Importing food-contact packaging film commonly triggers three operational risks: generic goods descriptions, wrong HS classification between roll film and formed bags/pouches, and missing food-safety evidence under the applicable QCVN. If handled incorrectly, the shipment may be asked for test reports, self-declaration documents, material-contact explanations or labelling clarification, or be routed to documentary/physical inspection. This article provides an E2E (End-to-End) review map before ETA: HS Code, duties, C/O, food-safety policy, dossier set and key points that may trigger DEM/DET.

Note: This article applies only to film used as packaging material in direct contact with food. Review must be based on catalogue, datasheet, material, specification, COA/test report, original label and actual import purpose.

QUICK FACT

Criteria	Quick review content
Product	PE/PP/BOPP/PET film or laminated film used for wrapping, packing or direct food-contact packaging.
Regulatory group	Food-contact packaging/tools/materials; review under Decree 15/2018/ND-CP and the applicable QCVN.
Reference HS codes	3920.10.90, 3920.20.10, 3920.20.99, 3920.62.99; if formed as bags/pouches: 3923.21.99 or 3923.29.90.
Reference MFN duty	Group 3920: commonly 6%; bags/pouches 3923.21.99 / 3923.29.90: reference 15%. Final duty must be checked on the customs declaration date.
VAT	Normally review 10%; 8% may be considered if the goods qualify under Decree 174/2025/ND-CP and are not excluded by the appendices.
Key specialized dossier	Food-safety self-declaration/import inspection dossier if applicable; QCVN test report, COA, specification, label and intended-use evidence.

Legal note

Do not conclude that “no specialized dossier is required” merely from the goods name “film”. If the film is imported for direct food contact, the importer should review food-safety documents, applicable QCVN, test reports and labelling. Industrial film, agricultural film, technical film or non-food-contact film may be subject to a different policy path.

SCOPE OF APPLICATION

Applicable product

Plastic film in rolls, sheets or leaves used for wrapping, packing or as the direct food-contact layer.
May include PE, PP, BOPP, PET, laminated film, shrink film and cling film if the dossier indicates food-contact use.

Not automatically applicable to

Industrial film, agricultural film, technical film, medical film, window film or materials not intended for food contact.
Formed packaging such as pouches, trays or boxes if the product nature is no longer roll film.

Variants requiring separate review

Printed film, aluminium-coated film, laminated paper/aluminium/plastic film, adhesive-coated film or anti-fog film.
Samples, trial goods, project goods, EPE/FDI imports or materials used to produce export packaging.

Application rule

Review must be made against catalogue, datasheet, specification, material, layer structure, test report and actual import purpose. Do not group all film variants into one conclusion.

CLASSIFICATION & PRODUCT IDENTIFICATION

The customs description should clarify the main polymer, goods form, thickness, number of layers, whether the film is printed/laminated/coated, and whether the direct contact with food is the film itself or only a specific layer. These facts determine whether group 3920 or 3923 is more appropriate and whether food-safety control applies.

Criteria to check	Documents to cross-check	Risk if described incorrectly	Suggested description on documents/declaration
Goods form	Catalogue, packing list, pictures of rolls/sheets/bags	Roll film may be mistaken for formed bags/pouches, or vice versa.	PE plastic film in rolls for food packaging, unprinted, not formed into bags.
Main material	Specification, COA, SDS/MSDS	Wrong HS code between PE, PP, PET or laminated materials.	BOPP/PET/PE film for food-contact packaging, thickness … microns.
Layer structure	Datasheet, laminate structure	Wrong QCVN or test scope for the food-contact layer.	PET/PE laminated film, PE layer is the direct food-contact layer.
Intended use	PO, contract, technical documents	Unable to determine whether food-contact policy applies.	Food-contact packaging film for food wrapping/packing.
Condition	Invoice, pictures, contract	Used goods or scrap may trigger a different policy path.	Brand-new goods, in rolls, unused.

HS CODE – DUTY – C/O

There is no single HS code for every “film” shipment. Classification depends on goods form, main polymer, reinforcement/lamination/coating status and whether the product has been formed into bags/pouches. The table below is an initial review guide only; final determination must be checked against the tariff and actual dossier on the declaration date.

