IMPORT PROCEDURES FOR CAPSULE/POWDER SUPPLEMENT
Capsule/powder supplement shipments are often treated too casually as ordinary food, while the actual dossier may indicate a health supplement, supplemented food, micronutrient premix or even a product to be reviewed under pharmaceutical controls if the label or claims suggest therapeutic effects. A wrong HS Code, missing product declaration registration, inconsistency between label – COA – test report, or late preparation of food safety inspection documents may result in customs inspection, additional document requests, denial of preferential C/O treatment and DEM/DET charges. This article provides an E2E (End-to-End) review map before ETA: HS Code, taxes, C/O, specialized policies, customs documents, clearance workflow and risks to block before arrival.
QUICK FACTS
| Product scope | Main reference HS | Reference duty proposal |
|---|---|---|
| Capsule/powder supplement: dietary/health supplement in hard capsule, softgel, tablet, sachet powder or nutrition powder form for human consumption. | 2106.90.72 – Other health supplements; also review 2106.90.71, 2106.90.73, 2106.10.00 or other headings depending on ingredients and claims. | For HS 2106.90.72: ordinary import duty 22.5%; MFN 15%; standard VAT 10%, potentially 8% during 01/07/2025–31/12/2026 if eligible and not listed in the exclusion appendices; FTA rate may be 0% with a valid C/O. Recheck on the customs declaration date. |
SCOPE OF APPLICATION
This article applies to capsule/powder supplement products under the group of vitamins, minerals, collagen, probiotics, gummies, capsules and nutrition powder supplements, packed for retail or B2B distribution.
- If the product is positioned as a health supplement, the key dossier usually includes product declaration registration before market circulation, state food safety inspection upon import, Vietnamese sub-label and supporting documents for ingredients/claims.
- If the product is only ordinary supplemented food and does not fall under Article 6 of Decree 15/2018/ND-CP, the self-declaration route may apply; however, the conclusion must be checked against ingredients, target users and label claims.
- Do not group it automatically with ready-to-drink collagen, gummies, specialized probiotics, medical foods, children’s products or therapeutic products.
- Samples, testing shipments, returns, EPE/FDI procurement and retail-chain shipments may require separate documentation control.
CLASSIFICATION & PRODUCT IDENTIFICATION
Product nature
The product is generally an edible preparation in hard capsule, softgel, tablet, jar powder or sachet form, used to supplement vitamins, minerals, protein, collagen, probiotics, fiber or nutritional actives.
Information to lock
Trade name, dosage form, packing, quantitative ingredients, active content, target users, dosage, warnings, manufacturing country, manufacturer and applicable standard.
Common mismatch
The generic term “supplement” may cover health supplements, protein concentrate, young-child food, micronutrient premix or medicines. Each route may affect HS, tax and specialized dossiers.
Suggested goods description
Use a clear description such as: “Health supplement/supplemented food [product name], [capsule/powder] form, packing…, main ingredients…, for human consumption, brand-new goods.”
| Criteria to verify | Documents to compare | Risk if wrongly described | Suggested declaration wording |
|---|---|---|---|
| Product form | Original label, package photos, specification, catalogue | Wrong HS between capsules, powder, ready-to-drink product or gummies | Clearly state capsule, tablet, softgel, drink powder or nutrition powder. |
| Main ingredients | Ingredient list, COA, formula/specification | Wrong food safety policy, missing test parameters or misclassification as drug/micronutrient | State key ingredients and nutritional supplementation purpose; avoid treatment claims. |
| Function/claims | Label, leaflet, website claims, declaration dossier | May be treated as medicine or non-compliant advertising | Use support/supplement language, not cure/treatment language. |
| Target users | Label and directions for use | Products for children, pregnant women or patients may trigger separate controls | Declare target users, dosage and warnings consistently with the declaration dossier. |
| Shelf life/storage | Label, COA, certificate of analysis | Insufficient shelf life or difficult food safety inspection/circulation | Show manufacturing date, expiry date and storage conditions. |
HS CODE – DUTIES – C/O
HS classification should be based on the product nature, ingredients, form, intended use and label claims. For ordinary capsule/powder supplements, heading 2106 is usually the first review route. However, products containing ginseng, micronutrient premix, protein concentrate, oil-based ingredients or pharmaceutical claims should not be assigned one generic code without dossier review.
