Cushion is a base make-up cosmetic product, usually a cream/lotion formula absorbed in a sponge core and packed in a compact case with an applicator puff. The practical import risk is not only the HS Code but also the correct product nature: cushion foundation, sunscreen cushion, cushion with refill, cushion with skincare/acne-related claims, or a make-up set.

If the Invoice and Packing List only state “makeup”, “BB cushion” or “cosmetic”, while the cosmetic notification, ingredient list, original label and catalogue show different product functions, the shipment may be requested to supplement cosmetic notification documents, clarify claims, review C/O, check labeling or undergo document inspection.

This article provides an E2E (End-to-End) roadmap for pre-ETA review: HS code, duty, VAT, C/O, cosmetic notification, document set, customs decision points and risks to block before arrival at port/airport.

QUICK FACTS

Item	Review point	Operational note
Product	Cushion for facial base make-up, commonly foundation/BB/CC cushion in a compact case.	Not automatically applicable to powder, lipstick, tint, mascara, eyeliner, skincare or cosmetic sets with a different nature.
Primary reference HS	3304.99.30 – Other face or skin creams and lotions.	Usually relevant when the cushion is a cream/lotion preparation used on facial skin. Review formula, product form and claims.
Alternative HS to review	3304.91.00 if the product is essentially powder/pressed powder; 3304.99.90 if it cannot be evidenced under 3304.99.30.	Do not classify only by the trade name “cushion”; review catalogue, formula, label and product form.
Reference taxes	For 3304.99.30: MFN 18%, normal duty 27%, VAT 8% or 10%.	VAT 8% depends on the VAT reduction policy and exclusion appendices at the declaration date.
Specialized policy	Imported cosmetics require a valid Cosmetic Product Notification receipt number before being placed on the market.	Control the notification form, authorization letter, CFS where applicable, ingredients, label, PIF and product claims.
Category IDs	VI 3078 / EN 3106 / ZH 3108.	Product group: Foundation, cushion, powder, lipstick, tint, blush, eyeliner, mascara and concealer.

Legal note

HS code, duty, VAT, C/O and cosmetic notification requirements are reference points for import planning. For an actual shipment, the importer must review the formula, original label, catalogue, claims, product form, origin, C/O and customs declaration date. Do not conclude that the shipment is eligible for import/market circulation without checking the cosmetic notification and labeling dossier.

SCOPE OF APPLICATION

Applicable products

This guide applies to cushion base make-up for facial use: foundation cushion, BB cushion, CC cushion, tone-up cushion, and cushion with sunscreen claims if still within cosmetic scope.

Excluded products

It does not automatically apply to powder, lipstick, tint, blush, eyeliner, mascara, concealer, skincare cream, standalone sunscreen or make-up set if the composition/function/packaging differs.

Separate review cases

Cushion with refill, puff, mirror, kit, samples/testers, gifts, mini size, EPE/FDI use, or products with treatment/acne/strong whitening/sunscreen claims must be checked against actual documents.

Review must be made against the actual catalogue, datasheet/product sheet, shade/model list, formula, original label and import purpose. For SPF/PA cushion, sunscreen claims must match the notification dossier, technical evidence and labeling. Claims such as “treat acne”, “cure”, “anti-inflammatory” or medical whitening must be reviewed for cosmetic-borderline risk.

CLASSIFICATION & PRODUCT IDENTIFICATION

Cushion should be identified by product nature, not only by trade name. At minimum, check product form, main function, use area, ingredients, shade/SKU, packaging, refill/puff accessories, product condition and label claims.

Criteria to check	Documents to compare	Risk if wrongly described	Suggested description on documents/declaration
Product form	Catalogue, product photo, original label, ingredient/COA documents	Cushion cream/lotion may be confused with compressed powder or a make-up set.	“Cushion foundation, cream/lotion type for facial make-up, shade…, volume/weight…, brand new 100%”.
Function/claims	Original label, notification form, approved marketing material	Medical or treatment claims may trigger clarification or correction.	Use only claims consistent with the notification: base make-up, coverage, tone correction, sunscreen if applicable.
Ingredients/formula	INCI list, CFS, PIF, notification dossier	Restricted/prohibited ingredients or INCI mismatch may create compliance risk.	Match INCI across notification, label, formula and manufacturer documents.
Shade/SKU/model	Invoice, Packing List, shade list	Mismatch may affect notification and customs documents.	Attach a shade/SKU list and quantity per shade where necessary.
Packaging/accessories	Packing List, packing photos, catalogue	Refill/puff/kit may be omitted, leading to quantity or description discrepancies.	Declare refill/puff if included; do not group as a set if policy differs.
Goods status	Contract, photos, manufacturer confirmation	Tester/sample/gift may be declared incorrectly as normal commercial goods.	State commercial goods/sample/tester/gift according to the actual purpose.

