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IMPORT PROCEDURE GUIDE FOR DAIRY RAW MATERIALS
Dairy raw materials are operationally sensitive because “milk material” may refer to liquid raw milk, liquid milk/cream, skimmed milk powder, whole milk powder, whey, modified whey or dairy fat. If the importer misapplies HS Code, lacks animal product quarantine documents, misses the Health/Veterinary Certificate, fails to review state import food safety inspection, loses cold-chain control or submits a C/O with inconsistent HS code, the shipment may face document/physical inspection, additional dossiers, loss of preferential duty, DEM/DET, reduced shelf-life and production disruption. This guide provides an E2E review map before ETA.
QUICK FACTS
Product
Animal-origin dairy raw materials for food manufacturing: raw milk, liquid milk/cream, skimmed milk powder, whole milk powder, whey or modified whey.
Key HS
0401 for liquid milk/cream; 0402 for concentrated/powdered milk; 0404 for whey; 0405 for dairy fat.
Reference duty
0401: MFN 15%, ordinary reference 22.5%; many 0402 lines: MFN 5%, ordinary reference 7.5%; VAT 10%.
Key policy
Animal product quarantine; import food safety inspection where applicable; declaration/registration if circulated; labeling and traceability.
Technical file
Health/Veterinary Certificate, COA, specification, test report, label, shelf-life, storage temperature.
Caution
Do not apply automatically to finished dairy products, infant formula, health supplements, feed-grade ingredients or plant-based products.
Legal note: This content applies only to animal-origin dairy raw materials used for food manufacturing/processing. Catalogue, datasheet, ingredients, packing, batch, storage condition, veterinary/food-safety certificates and actual import purpose must be reviewed.
SCOPE OF APPLICATION
This guide applies to imported dairy raw materials used for food manufacturing or processing, including liquid, powdered, concentrated dairy ingredients or natural milk constituents not elsewhere specified.
- Do not apply to infant formula, medical nutrition, meal replacements, collagen drinks or health supplements.
- Liquid raw milk requires temperature, transport time and remaining shelf-life review.
- Dairy powder/whey requires fat %, protein, lactose, sugar status, moisture, microbiology and packing review.
- Dairy fat/butteroil/cream requires separate HS and standard review.
- Review catalogue, datasheet, batch/model and actual import purpose.
CLASSIFICATION & TECHNICAL IDENTIFICATION
Technical identification must start from physical and chemical nature: liquid or powder, concentrated or not, sugar/sweetener status, fat content, protein, lactose, food-grade or feed-grade purpose, packing and storage condition.
| Checkpoint | Documents to review | Risk if described incorrectly | Suggested goods description |
|---|---|---|---|
| Product form and nature | Catalogue, specification, COA, original label, photos | Confusion among liquid milk, milk powder, whey, cream or finished product | Dairy raw material – skimmed milk powder/whole milk powder/liquid raw milk/whey…, food grade |
| Fat content and composition | COA, nutrition facts, test report | Wrong HS among 0401, 0402, 0404, 0405; wrong duty/C/O | Fat content…, protein…, lactose…, no added sugar/with sugar if any |
| Sugar/sweetener status | Ingredient list, specification, label | Wrong subheading 0402.21/0402.29 or other heading | Not containing added sugar or other sweetening matter |
| Packing specification | Packing list, label, package photos | Wrong detailed code by net weight or unit | 25 kg/bag, net weight…, batch/lot…, MFG/EXP… |
| Intended use | PO, contract, purpose letter, production plan | Food grade vs feed grade; raw material vs finished product confusion | Imported as food-grade raw material for dairy/food manufacturing |
HS CODE – DUTY – C/O
HS classification must be determined by product form, fat content, sugar/sweetener status, packing and intended use. Do not use one generic HS for all dairy raw materials.
