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IMPORT PROCEDURE GUIDE FOR STARCH
Starch may look simple, but a wrong distinction between native starch, modified starch, dextrin, maltodextrin or blended starch preparations may lead to incorrect HS classification, duty exposure, food compliance gaps and customs clarification. This guide provides an E2E (End-to-End) review map before ETA: product scope, HS code, duties, C/O, food safety dossier, labeling and customs decision points. For the product covered in this article, the importer should confirm the model, intended use, construction or composition, new/used condition, and technical documents before concluding the HS code, tax treatment, or specialist policy. The following sections organize the main controls from document receipt, catalogue and label review through dossier preparation, declaration, and coordination at the port of entry.
SCOPE OF APPLICATION
Included
- Wheat starch.
- Corn/maize starch.
- Potato starch.
- Tapioca/cassava starch.
- Sago or other plant starch.
Not automatically included
- Modified starch, usually requiring HS 3505 review.
- Dextrin, maltodextrin, glucose syrup or hydrolyzed starch products.
- Flour, premix, baking mix and blended baking ingredients.
- Samples, trial goods or non-food industrial goods may require different dossiers.
| Quick review item | Application to starch | Operational note |
|---|---|---|
| Product name | Native, unmodified starch in powder or fine granular form | The botanical source must be stated: wheat, corn/maize, potato, tapioca/cassava, sago or other starch. |
| Reference HS group | HS 1108 – starches; inulin | Do not use this group automatically for modified starch, dextrin, maltodextrin, glucose syrup or blended preparations. |
| Indicative MFN import duty | 15% or 20% depending on the 8-digit HS subheading | Final duty depends on HS, origin and the tariff schedule in force on the declaration date. |
| Import VAT | Usually reviewed under the 10% category; check 8% only if the VAT reduction policy is valid and applicable | Do not state a fixed VAT rate without checking the current VAT reduction policy. |
| Food safety policy | Self-declaration may apply if imported as food or food ingredient | If imported for non-food industrial use, purpose and technical dossier must be separated clearly. |
| Labeling | Original label and Vietnamese supplementary label should be reviewed before circulation | Product name, ingredients, quantity, MFG/EXP, origin and responsible party must be consistent. |
Legal note: this article applies only to native, unmodified starch. It does not automatically apply to modified starch, dextrin, maltodextrin, glucose syrup, blended flour, premix or baking mix. Review the actual specification, COA, original label, ingredients and import purpose.
PRODUCT CLASSIFICATION & IDENTIFICATION
The key classification question is whether the product is a native starch, whether it is modified or blended, and whether it is imported for food or non-food use.
| Criteria to check | Documents to compare | Risk if misdescribed | Suggested declaration wording |
|---|---|---|---|
| Starch source | Specification, COA, original label | Wrong subheading under 1108 | “Native tapioca starch, food grade, powder, 25 kg/bag, new 100%”. |
| Modification status | COA, SDS, production description | Confusion between 1108 and 3505 | State “native/unmodified starch” where accurate. |
| Ingredients/blending | Ingredient list, label, specification | Blended goods may fall under another heading | Do not declare simply as starch if mixed with additives. |
| Use purpose | Contract, PO, purpose letter | Wrong food safety or labeling treatment | State “for food manufacturing” or “for industrial use” as applicable. |
| Packaging and label | Packaging photos, label artwork, packing list | Quantity/origin/EXP mismatch | Align kg, bag count, net/gross weight across documents. |
HS CODE – DUTY – C/O
HS Code must be determined by botanical source and unmodified status. Do not use one HS code for flour, starch, premix and baking mix.
