IMPORT PROCEDURE GUIDE FOR BODY LOTION
Body lotion is generally treated as a skincare cosmetic for the body, usually supplied as lotion, fluid cream, gel-lotion or body moisturiser. The key import risk is not the commercial name itself, but whether the product is truly a skin-care lotion, a cleansing preparation, a body sunscreen, a product with therapeutic claims, or a multi-SKU gift set.
If the Invoice and Packing List only state “cosmetic”, “skin care” or “body product”, while the original label, formula, claims and cosmetic notification show a different product nature, Customs and the competent authority may request additional cosmetic documents, HS classification explanation, C/O review, label correction or documentary inspection.
This article provides an E2E (End-to-End) checklist before ETA (Estimated Time of Arrival): HS code, duties, C/O, cosmetic notification, customs dossier, clearance decision points and risks to block before the shipment arrives.
QUICK FACTS
| Item | What to verify | Operational note |
|---|---|---|
| Product scope | Body lotion for body skincare, packed in bottles, tubes, jars, sachets or retail kits. | Not automatically applicable to body wash, scrub, medicated massage oil, topical medicine or products with treatment claims. |
| Main reference HS | 3304.99.30 – creams and lotions for the face or other skin. | Relevant when the product is a cosmetic skin-care preparation, not a medicine and not a cleansing preparation under another heading. |
| Additional HS to review | 3304.99.90 if 3304.99.30 is not supported; 3401.30.00 if the product is mainly a liquid/cream skin-washing preparation for retail sale. | Do not classify only by the trade name “body lotion”; review formula, label, main use and directions for use. |
| Reference duties | For 3304.99.30: MFN 18%, ordinary duty 27%, VAT 8% or 10%. | VAT 8% applies only if the shipment meets the VAT reduction policy and is not excluded on the declaration date. |
| Specialized policy | Imported cosmetics require a valid cosmetic product notification receipt number before market circulation. | Documents to control: notification form, letter of authorization, CFS if applicable, ingredient list, label, PIF and claims. |
| Category IDs | VI 3076 / EN 3102 / ZH 3104. | Product menu: cleansers, toners, serums, essences, creams, lotions, masks, makeup removers and body lotions. |
SCOPE OF APPLICATION
This article applies only to imported body lotion used externally for moisturising, softening and body skin care within cosmetic scope.
It does not automatically apply to cleansers, toners, serums, essences, creams, lotions, masks, makeup removers or body lotions with different formula, claims, purpose or notification dossier. Review catalogue, datasheet, label, formula, SKU, volume, origin and actual import purpose.
CLASSIFICATION & PRODUCT IDENTIFICATION
Product nature
Usually an emulsion with moisturisers, oils/butters, silicone, sensory polymers and preservatives.
Directions for use
External skin application. If the instruction says rinse off or wash skin, review heading 3401.
Claim control
Moisturising and skin-care claims are typical cosmetics claims; treatment or healing claims require review.
| Technical criterion | Document to compare | Risk if wrongly described | Suggested declaration description |
|---|---|---|---|
| Product form | Original label, photos and formula. | Generic “cosmetic” description may cause wrong HS or missing notification. | Body lotion, lotion form, for body skin care, volume…, brand…, SKU… |
| Main use | Claims, directions, website and leaflet. | Medical claims may exceed cosmetic scope. | State cosmetic skin-care purpose and avoid medical claims without basis. |
| Ingredients | Ingredient list, PIF and SDS if any. | Restricted ingredients or UV filters may need explanation. | Attach ingredient list and matching notification dossier. |
| Packing/SKU | Packing list, label and SKU list. | SKU/volume mismatch between notification and goods. | State volume, quantity, packing and SKU. |
HS CODE – DUTY – C/O
HS classification must be based on the product nature: formula, main use, directions, label, product form and notification dossier, not merely the trade name.
