Meal replacement products may be misclassified if the importer relies only on commercial names. Powder, liquid, bar or sachet products may trigger product registration, state food-safety inspection, mandatory Vietnamese labeling and claim control when the dossier shows medical nutrition, foods for patients or foods for special dietary uses. Wrong HS code, missing product registration receipt, or discrepancies between label, COA, test report and product declaration may delay customs clearance, generate DEM/DET costs and prevent lawful market circulation. This article provides an E2E (End-to-End) map for review before ETA (Estimated Time of Arrival).

Scope focus: meal replacement products within medical nutrition, foods for patients and foods for special dietary uses. Review must be based on catalogue, datasheet, original label, formula, dosage form, target users and actual import purpose.

QUICK FACT

Item	Review direction	Operational note
Product name	Meal replacement products in powder, ready-to-drink, bar, sachet or mixed nutrition format.	Do not treat as ordinary processed food when label/claims refer to patients, special diets or meal-control use.
Reference HS codes	2106.90.96 – other medical food products under food preparations; 1901.90.91 – medical nutrition products under milk/flour/malt-based preparations; 2106.90.99 or 1901.90.99 for other food preparations; 2202.99.50 if ready-to-drink non-alcoholic beverage.	Final HS depends on composition, form, main function and technical dossier.
Product declaration policy	Likely subject to product declaration registration if classified as medical nutrition or food for special dietary uses.	Do not automatically apply the self-declaration logic for ordinary food.
Food-safety inspection	May be subject to state food-safety inspection for imported food under Decree 15/2018/ND-CP and MOH lists.	Check HS code, composition, use and competent authority.
VAT	Indicatively 8% or 10% depending on customs declaration date and exclusion appendices under current VAT policy.	Do not apply 8% without checking the actual goods and policy at declaration date.
C/O	Preferential duty may apply if a valid FTA Certificate of Origin is available.	Description, HS code, origin criterion, invoice and transport documents must match.

Legal note: Meal replacement is sensitive because classification between ordinary food, medical nutrition, food for special dietary uses and health supplements depends on label, claims, ingredients and target users. Do not conclude that no product registration or permit is required without reviewing the actual dossier.

SCOPE OF APPLICATION

Covered products

This article applies to imported meal replacement products for commercial distribution or business use in Viet Nam, including powder, sachet, ready-to-drink, bar or mixed nutrition formats.

Variants to separate

Do not automatically apply this guidance to infant formula, health supplements, ordinary beverages, weight-loss products with medical claims, or products containing dairy/animal-origin ingredients requiring additional review.

Shipment status

New goods, samples, trial goods, gifts, warranty replacements and imports for EPE/FDI/factory use may trigger different documentary and customs requirements.

Condition for application

Review must be based on catalogue, datasheet, SKU, label, composition, nutrition facts, certificates and actual import purpose.

CLASSIFICATION & TECHNICAL IDENTIFICATION

For meal replacement, the description “food powder” or “nutrition drink” is not sufficient. The dossier should demonstrate product nature, key ingredients, protein/fat/carbohydrate content, vitamins/minerals, energy per serving, target users, instructions, warnings and label claims.

Criteria to check	Documents to compare	Risk if described incorrectly	Suggested goods description
Product form	Catalogue, original label, photos, packing specification.	Wrong HS between 2106, 1901 and 2202.	Meal replacement powder / drink / nutrition bar – brand, flavor, packing size.
Function and users	Label, leaflet, website claims.	Wrong declaration route; possible claim violation.	Meal replacement for special dietary/portion-control use; do not state treatment claims unless supported.
Composition and nutrition facts	Formula, COA, test report.	Mismatch with product registration and HS rationale.	State protein, fiber, vitamins, minerals, sweeteners, milk solids if any.
Special ingredient origin	Ingredient list, allergen statement, animal-origin declaration.	Potential additional food-safety/quarantine review.	Declare milk powder, whey, casein, collagen, soy protein if present.
Label and warnings	Original artwork, Vietnamese sub-label, usage instruction.	Post-clearance circulation risk.	Ensure product name, quantity, ingredients, MFG/EXP, origin, usage and warnings.

