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. |
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. |
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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