IMPORT PROCEDURE GUIDE FOR CLEANSER
A cleanser shipment may be blocked at the product-description stage: the same commercial term may cover facial gel, foam cleanser, cleansing cream, cleansing milk or rinse-off makeup remover. Wrong HS Code, missing cosmetic proclamation receipt number, inconsistent INCI formula, incorrect Vietnamese label or claims beyond cosmetic scope may trigger document supplementation, channel inspection, loss of C/O preference and DEM/DET exposure. This guide provides an E2E map for pre-ETA review.
QUICK FACTS
| Review group | Content needs closing | Operating notes |
|---|---|---|
| Mặt hàng | Cleanser – facial/body cleansing products, usually in the form of gel, foam, cream, milk or wash-off balm. | Do not mix with toner, serum, essence, cream, lotion, mask, makeup remover or body lotion. |
| HS ưu tiên | 3401.30.00 – organic surface-active preparations for skin cleansing, liquid/cream form, retail packaging, whether or not containing soap. | Suitable when the main essence is “preparation for washing the skin”. |
| HS thay thế | 3304.99.90 – other cosmetics/skin care preparations. | Only consider when the product is skin care oriented or the dossier does not clearly show the nature of skin washing preparations according to group 3401. |
| Thuế tham khảo | 3401.30.00: MFN 27%, regular 40.5%, base VAT 10%. 3304.99.90: MFN 20%, regular 30%, base VAT 10%. | VAT 8% Only considered if eligible for VAT reduction and not in the exclusion list at the time of opening the declaration. |
| Specialized policies | Cleanser is an imported cosmetic; need Receipt number of cosmetic product proclamation form before being released into circulation. | Circular review 06/2011/TT-BYT và Circular 34/2025/TT-BYT. |
SCOPE OF APPLICATION
The article applies to cleanser Imported for cosmetics business, including facial cleanser, gel cleanser, foam cleanser, cleansing milk/cream wash-off form and retail packaged skin cleansing products. Do not automatically apply to toner, serum, essence, cream, lotion, mask, non-rinse makeup remover or body lotion. Sample goods, tester goods, gift goods, near-dated goods, used/refurbished goods or project goods may have different document checking methods. It is necessary to review according to the catalog, INCI formula, label, declaration form, model/SKU and actual import purpose.
CLASSIFICATION & PRODUCT IDENTIFICATION
Main function
Cleanse skin, remove dirt, excess oil, sunscreen or light makeup. If the claim changes to acne treatment, antiseptic, or dermatological treatment, the scope of management needs to be reviewed.
Technical facility
Compare product form, surfactant (surfactant) ingredients, instructions for use, retention time on skin, washing method, label and INCI formula.
| Criteria to check | Documents need to be compared | Rủi ro nếu mô tả sai | Suggestions on how to write product names |
|---|---|---|---|
| Dạng sản phẩm | Original label, catalog, packaging photo, COA if any | General records of “cosmetics” may require explanation of students and policies. | Facial cleanser in gel/foam/cream form, for skin cleansing, retail packaging, capacity … ml. |
| Cleaning mechanism | INCI formula, SDS/COA, manufacturer description | There is surfactant but declaring it as a cream/lotion can cause HS deviation. | Specify preparation for washing the skin if it is essentially a skin washing product. |
| Claim | Labels, leaflets, websites, publication records | Claim “acne treatment/antibacterial/treatment” may cross the cosmetic boundary. | Prioritize the claim of cleaning, helping to remove dirt/sebum. |
| Labels & claims | Announcement card, secondary label, LOA, CFS | Inaccurate product name, manufacturer, origin, capacity, batch number. | Product name and SKU must match 100% between documents, labels and declarations. |
HS CODE – DUTIES – C/O
For cleanser, the decisive point lies not in the trade name “cleanser” but in nature of the goods: Is the product a skin wash with surfactants, liquid/cream, retail packaging or other cosmetic/skin care. Therefore, it is necessary to create a classification memo before ETA to avoid amending the declaration when the goods have arrived.