| Reference HS code | Application condition | Risk if incorrect | Documents to review |
|---|---|---|---|
| 0401.10.10 / 0401.20.10 / 0401.40.10 | Liquid milk/cream, not condensed, not sugar mixed; Grouped according to fat content. | Using powdered milk code for liquid milk violates quarantine, tax, refrigerated transport and C/O. | COA, nhãn, fat content, temperature record, health certificate, invoice, packing list. |
| 0402.10.41 | Skimmed milk powder, not too much fat 1,5%, unsweetened, packaged from 20 kg trở lên. | Sai fat %, net weight hoặc sugar status làm sai mã chi tiết và C/O. | COA, fat %, net weight/bag, ingredient list, label, C/O, test report. |
| 0402.21.20 | Sữa bột nguyên kem, hàm lượng béo trên 1,5%, unsweetened, packaged from 20 kg trở lên. | Confused with skimmed milk powder or products containing sugar, causing incorrect tax and grouping. | COA, fat %, sugar status, net weight, specification, C/O. |
| 0402.29.xx / 0402.91.00 / 0402.99.00 | Condensed or sweetened milk/cream, powdered or otherwise. | Mistaking unsweetened ingredients for products containing sugar/sweeteners or concentrates. | Ingredient list, Brix/solids nếu có, sugar status, packing, label. |
| 0404.10.xx | Whey and modified whey, whether or not concentrated, whether or not sweetened. | Confusing whey with powdered milk causes the nature of the product, policies and taxes to be wrong. | COA, protein/lactose, whey type, food grade, label, health certificate. |
| 0405.xx | Butter, butteroil, anhydrous milk fat hoặc chất béo từ sữa. | Including milk fat in the powdered milk code causes errors in HS and testing criteria. | COA, fat %, moisture, product type, QCVN/standard, label. |
REFERENCE DUTY TABLE BY HS GROUP
| HS group / reference code | Reference ordinary duty | Reference MFN duty | VAT | FTA duty with valid C/O | Application note |
|---|---|---|---|---|---|
| 0401.10 / 0401.20 / 0401.40 | Khoảng 22,5% if the MFN 150% rule is applied when there is no separate normal level. | 15% | 10% | Có thể 0–5% or according to the FTA route if the C/O is valid. | Apply to uncondensed, unsweetened liquid milk/cream; Check by fat content. |
| 0402.10.41 | 7,5% tham khảo. | 5% | 10% | Có thể 0–5% theo FTA nếu C/O hợp lệ. | Unsweetened skim milk powder, packaged ≥20 kg. |
| 0402.21.20 | 7,5% tham khảo. | 5% | 10% | Có thể 0–5% theo FTA nếu C/O hợp lệ. | Unsweetened whole milk powder, packaged ≥20 kg. |
| 0404.10.xx | Need to review according to final code. | Theo mã cuối cùng, nhiều dòng whey tham khảo quanh 5%. | 10% | FTA theo C/O hợp lệ. | Whey food grade khác whey feed grade/protein preparation. |
| 0405.xx | Theo mã cuối cùng. | Theo mã cuối cùng. | 10% | FTA theo C/O hợp lệ. | Dairy fat/butteroil/cream may have its own codes and standards. |
Duty and C/O note: Rates are indicative for pre-checking. Verify tariff at declaration date, special preferential tariff schedule, C/O form, origin criteria, direct transport and goods description before declaration.
APPLICABLE SPECIALIZED POLICY
| Goods scenario | Possible policy | Documents to check | Authority / processing channel if identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Raw milk is of animal origin imported for food production | Quarantine of terrestrial animal products; State inspection of imported food safety if on the list; traceability. | Quarantine form, Health/Veterinary Certificate, COA, invoice, packing list, B/L/AWB, label, storage conditions. | Department of Animal Health/border gate veterinary agency; DVCQG/NSW if implemented electronically. | Before ETA, best before booking. | Missing veterinary certificates or certificates from the wrong batch can cause goods to be stuck at the port. |
| Sữa bột nguyên liệu food grade | Review quarantine, food safety, self-declaration/registration for declaration if circulating as a product; secondary label if marketed. | COA, specification, test report, declaration if applicable, original label/sub-label. | Food Safety Agency; Custom; veterinary agency if applicable. | Before ETA and before circulation. | Do not use feed grade records for food grade ingredients. |
| Raw fresh milk/liquid milk needs to be kept cold | Quarantine, food safety, cold-chain control, shelf-life, transportation/warehouse temperature. | Temperature log, COA, health certificate, label, booking note, reefer setting. | Customs, border veterinary, cold storage/unit logistics. | Before booking and throughout transportation. | Cold breakage or short shelf-life can pose a quality risk. |