HS CODE – DUTY – C/O

For cushion products, the HS code must be determined by the actual dosage form and principal use, not by the commercial name alone. A cream/lotion-type face make-up cushion is usually reviewed under heading 3304 – beauty or make-up preparations and skin-care preparations, excluding medicaments. If the product is powder, a make-up set, or carries therapeutic claims, classification should be reviewed separately before customs declaration.

Reference HS code	Application condition	MFN import duty	Ordinary import duty	VAT	Special preferential duty under C/O	Risk if misclassified	Documents to cross-check
3304.99.30	Cream/lotion-type cushion used as face make-up or skin application; not pressed powder; not a medicament.	18%	27% (normally 150% of MFN unless otherwise provided)	8% if eligible for VAT reduction at the declaration date; 10% if not eligible or after the reduction period.	May be reduced to 0% under certain FTAs if the C/O is valid; other FTAs may range around 2.5%–10% depending on agreement/origin.	If the product is actually powder, a set, or has a different function, customs may reclassify it and request additional explanation/tax payment.	Catalogue, original label, INCI ingredients, cosmetic notification, product photos/texture, dosage-form description, C/O and transport documents.
3304.91.00	Only considered where the product is essentially powder, whether or not compressed, used for make-up.	22%	33%	8% or 10% depending on VAT policy at declaration date.	The FTA schedule must be checked separately for HS 3304.91.00; do not infer from 3304.99.30.	Classifying a cream/lotion cushion as powder may create duty, description and C/O inconsistency.	Product images, texture, ingredient list, manufacturer description, catalogue and notification form.
3304.99.90	Other products under 3304.99 if the product cannot be substantiated as 3304.99.30 or has a special structure/function.	18%	27%	8% or 10% depending on VAT policy at declaration date.	The FTA schedule must be checked separately for HS 3304.99.90; do not automatically apply 3304.99.30 treatment.	May affect C/O preference, customs explanation and declaration description.	Technical dossier, label, notification, detailed description, principal use and product photos.

SPECIAL PREFERENTIAL DUTY BY C/O – REFERENCE FOR HS 3304.99.30

Market/FTA	Common C/O	Reference special preferential duty 2026	When to use	Control points before claiming preference
ASEAN – ATIGA	Form D	0%	Use when ASEAN origin and origin criteria are satisfied.	Correct form, origin criterion, direct transport, consistent description with customs declaration and cosmetic notification.
China – ACFTA	Form E	0% in many cases; verify the schedule at declaration date.	Usually more beneficial than MFN 18% if the C/O is valid.	Check exporter, third-party invoice, HS at 6-digit level, goods description and transport route.
Korea – AKFTA/VKFTA	Form AK / VK	AKFTA around 5%; VKFTA may be 0%.	Compare AK and VK before declaration and choose the eligible, more favorable schedule.	Do not default to AK if VK is better; verify actual origin, invoice and C/O.
Japan – AJCEP/VJEPA	Form AJ / VJ	May be 0% or lower rates under the applicable schedule.	Use when Japanese origin and C/O are valid.	Check origin criterion, direct transport, product name and HS on C/O.
EU/UK – EVFTA/UKVFTA	EUR.1 or qualifying origin statement	Around 2.5% in certain schedules; verify the correct year and origin.	Apply where EVFTA/UKVFTA origin documentation is valid.	Check origin certification mechanism, REX number if any, description and cumulation conditions.
Australia/New Zealand – AANZFTA	Form AANZ	0%	Use when Australia/New Zealand/ASEAN origin requirements are met.	Check form, origin country, transport route and cushion description.
CPTPP	C/O or self-certification document as allowed	0%	Use where the exporter/producer is eligible for origin certification.	Check origin document, producer/exporter information and product-specific origin rule.
RCEP	Form RCEP or qualifying document	Usually around 10%; Japan may be around 10.9%.	Use only where it is better than alternatives or no better FTA is available.	Compare with MFN and other bilateral/regional FTAs; do not use if not optimal.
India – AIFTA	Form AI	Around 5%	Use for qualifying Indian-origin goods.	Check origin criterion, HS, goods description and direct transport.
No valid C/O	Not applicable	MFN 18% if MFN conditions are met; ordinary duty 27% if MFN/FTA is not applicable.	Claim MFN/ordinary duty only, not special preference.	Do not claim preferential duty if the C/O is wrong, expired, inconsistent or direct transport is not satisfied.

