Additive premixes are high-risk import items because they are often declared generically as food ingredients, while their legal nature may be a compound food additive, a micronutrient premix for food fortification, a flavouring preparation or a chemical preparation used in food processing. Incorrect HS classification, missing product declaration, use of non-listed additives or use outside the permitted food category may lead to customs query, food-safety clarification, loss of C/O preferential duty, DEM/DET charges and disruption of production schedules. This article provides an E2E (End-to-End) map for reviewing HS code, duties, specialised policy, documents, customs process and ETA risks.

QUICK FACT – EXECUTIVE SUMMARY

Item	Review point	Operational note
Product name	Additive premix / compound food additive / micronutrient premix / blended food additive premix	Do not group it with baking premixes, finished supplements, single flavourings or animal-feed additives.
Indicative HS codes	2106.90.73; 2106.90.99; 3302.10.90	Selection depends on composition, main function, presentation and intended food/beverage use.
Indicative duties	2106.90.73/2106.90.99: MFN 15%, ordinary 22.5%; 3302.10.90: MFN 8%, ordinary 12%; VAT generally 10% or 8% if eligible for reduction	Duties must be rechecked against the tariff, C/O and VAT policy at the declaration date.
Food-safety policy	Ordinary additives may fall under self-declaration; compound additives with a new function, non-listed additives or additives not used for the permitted food category may require product declaration registration.	Do not conclude marketability before checking the permitted additive list, food category, maximum use level and technological function.
Labelling	Original label, Vietnamese supplementary label, quantitative composition, instruction for use, food category and maximum use level	For additive premixes, labels/specifications should clearly state component additives and intended use.
Website category IDs	VI 2760 / EN 2804 / ZH 2806	Final product category under IMPORT-EXPORT PROCEDURES BY PRODUCT.

Legal note An additive premix should not be handled as an ordinary food ingredient if it contains non-listed additives, has a new technological function or is intended for a non-permitted food category. Review catalogue, specification, COA, MSDS/SDS, quantitative composition, original label, SKU and actual import purpose. This English version is for operational reference and is not an official legal translation.

Illustration for Import procedures for additive premixes — Illustration of the product group and document review before customs clearance.

SCOPE OF APPLICATION

This article applies to additive premixes used in food or beverage manufacturing, including blends of acidity regulators, stabilisers, emulsifiers, thickeners, preservatives, antioxidants, sweeteners, colours, enzymes, flavour compounds or micronutrients for food fortification.

It does not automatically apply to animal-feed additives, pharmaceutical excipients, cosmetic additives, industrial chemicals, non-food flavourings, baking premixes that are finished food products or ordinary food ingredients.

Samples, R&D materials, EPE/FDI factory imports, internal-production materials, trading goods and products involving non-listed additives may be treated differently. Review by catalogue, specification, SKU/model, quantitative formulation and actual import purpose.

CLASSIFICATION & PRODUCT IDENTIFICATION

Classification must be based on the blended nature rather than the commercial name. A product may be named “premix”, “blend”, “compound”, “preparation”, “stabilizer system”, “emulsifier blend”, “flavour compound” or “fortification premix”; applicable policy depends on composition, technological function and target food category.

Check catalogue/specification: commercial name, intended use and applicable food sector.
Check COA/MSDS/SDS: ingredients, CAS where available, quantitative ratio and safety/quality indicators.
Check function: preservation, colouring, sweetening, thickening, stabilising, emulsifying, flavouring or fortification.
Check target food: confectionery, beverages, dairy, meat, seafood, seasonings, sauces, supplements.
Check condition: new goods, sample, R&D, internal production or commercial trading.

TECHNICAL IDENTIFICATION CRITERIA

Criteria	Documents to check	Risk if misdescribed	Suggested customs/commercial description
Product nature	Catalogue, specification, COA	Wrong HS between 2106, 3302 or chemical chapters	Food additive premix in powder/liquid form, used for [food category], main components…
Additive composition	Ingredient list, COA, MSDS/SDS, CAS if any	Unclear whether each additive is permitted	State the blend composition; avoid a generic “food additive” description.
Technological function	Specification and manufacturer’s instruction	Wrong policy if the compound additive has a new function	State stabiliser/emulsifier/preservative/sweetener/micronutrient premix as applicable.
Target food category	Application sheet, formula guideline, label	Permitted additive may still be used for a wrong food category	State “used for beverage/confectionery/dairy manufacturing…” if supported.
Form and packing	Packing List, original label, product photos	Quantity and physical inspection mismatch	Powder/liquid/paste; packing 25 kg/carton, 20 kg/can…
Import purpose	PO/contract, purpose letter, factory records	Confusion between commercial goods, samples and internal-use materials	State import for internal production/trading/R&D according to documents.

