Mục lục nội dung ẩn

1.3 CLASSIFICATION & TECHNICAL IDENTIFICATION

1.3.1 TECHNICAL IDENTIFICATION CRITERIA

1.4 HS CODE – DUTY – C/O

1.4.1 DUTY AND C/O/FTA REVIEW TABLE

1.4.2 Pre-ETA C/O checklist

1.5 SPECIALIZED POLICY MATRIX

1.6 LEGAL DOCUMENTS TO REVIEW

1.7 VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

1.8 CUSTOMS CLEARANCE DOCUMENT SET

1.8.1 OPERATIONAL DOCUMENT CHECKLIST

1.9 CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT

1.10 PRACTICAL E2E PROCESS

1.11 PRE-ETA RISK CHECKLIST

1.12 FAQ – COMMON BUSINESS QUESTIONS

1.13 TGIMEX EXECUTION SOLUTION

COSMETICS – MAKE-UP | CONCEALER

IMPORT PROCEDURE FOR CONCEALER

Concealer is a make-up cosmetic used to cover blemishes, dark circles or uneven skin tone. It is often described too generally as “cosmetic”, “make-up” or “skin care” on commercial documents, while the compliance file should identify the actual form: cream, liquid, stick, pen, palette, cushion or powder concealer.

If HS Code 3304.99.30/3304.99.90 is applied incorrectly, or if cosmetic notification, CFS, authorization letter, PIF, Vietnamese label or C/O is incomplete, the shipment may be requested for supplementary documents, routed for inspection, lose preferential duty and incur DEM/DET charges.

This article provides an E2E map for pre-ETA review: HS code, duty, C/O, cosmetic notification, labelling, import documents and clearance decision points.

Legal application note: Concealer must be reviewed based on actual catalogue, INCI ingredients, original label, product form, claims, SKU, CFS, authorization letter, product notification and import purpose. Do not apply one conclusion automatically to foundation, cushion, concealer, lipstick, tint, blush, eyeliner, mascara or treatment products.

QUICK FACTS FOR CONCEALER SHIPMENTS

Review group	Content to check	Operational note
Product	Concealer used as facial make-up, in cream, liquid, stick, pen, palette, cushion or powder-concealer form.	Do not automatically apply to foundation, cushion, powder, lipstick, tint, blush, eyeliner, mascara or treatment products.
Reference HS	3304.99.30 for face/skin cream or lotion-type products; 3304.99.90 for other forms; review 3304.91.00 if it is powder concealer.	Compare product form, use, claims, label, packaging and commercial description.
Reference duty	For 3304.99.30/3304.99.90: MFN 18%, ordinary duty 27%, base VAT 10%. For 3304.91.00: reference MFN 22%.	Check tariff schedule at declaration date and C/O under each FTA.
Specialized policy	Cosmetic product notification; review CFS, authorization letter, INCI ingredients, claims, PIF, original label and Vietnamese label.	The notification number is a key dossier point for imported cosmetics circulated in Vietnam.
Main risks	Wrong HS, missing notification, excessive cosmetic claims, mismatch of product name/SKU/shade, incorrect C/O form or origin criterion.	Review before ETA; do not wait until cargo arrival to supplement the dossier.

SCOPE OF APPLICATION

This article applies to concealer as a make-up cosmetic used to cover blemishes, dark circles, uneven skin tone or colour-correct areas on the face. Common forms include liquid concealer, cream concealer, stick concealer, concealer pen, concealer palette, cushion concealer and powder concealer if the principal function is coverage.

It must not be automatically applied to foundation, cushion, powder, lipstick, tint, blush, eyeliner, mascara, anti-acne/treatment skin products, cosmetic raw materials or goods not imported as finished cosmetic products. New goods, samples, marketing testers, gifts, EPE/FDI imports or non-commercial goods may require different dossier handling.

Review must be based on actual catalogue, datasheet, SKU/model, formula/ingredients, label, claims and import purpose.

CLASSIFICATION & TECHNICAL IDENTIFICATION

For concealer, product identification should cover not only the trade name but also product form, use area, claims, colour ingredients, packaging, shades, SKU and cosmetic notification dossier. A generic description such as “cosmetic” or “make-up” may not be sufficient to distinguish it from powder, eye make-up, cosmetic raw materials or treatment products.