Duty note

The tax section should not be reduced to one MFN line. Before ETA, the importer should lock at least five points: HS 3304.99.30 / 3304.91.00 / 3304.99.90; VAT 8% or 10%; whether C/O is available; which FTA is most favorable; and consistency across C/O – Invoice – Packing List – cosmetic notification – label. No tax calculation formula is provided without actual value, Incoterms and cost data.

APPLICABLE SPECIALIZED POLICIES

Goods scenario	Possible policy	Documents to check	Authority/portal if identifiable	Recommended timing	Risk note
Cushion imported for sale	Cosmetic product notification before market circulation; the responsible entity is accountable for safety, efficacy and quality.	Notification form/receipt, ingredients, label, authorization letter, CFS if applicable, manufacturer documents.	Drug Administration of Vietnam / Ministry of Health or relevant public service portal.	Before sale and preferably before ETA.	Without notification receipt, the goods may not be eligible for circulation.
Cushion with SPF/PA	Can still be cosmetic, but sunscreen claims must match dossier and technical evidence.	SPF/PA test if any, label, notification form, PIF.	Cosmetics authority during inspection/post-market surveillance.	Before notification and label printing.	Unsupported claims may lead to label correction or explanation.
Treatment/acne/strong whitening claims	Cosmetic–drug and advertising borderline review.	Claim list, label, marketing material, active ingredients.	Cosmetic/advertising/health authorities depending on case.	Before notification and import.	Avoid treatment wording if not consistent with cosmetic nature.
Samples/testers/gifts	Purpose and value may differ, but correct classification and applicable policy remain required.	Invoice, packing list, purpose letter, “tester/not for sale” marking if any.	Customs; specialized authority if applicable.	Before ETA.	Do not use sample status to avoid notification if goods are placed on the market.
Cushion set with refill/puff/kit	Description, quantity, value and policy may need to be separated by component.	BOM, packing list, set photos, detailed invoice.	Customs and specialized authorities if applicable.	Before documents are issued.	Generic “cosmetic set” may cause HS/quantity/notification mismatch.
EPE/FDI/factory use	Customs purpose and internal use may differ from domestic sale.	Contract, import purpose, enterprise documents, transport docs.	Managing Customs branch.	Before ETA.	If released to domestic market, cosmetic notification and labeling must be reviewed.

LEGAL INSTRUMENTS TO REVIEW

Document group	Document name/number	Issuing authority	Effective/application time	Role in procedure	Articles/appendices to note	Review note
Circular	Circular 06/2011/TT-BYT on cosmetics management	Ministry of Health	Issued 25 Jan 2011; check amendments	Core regulation on cosmetic notification, PIF, safety, labeling and import/export cosmetics.	Article 1; Articles 4–5; Article 10; Appendices 01-MP/02-MP/07-MP.	Use consolidated/amended version when filing.
Amending circular	Circular 34/2025/TT-BYT amending Circular 06/2011/TT-BYT	Ministry of Health	Issued 03 Jul 2025; effective 18 Aug 2025	Updates notification dossier and electronic/paper form requirements.	Amended Article 4.1 and Article 5; Form 01-MP.	Use the updated form/procedure from the effective date.
Decree	Decree 43/2017/ND-CP on goods labeling	Government	Effective 01 Jun 2017	Labeling requirements for goods in Vietnam.	Mandatory label content and supplemental labels.	Cosmetic label must match import and cosmetic rules.
Amending decree	Decree 111/2021/ND-CP amending Decree 43/2017/ND-CP	Government	Effective 15 Feb 2022	Updates labeling rules for imported goods.	Rules on original/supplemental labels and origin.	Review before printing/applying Vietnamese label.
Foreign trade decree	Decree 69/2018/ND-CP guiding the Law on Foreign Trade Management	Government	Effective 15 May 2018	Related to CFS and certain import/export management scenarios.	CFS and temporary import/sample scenarios where relevant.	Review according to actual documents.
VAT decree	Decree 174/2025/ND-CP on VAT reduction	Government	Effective 01 Jul 2025	Basis to review VAT 8% or 10%.	Exclusion appendices and declaration date.	Do not automatically apply 8% if excluded.
Tariff instruments	Current MFN tariff, normal tariff and FTA tariff schedules	MOF/Government	By applicable period	Determine MFN, normal and special preferential duties.	HS 3304.99.30, 3304.91.00, 3304.99.90.	Check at declaration date.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises may search by document number on official legal databases, the Government portal or issuing authority websites.