REFERENCE DUTY TABLE
This table is for initial costing only. The importer should verify the tariff schedule, VAT policy and C/O treatment on the customs declaration date.
| Reference HS Code | Application notes | Ordinary duty | MFN duty | VAT | Special preferential rate with valid C/O |
|---|---|---|---|---|---|
| 2106.90.72 | Other health supplements; main review route for many finished capsule/powder supplements. | 22.5% | 15% | 10%; potentially 8% during the VAT reduction period if eligible and not excluded. | May be 0% under some FTAs if origin rules, C/O form and shipment documents are valid. |
| 2106.90.71 | Health supplements from ginseng; only if composition and product nature match. | 22.5% | 15% | 10% or 8% if eligible. | Subject to each FTA and origin. |
| 2106.90.73 | Micronutrient mixtures for food fortification; often for premix/ingredient use. | 22.5% | 15% | 10% or 8% if eligible. | Review FTA schedule and C/O conditions. |
| 2106.10.00 | Protein concentrates/textured protein substances; possible for certain protein powders. | 7.5% | 5% | 10% or 8% if eligible. | Potentially lower under FTAs; verify on declaration date. |
| 3004.xx | Only if the product is actually a medicine/therapeutic preparation; not for ordinary supplements. | By specific drug HS | By specific drug HS | By applicable tax policy | Pharmaceutical registration/licensing may arise; review separately. |
HS REVIEW TABLE BY PRODUCT NATURE
This table is not a repeated tax table; it clarifies when each HS route may apply, the classification risk and the supporting dossier to check.
| Reference HS | Conditions for application | Risk of wrong HS | Documents to check |
|---|---|---|---|
| 2106.90.72 | Finished other health supplement for human consumption, not medicine. | Tax exposure and possible classification analysis. | COA, ingredient list, label, declaration dossier, catalogue. |
| 2106.90.71 | Ginseng-based health supplement with matching product nature. | Wrong classification if ginseng is only minor flavor/extract. | Formula, COA, evidence of ginseng ingredients. |
| 2106.90.73 | Micronutrient/premix for food fortification, usually as an ingredient. | Confusing ingredient premix with finished retail product. | Specification, import purpose, packing format. |
| 2106.10.00 | Protein concentrate or textured protein substance. | Wrongly used for multi-active mixed supplement. | Nutritional facts, protein COA, production process. |
| 3004.xx | Only when the product is actually a medicine or therapeutic preparation, has therapeutic claims or falls under pharmaceutical policy. | Misclassifying a supplement as medicine, or vice versa, may trigger licensing, marketing authorization and post-clearance issues. | Label, leaflet, claim dossier, active ingredients, marketing authorization/authorization documents if any. |
APPLICABLE SPECIALIZED POLICIES
| Goods situation | Potential policy | Documents to check | Authority / portal | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Health supplement capsules/powder for business import | Product declaration registration; state food safety inspection; food labeling. | Registration dossier, test report, CFS/health certificate if any, label, COA. | Ministry of Health / Vietnam Food Administration; public service portal/NSW where applicable. | Before arrival. | Missing acceptance/registration may delay market circulation. |
| Ordinary supplemented food | Self-declaration or registration depending on ingredients/claims; food safety inspection. | Ingredients, label, test report, claims dossier. | Competent food safety authority; NSW if applicable. | Before customs declaration. | Do not assume self-declaration if health-protection claims are present. |
| Treatment or disease claims | May fall under pharmaceutical or advertising compliance review. | Label, leaflet, website claims, sales materials. | MOH or drug authority depending on conclusion. | At PO stage. | High risk; legal review is required before import. |
| Probiotic/enzyme/botanical extract products | Food safety, testing indicators, microbiological/heavy metal/additive limits. | COA, certificates, test reports, specification. | Food safety inspection body/testing laboratory. | Before ETA. | Missing test indicators often delays processing. |
| Samples/testing shipments | Customs declaration still required; food safety policy depends on purpose and quantity. | Sample purpose letter, sample invoice, technical documents. | Customs/specialized authority if requested. | Before shipment. | Do not sell samples without circulation dossiers. |
| Foreign-label goods | Vietnamese sub-label before circulation. | Original label, Vietnamese label artwork, translated ingredients/claims. | Market surveillance/food safety authority at post-clearance stage. | Before market release. | Claim mismatch or missing warning may trigger post-clearance issues. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document name/number | Issuing body | Effective date | Role | Key points | Review note |
|---|---|---|---|---|---|---|
| Law | Law on Food Safety No. 55/2010/QH12 | National Assembly | Effective from 01/07/2011 | Legal foundation for imported food, declarations, inspection, labeling and advertising. | Review by product group. | Do not apply broadly when special claims exist. |
