Import procedures for filling lines

IMPORT-EXPORT PROCEDURES BY PRODUCT · MACHINERY

IMPORT PROCEDURES FOR FILLING LINES

Filling lines are often delayed not merely because of cargo size, but because the goods are described too broadly as “production line” or “filling machine”, while the actual shipment may include tanks, pumps, dosing units, fillers, cappers, sealers, labelers, conveyors, electrical cabinets and PLC/HMI control systems. If the HS code is incorrectly selected between 8422.30.00, 8422.40.00, 8423, 8413 or spare parts, the shipment may face additional explanation, channel inspection, loss of C/O preference and DEM/DET exposure. This article provides an E2E map to review HS code, duties, C/O, used machinery policy, customs dossier and pre-ETA risk controls.

QUICK FACTS

Review item Practical checkpoint
Product Filling line used to fill, close, cap, seal, label or integrate related operations for bottles, cans, boxes, bags, tubes, jars or similar containers.
Main reference HS 8422.30.00 – machinery for filling, closing, capping, sealing or labelling bottles, cans, boxes, bags or other containers; machinery for capsuling bottles, jars, tubes and similar containers; machinery for aerating beverages.
Commonly confused HS 8422.40.00 for other packing/wrapping machinery; 8423 for independent weighing/dosing equipment; 8413 for standalone pumps; 8422.90.90 for parts of heading 8422.
MFN import duty Reference from Vietnam Trade Portal: 0% for 8422.30.00; verify at declaration date.
Ordinary import duty Reference under Decision 15/2023/QD-TTg: 5% for 8422.30.00 if MFN/FTA treatment is not available.
Import VAT Reference from Vietnam Trade Portal: 10% for 8422.30.00; verify the tax policy at declaration date.
C/O/FTA If a valid C/O is available, the applicable rate may be 0% depending on the FTA. Where MFN is already 0%, C/O normally does not further reduce import duty but remains useful for origin control.
Specialized policy A standard new line is usually handled under customs, tax, label and origin control. Used machines or used production lines must be reviewed under Decision 18/2019/QD-TTg and Decision 28/2022/QD-TTg. Pressure tanks, laser modules, weighing devices, wireless devices or other special modules require separate review.
Legal note: This article applies only to filling lines. It must not be automatically applied to processing lines, packaging lines, integrated production lines, standalone fillers, tanks, standalone pumps, standalone scales or conditional special-purpose systems. Review based on catalogue, datasheet, line layout, model, new/used status and actual import purpose.

SCOPE OF APPLICATION

This article applies to a filling line, meaning an integrated system arranged to fill products into bottles, jars, cans, bags, tubes, boxes or similar containers. A line often includes a filler, capper, sealer, labeler, conveyor, rotary table, cap feeder, sensors, electrical cabinet and PLC/HMI controller.

The line may be used for beverages, liquid or semi-liquid foods, cosmetics, household chemicals, pharmaceuticals, industrial liquids or other products. Import policy must not be concluded from the commercial name alone. It depends on principal function, equipment composition, new/used status, industry of use and technical documents.

If the line includes pressure tanks, heating systems, laser marking units, inspection cameras, dosing scales, robots, wireless modules, batteries/adapters, control software, safety devices or separately imported accessories, each component must be reviewed separately.

CLASSIFICATION & TECHNICAL IDENTIFICATION

Principal function

Identify whether the line mainly fills and closes/caps/seals/labels containers or performs other packing/wrapping operations. The principal function determines HS direction.

Line configuration

Check line layout, equipment list, model of each machine, main machine, conveyors, electrical cabinet, pumps, tanks, dosing system, CIP, sensors and accessories.

Product to be filled

Liquid, paste, powder, granules, cosmetics, foods, chemicals or pharmaceuticals may affect configuration, product-contact materials and technical explanation.

New/used status

New and used machinery are handled differently. Used lines need year of manufacture, operating status, inspection certificate and supporting records.

Technical criterion Document to check Risk if misdescribed Suggested goods description
Principal function Catalogue, datasheet, line layout, operating video Wrong HS between 8422.30, 8422.40, 8423, 8413 or parts Filling and capping/sealing/labeling line for bottles/jars…, model…, capacity…, new/used
Equipment composition Detailed packing list, equipment list, BOM Customs may request separate classification for machines or parts State the main machine and integrated modules forming one line
Container/product Container sample, catalogue, filling parameters Wrong description as packing machine instead of filling line Filling line for … into bottles/jars/cans/bags/tubes …
Dosing mechanism Piston pump, flowmeter, scale, servo and sensor specifications Independent scales may require separate HS/measurement review State whether the dosing unit is part of the line or standalone
New/used status Invoice, contract, certificate, nameplate images, inspection report Unable to prove age criteria or used-line requirements Used filling line, year…, operating status… if applicable
Accessories/spares Parts list, spare parts list, packing list Incorrect HS for nozzles, pumps, sensors, electrical parts Separate standalone spares when not imported as line components

Generic descriptions such as “filling line”, “production line” or “packing machine” may lead to HS errors, used-machinery policy errors, labeling issues and misclassification of accessories.

