Cosmetic serum carries high compliance sensitivity because the trade name is usually short, while the regulatory treatment depends on INCI formula, claims, format, labels and notification dossier. Wrong HS classification, missing notification, mismatched product names across Invoice – CFS – label – notification, or over-claiming beyond cosmetic scope may trigger document requests, customs lane escalation, rejection of preferential C/O treatment and DEM/DET exposure. This article provides an E2E map for pre-ETA review: HS Code, tax, cosmetic notification, labels, documents, customs process and key risks.

QUICK FACT

Item	What to review
Product scope	Cosmetic serum for facial/body skin care, in essence, liquid, gel-like, ampoule or concentrate form; not a medicinal product.
Reference HS codes	Usually review 3304.99.30 or 3304.99.90; acne-prevention claims may require review of 3304.99.20 or a medicine-borderline assessment.
Reference duties	Typical MFN: 18% for 3304.99.30/3304.99.90; 10% for 3304.99.20; ordinary duty is commonly 27% or 15%.
VAT	Baseline 10%; review 8% only if a VAT reduction policy remains effective and the goods are not excluded.
Core policy	Cosmetic product notification, ingredient/claim control, labelling, C/O, PIF and market placement conditions.
Warning	Do not apply one conclusion to all serums. Review INCI formula, claims, packaging, labels, catalogue, CFS, authorization letter and import purpose.

Legal note: This article applies only to finished cosmetic serum. It does not automatically apply to medicines, medicinal claims, cosmetic raw materials, hair serum, beauty devices or research samples not placed on the market. Review based on catalogue, SKU, INCI formula, labels and actual import purpose.

SCOPE OF APPLICATION

Covered

Facial/body skin serum, essence, ampoule or concentrate within cosmetic scope.
Moisturizing, brightening, repairing, antioxidant or regular skin-care serum.
New finished goods for sale/distribution.

Not automatically covered

Medicinal claims or products presented as drugs.
Hair serum, essential oil, cosmetic ingredients, devices.
Gift sets, samples, testers, exhibition goods or research goods.
Products with flammable solvent requiring DG review.

CLASSIFICATION & TECHNICAL IDENTIFICATION

Serum must be identified by formula, claims, packaging format and use purpose, not merely by the word “serum” on the invoice.

Criterion	Documents to check	Risk if described incorrectly	Suggested declaration description
Product format	Catalogue, label, packaging photos	Confusion with lotion, set or raw material	Cosmetic facial serum, brand…, SKU…, capacity…, for skin care.
Claims	Label, website, brochure	Medicinal over-claiming	Use neutral cosmetic wording, avoid treat/cure.
INCI ingredients	Formula, COA, SDS/MSDS	Restricted/prohibited ingredients or missing warnings	Review INCI before notification and declaration.
Product name/SKU	Invoice, PL, CFS, LOA, notification	Name mismatch across documents	Lock product name/brand/SKU/capacity.
Goods status	Invoice, contract, label	Sample/commercial confusion	State commercial goods/sample/tester if applicable.
Solvent/flammability	SDS/MSDS, flash point	DG rejection by carrier	Request SDS before booking.

HS CODE – TAX – C/O

The HS code of a serum should not be determined by the trade name alone. Customs classification must consider whether the product is a skin-care preparation, an acne-prevention cosmetic, a set/combo, or a product making medicinal claims.

Reference HS code	When to consider	Risk if misclassified	Documents to check
3304.99.30	Serum/lotion/liquid preparation applied to face or skin for moisturizing, brightening, repair, antioxidant or regular skin care purposes.	Misclassification if the product is not a lotion/liquid skin preparation or is sold as a multi-product set.	Formula/INCI, label, catalogue, specification, CFS, product notification, invoice, packing list.
3304.99.90	Serum, ampoule, essence or skin-care product that is better treated as “other” within skin-care/make-up preparations and is not medicine.	Customs may request an HS explanation if the product is actually a lotion/cream or carries special claims.	Catalogue, texture/format, label claims, ingredients, packaging photos, notification dossier.
3304.99.20	Only when the product is an anti-acne cosmetic preparation within the cosmetic scope, without medicinal disease-treatment claims.	“Treat acne”, “cure dermatitis” or therapeutic claims may move the product out of the cosmetic scope.	Label, claims, marketing materials, active ingredients, cosmetic notification dossier.
3004 or other heading	A warning route only when the product is presented for disease treatment/prevention or as a medicine.	Wrong product nature may lead to missing permits and wrong regulatory treatment.	Instructions for use, claims, active ingredients, marketing authorization if any.