| Decree | Decree 15/2018/ND-CP | Government | 02/02/2018 | Self-declaration, product declaration registration, import food safety inspection, labeling/advertising. | Article 4 on self-declaration; Article 6 on product declaration registration; import inspection chapters. | Health supplements are generally subject to registration; ordinary supplemented foods must be reviewed separately according to ingredients and claims. |
| Circular | Circular 43/2014/TT-BYT | Ministry of Health | 01/02/2015 | Management of functional foods, including supplemented food and health supplements. | Labeling, directions for use and claims. | Check amendments if any. |
| Circular | Circular 28/2021/TT-BYT | Ministry of Health | 02/02/2022 | HS-based list serving state food safety inspection for imported food. | Food/supplemented food list. | Compare HS and management group before declaration. |
| Labeling | Decree 43/2017/ND-CP; Decree 111/2021/ND-CP | Government | 01/06/2017; 15/02/2022 | Goods label, sub-label, origin and mandatory information. | Food label requirements and appendices. | Sub-label must match declaration dossier and original label. |
| Tariff | Decree 26/2023/ND-CP | Government | 15/07/2023 | MFN import tariff schedule. | Heading 21.06 and related HS codes. | Recheck on the declaration date. |
| VAT | Decree 174/2025/ND-CP | Government | 01/07/2025; policy to 31/12/2026 | VAT reduction from 10% to 8% for eligible groups, excluding listed groups. | Article 1 and exclusion appendices. | Check customs system at declaration date. |
VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS
Businesses should additionally check the official legal document portal or the issuing authority’s website before application.
CUSTOMS CLEARANCE DOCUMENT SET
The dossier should be divided into commercial documents and specialized compliance documents. Goods name, packing, SKU, ingredients, active content, shelf life, origin, manufacturer and claims must match across commercial documents, original label, declaration dossier, test report and customs declaration.
| Document group | Required documents | Used for | Usually prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial documents | Commercial Invoice, Packing List, Sales Contract/PO | Value, quantity, product description | Importer/Supplier | Generic “supplement” description without form/packing | Compare each line with label, COA and packing. |
| Transport | B/L or AWB, Arrival Notice, Pre-alert | D/O, manifest, clearance | Forwarder/Carrier | Wrong consignee, packages, gross weight, description | Lock pre-alert before ETA. |
| Declaration/Food safety | Product declaration registration or self-declaration if eligible, test report, quality dossier | Food safety inspection and circulation | Importer/Legal/QA | Using self-declaration for a product requiring registration | Check Decree 15 route before ordering. |
| Manufacturer documents | CFS, Health Certificate, GMP/HACCP/ISO if any, COA | Prove circulation, safety and quality | Supplier/Manufacturer | CFS does not match product name or lacks legalization/translation where required | Check scans before shipment. |
| Labeling | Original label, Vietnamese sub-label artwork, directions, warnings | Market circulation after clearance | Importer/Brand owner | Treatment claims or missing “not a medicine” warning where applicable | Compare with declaration dossier and Circular 43. |
| C/O | C/O Form D/E/AK/VJ/AJ/AANZ/EVFTA/RCEP… if claiming preference | Preferential duty | Exporter/Supplier | Wrong HS, description, origin criterion or third-party invoice | Check draft C/O before original issuance. |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended handling |
|---|---|---|---|---|
| Product group | Is it health supplement, supplemented food, micronutrient premix, protein powder or medicine? | Label, formula, COA, declaration dossier | Wrong declaration, food safety or pharmaceutical policy | Legal/QA review before PO. |
| HS Code | Are ingredients and functions sufficiently supported? | COA, specification, catalogue, declaration dossier | Tax exposure and classification query | Prepare HS review table before ETA. |
| Product declaration | Is product declaration registration required? | Registration dossier, acceptance number, test report | Delayed circulation or missing specialized dossier | Prepare before arrival. |
| Claims | Are there cure/treatment claims? | Original label, website, leaflet | Potential drug/advertising compliance issue | Revise label and claims before import. |
| C/O | Is the C/O correct in HS, description, form and origin criterion? | Draft C/O, invoice, B/L | Loss of preferential duty and post-clearance queries | Check draft before sailing. |
| Sub-label | Does the sub-label match the original label and declaration dossier? | Label artwork, declaration dossier | No market circulation or post-clearance risk | Approve sub-label before ETA. |
PRACTICAL E2E WORKFLOW
Step 1 – Pre-ETA review
Confirm product group, HS, duties, C/O, food safety policy, product declaration, Vietnamese label and claims.