HS CODE – DUTIES – C/O

HS classification should be based on principal function, degree of integration and whether the modules are imported as one functional unit or as separate machines/parts.

Reference HS Conditions for application Risk of wrong application Documents to check
8422.30.00 Principal function is filling, closing, capping, sealing or labelling containers; includes beverage aerating machines. May be reclassified if the line only performs other packing/wrapping or consists of standalone machines. Catalogue, datasheet, line layout, equipment list, operating video, invoice, packing list.
8422.40.00 Other packing/wrapping machinery, including shrink-wrapping machines, where principal function is not filling/capping/sealing/labeling containers. Using 8422.30 for pure packaging may trigger HS explanation. Catalogue, process description, photos of output product.
8423.x Scales or weighing/dosing machines imported independently with weighing function. Standalone scale may be separated from 8422 classification. Scale datasheet, integration diagram.
8413.x Standalone liquid pumps not integrated as filling-line components. Standalone pumps may be reclassified. Pump datasheet, parts list.
8422.90.90 Parts of machinery under heading 8422. Declaring parts as complete machinery or vice versa causes tax and dossier errors. Parts list, BOM, invoice.
Tax item Reference rate Application conditions Risk note
Ordinary import duty 5% When MFN/FTA is not available; verify current tariff schedule. Do not use before HS is confirmed.
MFN import duty 0% for 8422.30.00 based on Vietnam Trade Portal reference. Applies under current MFN tariff if eligible. Recheck if final HS is not 8422.30.00.
Import VAT 10% for 8422.30.00 based on Vietnam Trade Portal reference. Generally applicable to machinery unless otherwise provided. Do not assume for different modules.
FTA/C/O preferential duty May be 0% or under the relevant FTA schedule if C/O is valid. C/O form, origin criterion, goods description, HS and transport route must match. If MFN is already 0%, C/O may not reduce duty further.
Other taxes/measures Not separately determined for a standard filling line. May arise if the line includes pressure equipment, laser, measuring devices, wireless modules or special safety devices. Review by model and configuration.
Control point: For a complete line, prepare documents proving integration and principal function. If the invoice/packing list shows many separate machines without layout or equipment list, customs may request separate classification.

APPLICABLE SPECIALIZED POLICIES

Goods situation Possible policy Documents to check Handling authority / portal Recommended timing Risk note
New standard filling line Standard customs, duty, label and C/O review. Invoice, packing list, B/L/AWB, catalogue, datasheet, line layout. Customs authority at declaration. Before booking and ETA. Do not conclude no policy before reviewing actual configuration.
Used/refurbished filling line Decision 18/2019/QD-TTg and Decision 28/2022/QD-TTg on used machinery and used technological lines. Year of manufacture, operating status, inspection certificate, standards, project file if applicable. Ministry of Science and Technology / designated inspection body; customs dossier. Before shipment leaves export port. Missing or incomplete inspection certificate may block clearance.
Line with pressure tanks/heating/pneumatics May trigger occupational safety or technical safety inspection before operation. Pressure, volume, medium, technical drawings. Relevant safety inspection body. Before import and installation. Depends on actual pressure, volume and medium.
Line with weighing/dosing device May trigger metrology control if used for trading/settlement or covered by regulated measuring instruments. Scale datasheet, certificate, use purpose. Metrology authority/inspection body if applicable. Before operation. Not every loadcell inside a line is regulated the same way.
Line with laser, camera, electronics, wireless module Review ICT, civil cryptography, radio frequency, electrical safety or other policy if special functions exist. Module datasheets, manuals, model list. Relevant specialized authority if triggered. Before final documents. Auxiliary modules may affect shipment policy.
Line for foods/cosmetics/pharmaceuticals The machine import procedure is separate from product/factory compliance; product-contact materials and GMP/HACCP/ISO may matter for operation. Product-contact materials, standards, use purpose, project contract. Relevant product/factory authority if applicable after import. Before commissioning. Machine import does not replace product circulation procedures.
EPE/FDI/factory import Import type, fixed asset management, tax exemption/refund and project goods controls. Contract, invoice, packing list, machinery list, investment documents if any. Customs, tax and investment authority as applicable. Before declaration. Wrong import type affects tax and post-clearance audit.