| Reference HS code | When applicable | Reference base tax | Risk if misclassified | Documents to compare |
|---|---|---|---|---|
| 3304.99.30 | Body lotion is a skin-care cream/lotion for body skin and is not a medicine. | MFN 18%; ordinary duty 27%; VAT 8% or 10%. | Wrong HS may affect duty, cosmetic notification, labeling and post-clearance records. | Formula, original label, claims, product image, cosmetic notification and C/O. |
| 3304.99.90 | Only review when 3304.99.30 is not sufficiently supported or the product is another skin-care preparation. | MFN 18%; ordinary duty 27%; VAT 8% or 10%, subject to verification. | Using “other” when 3304.99.30 is supported may trigger classification explanation. | Catalogue, ingredient list, label, main use and classification opinion if needed. |
| 3401.30.00 | Only when the product is mainly an organic surface-active skin-washing preparation in liquid/cream form for retail sale. | MFN 27%; ordinary duty 40.5%; VAT 8% or 10%. | Confusing body wash/cleansing lotion with body lotion may lead to wrong duty and dossier. | Directions for use, surfactant ingredients, wash/cleanser label and claims. |
Special preferential C/O/FTA table for HS 3304.99.30
| Origin/route | C/O form or origin proof | Special preferential duty reference | Conditions | Documents to check | Risk |
|---|---|---|---|---|---|
| ASEAN | Form D / ATIGA | Often 0%. | ATIGA origin criteria, direct transport, correct HS and product description. | Form D, Invoice, Packing List, B/L, HS and description. | Wrong origin criterion or description may lead to rejection. |
| China | Form E / ACFTA or RCEP | ACFTA often 0%; RCEP may be around 12% subject to schedule. | Choose the better agreement and satisfy its origin rules. | Form E or RCEP proof, third-party invoice if any, B/L. | Wrong form or direct transport issue may remove the benefit. |
| Korea | AKFTA / VKFTA / RCEP | VKFTA may be 0%; AKFTA around 5%; RCEP subject to schedule. | Use the agreement with the lowest valid duty if eligible. | AK/VK/RCEP C/O, WO/RVC/CTH/CTSH criterion, invoice and B/L. | Wrong agreement may increase duty or cause reassessment. |
| Japan | AJCEP / VJEPA / CPTPP / RCEP | AJCEP/VJEPA/CPTPP often 0%; RCEP subject to schedule. | Origin, origin criterion, transport and goods description must match. | C/O or origin proof, transport documents, invoice. | Incorrect form or HS may be rejected. |
| EU | EVFTA | May be around 5% or lower depending on schedule. | Valid EVFTA origin proof and origin rule compliance. | Origin proof, invoice, description, HS and country of origin. | Without valid proof, MFN 18% may apply. |
| UK | UKVFTA | May be around 5% or lower depending on schedule. | Apply UKVFTA origin documents, not EVFTA documents. | UKVFTA origin proof, invoice and B/L. | Using the wrong FTA document may lose the preference. |
| Australia/New Zealand | AANZFTA or CPTPP | Often 0%. | Meet origin and direct transport rules. | AANZ or CPTPP proof, invoice and B/L. | Origin or third-party invoicing mismatch. |
| India | AIFTA | May be around 5%. | Form AI and origin criterion must be valid. | Form AI, invoice, packing list and B/L. | Goods description mismatch may cause rejection. |
| United States/no FTA | No FTA preference with Vietnam | Usually MFN 18% if MFN conditions are met; otherwise ordinary duty 27% may be considered. | Check origin and MFN eligibility. | Invoice, packing list, B/L, origin documents if any. | No FTA basis for special preferential duty. |
C/O checklist
APPLICABLE SPECIALIZED POLICIES