| Reference HS | Description | Indicative MFN duty | Indicative ordinary duty | VAT review | Documents to check |
|---|---|---|---|---|---|
| 1108.11.00 | Wheat starch | 15% | 22.5% | 10% or reduction if applicable | COA, specification, label, invoice, packing list. |
| 1108.12.00 | Corn/maize starch | 15% | 22.5% | 10% or reduction if applicable | COA, specification, label, ingredient list. |
| 1108.13.00 | Potato starch | 20% | 30% | 10% or reduction if applicable | COA, specification, origin, C/O if any. |
| 1108.14.00 | Tapioca/cassava starch | 20% | 30% | 10% or reduction if applicable | COA, specification, original label, packaging photos. |
| 1108.19.10 / 1108.19.90 | Sago starch or other starches | 20% | 30% | 10% or reduction if applicable | Evidence of source and product nature. |
| Tax/C/O item | Correct approach | Risk to control |
|---|---|---|
| MFN import duty | Apply only when conditions for preferential import duty are met | Wrong HS may trigger reassessment or duty recovery. |
| Ordinary duty | Check when preferential duty conditions are not met | Do not default to MFN without sufficient basis. |
| Import VAT | Check VAT Law, implementing decrees and effective VAT reduction policy | A fixed VAT assumption may be wrong. |
| Special preferential duty by C/O | May apply under an FTA if C/O is valid and consistent | Wrong form, origin criterion, HS or description may lead to rejection. |
| Non-native starch | Modified starch/dextrin/maltodextrin must be reclassified | Misusing 1108 may affect duty and compliance. |
SPECIALIZED POLICY MATRIX
| Goods situation | Possible policy | Documents to check | Authority/portal if identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Imported as food/food ingredient | Self-declaration, safety testing, food label review | Self-declaration, test report, original/supplementary labels, COA | Food safety authority depending on product and locality | Before circulation and preferably before ETA | Do not wait until the goods arrive to review labels. |
| Imported for non-food industrial use | Purpose review, commodity label, technical dossier | Contract, PO, purpose letter, SDS if any | Customs and relevant authority if triggered | Before customs declaration | Do not describe as food grade if industrial. |
| Modified/blended indication | Recheck HS and policy based on actual composition | COA, ingredient list, specification | Customs and relevant specialized agency | Before final invoice/packing list | May not be HS 1108. |
| Sample/trial goods | Review import purpose, quantity, value and label | Invoice, packing list, sample confirmation letter | Customs office | Before ETA | Samples are not automatically exempt from all dossiers. |
| Imported by EPE/FDI/factory | Review customs regime and dossier retention | Contract, PO, inventory documents | Customs managing office | Before declaration | Wrong customs regime may affect reporting. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document | Issuing body | Effective timing | Role | Key point | Review note |
|---|---|---|---|---|---|---|
| Law | Law on Food Safety No. 55/2010/QH12 | National Assembly | Baseline legal framework | Food and food ingredient management | Food safety, declaration, labeling, inspection | Apply if imported as food/food ingredient. |
| Decree | Decree 15/2018/ND-CP | Government | Effective from 02 Feb 2018 | Detailed food safety implementation | Self-declaration and imported food safety inspection | Check status before filing. |
| Resolution | Resolution 15/2026/NQ-CP | Government | Effective upon signing per published information | Suspends Decree 46/2026 and Resolution 66.13/2026 | Transition in food safety regulation | Recheck before submission. |
| Decree | Decree 26/2023/ND-CP | Government | Effective from 15 Jul 2023 | Import/export tariff schedule | Preferential import tariff by HS | Check HS 1108 and amendments. |
| Labeling | Decree 43/2017/ND-CP and Decree 111/2021/ND-CP | Government | Decree 111 effective from 15 Feb 2022 | Goods labeling and supplementary labels | Mandatory label information | Review product name, quantity, origin and shelf life. |
| VAT | Decree 181/2025/ND-CP and Decree 174/2025/ND-CP | Government | As stated in each document | VAT guidance and reduction policy | Tax rate and reduction conditions | Do not fix VAT without checking the declaration date. |
VIEW / DOWNLOAD ORIGINAL DOCUMENTS
Enterprises should cross-check the documents on official legal portals or authority websites before application.
CUSTOMS CLEARANCE DOSSIER
Commercial documents
- Commercial Invoice.
- Packing List.
- Bill of Lading/Air Waybill.
- Sales Contract/Purchase Order if any.
- C/O if claiming preferential duty.
- Specification, COA, ingredient list and original label.
Specialized dossier if applicable
- Product self-declaration for food use.