HS CODE – DUTY – C/O

HS code must be determined by product nature, composition, use form and principal function. Commercial naming alone is not reliable.

Reference HS code	Application condition	Risk if misapplied	Documents to check
2106.90.96	Other medical food products, where the dossier shows medical nutrition / food for special medical purposes.	May be rejected if actual product is ordinary food or ready-to-drink beverage.	Label, claims, instructions, declaration dossier, scientific evidence, formula.
1901.90.91	Medical nutrition products under heading 1901; relevant where the product is milk/flour/malt-based and the dossier indicates medical nutrition or food for special medical purposes.	May be rejected if the product is not medical nutrition or actually falls under 2106/2202.	Milk/flour/malt content, formula, claims, product declaration dossier and scientific documents.
2106.90.99	Other food preparations not elsewhere specified.	May be challenged if clearly milk-based or beverage-form.	Formula, COA, nutrition facts, catalogue.
1901.90.99	Other preparations under heading 1901; consider where milk/flour/malt-based but not qualified as medical nutrition.	Wrong if product is a food preparation under 2106 or beverage under 2202.	Milk content, powder composition, preparation process.
2202.99.50	Ready-to-drink non-alcoholic beverage, not requiring dilution.	Wrong if powder/sachet or medical nutrition product.	Product form, bottle/can pack, usage instructions.

HS code to review	Ordinary import duty – indicative	MFN duty – indicative	VAT – indicative	Special preferential duty under C/O
2106.90.96	10.5%	7%	8% or 10% depending on timing and exclusion list	May be 0% or preferential rate under applicable FTA if C/O is valid.
1901.90.91	10.5%	7%	8% or 10%	May be 0% or preferential rate under applicable FTA if C/O is valid.
2106.90.99	22.5%	15%	8% or 10%	Check ATIGA, ACFTA, CPTPP, EVFTA, RCEP, etc.
1901.90.99	27%	18%	8% or 10%	Review preferential tariff schedule by exporting country.
2202.99.50	45%	30%	8% or 10%	Review FTA origin criteria and transport route.

C/O risk: Incorrect C/O form, origin criterion, description or HS code may cause denial of preferential duty. Check the draft C/O before ETA.

APPLICABLE SPECIALIZED POLICIES

Goods situation	Potential policy	Documents to check	Authority/portal if identifiable	Recommended timing	Risk note
Medical nutrition or special dietary meal replacement	Product declaration registration under Decree 15/2018/ND-CP.	Product declaration, CFS/Health Certificate/Certificate of Exportation, test report, scientific evidence, label.	Provincial-level competent authority designated by the People’s Committee; online public service where applicable.	Before commercial import and before ETA.	Do not use ordinary self-declaration logic.
Goods listed for MOH import food-safety inspection	State food-safety inspection for imported food.	Inspection registration, product declaration receipt, test report, shipment documents.	Designated food-safety inspection body / NSW where applicable.	Before or upon arrival; prepare before ETA.	Missing registration/results may delay clearance.
Contains milk, whey, casein, collagen or animal-origin protein	Additional animal-origin / food-safety review may apply.	Ingredient list, animal-origin statement, health certificate.	Relevant specialized authority depending on ingredient.	Before contract and booking.	No assumption of exemption without ingredient review.
Weight-control, blood-sugar, patient-nutrition claims	Claim, label, advertising and scientific evidence review.	Artwork, leaflet, website claims, scientific evidence.	Product declaration/advertising authority where applicable.	Before label printing and marketing.	Therapeutic claims may be non-compliant.

