Problem: For anti-caking agents, an incomplete goods description, missing E-number/CAS or confusion between food additive and industrial chemical may trigger HS queries, food safety inspection, declaration supplementation or labeling correction.

Agitate: Small discrepancies among Invoice, Packing List, COA, SDS, catalogue and label may delay clearance, affect C/O preference and create DEM/DET or post-clearance risks.

Solution: This guide provides an E2E map for pre-ETA review: HS code, duties, C/O, food additive policy, food safety dossier, customs documents, labeling and risk checklist.

QUICK FACTS

Review item	Application for anti-caking agent	Operational note
Product name	Food-grade anti-caking agent; may be silica, silicates, carbonates, phosphates or blended preparations.	Avoid declaring only “food additive” where the documents can state chemical name/E-number.
Reference HS codes	2811.22.10 for silicon dioxide; 3824.99.99 for certain chemical preparations; 2106.90.99 if the product is essentially a food preparation mixture.	Final classification must follow composition, CAS, COA, SDS and actual use.
Import duty	Indicative MFN: 0% for 2811.22.10/3824.99.99; 15% for 2106.90.99. Ordinary duty must be checked under Decision 15/2023/QD-TTg.	Valid C/O may trigger special preferential rates depending on FTA rules.
VAT	Indicative 10%; check 8% only if the VAT reduction policy is effective and the goods are not excluded at declaration time.	Do not finalize VAT before checking HS and policy on the declaration date.
Specialized policy	Review Decree 15/2018/ND-CP, Circular 24/2019/TT-BYT and QCVN 4-4:2010/BYT.	Distinguish single additives, blended additives, premixes and out-of-scope additives.
Authorities/portal	Customs, food safety authority and National Single Window if food safety inspection is required.	Prepare food safety dossier before ETA.

Legal note: This content applies to anti-caking agents used as food additives. It does not automatically apply to industrial chemicals, pharmaceutical ingredients, animal-feed additives or out-of-list food additives. Review actual catalogue, specification, COA, SDS, CAS/E-number, label and import purpose.

SCOPE OF APPLICATION

This guide applies to anti-caking agents imported for use as food additives in manufacturing, blending or trading food ingredients.

Applicable to single-substance or prepared anti-caking additives used to prevent lumping and improve powder flowability.
Related group: sweeteners, preservatives, food colors, acidity regulators, anti-caking agents and other food additives.
Not automatically applicable to multifunction premixes, out-of-list additives, wrong-use additives, technical chemicals or non-food ingredients.
Samples, R&D goods, project goods or imports for EPE/FDI/factories may require different explanations and dossiers.

Review by catalogue, specification, product code, CAS, E-number, COA, SDS and actual import purpose.

CLASSIFICATION & GOODS IDENTIFICATION

Technical identification

Anti-caking agents should be identified by chemical name, E-number, CAS, composition, concentration, food grade, physical form and anti-caking function in powdered food systems.

Description risk

Generic descriptions may lead to wrong HS, wrong food safety policy, wrong QCVN application, wrong declaration route or wrong label.

Technical criterion	Documents to check	Risk if wrongly described	Suggested goods description
Chemical name and E-number	Catalogue, specification, COA, SDS, original label	Misclassification as industrial chemical or non-listed additive	“Food additive anti-caking agent – Silicon dioxide E551, food grade, powder…”
Composition and concentration	COA, formula sheet, ingredient declaration	Wrong HS and wrong food safety procedure	State main substance, concentration and single/blended nature.
Intended use	Catalogue, use instruction, buyer dossier	Questions on permitted use in food	State “used as anti-caking agent in food manufacturing”.
Grade and packaging	Spec, food grade statement, manufacturer standard	Risk of not being accepted as food additive	Show food grade, net weight, lot/batch and shelf life.
Goods condition	Invoice, packing list, labels, photos	Wrong policy for sample/trial/re-import goods	State new goods or sample/no commercial value if true.
Label and packaging	Label artwork, original label, Vietnamese sub-label draft	Missing or inconsistent Vietnamese label	Name, ingredient, origin, manufacturer/importer and storage must align.