TECHNICAL IDENTIFICATION CRITERIA

Item to check	Documents to compare	Risk if described incorrectly	Suggested wording on documents/declaration
Product form	Catalogue, photos, original label, technical description	Confusion between cream/liquid, stick, palette, powder or eye make-up; wrong HS.	“Concealer, cream/liquid/stick/palette form – cosmetic make-up for covering blemishes, brand…, shade…, net weight…”
Function/claim	Label, artwork, product brief, website claims	Anti-acne, treatment, healing or medicinal claims may exceed cosmetic scope.	State cosmetic functions: cover blemishes, even skin tone, colour correction.
Ingredients/INCI	Formula, ingredient list, SDS/COA if any	Restricted/prohibited ingredients; notification mismatch with label/formula.	Compare label ingredients, notification and PIF before ETA.
Shade/SKU/model	SKU list, packing list, carton label, photo of each shade	Shade mismatch between Invoice, Packing List, notification and label.	List all shades/SKUs if each shade has separate notification data.
Brand owner/manufacturer	CFS, authorization letter, Invoice, contract	Manufacturer/owner mismatch; notification dossier may be questioned.	Company name, address and country of manufacture should be consistent.
Goods condition	Invoice, Packing List, contract, import purpose	Samples/gifts/testers handled as commercial goods or vice versa.	State brand-new finished cosmetic goods and actual purpose.

HS CODE – DUTY – C/O

Concealer is usually reviewed under heading 33.04 for beauty, make-up and skin-care preparations, excluding medicaments. The HS line should not be determined by the trade name “concealer” alone; the product form, use area, claims, packaging and tariff wording must be reviewed. For cream/liquid facial concealer, 3304.99.30 is often the main reference; other forms may require 3304.99.90.

Reference HS	Condition of application	Reference duty	Risk if misapplied	Documents to compare
3304.99.30	Cream, liquid or lotion-type concealer used on face/skin for covering blemishes or evening skin tone.	Reference MFN 18%; ordinary duty 27%; base VAT 10%.	Incorrect if the goods are powder concealer, eye make-up, raw material or treatment product.	Catalogue, label, formula, notification, CFS/LOA, product photos, SKU list.
3304.99.90	Other forms of make-up/skin-care cosmetics, e.g. stick, palette or form not matching cream/lotion wording.	Reference MFN 18%; ordinary duty 27%; base VAT 10%.	Using “other” when a more specific line applies may trigger explanation.	Actual photos, physical description, packing specification, label and notification.
3304.91.00	Only if the goods are powder concealer, whether or not compressed.	Reference MFN 22%; ordinary duty 33%; base VAT 10%.	Wrong for cream/liquid concealer.	Texture, photos, catalogue, palette, label.
3304.20.00	Only if the product is essentially an eye make-up preparation.	Reference MFN 22%; ordinary duty 33%.	Do not apply merely because it can be used under the eyes.	Use area, artwork, claims, product brief.
3304.99.20	Only if presented as anti-acne cream.	Reference MFN 10%; ordinary duty 15%.	Anti-acne/treatment claims may affect HS and cosmetic notification.	Label, claims, formula, PIF, notification dossier.

DUTY AND C/O/FTA REVIEW TABLE

Origin route	Origin proof	Duty to review	Conditions	Risk if incorrect
No preferential C/O	Not applicable or commercial origin evidence only	Reference MFN 18% for 3304.99.30/3304.99.90; ordinary duty 27%. If 3304.91.00/3304.20.00, reference MFN 22%.	Correct HS, value and consistent origin.	Higher duty cost; origin queries if documents are unclear.
ASEAN/ATIGA	Form D or permitted origin proof	Many HS 3304 cosmetics may enjoy 0% if origin criteria are met.	Origin criterion, direct transport, goods description and HS must match.	Wrong form or RVC/CTH/CTSH criterion may deny preference.
China/ACFTA or RCEP	Form E or RCEP C/O	ACFTA may provide deep preference; RCEP should be compared separately and is not automatically the lowest.	Check origin criterion, third-party invoice, direct transport and country of origin.	Wrong description, HS or exporter information often requires explanation.
Korea/VKFTA, AKFTA or RCEP	Form VK, AK or RCEP	Review each agreement; some routes may remain around 5% or lower depending on HS/year.	Goods must satisfy origin rules and transport documents must match.	Wrong form/agreement may lose preference.
Japan/VJEPA, AJCEP, CPTPP or RCEP	Proof under the applicable agreement	AJCEP/VJEPA/CPTPP may provide deep preference, sometimes 0%; compare RCEP separately.	Check PSR, invoice, transport route, exporting country and origin.	Failure to prove origin or direct transport.
EU/EVFTA, UK/UKVFTA	EUR.1 or self-certification where eligible	Some HS 3304 lines follow a staged rate, e.g. around 2.5% depending on year and HS.	Eligible exporter, correct description/HS and valid proof.	Wrong REX or origin statement wording may be rejected.
Australia–New Zealand/AANZFTA or CPTPP	C/O or permitted origin proof	Preferential rates may be deep if origin rules are met; transit alone is insufficient.	Origin criterion, transport documents, invoice and packing list must match.	Confusing exporting country with country of origin may cause wrong preference.

