclusions

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises should search by document number on the official legal database, Government portal or issuing authority website. Enterprises should also cross-check the official portal before applying any legal basis.

Decree 15/2018/ND-CP Circular 43/2014/TT-BYT Product registration procedure

CUSTOMS CLEARANCE DOCUMENT SET

Commercial documents

Commercial Invoice, Packing List, B/L or AWB, Sales Contract/PO, C/O where preferential duty is claimed, catalogue/specification, product images and original label.

Specialized documents

Product registration receipt, declaration dossier, CFS/Health Certificate, valid test report, GMP or equivalent certificate, scientific evidence for claims and Vietnamese supplementary label.

OPERATIONAL DOCUMENT CHECKLIST

Document group	Required documents	Used for	Usually prepared by	Common errors	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB	Declaration, duty calculation, cargo release	Shipper/importer/forwarder	Name, quantity or packing mismatch	Match SKU, lot, expiry, net/gross weight
Registration	Product declaration and receipt	Circulation and import food safety inspection	Importer/legal holder in Vietnam	Different product name, manufacturer or origin	Match product name, dosage form, ingredients and manufacturer
Food safety	CFS/HC, test report, GMP	Registration and import inspection	Manufacturer/shipper/importer	Expired, not legalized or untranslated documents	Check validity, language, legalization and safety wording
Origin	Preferential C/O or origin proof	FTA duty treatment	Exporter/shipper	Wrong form, HS, description or third-party invoice	Check form, origin criterion, direct transport and invoice
Labeling	Original label, Vietnamese supplementary label, leaflet	Inspection and circulation	Importer/distributor	Overstated claims, missing “not a medicine” warning	Compare label with registration dossier

DECISION POINTS THAT MAY HOLD THE SHIPMENT

CLEARANCE DECISION POINT TABLE

Decision point	Question	Evidence	Consequence if unclear	Recommended handling
Product classification	Is it a health supplement, supplemented food, raw material or medicine?	Label, ingredient list, claims, CFS	Wrong policy and HS	Confirm product definition before ordering
Product registration	Is the registration receipt available?	Declaration, receipt and food safety dossier	Insufficient circulation/import basis	Complete dossier before ETA or sales launch
HS and duty	Does HS 2106.90.72 match form and ingredients?	Spec, COA, label, product images	Duty reassessment and clearance delay	Prepare HS analysis for each SKU
C/O	Does C/O match HS, description, invoice and origin rule?	C/O, invoice, B/L, packing list	Preferential duty denied	Check draft C/O before issuance
Labeling	Does the Vietnamese label match registration and original label?	Artwork, label, registration dossier	Relabeling request or post-clearance risk	Review label before printing or bulk import

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review: finalize HS, food safety policy, VAT, C/O, labeling, registration and claims.

Step 2 – Lock documents: finalize Invoice, Packing List, B/L/AWB, CFS, Health Certificate, GMP, test report and original label.

Step 3 – Complete specialized dossier: register product declaration and prepare import food safety inspection dossier where applicable.

Step 4 – Customs declaration: handle Green/Yellow/Red channels and explain HS, value, C/O and specialized policy if requested.

Step 5 – Clearance and delivery: release cargo, apply supplementary label if needed, verify lots, expiry and storage conditions.

Step 6 – Post-clearance file retention: archive registration, customs, C/O, test, labeling and transport documents by shipment.

PRE-ETA RISK CHECKLIST

CRITICAL RISKS TO BLOCK BEFORE ARRIVAL

Risk	Consequence	Pre-ETA prevention	Documents to check
Unclear supplement vs medicine status	Policy challenge and dossier rejection	Review claims, form, dosage and marketing	Label, leaflet, website, CFS
Missing CFS/HC/GMP	Registration or import inspection cannot proceed	Request from manufacturer before booking	CFS, HC, GMP/equivalent certificate
Wrong C/O form or origin criterion	Loss of preferential duty	Check draft C/O against final HS	C/O, invoice, B/L, origin rule
Vietnamese label differs from registration	Relabeling and post-clearance risk	Match label, registration and test report	Artwork, original label, declaration dossier
Invalid or incomplete test report	Food safety dossier returned	Confirm required safety indicators	Test report, specification, COA

FAQ – COMMON BUSINESS QUESTIONS

Does importing vitamin supplements require a permit?

It should not be simplified as a “permit”. Vitamin health supplements generally require product registration declaration and import food safety procedures where applicable. If classified as medicine, a different regime applies.

Is product registration declaration required?

Very likely for imported health supplements/supplemented foods. The dossier should be reviewed under Decree 15/2018/ND-CP and VFA guidance.

Does HS 2106.90.72 apply to every vitamin product?

No. It may apply to many finished vitamin supplements, but not automatically to pure vitamin materials, vitamin medicines, micronutrient premixes or ready-to-drink beverages.

Is VAT 8% or 10%?

Standard VAT is generally 10%; 8% may apply during the VAT reduction period if the product is eligible and not excluded. Check at the customs declaration date.

Can C/O reduce import duty?

Yes, if the C/O form, origin criterion, goods description and direct transport requirements are valid for the final HS code.

What are the main labeling risks?

The Vietnamese label must match the registration dossier and original label, avoid treatment claims and include appropriate health supplement warnings.

IMPLEMENTATION SOLUTIONS FROM TGIMEX

This guide provides a map of HS code, duty, dossier and specialized policy for imported vitamin supplements. In practice, each shipment must still be reviewed against specification, ingredient list, label, CFS/Health Certificate, documents, origin and import purpose.

Pre-ETA review

HS, food safety policy, product registration, C/O, VAT, labeling and claim risks.

Compliance dossier control

Cross-check Invoice, Packing List, B/L/AWB, C/O, CFS, GMP, test report, COA and labels.

International logistics

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

Customs and post-clearance

Prepare declaration, handle customs channels, domestic delivery and post-clearance archiving.

For shipments that may involve specialized inspection, C/O or labeling requirements, enterprises should not wait until cargo arrival to start dossier review. TGIMEX supports E2E import planning to control schedule, cost and compliance risk from the preparation stage.

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