Reference HS code	Description / application condition	Reference ordinary duty	Reference MFN duty	VAT	Special preferential duty if valid C/O is available
3920.10.90	Film/sheet/leaf of ethylene polymers, non-cellular, not reinforced, not laminated or similarly combined with other materials; other.	9%	6%	10%; possibly 8% if eligible for VAT reduction	May be 0% or preferential under FTA if origin rules and C/O are valid.
3920.20.10	Biaxially oriented polypropylene film – BOPP.	9%	6%	10% or 8% depending on VAT policy at declaration date	Review under the relevant FTA and C/O.
3920.20.99	Film/sheet/leaf of propylene polymers, other.	9%	6%	10% or 8% if eligible	Review based on each FTA rule of origin.
3920.62.99	Film of poly(ethylene terephthalate) – PET, other.	9%	6%	10% or 8% if eligible	Check C/O, direct consignment and origin criteria.
3923.21.99	Bags and sacks of ethylene polymers, other; used when goods are already formed as bags/pouches.	22.5%	15%	10% or 8% if eligible	May be reduced if a valid FTA C/O is available; environmental protection tax must be reviewed if the goods are taxable plastic bags.
3923.29.90	Bags and sacks of other plastics, other.	22.5%	15%	10% or 8% if eligible	Review according to C/O and origin rules; environmental protection tax must be reviewed if the goods are taxable plastic bags.

Environmental protection / trade-remedy note: If the goods have been formed as plastic bags or thin plastic packaging that fall under the taxable plastic-bag scope, the importer should additionally review Law on Environmental Protection Tax No. 57/2010/QH12 and Resolution No. 579/2018/UBTVQH14; the rate for taxable plastic bags is VND 50,000/kg. For BOPP film or propylene-polymer film, trade-remedy status should also be checked at the declaration date, especially by origin and HS code.

Reference HS code	Application condition	Risk of wrong classification	Dossier to cross-check
3920.xx	Roll/sheet/leaf film not formed into bags; polymer-based classification.	Wrong duty, wrong description or possible classification analysis request.	Catalogue, COA, specification, pictures, material sample.
3923.xx	Finished bags/pouches or plastic packaging articles.	Misclassification between film and formed packaging.	Pictures, packing details and finished-product function.
Laminated film	Identify the main layer and food-contact layer.	Wrong QCVN/test scope if the contact layer is misidentified.	Laminate structure, technical data sheet, COA/test report.
Preferential C/O	C/O must match description, HS code, origin and transport route.	Loss of preferential duty or post-clearance tax exposure.	C/O, B/L, invoice, packing list, origin rule.

APPLICABLE SPECIALIZED POLICY

Goods scenario	Potential policy	Dossier to check	Authority/portal if identifiable	Recommended timing	Risk note
Plastic film in direct contact with food	Self-declaration and import food-safety inspection review under Decree 15/2018/ND-CP; QCVN 12-1:2011/BYT if synthetic-resin food-contact packaging applies.	Test report, COA, specification, label, self-declaration dossier if applicable.	Food-safety authority / Ministry of Health; National Single Window if the procedure is available.	Before ETA, preferably before shipment.	Missing test report or wrong QCVN may delay clearance.
Aluminium/paper/plastic laminated film	Review the direct-contact layer and corresponding material standard.	Layer structure, analysis report, declaration of compliance.	Food-safety inspection authority / accredited laboratory.	Before PO and invoice are finalized.	Do not rely only on the outer layer.
Film not intended for direct food contact	May fall outside direct food-contact packaging policy, but actual use must be evidenced.	PO, contract, intended-use description, catalogue.	Customs and specialized authority if queried.	Before customs declaration.	Do not state “food contact” if not true.
Thin plastic bags or plastic sacks	Review environmental protection tax if the goods are taxable plastic bags.	Polymer composition, grammage/weight, bag shape, intended use, commitment/declaration if a non-taxable case is claimed.	Customs/tax authority.	Before tax and value declaration.	Omitting environmental protection tax may distort total import tax exposure.
Samples / trial goods	May require separate handling on value, purpose, quantity and specialized dossier.	Sample invoice, explanation letter, test plan.	Customs office of declaration.	Before ETA.	Do not assume commercial and sample shipments have identical treatment.
Imports for EPE/FDI/factory	Review production purpose, local sales/export use, BOM and lot dossier.	Manufacturing contract, BOM, norms, warehouse records.	Supervising customs authority.	Before declaration.	Maintain lot dossier for post-clearance audit.