| Whey hoặc chất béo từ sữa | Review students individually 0404/0405, purpose of use, QCVN/standards, quarantine/food safety according to records. | COA, protein/fat/moisture, label, health certificate, specification. | Customs; veterinary/food safety agency if applicable. | Before ETA. | Do not combine whey, milk powder and butteroil into the same conclusion. |
| Samples/R&D/testing | May differ in type code, import purpose, and traffic conditions. | Letter of intent, invoice, packing, COA, label, sample quantity. | Customs; specialized agencies if required. | Before opening the declaration. | Do not use sample routes to import disguised commercial goods. |
| Imported goods for EPE/FDI/manufacturing factories | Review type codes, norms, storage, export/domestic production, and transfer to domestic consumption if any. | Contracts, BOM/norms, production plans, food safety records, warehouse documents. | Customs management of EPE/FDI; specialized agencies if introduced to the market. | Before ETA. | Domestic transfer requires review of taxes, labels, food safety and quarantine. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document name/number | Issuing authority | Effective timing | Role in procedure | Key points | Review note |
|---|---|---|---|---|---|---|
| Luật | Food Safety Law 55/2010/QH12 | National Assembly | Magnetic effect 01/07/2011 | Platform for managing food safety, imported food, traceability and circulation. | Regulations on imported food, food safety conditions, labeling and traceability. | Need to compare amended/supplemented documents, if any. |
| Luật | Veterinary Law 79/2015/QH13 | National Assembly | Magnetic effect 01/07/2016 | Basis for quarantine of animals and animal products. | Điều 45–47 on dossiers, procedures and content of import quarantine. | Raw milk of animal origin requires quarantine inspection. |
| Nghị định ATTP | Nghị định 15/2018/NĐ-CP | Government | Magnetic effect 02/02/2018 | Imported food safety inspection facility, self-declaration/registration for announcement if circulating. | Điều 4 about self-declaration; regulations on imported food safety inspection. | Do not publish conclusions if the purpose of circulation is unclear. |
| Validity status | Nghị quyết 15/2026/NQ-CP | Government | Magnetic effect 06/04/2026 | Temporarily suspend the validity of the Decree 46/2026/NĐ-CP và NQ 66.13/2026/NQ-CP. | Summary temporarily suspended. | Do not mistakenly apply Decree 46/2026 if you have not rechecked. |
| Quarantine | Circular 01/2026/TT-BNNMT | Ministry of Agriculture and Environment | Magnetic effect 01/01/2026 | Regulations on quarantine of terrestrial animals and animal products. | Appendix of application form and related procedures. | It is necessary to check according to the type of dairy product and exporting country. |
| List of students managing agriculture | Circular 11/2021/TT-BNNPTNT | Bộ NN&PTNT | Magnetic effect 06/11/2021; thay TT 15/2018/TT-BNNPTNT | HS code table of goods under agricultural management/specialization. | Appendixes I and II relate to animal products and specialized inspection. | It is necessary to compare the amended/replaced text, if any. |
| QCVN sữa | QCVN 5-1:2010/BYT, 5-2:2010/BYT, 5-4:2010/BYT | Ministry of Health | QCVN 5-2 theo TT 31/2010/TT-BYT, hiệu lực 01/01/2011 | Safety criteria for liquid milk, powdered milk, and milk fat if within scope. | Theo từng QCVN. | Do not apply one QCVN to all raw milk. |
| Goods labeling | NĐ 43/2017/NĐ-CP và NĐ 111/2021/NĐ-CP | Government | Effect sequentially 01/06/2017 và 15/02/2022 | Regulations on original labels and Vietnamese sub-labels. | Product name, ingredients, quantity, manufacturer/expenditure, origin, preservation. | Secondary labels must match COA, specification and documents. |
| Biểu thuế | NĐ 26/2023/NĐ-CP; NĐ 108/2025/NĐ-CP | Government | NĐ 26 hiệu lực 15/07/2023; NĐ 108 hiệu lực 19/05/2025 | Based on the MFN tariff and Chapter structure 04. | Nhóm 0401, 0402, 0404, 0405. | Tax rates are for reference only; reviewed at the declaration date. |
| VAT | Luật GTGT 48/2024/QH15; NĐ 181/2025/NĐ-CP; NQ 204/2025/QH15; NĐ 174/2025/NĐ-CP | National Assembly/Government | Apply from 01/07/2025 according to each text | Based on standard VAT and VAT reduction policy if applicable. | Decree 174 stipulates VAT reduction according to Decree 204. | Check exclusion groups and application deadlines. |
VIEW / DOWNLOAD ORIGINAL LEGAL TEXTS
Decree 15/2018/ND-CPCircular 01/2026/TT-BNNMTQuarantine procedure portalCircular 11/2021/TT-BNNPTNTCircular 31/2010/TT-BYT
Enterprises should additionally verify the documents on official legal document portals or issuing authority websites before applying them.
