Tiếng Việt
中文 (中国)
IMPORT PROCEDURES FOR ADDITIVE PREMIXES
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. |
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. |
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.
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. |
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
Consequence: no clear basis for declaration/circulation. Prevention: review every component additive before ordering.
Consequence: regulatory challenge. Prevention: lock application sheet and maximum use level.
Consequence: wrong declaration route. Prevention: compare component functions with final premix function.
Consequence: rejection, additional duty and delay. Prevention: prepare HS memo based on COA/SDS/specification.
Consequence: loss of preferential duty. Prevention: approve draft C/O before issuance.
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. |
RELATED ARTICLES
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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