| Goods scenario | Potential policy | Documents to check | Authority/portal | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Standard body lotion cosmetic | Cosmetic notification, labeling and customs import rules. | Notification, authorization, CFS if any, formula, label and commercial docs. | Provincial health authority/related system; Customs. | Before arrival and before circulation. | Do not wait until cargo arrival to check notification and labels. |
| Treatment/anti-inflammatory/healing claims | May exceed cosmetic scope; review case by case. | Label, brochure, website, active ingredients and claims. | Health/specialized authority. | Before purchase and label printing. | Wrong claim can make notification unsuitable. |
| SPF/PA body sunscreen function | May still be under heading 3304, but claims, UV filters and label must be checked. | Formula, SPF evidence if any, label and notification. | Health authority and Customs. | Before ETA and notification. | Do not group with ordinary moisturising lotion. |
| Samples/testers/gift sets | Policy depends on purpose, quantity and circulation. | Invoice, packing list, import purpose, sample label and SKU list. | Customs and specialized authority if needed. | Before declaration. | “Sample” wording does not automatically remove compliance requirements. |
| EPE/FDI/factory import | Review customs type, use purpose and market circulation. | Contract, PO, declaration type and internal documents. | Managing Customs branch. | Before declaration type is fixed. | Wrong purpose may create post-clearance risk. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document name/number | Issuer | Effective/applicable time | Role in procedure | Key articles/appendices | Review note |
|---|---|---|---|---|---|---|
| Circular | Circular 06/2011/TT-BYT on cosmetics management. | Ministry of Health | Effective from 01/04/2011. | Main basis for cosmetic notification, dossiers, labeling and circulation. | Cosmetic notification and Product Information File provisions. | Check amendments and supplements. |
| Amending circular | Circular 34/2025/TT-BYT amending Circular 06/2011/TT-BYT. | Ministry of Health | Issued 03/07/2025, effective 18/08/2025. | Updates cosmetic notification dossier requirements. | Amended provisions on notification dossier and receipt process. | Apply according to actual submission date. |
| Decree | Decree 43/2017/NĐ-CP on goods labeling. | Government | Effective from 01/06/2017. | Basis for imported goods labeling in Vietnam. | Mandatory contents, language and supplementary label. | Amended by Decree 111/2021/NĐ-CP. |
| Amending decree | Decree 111/2021/NĐ-CP. | Government | Effective from 15/02/2022. | Amends labeling requirements, especially for imported goods. | Mandatory original/supplementary label content and origin. | Review when original label lacks Vietnamese mandatory content. |
| Tariff | Current MFN and special preferential import tariff schedules. | Ministry of Finance/Government depending on schedule. | At customs declaration date. | Determines MFN, ordinary, FTA and VAT rates. | Chapter 33, heading 3304, code 3304.99.30. | Recheck on declaration date. |
| VAT | Decree 174/2025/NĐ-CP on VAT reduction. | Government | Effective 01/07/2025, applicable to 31/12/2026 unless changed. | Determines whether VAT 8% can apply instead of 10%. | Articles 1 and 2 and exclusion appendices. | Do not apply 8% automatically if excluded. |
VIEW / DOWNLOAD ORIGINAL LEGAL TEXTS
Businesses should cross-check legal texts on official legal portals or issuer 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 preferential duty is claimed.
Specialized documents
- Cosmetic notification receipt number.
- Authorization letter, CFS if applicable.
- Ingredient list, original label and draft supplementary label.
- PIF (Product Information File) for circulation records.