REFERENCE HS CODES

The HS code for anti-caking agents should not be fixed based on the trade name alone. The key basis is the chemical nature, composition, percentage, function, mixture status and actual use. The table below is for classification orientation only and should not replace a customs classification conclusion.

Reference HS code	Condition for application	Risk if wrong	Documents to check
2811.22.10	Silicon dioxide/silica by chemical nature, powder, food grade, commonly E551.	If actually blended, customs may request re-classification.	COA, SDS, CAS, specification, label, catalogue.
3824.99.99	Chemical preparation/additive blend not specifically classified elsewhere.	Broad code, often requires composition explanation.	Ingredient list, formula, COA, technical documents.
2106.90.99	Food manufacturing mixture/preparation not elsewhere specified.	May change duty and food safety procedure.	Catalogue, intended use, composition, food application.

Operational principle: Request COA, SDS, specification, CAS/E-number, original label and use instruction before finalizing HS and duty plan.

INDICATIVE DUTY TABLE

The duty table is separated from the HS table so that importers can review tax exposure more clearly. All rates below are indicative and must be checked against the tariff schedule, C/O and VAT policy on the customs declaration date.

Reference HS code	Goods scenario	Ordinary import duty	MFN import duty	VAT	Special preferential duty if valid C/O is available	Cross-check note
2811.22.10	Silicon dioxide/silica used as an anti-caking agent, commonly E551, food grade.	Indicative 0%; verify under Decision 15/2023/QD-TTg and the tariff in force at declaration date.	Indicative 0%.	Indicative 10%; check 8% if the VAT reduction policy is still effective and the goods are not excluded.	May be 0% or another preferential rate depending on the applicable FTA and actual C/O.	Check COA, SDS, CAS, E-number, specification, label and origin.
3824.99.99	Chemical preparation or blended additive not elsewhere specified or included.	Indicative 0%; re-check the current ordinary tariff.	Indicative 0% based on published policy information for this code group.	Indicative 10%; verify VAT policy at declaration date.	May enjoy special preferential duty if the C/O, HS code and goods description meet origin rules.	This is a broad heading; composition, formulation and use documents are needed to avoid reclassification.
2106.90.99	Mixture used in food processing, closer to a food preparation not elsewhere specified.	Indicative 22.5%; verify under Decision 15/2023/QD-TTg and the tariff in force at declaration date.	Indicative 15%.	Indicative 10%; check 8% if VAT reduction conditions are met.	May be 0% or another preferential rate under an FTA if the C/O is valid and origin rules are met.	Consider only when the product is a food mixture/preparation rather than an inorganic single substance.

Operating principle: Do not use this table to finalize tax liability without reviewing the actual dossier. For food additives, switching among Chapters 28, 38 and 21 may materially change duty, specialized policy and food safety documentation.

SPECIALIZED MANAGEMENT POLICY

Goods situation	Potential policy	Dossier to check	Authority/portal	Recommended timing	Risk note
Listed single anti-caking additive	Self-declaration/food safety import inspection under Decree 15; additive management under Circular 24.	Self-declaration, test result, COA, spec, label, HS.	Food safety authority, Customs, NSW if applicable.	Before ETA.	Do not assume exemption without E-number, concentration and use.
Goods under QCVN 4-4:2010/BYT	Technical/safety indicators must be checked.	COA, test report, food grade certificate.	Testing body/food safety authority.	Before declaration or inspection.	Missing indicators may block circulation.
Blended additive/premix	May require more complex review or registration.	Ingredient list, formula, ratio, main/secondary functions.	Food safety authority.	Before purchase contract.	Do not apply single-additive logic automatically.
Out-of-list/wrong food application additive	May not be eligible for import/circulation.	Additive list, CAC/JECFA if needed, manufacturer documents.	Food safety authority.	Before contract.	High risk of hold, re-export or disposal.
Samples/R&D goods	May need purpose explanation despite smaller quantity.	PO, purpose letter, sample quantity, technical dossier.	Customs/specialized authority.	Before ETA.	Wrong declared purpose can be treated as commercial goods.
EPE/FDI/factory import	HS, label, use purpose and internal material control still matter.	Contract, BOM, warehouse dossier, transport documents.	Managing customs office.	Before declaration.	Wrong use purpose may affect post-clearance audit.