| Mã HS tham khảo | Basis of determination | Normal import tax | Thuế MFN | VAT | Risk of wrong application | Records need to be compared |
|---|---|---|---|---|---|---|
| 3401.30.00 | Organic surface-active preparations for cleaning the skin, in liquid or cream form, in retail packing, whether or not containing soap. | 40,5% Refer to the 150% MFN principle. | 27% | 10% facility; 8% chỉ nếu đủ điều kiện giảm VAT. | Applying 3304 when the product is a skin cleansing gel/foam with surfactant can cause tax errors, wrong descriptions and wrong C/O. | INCI, labels, catalogs, uses, instructions for use, packaging photos. |
| 3304.99.90 | Other cosmetics/skin care preparations; Consider only when the application does not demonstrate the nature of a skin wash preparation according to 3401 or is biased toward typical non-rinse skin care. | 30% Refer to the 150% MFN principle. | 20% | 10% facility; 8% chỉ nếu đủ điều kiện giảm VAT. | Applying 3304 to conventional skin cleansers may require reclassification under 3401.30.00. | Claim, formula, label, announcement form, instructions for use. |
| Tình huống C/O | Students apply | Special preferential taxes need to be reviewed | Operating conditions | Risks need to be blocked before ETA |
|---|---|---|---|---|
| ASEAN – Form D / ATIGA | 3401.30.00 / 3304.99.90 | Can return 0% If the form is correct, the origin is correct and the year of application is correct. | Check origin criteria, direct shipping, third party invoices if any. | C/O with wrong description, wrong HS, wrong origin criteria will cause loss of incentives. |
| Trung Quốc – Form E / ACFTA | 3401.30.00 This is usually the branch that needs to be carefully examined with a cleanser | Decree must be compared to the current ACFTA tariff schedule; Do not apply without checking the original form. | Check the exporter, manufacturer, product description box, HS and origin criteria. | Sai invoice Third parties or wrong criteria may be subject to C/O verification. |
| Hàn Quốc – Form AK/VK | 3401.30.00 / 3304.99.90 | Look up according to AKFTA/VKFTA at the correct stage; Do not confuse AK and VK. | Compare exporting country, place of production, CTH/RVC criteria if applicable. | Mismatch between C/O and declaration leads to loss of incentives. |
| EU/UK/CPTPP/RCEP | Theo HS chốt cuối cùng | Review the EVFTA/UKVFTA/CPTPP/RCEP schedule according to the year of declaration opening. | Check EUR.1, self-certification documents of origin or C/O RCEP according to the conditions of each agreement. | Applying the wrong form according to the country of origin or using invalid C/O. |
SPECIALIZED MANAGEMENT POLICY
| Commodity situation | Policies may apply | Documents to check | Processing authority/gateway | Time to do it | Ghi chú rủi ro |
|---|---|---|---|---|---|
| Cleanser imported for business | Announcing cosmetic products | Announcement form, LOA, CFS, formula, label | Public service portal/Ministry of Health or authorized agency at the time of application | Before releasing goods into circulation | The product name and responsible organization must match the records. |
| Claim nhạy cảm | Review the boundaries of cosmetics – pharmaceuticals/antibacterial | Labels, leaflets, websites, promotional materials | Health/market regulatory agency | Before label printing and before ETA | Claiming therapy can mislead the management team. |
| Product contains alcohol/solvents | Review shipping DG if any | SDS/MSDS, thành phần, packing | Shipping company/airline/warehouse | Before booking | Failure to declare DG may result in refusal of transportation. |
| Hàng mẫu/tester/quà tặng | Still need to review import purpose and declaration/label | Invoice, packing, explanation letter, label | Customs/specialized agencies | Before ETA | Not automatically exempt from specialized obligations. |
LEGAL REFERENCES TO REVIEW
| Text group | Name/number | Issuing authority | Hiệu lực | Vai trò | Articles/appendixes need attention | Ghi chú |
|---|---|---|---|---|---|---|
| Circular mỹ phẩm | Circular 06/2011/TT-BYT | Ministry of Health | 01/04/2011, has been revised/supplemented | Cosmetic management, declaration, PIF, labels, product safety. | Articles 4–10 on publication; Article 18 on labeling; relevant appendices. | Compare the consolidated/amended version. |
| Circular sửa đổi | Circular 34/2025/TT-BYT | Ministry of Health | 18/08/2025 | Update some regulations on cosmetic announcement and management forms. | Appendix Announcement form and how to record content. | Applies at the time of application submission. |
| Goods labeling | Decree 43/2017/NĐ-CP, Decree 111/2021/NĐ-CP | Government | Currently being applied, need to compare effectiveness | Product label frame, Vietnamese sub-label. | Required content, origin, responsible organization. | Cosmetic labels must also comply with specialized regulations. |
| Biểu thuế | Biểu thuế XNK và Vietnam Trade Portal | Ministry of Finance/General Department of Customs | According to the declaration opening date | Check HS, MFN, VAT. | 3401.30.00, 3304.99.90. | Check again before transmitting the declaration. |
| VAT | Decree 174/2025/NĐ-CP | Government | 01/07/2025 | Determine whether VAT is 10% or reduced by 8%. | List of goods/services that are not subject to VAT reduction. | No default 8%. |
| FTA/C/O | Special preferential tariff decrees ATIGA, ACFTA, AKFTA, VKFTA, EVFTA, CPTPP, RCEP… | Government/Ministry of Finance | According to each stage | Apply special preferential tax if C/O is valid. | Rules of origin, direct shipping, third party invoices. | Need to review further according to actual records. |
VIEW / DOWNLOAD ORIGINAL REFERENCES
Enterprises should further compare on the Legal Document Portal or the issuing agency’s website before applying.
CUSTOMS CLEARANCE DOSSIER
Set of commercial documents
- Commercial Invoice, Packing List, Bill of Lading/Air Waybill.
- Sales Contract/Purchase Order nếu có.
