Tiếng Việt
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IMPORT PROCEDURE GUIDE FOR SCRUBBING TOOLS
Scrubbing tools may look simple, but an unclear description between scrubbing brushes, plastic scouring tools, steel wool/pot scourers and cleaning cloths can lead to wrong HS classification, wrong duty, label inconsistency and customs queries. Any mismatch in catalogue, material or function may cause document inspection, loss of C/O preferential duty, DEM/DET exposure and delivery delay. This guide provides an E2E (End-to-End) operational map for pre-ETA review: HS Code, duties, specialized policy, customs dossier, labelling and key risks.
QUICK FACT TABLE
| Checkpoint | Quick review content |
|---|---|
| Product scope | Non-electric scrubbing tools: scrubbing brushes, bottle/dish/sink/toilet cleaning tools, hand scrubbers, scrub pads with holder and ordinary household cleaning sets. |
| Not automatically covered | Brooms, mops, cleaning cloths, glass wipers, powered scrubbers, chemical-impregnated or disinfecting goods, medical cleaning devices or goods with special claims. |
| Main HS codes | 9603.90.40 for brush-type scrubbers; 9603.90.90 for other goods under heading 96.03. Depending on actual material and structure, review 3924.90.90 or 7323.10.00. |
| Reference duties | For 9603.90.40/9603.90.90: MFN 25%, ordinary duty 37.5%, FTA preferential duty may be 0% if a valid C/O is available. VAT should be reviewed at 8%/10%. |
| Specialized policy | Normally handled under standard customs and labelling requirements. Do not conclude “no permit required” without checking material, claims, new/used condition and import purpose. |
| Pre-ETA lock points | Product name, material, cleaning function, presence of bristles, metal component, chemical/disinfecting claim, original label, C/O and product images must be consistent. |
SCOPE OF APPLICATION
Applicable to
- Scrubbing tools for household, restaurant, hotel, office or general cleaning use.
- Non-electric goods without motor, Wi-Fi/Bluetooth module, rechargeable battery or electronic controller.
- Hand scrubbers, cleaning brushes, bottle brushes, toilet brushes, scrub pads with holder and multi-piece scrubbing sets.
- Brand-new goods imported for trading, retail supply or internal operation.
Not automatically applicable to
- Cleaning cloths or textile wipes, which may fall under Chapter 63.
- Steel wool/pot scourers, which may fall under 7323.10.00.
- Chemical-impregnated, detergent or disinfecting products.
- Medical cleaning devices, specialized equipment-cleaning tools or machine parts.
- Used consumer goods, which require separate review under prohibited/restricted import lists.
Review must be based on catalogue, datasheet, product images, material, model and actual import purpose. Do not group all household cleaning goods under one HS code.
CLASSIFICATION & TECHNICAL IDENTIFICATION
Scrubbing tools should be identified by actual structure: whether they have bristles, the main material, whether they have a handle, whether they clean ordinary surfaces or bottles/equipment, and whether they are impregnated with chemicals. Commercial descriptions such as “scrubber”, “cleaning brush”, “dish brush”, “scouring pad” or “bottle brush” are not sufficient to lock HS classification.
| Technical checkpoint | Documents to compare | Risk if described incorrectly | Suggested goods description |
|---|---|---|---|
| Main function | Catalogue, product image, package description | Generic “cleaning tools” may trigger HS queries | Non-electric hand scrubbing tool for household use |
| Bristles/brush structure | Close-up photo, material list, packing specification | Misclassification between 9603.90.40 and 9603.90.90 | Plastic scrubbing brush with nylon bristles, non-electric |
| Main material | Datasheet, BOM, original label | Possible shift to Chapter 39, 63 or 73 | Clearly state PP/PE plastic, nylon fiber, stainless steel, textile if applicable |
| Chemical/disinfecting claim | Label, SDS/MSDS if any, product claim | May trigger additional chemical or disinfecting policy | State “not impregnated with chemicals” only if supported by documents |
| Goods condition | Invoice, contract, product images | Used consumer goods may be restricted/prohibited | Brand new 100%, with brand/model and packing specification |
| Labelling | Original label, Vietnamese sub-label artwork, packing list | Missing origin/responsible party may create circulation risk | Prepare Vietnamese sub-label before domestic distribution |
HS CODE – DUTY – C/O
For non-electric scrubbing tools, heading 96.03 is the first review point. If the goods do not have the nature of brooms/brushes/scrubbing tools under heading 96.03, classification may shift based on the dominant material such as plastic, iron/steel or textile.