LEGAL DOCUMENTS TO REVIEW

Document group	Name/number	Issuing authority	Effective time	Role	Articles/appendix to note	Review note
Law	Law on Food Safety 55/2010/QH12	National Assembly	From 01/07/2011	General food safety legal framework.	Food safety management principles.	Check implementing documents.
Decree	Decree 15/2018/ND-CP	Government	02/02/2018	Self-declaration, registration, import food safety inspection and food labeling.	Chapters on declaration and import inspection.	Main procedural basis.
Circular	Circular 24/2019/TT-BYT	Ministry of Health	16/10/2019	Management and use of food additives.	Additive list and use principles.	Check correct substance and food category.
Circular/QCVN	Circular 21/2010/TT-BYT; QCVN 4-4:2010/BYT	Ministry of Health	01/01/2011	National technical regulation for anti-caking food additives.	QCVN 4-4:2010/BYT.	Check indicators by actual substance.
Decree	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	NĐ 43 from 01/06/2017; NĐ 111 amends/supplements	Goods labeling for imported goods.	Mandatory labeling contents.	Vietnamese sub-label must align with dossier.
Tariff	Current import tariff; Decision 15/2023/QD-TTg	Government/Ministry of Finance	At declaration date	MFN, ordinary duty, VAT and preferential duty.	HS and tariff line.	Do not finalize tax without current tariff check.

VIEW / DOWNLOAD OFFICIAL DOCUMENTS

Enterprises should also verify documents on the official legal portals or issuing authority websites before applying them.

Decree 15/2018/ND-CP Circular 21/2010/TT-BYT Circular 24/2019/TT-BYT Decree 43/2017/ND-CP

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if available.
C/O if preferential duty is claimed.
Catalogue, COA, SDS, specification and original label.

Specialized documents if applicable

Self-declaration or registration dossier under Decree 15.
Test report with applicable indicators.
Label/sub-label dossier.
Evidence that additive is permitted for the intended food category.
COA/test report under QCVN 4-4 if applicable.

Dossier group	Required documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial docs	Invoice, Packing List, Contract/PO, B/L/AWB	Customs declaration and value/quantity check	Importer, shipper, forwarder	Generic name, missing E-number/CAS	Match name, package, lot, origin, price and Incoterms.
Origin docs	C/O if claiming preference	FTA preferential duty	Shipper/exporter	Wrong form, HS or description	Check draft C/O against invoice, packing list and bill.
Technical docs	Catalogue, specification, COA, SDS, CAS, E-number, food grade statement	HS and food safety policy	Manufacturer/importer	COA lacks key indicators	Check composition, concentration, standard and use.
Food safety dossier	Self-declaration/registration if applicable, test report, label	Clearance/circulation	Importer/QA/Compliance	Expired or insufficient test report	Review indicators under QCVN 4-4 and Circular 24.
Label dossier	Original label, Vietnamese sub-label, packaging images	Post-clearance/circulation	Importer/Legal/QA	Wrong additive name or missing details	Match label with declaration, COA and original label.

Consistency rule: Goods name, quantity, lot/batch, origin, composition, E-number/CAS, packaging and use purpose must match across commercial documents, technical dossier, food safety dossier, label and customs declaration.