LEGAL DOCUMENTS TO REVIEW

Document group	Document	Issuer	Effective date/application	Role in procedure	Key articles/appendices	Review note
Law	Law on Food Safety No. 55/2010/QH12	National Assembly	Effective from 01/07/2011	Framework for food safety requirements.	Imported food, labeling, advertising and inspection provisions.	Apply by product type.
Decree	Decree 15/2018/ND-CP	Government	Effective from 02/02/2018	Product self-declaration, product registration, import food-safety inspection and labeling.	Articles 3, 6, 7, 8 and Appendix I.	Medical nutrition and special dietary foods require registration.
Circular	Circular 43/2014/TT-BYT and consolidated/amended texts if any	Ministry of Health	Effective from 01/02/2015; check consolidated version	Management of functional foods including medical nutrition and special dietary foods.	Scope, labeling, usage instructions and advertising.	Check consolidated text 11/VBHN-BYT where relevant.
Circular	Circular 15/2024/TT-BYT	Ministry of Health	Effective from 02/11/2024	MOH list of imported food/food additives/food-contact packaging subject to state food-safety inspection.	HS-code list and correction Decision 988/QD-BYT if relevant.	Check each SKU HS code.
Circular	Circular 29/2023/TT-BYT	Ministry of Health	Effective from 15/02/2024	Nutrition labeling guidance.	Nutrition content and presentation.	Important where nutrition facts are shown.
Decree	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Currently applied; re-check at import date	Goods labeling and Vietnamese sub-label.	Product name, origin, quantity, ingredients, MFG/EXP, warnings.	Label must match declaration dossier.
Tariff	Decree 26/2023/ND-CP and Decree 199/2025/ND-CP	Government	15/07/2023 and 08/07/2025	MFN tariff and amendments.	Appendix II import tariff.	Finalize at declaration date.
VAT	Decree 174/2025/ND-CP	Government	01/07/2025 to 31/12/2026	VAT reduction policy under Resolution 204/2025/QH15.	Exclusion appendices and application timing.	Do not apply 8% without checking exclusions.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises should cross-check the official legal text on the Government legal portal, the Official Gazette or the issuing authority’s website before application.

Law 55/2010/QH12 Decree 15/2018/ND-CP Circular 43/2014/TT-BYT Circular 15/2024/TT-BYT Decision 988/QD-BYT Circular 29/2023/TT-BYT Decree 26/2023/ND-CP Decree 199/2025/ND-CP Decree 174/2025/ND-CP

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
C/O if preferential duty is claimed.
Catalogue, datasheet, photos, original label, SKU list.

Specialized dossiers if applicable

Product declaration registration receipt.
Product declaration and supporting dossier.
CFS/Health Certificate/Certificate of Exportation if required.
Food-safety test report.
Vietnamese sub-label dossier.
Import food-safety inspection registration/result if required.

Dossier group	Required documents	Used for	Usually prepared by	Common errors	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB, contract/PO.	Customs declaration, customs value, quantity and Incoterms.	Buyer, supplier, forwarder.	Generic description and mismatched quantity.	Check SKU, packing size, batch and weights.
Technical	Catalogue, datasheet, label artwork, nutrition facts, ingredients.	HS and policy classification.	Supplier/manufacturer.	Claims not matching dossier.	Compare claims, target users and main ingredients.
Product registration	Registration receipt, declaration, test report, CFS/HC/CE.	Food-safety and circulation basis.	Importer/legal/compliance.	Wrong SKU/flavor or expired test report.	Check receipt number, product name and manufacturer.
Labeling	Original label, Vietnamese sub-label, instructions, warnings.	Clearance and post-clearance market circulation.	Importer/marketing/compliance.	Missing mandatory wording for medical/special dietary foods.	Compare against Decree 15 and labeling rules.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Proof documents	Consequence if unclear	Recommended handling
Product classification	Is it ordinary food, medical nutrition or special dietary food?	Label, claims, formula, usage instructions.	Wrong registration route.	Classify before purchase order.
HS code	Powder, ready-to-drink or medical food product?	COA, formula, catalogue, label.	Channel inspection or HS dispute.	Prepare HS rationale before ETA.
Product registration receipt	Does it cover the exact SKU/flavor/pack size?	Receipt, declaration, appendix.	Unable to prove circulation basis.	Lock registration dossier before arrival.
Import food-safety inspection	Is the HS/SKU listed for inspection?	Circular 15/2024/TT-BYT, inspection registration.	Clearance delay.	Prepare inspection dossier before ETA.
Vietnamese sub-label	Are mandatory wording and warnings present?	Artwork, original label, sub-label.	Post-clearance circulation risk.	Review before printing.