HS code	Reference MFN	Reference ordinary duty	Reference VAT	C/O/FTA notes
3304.99.30	18%	27%	10%; review 8% if eligible under a valid VAT reduction policy.	May be reduced under an FTA if the C/O is valid and matches description, HS and origin criteria.
3304.99.90	18%	27%	10%; review 8% if eligible.	Check the C/O description carefully against invoice and notification documents.
3304.99.20	10%	15%	10%; review 8% if eligible.	Use only when the nature and claim fit this subheading; do not classify solely due to the word acne.

Tax component	Practical meaning	What to lock before declaration
MFN import duty	Used where the origin is eligible for MFN treatment and no special preferential C/O is claimed.	Lock the 8-digit HS code, origin, customs value, goods description and cosmetic nature.
Ordinary import duty	Often referenced at 150% of the MFN rate if MFN/FTA does not apply and no separate rate exists.	Confirm country of origin, trading route and origin evidence.
Import VAT	Baseline 10%; any reduction must be checked against the declaration date and exclusion list.	Review VAT and reduction policy at the declaration date.
Special preferential duty under C/O	May be lower than MFN, potentially 0% under certain FTAs if the C/O is valid.	Check C/O form, origin criteria, goods description, HS and third-party invoice if any.

APPLICABLE SPECIALIZED POLICIES

Goods situation	Possible policy	Documents to check	Authority/portal if identifiable	Recommended timing	Risk note
Finished cosmetic serum for sale	Cosmetic product notification under Circular 06/2011/TT-BYT, as amended/supplemented by relevant instruments including Circular 34/2025/TT-BYT; verify product notification before market placement.	Notification form/receipt, CFS, authorization letter, formula/INCI, label, C/O.	Drug Administration of Vietnam / Ministry of Health or the applicable public service portal.	Before ETA, preferably before commercial purchase.	Do not wait until arrival if the notification dossier is not ready.
Strong claims: melasma treatment, acne treatment, disease repair	Review the cosmetic–medicine boundary and whether the claims remain cosmetic.	Label, brochure, website listing, ingredients, instructions.	Ministry of Health / Drug Administration or relevant authority if questioned.	Before contract and label printing.	Over-claiming may change the regulatory pathway.
Sensitive actives: AHA/BHA, retinoids, vitamin C, arbutin, peptides, strong acids	Review restrictions, usage conditions, warnings and body area under ASEAN/Vietnam cosmetics rules.	INCI, concentration where needed, COA, SDS, test reports if any.	Drug Administration / cosmetic regulatory team.	Before notification and import.	Ingredient or warning errors may affect notification and post-market checks.
Ampoule, gift set, sample, tester	May require product-by-product or set-based review depending on sale format.	Set BOM, SKU list, labels, CFS/LOA.	Drug Administration / Customs if relevant.	Before invoice and packing list issuance.	Grouping several SKUs under one description may create HS and notification mismatch.
Serum containing flammable solvents	Review dangerous goods risk in international transport.	SDS/MSDS, flash point, UN number if any.	Carrier/airline/shipping line/forwarder.	Before booking.	Incorrect DG status may lead to cargo rejection or extra handling costs.