LEGAL DOCUMENTS TO REVIEW

Document group Document name/number Issuing body Effective/application timing Role in procedure Key provisions/annexes Review note
Law Customs Law 54/2014/QH13 and amendments if any National Assembly Current effect Customs declaration, inspection and supervision basis. Customs dossier, declaration and post-clearance audit provisions. Check consolidated/current version at declaration time.
Decree Decree 08/2015/ND-CP, Decree 59/2018/ND-CP, Decree 167/2025/ND-CP Government Decree 167/2025/ND-CP takes effect from 15/08/2025 Detailed customs procedures, inspection and supervision. Relevant amended provisions. Verify current rules when declaring.
Decree Decree 69/2018/ND-CP Government Current effect Foreign trade management, prohibited/restricted goods and specialized management. Relevant lists if special goods appear. Do not conclude without checking special modules.
Decision Decision 18/2019/QD-TTg Prime Minister Effective from 15/06/2019 Import of used machinery, equipment and technological lines. Articles 1, 3, 4, 5, 6, 10, 14, 15. Applies to used machines/lines for production in Vietnam.
Decision Decision 28/2022/QD-TTg Prime Minister Effective from 01/03/2023 Amends Decision 18/2019/QD-TTg. Amended dossier/procedure content for certain used technological lines. Important for used line projects.
Decree Decree 43/2017/ND-CP and Decree 111/2021/ND-CP Government Current effect Goods labeling, Vietnamese supplementary labels. Mandatory label contents, original label and supplementary label. Machinery should show appropriate technical parameters.
Tariff Decree 26/2023/ND-CP and Decision 15/2023/QD-TTg Government / Prime Minister Current tariff schedule MFN and ordinary duty review. HS 8422.30.00 and alternatives. Do not apply rates before HS is confirmed.
Specialized documents Metrology, occupational safety, ICT or pressure-equipment regulations if the actual modules fall under specialized management Relevant specialized authorities Review based on actual dossier Applies when the filling line includes weighing units, pressure tanks, lasers, wireless devices, special electrical equipment or other controlled modules. Relevant specialized list if triggered by model/function. No legal conclusion should be made before checking model, specifications and intended use.

VIEW / DOWNLOAD ORIGINAL DOCUMENTS

Enterprises may search documents by number on the legal document portal, Government portal or the issuing authority website. Enterprises should cross-check official sources before application.

CUSTOMS CLEARANCE DOSSIER

Commercial documents

  • Commercial Invoice.
  • Packing List with detailed modules of the line.
  • Bill of Lading/Air Waybill.
  • Sales Contract/Purchase Order if available.
  • C/O if preferential treatment or origin proof is required.
  • Catalogue, datasheet, line layout, equipment list, BOM, model/serial list.
  • Photos, nameplate images and operating video if needed for explanation.

Specialized documents if triggered

  • Inspection certificate for used machinery/used technological lines.
  • Goods label and Vietnamese supplementary label documents.
  • Technical documents for pressure tanks, dosing scales, laser, wireless or special equipment if any.
  • Post-import inspection/conformity records if required before operation.
Dossier group Required document Used for Typical preparer Common error Pre-ETA check
Commercial Invoice, Packing List, Contract/PO Declaration, value review, goods matching Importer, seller, purchasing Generic goods name, missing model/module quantity Match name, model, serial, packages and weight.
Transport B/L or AWB, Arrival Notice, Pre-alert D/O, declaration, ETA control Forwarder, carrier, agent Wrong port/consignee or late documents Lock pre-alert before ETA.
Technical Catalogue, datasheet, layout, equipment list, operating video HS decision, functional explanation, policy check Supplier, engineering, compliance Cannot prove integrated line or principal function Request layout and equipment list before booking.
Origin C/O, invoice, direct transport records FTA claim/origin proof Exporter, importer, logistics Wrong form, description, HS or route Check C/O against invoice, HS and B/L.
Used line Inspection certificate, year, operating status, standards Used machinery policy Importer, inspection body, supplier Certificate incomplete or unsuitable Arrange inspection before shipment where required.
Label Original label, nameplate photos, draft supplementary label Physical inspection, circulation Importer, warehouse, compliance Label mismatch in model/origin/specs Review label before delivery to warehouse.

Matching rule: goods name, quantity, model, serial number, origin, year, capacity, voltage, line configuration and technical specifications must match across commercial documents, catalogue, label, specialized dossier and customs declaration.

CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point Question to answer Evidence Consequence if unclear Recommended action
HS basis Is the principal function filling/capping/sealing/labeling or other packing? Catalogue, datasheet, layout, video Reclassification, inspection, amendment Prepare functional HS analysis.
Line integration Is it an integrated line or separate machines/parts? Equipment list, BOM, detailed packing list Separate classification requested Prepare functional-unit explanation and layout.
New or used Is year, condition and inspection evidence available? Invoice, certificate, inspection report, nameplate Used machinery dossier may fail Review Decision 18/2019 and 28/2022 before shipment.
Special modules Are there pressure tanks, laser, scales, wireless, safety devices? Datasheet, user manual Late specialized policy issues Review each special module separately.
C/O validity Is form, origin criterion, description, HS and route correct? C/O, B/L, invoice, packing list No preferential treatment or verification Check C/O before declaration.
Label/model consistency Do invoice, packing list, catalogue and nameplate match? Nameplate photos, model list Inspection and delay Lock model list before final documents.