LEGAL DOCUMENTS TO REVIEW

Document group	Document name/number	Issuing authority	Effective/application date	Role in procedure	Key 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 and food-contact materials.	Food-safety conditions and import inspection provisions.	Apply based on actual intended use.
Decree	Decree 15/2018/ND-CP	Government	Effective from 02/02/2018	Self-declaration, import food-safety inspection and labelling framework.	Article 4 on self-declaration and import inspection provisions.	Do not assume exemption without checking actual dossier.
Technical regulation	QCVN 12-1:2011/BYT	Ministry of Health	Issued with Circular 34/2011/TT-BYT	Safety and hygiene regulation for synthetic-resin implements, containers and packaging in direct contact with food.	Technical requirements and testing for plastic food-contact materials.	Apply if the film is synthetic-resin food-contact packaging.
Circular	Circular 15/2024/TT-BYT	Ministry of Health	Effective from 02/11/2024	List of food/additives/tools and packaging materials under MOH import food-safety inspection.	Cross-check HS code and product scope.	Review by HS and product nature.
Decree	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Decree 43 from 01/06/2017; Decree 111 from 15/02/2022	Labelling requirements for imported goods and Vietnamese supplementary labels.	Original label, supplementary label, origin and responsible entity.	Labelling errors may affect clearance or circulation.
Tariff	Decree 26/2023/ND-CP and Decree 199/2025/ND-CP	Government	Decree 199 effective from 08/07/2025	Reference import tariff by HS code.	Chapter 39 and amendments.	Finalize according to declaration date.
Environmental protection tax	Law on Environmental Protection Tax No. 57/2010/QH12; Resolution No. 579/2018/UBTVQH14	National Assembly; Standing Committee of the National Assembly	Resolution 579 applies from 01/01/2019	Review if goods are taxable plastic bags/thin plastic packaging.	Taxable plastic bag rate: VND 50,000/kg.	Do not apply automatically to film rolls that are not yet formed as taxable bags/sacks.
VAT	Decree 174/2025/ND-CP	Government	Effective from 01/07/2025 to 31/12/2026	Review possible VAT reduction from 10% to 8% if not excluded.	Exclusion appendices and declaration date.	Do not apply 8% without checking the appendices.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Decree 15/2018/ND-CP QCVN 12-1:2011/BYT Circular 15/2024/TT-BYT Decree 199/2025/ND-CP Decree 174/2025/ND-CP Law 57/2010/QH12 Resolution 579/2018/UBTVQH14

Enterprises should cross-check the documents on official legal databases or the issuing authority website before application.

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, datasheet, film roll pictures and original label.

Specialized dossier if applicable

Self-declaration dossier for food-contact packaging materials.
Test report under QCVN 12-1 or the applicable regulation.
COA, specification, SDS/MSDS, declaration of compliance.
Vietnamese supplementary label and intended-use evidence.

Dossier group	Required documents	Used for which step	Typical preparer	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO	Declaration, customs value, quantity	Importer, seller, logistics/docs	Generic name such as “plastic film”	Add polymer, roll form, thickness and food-contact use.
Transport	B/L or AWB, arrival notice	D/O, manifest and delivery	Forwarder/carrier	Wrong consignee, package count or weight	Check against booking and packing before ETA.
HS and duties	Catalogue, COA, specification	HS classification and duty calculation	Importer, customs broker	Main polymer not identified	Ask supplier to state PE/PP/PET/BOPP and layer structure.
Food safety/QCVN	Test report, declaration, self-declaration dossier if applicable	Specialized inspection, post-clearance audit	Importer, legal/compliance, supplier	Test report does not match contact material	Match test parameters with applicable QCVN.
Labelling	Original label, Vietnamese supplementary label	Clearance/circulation	Importer/distributor	Missing origin or responsible entity	Prepare Vietnamese label before circulation.