Pre-ETA C/O checklist

Correct C/O form or self-certification mechanism.
HS code, goods description, quantity, weight and value match Invoice/Packing List.
Origin criterion such as WO, RVC, CTH, CTSH matches the PSR.
Third-party invoice, back-to-back C/O or third-country transport is handled correctly.
Issue date, signature/stamp, origin country and transport route are valid.

SPECIALIZED POLICY MATRIX

Goods scenario	Policy that may apply	Documents to check	Authority/portal if identifiable	Recommended timing	Risk note
Finished concealer imported for sale	Cosmetic product notification and labelling review.	Notification, CFS, authorization letter, formula, label, PIF.	Drug Administration of Vietnam – Ministry of Health; relevant public service portal.	Before ETA, preferably before booking.	Missing notification number may cause document queries.
Concealer with special claims	Review cosmetic scope; avoid treatment/disease-prevention claims without basis.	Artwork, label, marketing content, product brief.	Drug Administration/Ministry of Health if clarification is needed.	Before finalizing label and notification.	Excessive claims may affect notification and classification.
Multiple shades/SKUs	Each variant should be checked against notification and ingredient/color data.	Shade list, color formula, label per SKU, packing list.	Cosmetic notification receiving authority.	Before supplier issues Invoice.	Mismatch between shades/SKUs and notification may trigger supplement request.
Samples/test marketing/gifts	May require different handling from commercial goods; cosmetic policy and label still need review.	Invoice, purpose letter, sample quantity, label, ingredients.	Customs; specialized authority if relevant.	Before ETA.	“Sample” used for commercial sale may be treated as wrong purpose.
EPE/FDI/factory import	Review purpose, import/distribution rights, internal file and post-clearance management.	Contract, PO, import purpose, business license if relevant.	Managing customs authority.	Before declaration.	Wrong regime or import purpose may affect taxes and post-clearance management.
Packaging/sub-label	Imported goods labelling and mandatory Vietnamese information for circulation.	Original label, Vietnamese sub-label, ingredients, lot, expiry, origin, responsible entity.	Market surveillance/customs when inspected.	Before clearance or before circulation depending on case.	Incorrect label may require correction or incur penalties.

LEGAL DOCUMENTS TO REVIEW

Document group	Document name/number	Issuing body	Effective date/application time	Role in the procedure	Key article/clause/appendix if any	Review note
Law	Customs Law 54/2014/QH13	National Assembly	In force; check amendments if any.	Basis for declaration, inspection and customs supervision.	Review rules on customs dossier, inspection, clearance and post-clearance.	Does not replace guidance of customs authorities at declaration time.
Decree	Decree 08/2015/ND-CP, 59/2018/ND-CP, 167/2025/ND-CP	Government	Decree 167/2025/ND-CP effective 15 Aug 2025.	Detailed customs procedures and supervision.	Review customs dossier, declaration and physical inspection rules.	Check consolidated/current version.
Customs circular	Circular 38/2015/TT-BTC, 39/2018/TT-BTC, 121/2025/TT-BTC	Ministry of Finance	Circular 121/2025/TT-BTC effective 01 Feb 2026.	Guidance on dossiers, declaration and import tax administration.	Review e-dossier and declaration indicators.	Apply by declaration date.
Cosmetic circular	Circular 06/2011/TT-BYT and 34/2025/TT-BYT	Ministry of Health	Circular 34/2025/TT-BYT effective 18 Aug 2025.	Cosmetic management, notification, PIF and market responsibility.	Review notification number, PIF and amended forms.	Use the form effective at submission time.
Goods labelling	Decree 43/2017/ND-CP, 111/2021/ND-CP	Government	Decree 111/2021/ND-CP effective 15 Feb 2022.	Imported/circulated goods labelling.	Language, name, origin, responsible party, quantity, ingredients.	Cosmetic label must match notification dossier.
HS nomenclature	Circular 31/2022/TT-BTC	Ministry of Finance	Effective 01 Dec 2022.	Vietnam import-export nomenclature and HS basis.	Heading 33.04 and subheading 3304.99.30.	Final HS depends on actual dossier and customs ruling if any.
Tariff	Decree 26/2023/ND-CP; Decision 15/2023/QD-TTg; FTA tariff decrees	Government/Prime Minister	Apply by declaration year/time.	Determine MFN, ordinary and special preferential duty.	Check HS, origin, C/O form and phase-down schedule.	Do not use absolute duty without checking current tariff.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