KEY DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Proof document	Impact if unclear	Recommended action
HS basis	Single substance, inorganic salt, chemical preparation or food mixture?	COA, SDS, CAS, spec	Query/reclassification/tax adjustment	Confirm chemical nature before booking.
Food additive status	Food grade, E-number and food use available?	Catalogue, label, manufacturer documents	May be treated as ordinary chemical	Get food grade and application confirmation.
QCVN 4-4 applicability	Is the substance within the anti-caking regulation?	QCVN, COA, test report	Missing test indicators	Build testing checklist before ETA.
Declaration route	Self-declaration or registration?	Declaration, test report, label	Insufficient circulation basis	Review under Decree 15.
C/O usability	Does form/origin criterion match HS and description?	C/O, invoice, packing list, bill	No preferential duty	Check draft C/O before shipment.
Label readiness	Does label show correct name/composition/origin?	Original/sub-label	Supplement or correction requested	Approve sub-label before ETA.

PRACTICAL E2E PROCEDURE

Step 1: Pre-ETA review

Finalize HS, policy, duty, C/O, label, declaration status and food safety inspection if any.

Step 2: Lock documents

Cross-check Invoice, Packing List, B/L/AWB, COA, SDS, specification, label, E-number/CAS and origin.

Step 3: Prepare food safety dossier

Review declaration, testing, QCVN 4-4, Circular 24 and label documents.

Step 4: Customs declaration

Green channel: system clearance subject to conditions; Yellow: document check; Red: document and physical inspection.

Step 5: Clearance handling

Explain HS, value, C/O, food safety dossier, label and technical data when requested.

Step 6: Post-clearance completion

Apply sub-label if needed, archive shipment dossier and prepare for post-clearance audit.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents to check
Generic goods name	Difficult HS/policy determination	Ask supplier for chemical name, E-number, CAS and food grade.	Invoice, PL, COA, SDS.
Wrong HS among 2811/3824/2106	Wrong duty and policy	Review composition and function before declaration.	COA, SDS, formula, spec.
Out-of-list or wrong application additive	May not circulate	Check Circular 24 list and actual use.	Additive list, application guide.
Missing QCVN 4-4 indicators	Insufficient declaration/explanation dossier	Prepare testing checklist.	QCVN, test report, COA.
Invalid C/O	No preferential duty	Check C/O draft.	C/O draft, invoice, PL, B/L.
Inconsistent sub-label	Post-clearance risk	Review label under Decrees 43/111.	Original label, sub-label, declaration.

FAQ

1. Does anti-caking agent require an import license?

Do not conclude by name alone. Review composition, E-number, intended use, additive list and food safety dossier.

2. Is product declaration required?

Food additives usually require review for self-declaration or registration under Decree 15 depending on the actual product.

3. Is testing required?

Testing may be required for declaration, import inspection or post-clearance audit.

4. Can C/O reduce duty?

Yes, if form, origin criteria, description and HS are valid.

5. Is “anti-caking agent” enough on invoice?

Usually not ideal. Add chemical name, E-number/CAS, food grade and packaging.

6. Are samples handled like commercial goods?

Not automatically. Prove sample/R&D purpose and check policy accordingly.

7. Does blended anti-caking additive use the same HS as silica?

Not necessarily. A blend may fall under 3824 or 2106 depending on its nature.

8. What should the Vietnamese sub-label show?

Mandatory labeling contents must align with declaration dossier, COA, original label and use purpose.

IMPLEMENTATION SUPPORT FROM TGIMEX

This article provides a map of HS, duties, documents and specialized policies. In practice, enterprises still need to review catalogue, specification, COA, SDS, shipment documents, origin and import purpose.

Coordination capability

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, permits, warehousing and inland delivery.

Support scope

Pre-ETA review: HS, policy, C/O, duty, label, COA/SDS.
Compliance dossier control.
International logistics coordination and pre-alert tracking.
Customs declaration, channel handling and post-clearance archiving.

For shipments that may involve specialized inspection, C/O or labeling requirements, enterprises should not wait until arrival to review the dossier. Even minor discrepancies may lead to document supplementation, clearance delay or storage costs.

TGIMEX supports an E2E import plan covering pre-ETA policy review, document control, international freight, customs clearance, inland delivery and post-clearance dossier retention.

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