Dossier matching rule: goods name, material, thickness, specification, quantity, origin, intended use and HS code must match across commercial documents, catalogue, test report, labels, specialized dossier and customs declaration.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended handling
HS code	Is the product roll film or formed bags/pouches?	Pictures, catalogue, packing list	Classification analysis request or wrong duty	Lock product nature before declaration.
Food contact	Will the film directly contact food?	PO, datasheet, declaration, label	Food-safety dossier/test report query	Clarify use and prepare proper test report.
Material	Which layer directly contacts food and what is the main polymer?	Layer structure, COA, specification	Wrong QCVN and test scope	Obtain supplier confirmation.
Labelling	Does original/supplementary label contain mandatory information?	Artwork, label file	Supplementary label request or enforcement risk	Prepare Vietnamese label before circulation.
C/O	Does C/O match HS, description and origin?	C/O, B/L, invoice	Preferential duty may be denied	Check draft C/O before issuance.

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review

Confirm HS code based on form and main polymer.
Review food-safety/QCVN policy, duty, C/O and labels.
Determine whether self-declaration/import inspection is needed.

Step 2 – Lock documents and technical dossier

Finalize Invoice, Packing List and B/L/AWB.
Finalize catalogue, datasheet, COA/test report.
Check goods name, specification, thickness, origin and quantity.

Step 3 – Prepare specialized dossier

Prepare test report and self-declaration dossier if applicable.
Match QCVN with material/contact layer.
Do not wait until arrival if dossier risk is high.

Step 4 – Customs declaration

Green channel: system-based clearance subject to conditions.
Yellow channel: documentary check.
Red channel: documentary and physical inspection.
Common queries: HS, value, catalogue, QCVN and use.

Step 5 – Clearance and post-clearance control

Deliver goods to warehouse and complete supplementary label if circulated.
Archive lot dossier: declaration, test report, C/O and label.
Prepare explanation dossier for post-clearance audit.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA prevention	Documents to check
Generic description “plastic film”	Wrong HS and wrong policy path	State polymer, form, thickness and food-contact use	Invoice, catalogue, COA
Food-contact layer not identified	Invalid test report scope	Obtain layer structure and declaration of compliance	Datasheet, test report
Roll film confused with formed bags	Wrong duty and classification	Check pictures and packaging format	Packing list, product photos
Missing Vietnamese supplementary label	Labelling enforcement risk	Prepare label artwork in advance	Original label, Decree 43/111
C/O mismatches HS or description	Loss of preferential duty	Check draft C/O before issuance	C/O, B/L, Invoice

FAQ

Does food-contact packaging film require self-declaration?

Possibly. If it is a packaging material in direct contact with food under Decree 15/2018/ND-CP, self-declaration and import food-safety review may be required depending on the actual dossier and QCVN.

Is quality inspection/conformity certification required?

Do not conclude absolutely. For plastic food-contact film, review QCVN 12-1:2011/BYT, test reports and import food-safety inspection mechanism if applicable.

Should HS 3920 or 3923 be used?

Roll film/sheets normally point to group 3920. Formed bags/pouches or finished packaging articles require review under group 3923.

Is Vietnamese supplementary labelling required?

Yes, if the goods are circulated in Vietnam and the original label lacks mandatory Vietnamese information. The original label must be kept.

Can C/O reduce duty?

It may. Preferential duty depends on the FTA, HS code, origin criteria, direct consignment and validity of C/O.

Are samples treated the same as commercial goods?

Not automatically. Samples require review of purpose, quantity, value and specialized dossier; food-contact testing purpose may still be questioned.

IMPLEMENTATION SUPPORT FROM TGIMEX

This article provides a reference map on HS code, duties, dossier and specialized policy for food-contact packaging film. In real shipments, enterprises still need product-specific review based on catalogue, datasheet, material structure, test report, documents, origin and import purpose.

Execution capability

Agent network in more than 60 countries.
Membership: WCA, WCA China Global, VLA, HNLA.
Sea, air, road/rail, warehousing and domestic delivery capability.

Support scope

Pre-ETA review: HS, policy, C/O, duty, labels and datasheet.
Compliance dossier control: Invoice, Packing List, B/L/AWB, C/O, test report and labels.
Customs declaration, Green/Yellow/Red channel handling and post-clearance dossier archiving.

For shipments that may involve specialized inspection, C/O or labelling requirements, enterprises should not wait until cargo arrival to start dossier review. Small discrepancies among Invoice, Packing List, catalogue, datasheet, C/O or labels can lead to document supplementation, clearance delay or unplanned storage costs.

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