The company may search the document number on Vietnam’s legal document portal, the Government portal or the website of the issuing authority. Companies should cross-check the applicable document on official legal databases or authority websites before applying it.

Circular 06/2011/TT-BYT Circular 34/2025/TT-BYT Goods labelling

CUSTOMS CLEARANCE DOCUMENT SET

The concealer import file should be locked simultaneously between commercial documents and cosmetic regulatory documents. Goods name, quantity, shade/SKU, lot number, expiry date, origin, manufacturer, label, ingredients and cosmetic notification number must be consistent throughout the file.

OPERATIONAL DOCUMENT CHECKLIST

Document group	Required documents	Used for which step	Usually prepared by	Common error	Pre-ETA checking method
Commercial documents	Commercial Invoice, Packing List, Sales Contract/PO, B/L or AWB.	Declaration, customs value, quantity and origin check.	Buyer, seller, forwarder, docs team.	Goods name too generic; missing shade/SKU; wrong quantity.	Compare each line with packing list, carton label and product notification.
Origin documents	C/O Form D/E/VK/AK/EUR.1/RCEP or valid origin statement, if any.	Claiming special preferential duty.	Seller/exporter or manufacturer.	Wrong form, HS, description or origin criterion.	Check form, origin criterion, issue date and direct consignment.
Cosmetic regulatory file	Cosmetic product notification, CFS, authorization letter, formula/ingredients, PIF.	Specialized policy review and customs explanation.	Importer/RA, brand owner, manufacturer.	Expired CFS/LOA, product name mismatch, missing PIF.	Check notification number, product name, manufacturer, ingredients and validity.
Labelling file	Original label, Vietnamese sub-label, artwork, product photos, lot/expiry information.	Clearance, circulation and post-clearance review.	Importer, marketing, QA/RA.	Missing responsible entity, origin, ingredients or net quantity.	Compare label with notification, Invoice and packing list.
Technical documents	Catalogue, product brief, product-form photos, shade/SKU list.	HS classification, product use and policy determination.	Supplier, brand owner, importer.	Insufficient evidence that goods are concealer, whether or not compressed.	Standardize goods description before documents are issued.

CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Evidence document	Consequence if unclear	Recommended handling
HS code	Is the product truly concealer, whether or not compressed, under 3304.99.30?	Catalogue, photos, label, formula, use.	HS explanation, inspection routing or tax adjustment may arise.	Prepare an HS classification memo before ETA.
Cosmetic notification	Is there a valid notification receipt matching product name/shade?	Notification, CFS, LOA, PIF.	Import/circulation conditions may be insufficient; supplement request may occur.	Check notification before booking.
Goods labelling	Do original label and Vietnamese sub-label match notification and commercial documents?	Artwork, labels, product photos.	Cargo may be held for label correction or violation handling.	Review labels together with notification dossier.
C/O	Does the C/O have correct form, criterion, HS, description and direct consignment?	C/O, B/L/AWB, Invoice, Packing List.	Preference may be rejected and additional duty incurred.	Pre-check draft C/O before original issuance.
Product claims	Do product claims stay within cosmetic scope?	Label, website, product brief, marketing materials.	The product may be suspected as medicinal/treatment goods.	Remove unsuitable claims before notification/import.
Goods status	Is the shipment commercial goods, samples or test goods?	Invoice, PO, purpose letter, quantity.	Wrong customs regime or import purpose.	State the purpose and prepare corresponding documents.