| Reference HS code | Application condition | Risk if misclassified | Documents to review |
|---|---|---|---|
| 9603.90.40 | Other brushes/scrubbing brushes with bristles for surface cleaning | Wrong shift to 3924 or 9603.90.90 | Product images, bristle structure, catalogue, packing specification |
| 9603.90.90 | Other scrubbing/cleaning tools under heading 96.03 | Customs query if description is too generic | Catalogue, image, invoice description, label sample |
| 3924.90.90 | Plastic household/sanitary article, not a brush/scrubbing tool of heading 96.03 | Wrong if the actual product has brush nature | Material list, structure, image and use |
| 7323.10.00 | Iron/steel wool, pot scourers, scouring/polishing pads of iron or steel | Wrong duty/VAT and wrong material declaration | Material proof, close-up image, original label |
| 6307.10.xx | Only for textile cleaning cloths/wipes, not hand scrubbing tools | Not suitable for brush/scrubber goods | Image, textile material and packing specification |
Reference duty table
| HS code | Reference description | MFN | Ordinary duty | VAT | FTA preferential duty with valid C/O |
|---|---|---|---|---|---|
| 9603.90.40 | Other brushes | 25% | 37.5% | 8%/10% | May be 0% under eligible FTA |
| 9603.90.90 | Other goods under heading 96.03 | 25% | 37.5% | 8%/10% | May be 0% if origin rule is met |
| 3924.90.90 | Other plastic household/sanitary articles | 22% | 33% | 8%/10% | Many FTAs may be 0% |
| 7323.10.00 | Iron/steel wool or scouring pads | 25% | 37.5% | 8%/10% | Many FTAs may be 0% |
APPLICABLE SPECIALIZED POLICY MATRIX
| Goods scenario | Potential policy | Documents to review | Authority/portal if identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Brand-new, non-electric scrubbing tool, not chemical-impregnated | Standard customs procedure and labelling review | Invoice, Packing List, B/L/AWB, catalogue, original label, C/O | Customs; VNACCS/VCIS | Before ETA | Do not conclude no permit is needed without actual catalogue/label. |
| Plastic article without brush nature | Review possible classification under 3924 | Material list, image, catalogue | Customs | Before HS finalization | Do not force heading 96.03 based on trade name only. |
| Steel wool or metal scourer | Review 7323.10.00 and VAT exclusion appendix if relevant | Material composition, close-up image, technical note | Customs | Before declaration | Metal goods may affect VAT reduction assessment. |
| Chemical/disinfecting claim | Additional chemical/disinfecting policy may apply | SDS/MSDS, label claim, composition | Relevant specialized authority depending on product nature | Before booking | Not treated as ordinary scrubbing tools. |
| Powered, battery or electronic goods | Shift to electrical/electronic equipment policy | Datasheet, electrical specification, battery/charger file | Relevant specialized authority | Before booking | Not covered by this non-electric product guide. |
| Used goods | Review used consumer goods import restrictions/prohibitions | Invoice, photos, condition confirmation | MOIT/Customs where applicable | Before purchase | May be refused import clearance. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document name/number | Issuing authority | Effective date/timing | Role in procedure | Key article/appendix | Review note |
|---|---|---|---|---|---|---|
| Law | Customs Law 2014 | National Assembly | Currently applicable; review amendments if any | Basis for customs procedures and supervision | General declaration and inspection rules | Apply by import regime. |
| Decree | Decree 69/2018/ND-CP | Government | 15/05/2018 | Foreign trade management framework | Lists of restricted/conditional goods | Important for used or special-claim goods. |
| Customs circular | Circular 38/2015/TT-BTC, amended by 39/2018/TT-BTC | Ministry of Finance | Circular 39 effective 05/06/2018 | Customs dossier and tax management | Article 16 as amended | Compare commercial and technical documents. |
| Labelling | Decree 43/2017/ND-CP, amended by 111/2021/ND-CP | Government | Decree 111 effective 15/02/2022 | Original label/Vietnamese sub-label requirements | Goods name, origin, responsible party | Review before domestic circulation. |
| Tariff | Decree 26/2023/ND-CP and amendments if any | Government | From 15/07/2023 | MFN import duty tariff | Headings 96.03, 39.24, 73.23 | Check on declaration date. |
| Ordinary duty | Decision 15/2023/QD-TTg | Prime Minister | 15/07/2023 | Ordinary import duty if MFN/FTA not available | 150% rule if not specifically listed | Use only where relevant. |
| VAT | Resolution 204/2025/QH15; Decree 174/2025/ND-CP | National Assembly; Government | 01/07/2025–31/12/2026 | VAT reduction assessment | Appendices of non-reduced goods/services | Plastic/metal goods should be checked carefully. |
| Used goods | Circular 12/2018/TT-BCT, amended by Circular 08/2023/TT-BCT | Ministry of Industry and Trade | Circular 08 effective 16/05/2023 | Review of used consumer goods, medical equipment and vehicles banned from import | Appendix I issued with Circular 08/2023/TT-BCT | Only when goods are used; verify against the actual HS code. |
VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS
Companies may search legal documents by number on the Government portal or the issuing authority’s website. Companies should also verify the documents on official legal portals or the issuing authority’s website 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 preferential duty is claimed.
- Catalogue, product images, original label and material list.
Specialized documents if triggered
- SDS/MSDS if chemical/disinfecting claim exists.
- Evidence of brand-new condition.
- Vietnamese sub-label file.
- Test report/material certificate if requested.
- HS classification support if several materials or product lines are included.