- C/O nếu xin ưu đãi thuế.
- Catalog, product photos, original labels, SKU/model list.
Specialized profile
- Cosmetic product announcement form.
- LOA, CFS, ingredient formula, label.
- PIF (Product Information File – product information file) to serve post-inspection.
- SDS/MSDS if there is a risk of transporting dangerous goods.
| Profile group | Documents required | Which step to use? | Who usually prepares | Common errors | How to check ETA in advance |
|---|---|---|---|---|---|
| Thương mại | Invoice, Packing List, B/L/AWB | Open the declaration, check the value and quantity | Seller, importer, forwarder | Generic product name, missing capacity/SKU. | Compare labels, catalogs, bookings. |
| HS–thuế | Memo classifies HS, INCI, uses | Chốt mã HS, MFN, VAT, C/O | Customs/Compliance | Do not separate 3401 and 3304; Apply default 8% VAT. | Look up the tax schedule and make a comparison table. |
| Cosmetic announcement | Announcement card, LOA, CFS, label | Specialized review | Regulatory/Legal | Product/manufacturer name does not match. | Compare each line before the ETA. |
| C/O | Draft C/O and valid original | Apply special offers | Seller/importer | Sai HS, sai mô tả, sai tiêu chí. | Check draft C/O before issuing. |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Điểm quyết định | Questions to answer | Tài liệu chứng minh | Consequences if unknown | Recommended treatment |
|---|---|---|---|---|
| HS | Cleanser thuộc 3401.30.00 hay 3304.99.90? | INCI, nhãn, catalogue | Correction of declarations, explanations, collection. | Finalize memo to classify before ETA. |
| Announcement | Do you have the correct product announcement receipt number? | Announcement form, LOA, CFS | Not enough circulation facilities. | Complete documents before goods arrive. |
| Claim | Does it claim to treat acne/antiseptic/treatment? | Nhãn, leaflet, website | Wrong cosmetic range. | Edit claim or review management group. |
| C/O | Is the C/O in the correct form, documents, description, and criteria? | C/O, Invoice, Packing List, B/L | Mất ưu đãi thuế. | Check draft C/O before ETA. |
PRACTICAL E2E WORKFLOW
Step 1: Review ETA in advance
- Chốt HS, thuế, C/O, VAT.
- Review announcement forms, labels, and claims.
Step 2: Lock documents
- Chốt Invoice, Packing List, B/L/AWB.
- Compare SKU, capacity, origin, manufacturer.
Bước 3: Hoàn thiện chuyên ngành
- Check the receipt number of the Announcement Form.
- Prepare secondary labels and PIF documents for post-inspection.
Bước 4: Mở tờ khai
- Green Stream: according to system conditions.
- Yellow Stream: check records.
- Red Channel: check documents and actual goods.
Step 5: Customs clearance and post-inspection
- Pull goods back to warehouse, add additional labels if necessary.
- Save documents in batches for explanation after customs clearance.
PRE-ETA RISK CHECKLIST
| Rủi ro | Hậu quả | How to block ETA in advance | Documents to check |
|---|---|---|---|
| Áp sai HS 3401/3304 | Wrong tax, wrong C/O, must explain. | Create memos classified by uses and ingredients. | INCI, nhãn, catalogue. |
| Missing/mismatching Announcement Form | Delay in customs clearance/circulation. | Lock product name, responsible organization, manufacturer. | Announcement form, LOA, CFS. |
| Claim transcends the boundaries of cosmetics | Labels/records may be required to be corrected. | Check claims before printing labels. | Artwork, leaflet, website. |
| C/O sai form/HS/mô tả | Not eligible for incentives. | Please draft C/O before ETA. | C/O, Invoice, B/L. |
| The product has solvent/alcohol but is not tested for DG | Rejected booking or holding goods. | Request SDS/MSDS before booking. | SDS/MSDS, thành phần. |
FAQ
1. Does imported cleanser need to declare cosmetics?
Yes, if it is an imported cosmetic for circulation in Vietnam, it is necessary to review and declare the cosmetic product according to current regulations.
2. Cleanser áp HS 3401.30.00 hay 3304.99.90?
Normally review is a priority 3401.30.00 if it is a liquid/cream skin cleansing product containing surfactant. 3304.99.90 Only considered when the nature is other cosmetics/skin care.
3. Is there a need for a Vietnamese secondary label?
Yes, the secondary label needs to be consistent with the original label, declaration form and import documents.
4. Does C/O help reduce taxes?
It is possible, if the C/O has the correct form, correct origin criteria, correct HS/description and meets the regulations of the corresponding FTA.
5. Are sample/tester products made the same as business products?
Should not default to the same. It is necessary to review the import purpose, quantity, label, declaration and documentation obligations.
6. What if the name on the Invoice is different from the Announcement Form?
Need to adjust ETA in advance or prepare explanation. Inaccuracies in product/SKU/manufacturer names are errors that often increase the risk of yellow/red flows.
Tiếng Việt
中文 (中国)
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