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Confirm HS 3304.99.30 where supported; check MFN/ordinary/FTA duty; review notification, label, C/O and claim risks.

Step 2: Lock documents and technical file

Finalize Invoice, Packing List, B/L/AWB, catalogue, label, shade/SKU list, notification number, CFS/LOA/PIF.

Step 3: Complete cosmetic regulatory file

Review product notification, CFS, authorization letter, PIF, ingredients and sub-label before cargo arrival.

Step 4: Lodge customs declaration

Prepare explanations for customs value, HS, goods name, use, C/O, notification and label. Green channel is system-based clearance; Yellow channel checks documents; Red channel checks documents and physical goods.

Step 5: Clearance, delivery and post-clearance retention

Deliver to warehouse, check Vietnamese sub-label before sale, retain lot-based files and prepare for post-clearance or market inspection.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents to check
Generic goods name “cosmetic concealer”	Insufficient basis for HS/policy; supplementary documents may be requested.	Standardize product name by form, use, brand, shade and net weight.	Invoice, packing list, label, catalogue.
Missing/incorrect cosmetic notification	Regulatory file may be insufficient; clearance/sale may be delayed.	Check notification number, product name, manufacturer, ingredients and validity.	Notification, CFS, LOA, PIF.
Incorrect C/O form or origin criterion	Special preferential duty may be rejected.	Pre-check draft C/O before issuance.	C/O, Invoice, B/L, PSR.
Mismatch in shade/SKU	Customs may request SKU/model explanation.	Lock shade list before Invoice issuance.	Model list, label, packing list, notification.
Claims exceeding cosmetic scope	Product may be considered treatment/pharmaceutical.	Review claims on label, website and sales materials.	Artwork, product brief, formula.
Vietnamese sub-label missing mandatory information	Risk of penalty or corrective action before sale.	Prepare sub-label under Decree 43/2017 and 111/2021, aligned with notification.	Original label, sub-label, notification.

FAQ – COMMON BUSINESS QUESTIONS

Does imported concealer need cosmetic notification?

If concealer is a finished cosmetic product imported for circulation in Vietnam, the company should review cosmetic product notification under Circular 06/2011/TT-BYT and current amendments.

What HS code is commonly used for concealer?

Reference HS is 3304.99.30 for concealers, whether or not compressed. Final classification depends on actual documents.

What is the import duty?

Indicative MFN is 18%; ordinary reference is 27%; base VAT is 10%. Check the tariff and VAT policy at declaration time.

Can C/O reduce duty?

Yes, if the C/O or origin document is valid and meets the selected FTA conditions.

Are samples handled like commercial goods?

Not automatically. Purpose, quantity, label and cosmetic policy should be reviewed based on the actual file.

What if the label says “treat acne” or “medical concealer”?

The cosmetic scope must be reviewed. Treatment claims may trigger a different policy.

Is Vietnamese sub-labelling required?

Goods circulated in Vietnam must meet Vietnamese labelling requirements; the sub-label must align with original label and notification.

Does a shipment with many shades need separate checking?

Yes. Compare each SKU/shade against the notification and ingredient/label data.

TGIMEX EXECUTION SOLUTION

This article provides a map of HS code, duty, C/O, cosmetic notification dossier and key risks for importing concealer. For an actual shipment, the company should still review catalogue, datasheet, label, ingredient list, product notification, commercial documents, origin and import purpose.

Pre-ETA review: HS, cosmetic policy, C/O, duty, labelling, catalogue/datasheet/model/shade.

Compliance file control: Invoice, Packing List, B/L/AWB, C/O, notification, CFS, authorization letter, PIF and labels.

International logistics: agent/carrier coordination, ETA tracking, pre-alert and transport documents.

Customs declaration: dossier preparation, Green/Yellow/Red channel handling, HS/value/origin explanation.

Post-clearance: lot-based file retention, sub-label review, notification dossier and origin evidence.

For concealer shipments that may involve cosmetic notification, C/O or labelling requirements, companies should not wait until cargo arrival to start document review. A small discrepancy between Invoice, Packing List, catalogue, notification dossier, C/O or label may trigger supplementary document requests, delayed clearance or unplanned storage charges. TGIMEX supports an E2E import approach: pre-ETA policy review, document checking, international freight coordination, customs declaration, clearance handling, domestic delivery and post-clearance file retention.

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