LEGAL DOCUMENTS TO REVIEW

Document group	Document name/number	Issuing authority	Effective/applicable timing	Role	Key provisions/appendices	Review note
Cosmetics management	Circular 06/2011/TT-BYT on cosmetics management; Circular 34/2025/TT-BYT amending/supplementing certain provisions	Ministry of Health	Circular 06 issued 25 Jan 2011; Circular 34 effective 18 Aug 2025; check the consolidated/amended text at the time of use.	Core rules for notification, PIF, safety, labelling and responsible person obligations.	Product notification, CFS, authorization letter, PIF, electronic dossier/e-signature requirements and product safety requirements.	Check the consolidated text of Circular 06/2011/TT-BYT as amended by Circular 29/2020/TT-BYT and Circular 34/2025/TT-BYT.
Import tariff	Decree 26/2023/ND-CP	Government	Effective 15 Jul 2023.	MFN tariff basis for heading 33.04.	Preferential import tariff schedule.	Confirm the current tariff at declaration date.
Ordinary duty	Decision 15/2023/QD-TTg	Prime Minister	Check validity at import date.	Basis for ordinary import duty where MFN/FTA does not apply.	Ordinary duty list and 150% MFN principle where applicable.	Do not use if MFN or valid FTA C/O applies.
Labelling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Decree 111 effective 15 Feb 2022.	Imported goods and Vietnamese labelling requirements.	Mandatory contents, origin, responsible entity, supplementary label.	Also check cosmetic-specific labelling rules.
VAT	VAT laws/decrees and temporary VAT reduction policies	National Assembly/Government/Ministry of Finance	At declaration date.	Determine 10% VAT or reduced rate if valid.	Exclusion appendices if VAT reduction applies.	Do not assume 8% without review.
FTA/C/O	Special preferential import tariff decrees by FTA	Government/competent authorities	By each FTA and annual schedule.	Determine special preferential duty with valid C/O.	C/O form, origin criterion, direct transport, third-party invoice.	Review by actual origin and 8-digit HS.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Businesses may search legal documents by document number on Vietnam legal document portals, the Government portal or the issuing authority’s website. Businesses should also cross-check on official legal portals or issuing authority websites before application.

Circular 06/2011/TT-BYT Consolidated Circular 06/2011 – 29/2020 – 34/2025 Decree 26/2023/ND-CP Decree 43/2017/ND-CP Decree 111/2021/ND-CP

CUSTOMS DOCUMENT SET

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading or Air Waybill.
Sales Contract/Purchase Order if any.
C/O if preferential duty is claimed.
Catalogue, original label images, SKU/model list if any.

Cosmetic compliance documents

Cosmetic product notification receipt/number if the goods are placed on the market.
CFS used for the notification dossier.
Authorization letter from manufacturer/product owner.
Formula/INCI, specification, original label and Vietnamese supplementary label.
PIF maintained by the responsible person.
SDS/MSDS when transport DG risk must be checked.

OPERATIONAL DOCUMENT CHECKLIST

Document group	Required documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO	Declaration, value, quantity, SKU	Buyer/Supplier	Only “serum” stated without capacity/SKU/function	Use complete description: cosmetic facial serum, capacity, SKU, origin.
Transport	B/L or AWB, arrival notice, pre-alert	Cargo release and declaration	Forwarder/Carrier	Mismatch in weight/packages or liquid cargo details	Reconcile PL with booking and pre-alert.
Cosmetic	Notification, CFS, LOA, INCI	Notification, customs, post-clearance	Importer/Regulatory/Supplier	Product name mismatch among documents	Match name, brand, manufacturer and origin.
Tax/C/O	C/O and third-party invoice if any	FTA duty claim	Supplier/Docs	Wrong HS/description/origin criterion	Check draft C/O before issuance.
Labelling	Original and supplementary labels	Market placement	Importer/QA	Claims inconsistent with notification	Check against notification and INCI.
DG if any	SDS/MSDS, flash point	Booking and transport	Supplier/Forwarder	Flammable solvent not declared	Request SDS before booking.