OPERATIONAL DOSSIER CHECKLIST
| Dossier group | Required document | Used for | Common owner | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO | Declaration and value review | Importer, seller, Docs | Generic “cleaning tools” | Split by model/material/function. |
| Transport | B/L or AWB, Arrival Notice | D/O and manifest check | Forwarder, carrier | Wrong package/weight/consignee | Compare with Packing List before ETA. |
| Technical | Catalogue, image, material list | HS and policy review | Supplier, Procurement | No material or bristle information | Request close-up images and material statement. |
| C/O | FTA origin certificate/document | Preferential duty | Supplier, Docs | Wrong description, quantity or HS | Check draft C/O before issuance. |
| Labelling | Original label, Vietnamese sub-label | Domestic circulation | Importer, Compliance | Missing origin or responsible party | Approve sub-label artwork before ETA. |
| Special claims | SDS/MSDS, claim file, test report if any | Specialized policy review | Supplier, Legal/Compliance | Unsupported “antibacterial/disinfecting” claim | Remove unsupported claim or shift to correct policy. |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Impact if unclear | Recommended action |
|---|---|---|---|---|
| HS basis | Is it heading 96.03, 39.24 or 73.23? | Catalogue, image, material list | HS consultation or query | Lock technical description before declaration. |
| Model/material consistency | Do invoice, packing, label and catalogue match? | Invoice, Packing List, label, catalogue | Yellow/red channel and additional documents | Line-by-line document check. |
| Chemical/disinfecting claim | Is it merely a tool or chemically impregnated? | Label, SDS/MSDS | Specialized policy shift | Review claim at purchase stage. |
| C/O validity | Do form, origin criterion, description, quantity and HS match? | C/O, invoice, B/L, catalogue | Loss of preferential duty | Check draft C/O before original issuance. |
| New or used | Is it used consumer goods? | Invoice, photos, condition confirmation | Possible import refusal | Import only brand-new goods for normal trading. |
| Vietnamese sub-label | Is mandatory labelling ready? | Original label, sub-label artwork | Domestic circulation risk | Approve sub-label before customs clearance. |
PRACTICAL E2E PROCESS
Pre-ETA review
Lock HS, duty, C/O, label, goods condition and any specialized policy signals.
Lock documents and technical file
Finalize invoice, packing list, B/L/AWB, catalogue, images and material list; split line items if multiple product types are shipped.
Specialized policy review if triggered
If claims, chemicals, medical use or used condition appear, conduct a separate legal review before arrival.
Customs declaration
Green channel may clear under system conditions; yellow channel checks documents; red channel checks documents and physical goods. HS, value, description, C/O and label are common query points.
Clearance, delivery and post-clearance file
Pay duties, pick up cargo, apply Vietnamese sub-label for domestic sale, archive shipment file and prepare post-clearance explanations if required.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA control | Documents to check |
|---|---|---|---|
| Generic goods name | Insufficient HS basis | Split by brush, plastic pad, steel wool, etc. | Invoice, catalogue, image |
| Wrong main material | Wrong HS and duty | Request material list/BOM | Material list, label, image |
| C/O mismatch | Loss of FTA preferential duty | Check draft C/O before ETA | C/O draft, invoice, B/L |
| Unsupported disinfecting claim | Additional policy or document request | Review label and SDS/MSDS | Label, SDS/MSDS, test report |
| Used goods | Possible import refusal | Confirm brand-new condition | Contract, invoice, packing photos |
| Late sub-label preparation | Delay in market circulation | Approve sub-label before ETA | Original label and sub-label artwork |
FAQ
Do scrubbing tools require an import permit?
For brand-new, non-electric, non-chemical tools, they are normally handled under standard customs procedure. Review actual product documents before concluding.
Which HS codes are common?
Common review codes are 9603.90.40 and 9603.90.90; plastic-only or steel scourers may shift to 3924.90.90 or 7323.10.00.
Is import duty high?
Heading 96.03 generally has MFN 25% and ordinary duty 37.5%. A valid FTA C/O may reduce duty to 0%.
Is Vietnamese labelling required?
Yes, when the goods are circulated in Viet Nam. The label should show the goods name, origin, responsible party and other mandatory information where applicable.
Are disinfecting or chemical-impregnated items handled the same?
No. SDS/MSDS, label claims, composition and specialized policy must be reviewed before booking.
What if invoice model differs from catalogue?
Ask the supplier to correct or explain before ETA. Do not declare if model, description, image and label do not match.
RELATED ARTICLES
IMPLEMENTATION SOLUTION FROM TGIMEX
This article provides an operating map for HS, duties, documents and specialized policy for scrubbing tools. In actual shipments, companies should still verify catalogue, product images, materials, documents, origin and import purpose.
Pre-ETA review
HS, duties, C/O, label, material and policy triggers.
Compliance dossier control
Invoice, Packing List, B/L/AWB, C/O, catalogue, label and image matching.
E2E customs operation
International freight, pre-alert, customs declaration, channel handling and inland delivery.
For shipments with potential C/O, labelling or specialized policy risks, companies should not wait until cargo arrival to review documents. Minor inconsistencies may cause document requests, clearance delay or additional storage costs.
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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