PRACTICAL E2E PROCESS

Step 1 · Pre-ETA review

Confirm principal function, HS, duties, C/O, new/used status, label, line configuration and special modules.

Step 2 · Lock documents and technical file

Finalize invoice, packing list, B/L/AWB, catalogue, datasheet, line layout, equipment list, model/serial list and nameplate photos.

Step 3 · Handle specialized policy if any

For used lines, prepare inspection dossier under Decision 18/2019 and 28/2022. For special modules, review safety/metrology/ICT policy before arrival.

Step 4 · Submit customs declaration

Declare correct goods name, HS, customs value, origin and model; prepare explanations for Yellow/Red channel.

Step 5 · Clearance, delivery and post-clearance file

Pay duties, take delivery, check supplementary label, keep the line dossier and inspection records for post-clearance audit.

PRE-ETA RISK CHECKLIST

Risk Consequence Pre-ETA control Documents to check
Generic “production line” description Insufficient HS basis and higher inspection risk Describe product, container and line operations clearly Catalogue, layout, invoice, packing list.
Wrong HS between 8422.30, 8422.40, 8423/8413 Wrong duty, amended declaration or query Analyze principal function and separate independent equipment if needed Datasheet, equipment list, BOM.
Used machinery not reviewed Missing inspection certificate or age criteria Confirm new/used status and require year/inspection evidence Invoice, certificate, nameplate, inspection report.
Wrong C/O form or description No preferential treatment or verification Check C/O before declaration C/O, B/L, invoice, packing list.
Model mismatch Inspection, explanation or document amendment Lock model/serial list before shipment Model list, nameplate photos, packing list.
No line layout/equipment list Cannot prove integration; separate HS risk Request layout with module numbers Layout, BOM, equipment list.
Special modules overlooked Late specialized policy issue Separate pressure tanks, scales, laser, wireless and safety devices for review Module datasheets, manuals.

FAQ – FREQUENTLY ASKED QUESTIONS

Question Short answer
Does importing a filling line require an import license? Do not conclude absolutely. A standard new line is usually reviewed under customs, tax, label and C/O controls; used lines or special modules require separate policy review.
What HS code is commonly used? The common reference is 8422.30.00 if the principal function is filling, closing, capping, sealing or labelling containers.
What are the import taxes? For 8422.30.00, reference MFN 0%, VAT 10%, ordinary duty 5%. Verify when final HS is confirmed.
Does C/O reduce duty? If MFN is already 0%, C/O usually does not further reduce import duty, but remains useful for origin management and post-clearance file.
Can used filling lines be imported? Possibly, but Decision 18/2019/QD-TTg and 28/2022/QD-TTg must be reviewed, especially year of manufacture and inspection certificate.
Is Vietnamese supplementary labeling required? If goods circulate in Vietnam, label requirements under Decree 43/2017 and 111/2021 must be reviewed.
One HS or several HS for multiple machines? It depends on integration and principal function. If not proven as one functional unit, separate classification may be required.
Are sample/warranty imports handled like business imports? Not automatically. Import type, purpose, value, condition and policy triggers must be reviewed.

RELATED ARTICLES

IMPLEMENTATION SOLUTION FROM TGIMEX

This article provides a map of HS code, duties, documents and specialized policies for filling lines. In practice, enterprises still need to review catalogue, datasheet, line layout, model, documents, origin, machine status and import purpose.

Pre-ETA review

Check HS, used-machinery policy, C/O, duty, label, catalogue/datasheet/layout/model.

Compliance dossier control

Match Invoice, Packing List, B/L/AWB, C/O, catalogue, equipment list, labels and technical documents.

International logistics coordination

Coordinate agents, carriers/airlines, ETA, pre-alert and container/OOG plan if the line is bulky.

Customs declaration

Prepare customs dossier, handle Green/Yellow/Red channel and support HS, value, origin and policy explanations.

Post-clearance file

Keep shipment file, supplementary label and inspection certificate if any for audit readiness.

For shipments with potential specialized policy, C/O or labeling requirements, enterprises should not wait until cargo arrival to review the dossier. Small discrepancies between Invoice, Packing List, catalogue, datasheet, C/O or labels may lead to document supplements, delayed clearance or unplanned storage costs.

TGIMEX supports enterprises in establishing an E2E import approach: pre-ETA policy review, document control, international freight coordination, customs declaration, clearance handling, domestic delivery and post-clearance file retention. This approach helps control schedule, cost and compliance risk from the preparation stage.

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