Import procedure guide for body lotion

IMPORT PROCEDURE • SKINCARE COSMETICS

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.
Legal note: HS codes, duty rates, VAT and specialized requirements are for planning and compliance review. Before declaration, the importer must verify the current tariff, cosmetic notification dossier, formula, original label, claims, C/O, origin and actual import purpose.

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

Correct C/O form or origin proof for the selected agreement.
Correct origin criterion: WO, RVC, CTH, CTSH or product-specific rule.
Goods description, HS, quantity, weight and origin match Invoice/Packing List/B/L.
Third-party invoice information shown where relevant.
Direct transport and timing requirements met.
Issue date, stamp/signature or electronic verification code valid.

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

Government legal portalDrug Administration of Vietnam

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.
Consistency rule: Goods name, quantity, volume, SKU, origin, ingredients, claims and labels must match commercial docs, notification dossier, labels and customs declaration.

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.

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