Identification warning A generic product name may lead to incorrect HS code, food-safety policy, declaration pathway, labelling and customs explanation when the dossier or goods are inspected.

HS CODE – DUTIES – C/O

The HS code is not determined merely by the word “premix”. The review must consider whether the product is a food preparation, a micronutrient premix for fortification, a flavouring preparation for food/beverage manufacture or another chemical preparation. For complex premixes, a written HS memo supported by catalogue, COA, specification and label is recommended.

Indicative HS	When it may apply	Ordinary import duty	MFN duty	VAT	Preferential duty with C/O	Documents to check
2106.90.73	Micronutrient premix for food fortification.	Indicative 22.5%	Indicative 15%	Usually 10%; review 8% if eligible	May be reduced under FTA tariff if C/O is valid	COA, specification, composition, instruction, declaration dossier
2106.90.99	Other food preparation not more specifically classified.	Indicative 22.5%	Indicative 15%	Usually 10%; review 8% if eligible	May be reduced if C/O meets the applicable FTA	Catalogue, formula, label, self-declaration/registration dossier
3302.10.90	Mixtures of odoriferous substances/flavouring preparations for food or beverages.	Indicative 12%	Indicative 8%	Usually 10%; review 8% if eligible	Many FTAs may offer 0% subject to conditions; check each agreement	Flavour specification, COA, MSDS/SDS, flavouring function

HS RISK REVIEW TABLE

HS code	Application condition	Risk if misapplied	Documents to verify
2106.90.73	Vitamin/mineral fortification premix for food	Rejected if the item is actually a flavour or a technological additive blend	Vitamin/mineral composition, quantitative ratio, fortification purpose
2106.90.99	Other edible food preparations not elsewhere specified	Customs may ask why it is not 3302 or a more specific line	Catalogue, COA, instruction, target food category
3302.10.90	Flavouring preparations used in food/beverage industries	Wrong if the premix has no flavouring nature	SDS, flavour description, CAS/ingredients, sensory function
3824.99.99	Exclusion review only for other chemical preparations	Risky if the product is actually a food additive used in F&B	SDS, chemical composition, non-food use evidence if any

C/O risk usually relates to product description, HS code, origin criterion and transport route. Because premixes may contain many ingredients, businesses should review CTH/CTSH/RVC or product-specific rules under the relevant FTA.

APPLICABLE SPECIALISED POLICY

SPECIALISED POLICY MATRIX

Goods situation	Possible policy	Documents to check	Authority/portal	Recommended timing	Risk note
Ordinary premix with permitted additives and permitted target food	Self-declaration; state food-safety inspection on import if applicable	Self-declaration, test report, label, COA, specification	Competent food-safety authority; NSW where applicable	Before ETA, ideally before shipment	Do not exceed maximum use level or use for a wrong food category.
Compound additive with a new function	May require product declaration registration under Decree 15/2018/ND-CP	Composition, function of each additive, new function, safety evidence	Ministry of Health / Vietnam Food Administration or delegated authority	Before commercial import	High risk if treated as an ordinary self-declared additive.
Non-listed additive or wrong target food	Specialised review is required; do not import/market without clear legal basis	Permitted additive list, target food, max use level, manufacturer dossier	Ministry of Health / VFA	Before contracting or ordering	May not be eligible for declaration or circulation in Viet Nam.
Flavouring preparation	Review as flavour/additive and label according to its nature	Specification, SDS, COA, HS 3302 if applicable	Competent food-safety authority	Before ETA	Do not use 3302 if the goods are not flavouring preparations.
Sample/R&D goods	Treatment may differ from trading goods but is not automatically exempt	Purpose letter, sample quantity, label, test plan	Customs and specialised authority if requested	Before declaration	Risk if samples are later used for production/trading.
EPE/FDI/internal factory import	HS, duty, food-safety policy, internal label and record retention still need review	Contract, production formula, factory records, use purpose	Managing customs branch and specialised authority if applicable	Before booking	Internal use does not remove HS and compliance obligations.