Step 2 – Lock documents and technical dossier
Compare Invoice, Packing List, B/L/AWB, ingredient list, COA, CFS/health certificate, original label, SKU list and declaration dossier.
Step 3 – Register specialized dossiers if applicable
Complete product declaration registration/self-declaration route, testing indicators, food safety inspection and sub-label preparation.
Step 4 – Customs declaration
Declare HS, value, goods description, quantity, origin, C/O and food safety policy. Green channel may clear subject to system conditions; Yellow checks documents; Red checks documents and physical goods.
Step 5 – Clearance, delivery and post-clearance file
Deliver to warehouse, complete sub-labeling, keep shipment files, declaration/test/C/O documents and prepare explanations if post-clearance audit arises.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | How to block before ETA | Documents to check |
|---|---|---|---|
| Using self-declaration for a product requiring registration | Delayed circulation and additional compliance dossier | Determine product group before import | Label, claims, ingredients, Decree 15 |
| Wrong HS among 2106.90.72, 2106.90.73, 2106.10.00 or 3004 | Tax difference and classification analysis | Lock composition and function before ETA | COA, formula, specification |
| Treatment claims on label or sales materials | Drug/advertising compliance risk | Review all label, leaflet and web claims | Original label, translation, catalogue |
| C/O with wrong HS or description | No preferential duty and possible document debt | Check draft C/O before issuance | Draft C/O, invoice, packing list, B/L |
| Test report missing required indicators | Insufficient food safety/declaration dossier | Map testing indicators against formula and product group | Test report, COA, specification |
| Vietnamese sub-label mismatches declaration dossier | No circulation or post-clearance risk | Approve artwork before labeling | Original label, sub-label, declaration dossier |
FAQ
Does capsule/powder supplement need an import license?
The key issue is usually not a trade import license, but product declaration, food safety inspection, labeling and circulation conditions. Products with treatment claims or special ingredients require separate review.
Is product declaration registration required?
If classified as a health supplement, product declaration registration is generally required under Decree 15/2018/ND-CP before market circulation. Do not assume self-declaration.
What is the common HS for capsule/powder supplements?
HS 2106.90.72 is common for other health supplements. Ginseng-based products, micronutrient premixes, protein powders or drug-like products must be reviewed separately.
Is VAT 8% or 10%?
The standard VAT rate is 10%. During the VAT reduction period, 8% may apply if eligible and not excluded. Check the declaration date.
Can C/O reduce duty?
Potentially yes. For HS 2106.90.72, MFN is commonly 15%, while some FTAs may reduce the rate to 0% if origin rules and C/O are valid.
Are samples handled like commercial goods?
Customs declaration is still required. Food safety/declaration requirements depend on purpose, quantity and whether the sample will be used for testing or sale.
What must be checked on Vietnamese sub-label?
The sub-label must match original label and declaration dossier, including ingredients, quantity, directions, warnings, target users, origin, responsible importer and compliant claims.
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