- Safety testing report.
- Vietnamese supplementary label.
- Purpose explanation for non-food use.
- SDS if required for industrial handling.
| Dossier group | Required document | Used for | Prepared by | Common mistake | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO | Declaration and value check | Importer, shipper, docs team | Generic “powder” description | Match product name, quantity, kg unit and origin. |
| Transport | B/L or AWB, arrival notice, pre-alert | Delivery order and cargo receipt | Forwarder/carrier | Wrong consignee or weight | Compare with packing list. |
| Technical | Specification, COA, ingredient list, label | HS, food safety, labeling | Manufacturer/shipper | No native/unmodified status | Request lot-based or official documents. |
| Origin | C/O if claiming preference | Special preferential duty | Exporter/shipper | Wrong form/criterion/description | Check draft C/O before ETA. |
| Food/label | Self-declaration, test report, supplementary label | Market circulation and inspection | Importer/compliance | Missing indicators or wrong product name | Review before arrival. |
CUSTOMS DECISION POINTS
| Decision point | Question | Evidence | Consequence if unclear | Recommended action |
|---|---|---|---|---|
| HS basis | Native starch or modified/blended product? | COA, specification, ingredient list | Reclassification or duty challenge | Lock HS before final documents. |
| Use purpose | Food ingredient or industrial use? | PO, contract, purpose letter | Wrong specialized policy | State purpose consistently. |
| C/O usability | Is form, origin criterion, HS and description consistent? | C/O, invoice, B/L, packing list | Preference rejection | Check C/O draft early. |
| Label readiness | Are product name, quantity, origin and shelf life clear? | Original label, supplementary label | Circulation issue | Prepare label before market release. |
| Food safety dossier | Is self-declaration/testing required? | Test report, self-declaration | Delayed circulation | Review regulations before ETA. |
PRE-ETA RISK CHECKLIST
Generic goods name
Control through COA/specification.
Control through COA/specification.
Confusion with modified starch
Confirm native/unmodified status.
Confirm native/unmodified status.
C/O mismatch
Review draft C/O before arrival.
Review draft C/O before arrival.
Food safety dossier gap
Review food use and declaration plan.
Review food use and declaration plan.
Label data missing
Approve original and supplementary labels.
Approve original and supplementary labels.
Wrong customs regime
Confirm trading, manufacturing, EPE/FDI or sample use.
Confirm trading, manufacturing, EPE/FDI or sample use.
FAQ
| Question | Answer |
|---|---|
| Does starch import require a permit? | Do not conclude absolutely. Review use purpose, ingredients, label and food policy at the time of import. |
| Is product self-declaration required? | If imported as food or food ingredient for circulation, self-declaration should be reviewed under food safety rules. |
| Can modified starch use HS 1108? | Not by default. Modified starch commonly requires review under another heading, often 3505 depending on actual nature. |
| What is the VAT rate? | Check VAT Law, implementing decrees and the reduction policy in force on the declaration date. |
| Can C/O reduce duty? | Possibly, if the C/O is valid under the relevant FTA and matches HS, description and origin criteria. |
| What if invoice says “powder” but COA says “tapioca starch”? | Align documents before customs declaration to avoid HS/name challenges. |
STARCH IMPORT PROCEDURE
| Step | Action | Expected result |
|---|---|---|
| Step 1 – Pre-ETA review | Confirm HS, import purpose, food policy, VAT, C/O, label and specialized dossier. | A clear checklist before arrival. |
| Step 2 – Lock documents | Compare invoice, packing list, B/L/AWB, COA, specification, label and C/O. | Consistent product name, quantity, origin, weight and technical description. |
| Step 3 – Prepare food/label dossier if applicable | Self-declaration, testing, supplementary label or purpose explanation. | No passive response after arrival. |
| Step 4 – Customs declaration | Declare HS, value, origin, C/O and goods description; handle Green/Yellow/Red channel if any. | A file with sufficient basis. |
| Step 5 – Clearance and post-clearance | Receive goods, label if applicable, keep shipment dossier and prepare for post-clearance review. | Controlled compliance file. |
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