Circular 06/2011/TT-BYT Circular 34/2025/TT-BYT Decree 43/2017/ND-CP Decree 111/2021/ND-CP

Enterprises should cross-check on official legal databases or the issuing authority’s website before application.

CUSTOMS CLEARANCE DOCUMENT SET

Commercial documents

Commercial Invoice, Packing List, Bill of Lading/Air Waybill, contract/PO if any, C/O if claiming preference, catalogue/product photos/shade list.

Cosmetic dossier

Cosmetic notification receipt number, notification form, authorization letter, CFS where applicable, INCI ingredient list, PIF and claim evidence.

Labeling & post-clearance dossier

Original label, Vietnamese supplemental label, packaging photos, shade code, batch/expiry, responsible entity information.

Document group	Required documents	Used for which step	Usually prepared by	Common errors	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB, contract/PO	Declaration, value and quantity review	Importer, shipper, forwarder	Generic product name; missing shade/SKU; wrong refill quantity	Lock draft documents and compare with notification/label.
C/O – duty	C/O Form D/E/AK/VK/VJ/AJ/EUR.1/RCEP… if any	Special preferential duty claim	Exporter/Importer	Wrong HS, description, third-party invoice issue	Review C/O draft before issuance.
Cosmetic notification	Notification form/receipt, authorization, CFS if applicable	Market circulation and explanation if requested	Regulatory/QA/Importer	Mismatch in product name, shade, manufacturer or ingredients	Compare line by line with label and documents.
Ingredients & claims	INCI, PIF, SPF/PA evidence if any, claim documents	Safety and cosmetic-borderline review	Manufacturer/RA	Treatment claims; ingredient mismatch; missing PIF	Block at label approval stage.
Labeling	Original label, supplemental label, packaging photos, batch/expiry	Post-clearance circulation	Importer/QA	Missing origin, responsible entity, ingredients or expiry	Approve supplemental label before ETA.

Control rule: product name, quantity, shade/SKU, batch, expiry, origin, manufacturer, ingredients and claims must match 100% among commercial documents, cosmetic notification, labels, cosmetic dossier and customs declaration.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Supporting documents	Consequence if unclear	Recommended handling
Is HS sufficiently evidenced?	Is the cushion a face cream/lotion, powder or other product?	Catalogue, label, ingredients, texture photos	Reclassification, duty assessment or explanation request	Prepare HS comparison table by SKU/shade before ETA.
Is cosmetic notification available?	Does the product for market sale have a valid notification receipt?	Notification receipt/form, RA dossier	May not be eligible for circulation	Complete notification before commercial import plan.
Do product names match?	Do invoice, notification, label and catalogue use consistent names?	Invoice, notification, original label	Questions due to name/SKU/shade mismatch	Standardize bilingual name and SKU mapping.
Are claims within cosmetic scope?	Any acne treatment, cure, anti-inflammatory or medical whitening wording?	Label, marketing material, formula	Label correction or regulatory risk	Use only claims supported by the notification and ASEAN cosmetic claim principles.
Is C/O acceptable?	Correct form, HS, description, origin criterion and direct transport?	C/O, B/L, invoice	Preference may be rejected	Review C/O draft before official issuance.
Is Vietnamese label ready?	Does label include ingredients, use, batch, expiry, origin and responsible entity?	Original/supplemental label	Not eligible for market circulation	Approve supplemental label before warehouse release.