| Dossier group | Required documents | Used for | Usually prepared by | Common mistake | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial docs | Commercial Invoice, Packing List, Contract/PO. | Customs declaration, value and goods description. | Exporter, importer, purchasing. | Generic name, missing SKU/volume, wrong origin. | Compare with label, notification and packing list. |
| Transport docs | B/L or AWB, arrival notice and pre-alert. | Cargo release, manifest and declaration. | Forwarder/carrier. | Wrong consignee, package count or weight. | Compare with Invoice and Packing List before ETA. |
| C/O | Preferential C/O or origin proof if FTA is claimed. | Special preferential duty. | Shipper, exporter and importer. | Wrong form, criterion, description or third-party invoice. | Check form, HS, description, quantity, issue date and direct transport. |
| Cosmetic notification | Notification receipt number, authorization, CFS if applicable. | Market circulation and compliance proof. | Importer/RA, regulatory/legal team. | Imported SKU/formula/label does not match notification. | Compare product name, brand, form, ingredients and manufacturer. |
| Label and technical docs | Original label, draft Vietnamese supplementary label, ingredient list, artwork and claims. | Label review, product explanation and post-clearance file. | Brand owner, importer and regulatory team. | Overclaim, missing origin, volume or ingredient information. | Review against labeling rules and notification dossier. |
CLEARANCE DECISION POINTS
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended handling |
|---|---|---|---|---|
| HS Code | Is the body lotion under 3304.99.30, 3304.99.90 or 3401.30.00? | Label, formula, claims and catalogue. | HS explanation and duty impact. | Fix product nature before Invoice issuance. |
| Cosmetic notification | Is there a valid notification receipt for the SKU? | Notification, authorization and CFS if any. | Insufficient basis for market circulation. | Prepare notification before ETA. |
| Claims | Do claims exceed cosmetic scope? | Label, website, leaflet and formula. | Label/dossier correction or reclassification risk. | Control claims before label printing and import. |
| C/O | Is C/O valid for the chosen FTA? | C/O, B/L, Invoice and Packing List. | No special preferential duty. | Check C/O before original/electronic acceptance. |
| Label | Are original and supplementary labels compliant? | Label image, artwork and supplementary label. | Label supplement or circulation risk. | Review under Decree 43/2017 and 111/2021. |
PRACTICAL E2E PROCESS
Step 1: Pre-ETA review
Confirm HS, duty, C/O, cosmetic notification, labels, claims and declaration type.
Step 2: Lock documents
Finalize Invoice, Packing List, B/L/AWB, label, ingredient list, SKU list and notification file.
Step 3: Prepare specialized dossier
Review notification receipt, authorization, CFS if applicable, supplementary label and PIF.
Step 4: Customs declaration
Control green/yellow/red channel and prepare HS, value, origin, C/O and cosmetic explanations.
Step 5: Clearance and post-clearance
Release cargo, complete supplementary labels, archive lot dossier and prepare post-clearance file.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | How to block before ETA | Documents |
|---|---|---|---|
| Wrong HS between 3304 and 3401 | Wrong duty and specialized dossier. | Determine main function: skin care or cleansing. | Label, ingredient list, directions. |
| Notification missing or mismatched | No clear basis for circulation. | Compare imported SKU with notification receipt. | Notification, label and packing list. |
| Invalid C/O | Loss of special preferential duty. | Check C/O before arrival. | C/O, Invoice, B/L and origin rule. |
| Overclaiming | Label/dossier correction or reclassification risk. | Review claims before import. | Artwork, brochure and formula. |
| Incomplete supplementary label | Circulation/post-clearance risk. | Prepare supplementary label based on notification and label rules. | Original label, supplementary label and notification. |
FAQ
1. Does imported body lotion need cosmetic notification?
Yes, if it is circulated in Vietnam and falls within cosmetic scope.
2. What HS code is usually reviewed?
3304.99.30 is commonly reviewed, but final classification depends on product nature.
3. Is VAT 8% or 10%?
VAT may be 8% if eligible under the VAT reduction policy and not excluded; otherwise 10%.
4. Can C/O reduce import duty?
Yes, if the FTA proof is valid and origin rules are satisfied.
5. Are testers/samples treated like commercial goods?
Not always. Purpose, quantity and circulation plan must be reviewed.
6. What if the label claims dermatitis treatment?
Review immediately because it may exceed cosmetic scope.
RELATED ARTICLES
IMPLEMENTATION SOLUTION FROM TGIMEX
This article provides a map of HS, duty, dossiers and specialized policy. In practice, every shipment must still be reviewed against catalogue, formula, label, documents, origin and import purpose.
Pre-ETA review
HS, duty, C/O, cosmetic notification, label and claims.
Compliance file control
Cross-check Invoice, Packing List, B/L/AWB, C/O, label and notification file.
International logistics & customs
Agent coordination, ETA tracking, pre-alert, customs declaration and channel handling.
Post-clearance
Lot dossier archiving, supplementary label and explanation documents.
For shipments that may involve cosmetic notification, C/O or labeling requirements, businesses should not wait until cargo arrival to start reviewing documents. Small mismatches among Invoice, Packing List, label, formula, C/O or notification may delay clearance and create unplanned storage costs.
Tiếng Việt
中文 (中国)
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