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review

Finalize HS code, product classification, duty, C/O, labeling, product registration and import food-safety inspection possibility.

Step 2 – Lock documents

Lock Invoice, Packing List, B/L/AWB, catalogue, label artwork, nutrition facts, ingredient list and SKU/flavor list.

Step 3 – Prepare registration / food-safety dossier

Review registration receipt, test report, CFS/Health Certificate and inspection registration where applicable.

Step 4 – Customs declaration

Explain product name, HS, value, origin, C/O and specialized policy. Green channel allows conditional clearance, Yellow checks documents, Red checks documents and physical goods.

Step 5 – Clearance and delivery

Release cargo, deliver to warehouse, inspect packaging, batch/lot and storage condition if required.

Step 6 – Post-clearance control

Apply Vietnamese sub-label, archive shipment dossier, declaration, inspection result, test report, tax and C/O documents.

PRE-ETA RISK CHECKLIST

Risk	Consequence	How to block before ETA	Documents to check
Generic goods name	Wrong HS and wrong product registration route.	Standardize name by nature and form.	Label, catalogue, ingredient list.
No product registration receipt	No basis for food-safety inspection/circulation.	Complete product registration before commercial import.	Receipt, declaration, test report.
SKU/flavor mismatch	Supplement request or explanation.	Prepare SKU list and compare every invoice line.	Invoice, Packing List, label, declaration.
Overstated claims	Label/advertising violation risk.	Review claims before label and marketing use.	Artwork, leaflet, website, evidence.
Incorrect C/O	Loss of preferential duty.	Request draft C/O before issuance.	C/O, invoice, B/L.

FAQ

1. Does meal replacement require product registration?

Likely yes if classified as medical nutrition or food for special dietary uses. The actual label, ingredients and claims must be reviewed.

2. Is import food-safety inspection required?

It may be required where the HS/SKU falls under the MOH inspection list. Check Circular 15/2024/TT-BYT and the actual dossier.

3. Which HS code is commonly reviewed?

Common candidates include 2106.90.96, 1901.90.91, 2106.90.99, 1901.90.99 and 2202.99.50 depending on form, composition, milk/flour base and declared use.

4. Is VAT 8% or 10%?

Check the declaration date and exclusion appendices. Do not automatically apply 8%.

5. What must be noted on Vietnamese sub-label?

Product name, ingredients, nutrition facts where applicable, MFG/EXP, origin, instructions, warnings and mandatory wording for medical/special dietary foods.

6. Can samples skip the full dossier?

It depends on purpose and quantity. Samples must not be commercially circulated without satisfying applicable registration, inspection and labeling requirements.

IMPLEMENTATION SUPPORT FROM TGIMEX

This article provides a map of HS code, duty, documentation and specialized policies for meal replacement products. In real shipments, enterprises still need to review catalogue, datasheet, original label, formula, commercial documents, origin and actual import purpose.

Execution capability

TGIMEX has an agent network in more than 60 countries and memberships with WCA, WCA China Global, VLA and HNLA; with capabilities in sea, air, road/rail transport, warehousing, domestic delivery, customs clearance, C/O and import permits.

Support scope

Pre-ETA review: HS, food-safety policy, product registration, C/O, duty and labeling.
Compliance document control: Invoice, Packing List, B/L/AWB, C/O, test report, label and declaration dossier.
International logistics coordination: agents, carriers, ETA, pre-alert and transport documents.
Customs declaration and Green/Yellow/Red channel handling.
Post-clearance document archiving and audit readiness.

For shipments that may involve specialized inspection, product registration, C/O or labeling requirements, enterprises should not wait until arrival to review documents. Even a small discrepancy between Invoice, Packing List, catalogue, datasheet, C/O or label can cause supplement requests, clearance delay or unexpected storage costs.

TGIMEX supports E2E import execution: pre-ETA policy review, document check, international transport coordination, customs declaration, clearance handling, domestic delivery and post-clearance archiving.

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