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Finalize HS, duty, VAT, C/O; check cosmetic notification, label, claims, ingredients, receipt number and market circulation conditions.

Step 2: Lock documents and technical dossier

Finalize Invoice, Packing List, B/L/AWB, catalogue, shade list, INCI formula, original label, notification dossier and C/O draft.

Step 3: Complete cosmetic dossier

Check notification receipt, authorization letter, CFS if applicable, PIF and claim/SPF evidence where relevant.

Step 4: Open customs declaration

Green lane: conditional clearance; Yellow lane: documentary inspection; Red lane: documentary and physical inspection.

Step 5: Clearance, delivery and labeling

Pay duties, release cargo, check supplemental label, batch/expiry, packaging condition and circulation readiness.

Step 6: Post-clearance archive

Archive declaration, documents, C/O, notification, PIF, labels, product photos and explanations by shipment.

PRE-ETA RISK CHECKLIST

Wrong HS: confirm cream/lotion cushion 3304.99.30 or powder 3304.91.00 before declaration.

No notification receipt: complete cosmetic notification and check validity before commercial import.

Name/shade mismatch: map SKU among invoice, packing list, label, notification and catalogue.

Overstated claims: remove/tune treatment, cure or anti-inflammatory claims if not cosmetic-compliant.

C/O error: review form, origin criterion, direct transport and third-party invoice.

Wrong VAT 8%/10%: check Decree 174/2025/ND-CP and exclusion appendices at declaration date.

Incomplete supplemental label: check ingredients, use, batch, expiry, origin and responsible entity.

Tester/gift declared as normal goods: prepare purpose letter and matching documents.

FAQ – COMMON BUSINESS QUESTIONS

Question	Brief answer
Does imported cushion require a license?	For cushion as cosmetics, the key requirement is cosmetic notification, labeling dossier and market circulation conditions. Review formula, claims and import purpose.
What HS is usually used for cushion?	Reference 3304.99.30 for cream/lotion facial cushion. Review 3304.91.00 if it is powder; 3304.99.90 if not evidenced.
What are the import taxes?	For HS 3304.99.30: MFN 18%, normal 27%, VAT 8% or 10%. Valid C/O may reduce duty under many FTAs.
Can C/O reduce duty?	Yes, if the C/O is valid. Several FTAs can be 0% or below MFN for HS 3304.99.30, subject to review at declaration date.
Does SPF cushion need additional evidence?	SPF/PA claims should match notification and supporting evidence. Label and PIF should be consistent.
Do samples/testers need notification?	It depends on purpose and whether the goods enter the market. They must still be declared correctly and comply with applicable policy.
What if invoice name differs from notification?	Do not file immediately. Request document correction or official SKU/name mapping from manufacturer/shipper.
Is Vietnamese supplemental label required?	Yes if the goods are circulated in Vietnam, subject to Decree 43/2017, Decree 111/2021 and cosmetic labeling rules.

IMPLEMENTATION SUPPORT FROM TGIMEX

This article provides a roadmap for HS, taxes, documents and specialized policy; however, each actual shipment must be reviewed against catalogue, ingredients, label, notification, C/O, shipping documents and import purpose.

Pre-ETA review

HS, duty, C/O, cosmetic notification, label, claims, ingredients and shade/SKU list.

Compliance file control

Compare Invoice, Packing List, B/L/AWB, C/O, notification, POA, CFS, PIF and labels.

Logistics & customs

Coordinate agents, monitor ETA/pre-alert, file customs declaration, handle inspection lanes and domestic delivery.

TGIMEX has an agent network in more than 60 countries and is a member of WCA, WCA China Global, VLA and HNLA, with capabilities in sea, air, road/rail transport, customs clearance, C/O, import permits, warehousing and domestic delivery.

For cosmetic shipments involving notification, C/O, labeling or claim explanation, enterprises should not wait until arrival to review documents. Any discrepancy between Invoice, Packing List, label, notification, ingredients or C/O may cause document supplementation, delayed clearance or unplanned storage costs.

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