CLEARANCE DECISION POINTS

Decision point	Question	Evidence	If unclear	Recommended handling
HS code	Is it 3304.99.30, 3304.99.90 or another code?	Label, INCI, catalogue, use, format	Reclassification or duty adjustment.	Determine HS by product nature.
Notification	Is the notification receipt aligned with the exact product/SKU?	Notification, CFS, LOA, label	Delay or market placement risk.	Review before ETA.
Claims	Do the claims exceed cosmetic scope?	Label, website, brochure	Potential medicine-borderline issue.	Standardize claims early.
Ingredients	Any prohibited/restricted ingredient or warning?	Formula, COA, SDS, PIF	Post-market risk.	Review against cosmetic rules.
C/O	Is the C/O form, HS, description and origin criterion correct?	C/O, invoice, B/L	FTA duty rejected.	Check draft C/O.
Label	Do original and supplementary labels match the notification?	Label artwork, translation, notification	Relabelling or explanation required.	Lock label master before shipment.

OPERATIONAL E2E PROCESS

Step 1: Pre-ETA review

Lock the 8-digit HS, VAT, C/O, cosmetic notification, claims, labels, INCI and DG risk if solvents are present.

Step 2: Lock documents and cosmetic dossier

Reconcile Invoice, Packing List, B/L/AWB, CFS, LOA, notification, original label, supplementary label, SKU, capacity and origin.

Step 3: Complete notification/specialized explanations if needed

If no notification receipt is available or the serum has sensitive claims/actives, handle the dossier before arrival.

Step 4: Open customs declaration

Green lane permits conditional clearance; Yellow lane checks documents; Red lane checks documents and physical cargo. Frequent questions involve HS, value, C/O, notification, label, claim and ingredients.

Step 5: Clearance, delivery and record keeping

Release goods, deliver to warehouse, complete labels if applicable, control distribution and retain all shipment records for audit.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA prevention	Documents
Generic goods description “serum”	Wrong HS/notification/label	State serum type, use area, capacity, SKU and cosmetic use	Invoice, PL, label, catalogue
Over-claiming	Regulatory explanation or reclassification risk	Review claims before label and notification	Label, website, formula
Product name mismatch	Delay and post-clearance issue	Lock product name/brand/SKU	Notification, Invoice, CFS, label
Wrong C/O	FTA duty rejected	Review draft C/O	C/O, Invoice, B/L
Invalid CFS/LOA	Notification cannot be completed	Request documents before PO	CFS, LOA
INCI not reviewed	Post-market risk	Review ingredient list and warnings	Formula, COA, SDS, PIF

FAQ

Does imported serum need cosmetic notification?

If the finished cosmetic serum is placed on the Vietnamese market, the cosmetic notification dossier must be reviewed under Circular 06/2011/TT-BYT and relevant amendments, including Circular 34/2025/TT-BYT.

What is the main HS code?

Usually 3304.99.30 or 3304.99.90, depending on format, claim, ingredients and actual documents.

What is the import duty?

For 3304.99.30/3304.99.90, MFN is commonly 18%, ordinary duty 27%, baseline VAT 10%. Valid C/O may reduce duty.

Is acne serum still cosmetic?

It depends on claims, formula and presentation. Disease-treatment claims may exceed cosmetic scope.

Is a Vietnamese supplementary label required?

For market circulation, labelling must comply with imported goods labelling and cosmetic-specific labelling requirements.

Are samples treated the same as commercial goods?

Not automatically. Import purpose, quantity, label, ingredients and market placement must be reviewed.

IMPLEMENTATION SUPPORT FROM TGIMEX

This article outlines HS codes, tax, cosmetic notification documents and specialized compliance points for serum. For actual shipments, the dossier must still be reviewed against INCI formula, claims, catalogue, label, documents, origin and import purpose.

Pre-ETA review

HS, cosmetic notification, C/O, tax, label, claims, formula and PIF.

Compliance document control

Cross-check Invoice, Packing List, B/L/AWB, C/O, CFS, LOA, labels and technical files.

Logistics & customs

Coordinate agents, carriers, ETA, pre-alert, declaration and lane handling.

Post-clearance records

Retain notification, C/O, declaration, PIF, labels, CFS and LOA by shipment.

For serum shipments involving cosmetic notification, C/O or labelling requirements, businesses should not wait until cargo arrival to review documents. Small inconsistencies among Invoice, Packing List, catalogue, CFS, LOA, notification and labels can delay clearance and create unplanned storage costs.

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