CUSTOMS CLEARANCE DOCUMENT SET
Commercial documents
Commercial Invoice, Packing List, B/L/AWB, Contract/PO, C/O, catalogue/specification, original label.
Quarantine / food safety dossier
Health/Veterinary Certificate, quarantine application, COA/test report, declaration dossier if applicable, supplementary label.
Shipment control data
Fat %, protein, lactose, net weight, batch/lot, MFG/EXP, storage temperature, manufacturer and origin.
| File group | Required documents | Used for | Usually prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO | Value, quantity and trade terms | Procurement/Docs/Importer | Generic name; missing fat %, net weight or batch | Match SKU/batch, description, net weight and packing with COA |
| Quarantine | Application, Health/Veterinary Certificate, quarantine list | Pre-clearance quarantine | Importer/QA/Compliance/Supplier | Certificate missing batch, factory or country | Check draft certificate before ETA |
| HS–tax | COA, specification, ingredient list, label, draft C/O | HS, MFN, VAT and FTA review | Importer/Compliance/Broker | Confusing 0401, 0402, 0404 and 0405 | Prepare HS analysis by form, fat %, sugar and net weight |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended handling |
|---|---|---|---|---|
| HS by product form | Does the product fall under 0401, 0402, 0404 or 0405? | COA, specification, label, packing | HS query, duty adjustment, C/O discrepancy | Finalize HS by form, fat %, sugar and packing before ETA |
| Animal product quarantine | Is quarantine required? | Circular 01/2026, veterinary certificate, HS list | Quarantine hold and delay | Register/declare quarantine before arrival |
| Cold-chain/shelf-life | Is cold-chain required? Is shelf-life sufficient? | Label, COA, temperature log, reefer setting | Quality risk and claims | Lock transport condition and temperature monitoring |
PRACTICAL E2E WORKFLOW
Pre-ETA review
Finalize product form, HS, duty, VAT, C/O, quarantine, food safety/declaration, label and storage.
Lock documents
Chốt Invoice, Packing List, B/L/AWB, COA, specification, Health/Veterinary Certificate, C/O draft.
Register quarantine / specialized inspection
Register/declare animal product quarantine and prepare food safety dossier if applicable.
Lodge customs declaration
Green/Yellow/Red channels may query value, HS, fat %, sugar, packing, certificate, C/O, label and temperature.
Clear, deliver and archive records
Move cargo to proper warehouse and retain batch dossier, quarantine/food safety results, COA, C/O and transport documents.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA prevention | Documents to check |
|---|---|---|---|
| Generic goods name | Wrong HS, quarantine and explanation | State product form, fat %, sugar, packing and use | Invoice, COA, specification, label |
| Missing/incorrect Health/Veterinary Certificate | Quarantine hold and clearance delay | Check certificate draft before shipment | Draft certificate, invoice, packing, COA |
| Confusing skimmed, whole milk powder and whey | Wrong duty, C/O and testing | Map form – fat % – HS – duty – C/O | COA, nutrition facts, HS analysis |
| Cold-chain/shelf-life not controlled | Quality loss and claims | Lock cold-chain booking and temperature monitoring | Booking note, label, COA, temperature record |
| C/O with wrong HS/description | FTA preference denied | Check draft C/O after final HS | C/O, invoice, B/L/AWB |
FAQ
| Question | Short answer |
|---|---|
| Does importing dairy raw material require a permit? | Do not treat it as a generic permit; key controls are quarantine, food safety if applicable, declaration/labeling and customs documents. |
| Is dairy raw material subject to quarantine? | Highly likely if it is listed terrestrial animal product; review final HS and dossier. |
| Which HS code for dairy powder raw material? | Usually heading 0402; skimmed milk powder may be 0402.10.41 and whole milk powder may be 0402.21.20 if conditions match. |
| Can whey use the same HS as milk powder? | No. Whey is generally reviewed under heading 0404, not automatically under 0402. |
| Is Vietnamese supplementary label required? | Yes if circulated in Vietnam; internal manufacturing still needs original label and traceability control. |
| Can C/O reduce duty? | Potentially, if C/O form, HS, description, origin criteria and direct transport are compliant. |
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.
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