LEGAL DOCUMENTS TO REVIEW

Group	Document	Issuing body	Effective/application time	Role	Key points	Review note
Law	Law on Food Safety No. 55/2010/QH12	National Assembly	Core legal framework; check amendments if any	Food safety obligations	Food safety conditions and responsibilities	Review according to product and authority.
Decree	Decree 15/2018/ND-CP	Government	Effective from 02 Feb 2018	Self-declaration, registration and import food-safety inspection	Article 4, Article 6 and import inspection chapter	Critical for new-function compound additives and non-listed additives.
Resolution	Resolution 15/2026/NQ-CP	Government	Effective from 06 Apr 2026	Suspends Decree 46/2026/ND-CP and Resolution 66.13/2026/NQ-CP	Article 1 on suspension	Check the applicable regime at declaration date.
Circular	Circular 24/2019/TT-BYT	Ministry of Health	Effective from 16 Oct 2019; partially amended	Management and use of food additives	Permitted additives, food categories, use levels and blending requirements	Core document for additive premixes.
Circular	Circular 17/2023/TT-BYT	Ministry of Health	Issued on 25 Sep 2023	Amends several food-safety documents, including Circular 24/2019/TT-BYT	Compound additives and food-safety amendments	Read together with Circular 24/2019/TT-BYT.
Labelling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	01 Jun 2017 and 15 Feb 2022 respectively	Goods labelling and Vietnamese supplementary labels	Mandatory label contents and importer responsibility	Check quantitative composition, usage instruction and warnings.
Tariff	Decree 26/2023/ND-CP, Decree 199/2025/ND-CP and relevant amendments	Government	According to customs declaration date	Import/export tariff basis	HS 2106, 3302 or other final classification	Do not use a fixed duty rate before HS and date are confirmed.
Standards	QCVN 4 series/BYT and relevant standards	Ministry of Health/standards bodies	Ingredient-specific review	Technical/safety criteria for certain additives	Purity and contaminant limits if applicable	Further review is required based on actual composition.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Businesses may search by document number on the national legal database, the Government portal or the issuing authority’s website. Always cross-check the applicable version before implementation.

Decree 15/2018/ND-CP Circular 24/2019/TT-BYT Circular 17/2023/TT-BYT Resolution 15/2026/NQ-CP

CUSTOMS CLEARANCE DOCUMENT SET

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, specification, COA, MSDS/SDS.
Product photos, original label, SKU/model list if required.

Food-safety dossier

Self-declaration or registration receipt if applicable.
Test report.
Evidence that additives are permitted, for the right food category and within maximum levels.
Original and Vietnamese supplementary labels.
Technical documents on function and usage instruction.

Logistics records

Pre-alert, arrival notice, debit note if any.
ETA, destination port and carrier details.
Delivery order, customs declaration and inspection schedule.
Lot records for post-clearance review.

OPERATIONAL DOCUMENT CHECKLIST

Dossier group	Documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO	Customs declaration, value and quantity	Importer, shipper, logistics sales	Generic name, missing packing details	Compare with catalogue, label and COA.
Transport	B/L or AWB, arrival notice, pre-alert	D/O, declaration and ETA control	Forwarder, agent, carrier/airline	Late documents, wrong consignee	Request early pre-alert and lock the document timeline.
Technical	Catalogue, specification, COA, MSDS/SDS, ingredient breakdown	HS classification and additive policy	Manufacturer, QA/R&D, importer	No quantitative ratio or function	Check ingredients, CAS, function and target food.
Food safety	Declaration, test report, label	Food-safety inspection and circulation	Regulatory/QA, importer	Declaration does not match label; non-listed additive	Review under Circular 24/2019 and Circular 17/2023.
C/O	FTA C/O if any	Preferential duty	Shipper, supplier, importer	Wrong description, HS or origin criterion	Approve draft C/O before issuance.
Label	Original label, Vietnamese label, instruction, warning	Post-clearance circulation	Importer/brand owner/QA	Missing quantitative composition or maximum use level	Compare label with specification and declaration dossier.

Dossier consistency rule Product name, quantity, packing, lot, expiry, origin, additive composition, technological function, target food category and maximum use level must match across commercial documents, label, food-safety dossier, C/O and customs declaration.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question	Evidence	Consequence if unclear	Recommended handling
Additive list	Is each component additive permitted in Viet Nam?	Ingredient breakdown, Circular 24/2019, manufacturer documents	Insufficient legal basis for declaration/circulation	Review each additive, not only the premix name.
Target food	Which food category is the premix intended for?	Specification, application sheet, instruction	Correct additive may be used in a wrong food category	State target food and maximum use level.
New function	Does the compound additive create a new function?	Comparison between component functions and premix function	Wrong declaration route	Review Decree 15/2018 and Circular 17/2023.
HS code	Is it 2106.90.73, 2106.90.99 or 3302.10.90?	Catalogue, COA, SDS, function description	HS rejection, additional duty, delay	Prepare an HS memo with technical evidence.
C/O	Is the C/O form, HS, description and origin criterion correct?	C/O draft, B/L, Invoice, Packing List	No preferential duty	Check C/O before original issuance.
Supplementary label	Does the label show quantitative composition, instruction and warnings?	Original label, Vietnamese label, specification	Circulation/post-clearance risk	Approve the Vietnamese label with QA/Regulatory.

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Lock HS code, additive policy, permitted list, target food, maximum use level, declaration dossier, duty, C/O and label. If the product may be non-listed or has a new function, review before contracting.

Step 2: Lock commercial and technical documents

Finalise Invoice, Packing List, B/L/AWB, catalogue, specification, COA, MSDS/SDS, ingredient breakdown, original label and instruction. Avoid generic “food additive” descriptions.

Step 3: Complete food-safety/declaration dossier if applicable

Conduct self-declaration or registration according to the actual classification. Compound additives with a new function, non-listed additives or wrong target-food use should not be treated as ordinary additives.

Step 4: Lodge customs declaration

Green Channel allows conditional clearance; Yellow Channel checks documents; Red Channel checks documents and physical goods. Common questions involve HS, value, name, composition, label, C/O and food-safety basis.

Step 5: Clearance, delivery and post-clearance records

Release goods, deliver to warehouse, apply supplementary label if required, keep lot records and prepare explanations for post-clearance audit.

PRE-ETA RISK CHECKLIST

Risk 1: Non-listed additive

Consequence: no clear basis for declaration/circulation. Prevention: review every component additive before ordering.

Risk 2: Permitted additive but wrong target food

Consequence: regulatory challenge. Prevention: lock application sheet and maximum use level.

Risk 3: New-function compound additive

Consequence: wrong declaration route. Prevention: compare component functions with final premix function.

Risk 4: Wrong HS code

Consequence: rejection, additional duty and delay. Prevention: prepare HS memo based on COA/SDS/specification.

Risk 5: Incorrect C/O

Consequence: loss of preferential duty. Prevention: approve draft C/O before issuance.

Risk 6: Incomplete label

Consequence: circulation and post-clearance risk. Prevention: approve Vietnamese label against declaration and specification.

FAQ – FREQUENTLY ASKED QUESTIONS

Question	Answer
Does importing additive premix require a licence?	Do not use a generic “licence” conclusion. Determine whether the product is subject to self-declaration or registration; new-function, non-listed or wrong-target additives require careful review.
Can the invoice simply state “food additive premix”?	Not recommended. State form, main components/function, target food category and packing to support HS and specialised policy review.
Should additive premix be classified under HS 2106 or 3302?	It depends. Micronutrient/food preparations may fall under 2106; flavouring preparations for food/beverages may fall under 3302.
Can non-listed additives be imported?	No conclusion can be given without a clear legal basis. Review with the competent authority or compliance adviser before commercial import.
Can C/O reduce duty?	Yes, if the C/O form, origin rule, goods description, HS code and direct transport conditions are valid under the relevant FTA.
Are sample/R&D goods handled like trading goods?	Not automatically. Review import purpose, quantity, label and specialised policy based on the actual dossier.
What should the Vietnamese label show?	Quantitative composition, instruction, maximum use level, target food category, warning if any and the responsible organisation in Viet Nam.

IMPLEMENTATION SOLUTION FROM TGIMEX

This article provides a map of HS code, duty, dossier and specialised policy for additive premixes. In practice, businesses should still review catalogue, specification, COA, MSDS/SDS, documents, origin, composition, function and import purpose.

Execution capability is supported by an agent network in more than 60 countries, memberships in WCA, WCA China Global, VLA, HNLA and multimodal operations including ocean, air, road/rail, warehousing, customs clearance, C/O and import permits.

Pre-ETA review

HS, additive policy, permitted list, C/O, duties, labelling, catalogue and specification.

Compliance dossier control

Invoice, Packing List, B/L/AWB, C/O, COA, MSDS/SDS, label, test report and declaration dossier.

Logistics & customs

Agent/carrier coordination, ETA tracking, pre-alert, declaration, Green/Yellow/Red channel handling and local delivery.

For shipments that may trigger specialised inspection, permits, C/O or labelling requirements, businesses should not wait until arrival to review documents. A small discrepancy among Invoice, Packing List, catalogue, specification, C/O or label may lead to additional documents, clearance delay and storage charges.

TGIMEX supports E2E import planning: pre-ETA policy review, document checking, international transportation coordination, customs declaration, clearance handling, domestic delivery and post-clearance record retention.

Applicable information must be cross-checked against legal documents, tariff schedule, C/O and the actual dossier at declaration date.

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