IMPORT PROCEDURE GUIDE FOR BLUSH
Blush is a color cosmetic used on the cheek area. For import clearance, the shipment should not be described only as “makeup” or “cosmetics”; the importer should lock the product form, INCI formula, claims, HS Code, cosmetic notification number and labeling before ETA.
If powder blush is confused with cream, liquid or stick blush, or if the authorization letter/CFS, notification dossier, invoice, original label or claims do not match, the shipment may face additional document requests, clearance delays, loss of preferential C/O duty treatment and DEM/DET charges.
This article provides an E2E operational map to review HS classification, duties, C/O, cosmetic notification dossier, labeling, PIF and key risk controls before customs declaration.
QUICK FACTS
| Item | Quick review point | Operational note |
|---|---|---|
| Product name | Blush / cheek color in powder, pressed, cream, liquid, gel, balm or stick form | The product name on Invoice, Packing List, notification dossier and label should be consistent. |
| Reference HS | 3304.91.00 for powders, whether or not compressed; 3304.99.90 or another suitable code for non-powder cream/liquid/gel/stick forms | Do not classify mechanically by marketing name; use product form and makeup function. |
| Reference taxes | 3304.91.00: MFN 22%, ordinary 33%. 3304.99.90: MFN 18%, ordinary 27%. Standard VAT 10%, possibly 8% if eligible and not excluded. | Check the tariff schedule on the declaration date and the applicable FTA tariff if using preferential origin. |
| Specialized policy | Imported cosmetics require a valid cosmetic product notification number before market circulation | Typical dossier includes notification form, authorization letter, CFS and product documents. |
| Labeling | Review original label/Vietnamese supplementary label, batch number, expiry date, ingredients, responsible entity, origin and warnings if any | Claims such as whitening, acne, SPF or treatment should be reviewed against cosmetic claim boundaries. |
| PIF | Product Information File must be kept by the organization responsible for placing the product on the market | Part 1 should be immediately available when requested by authorities. |
SCOPE OF APPLICATION
Applicable products
Loose powder blush, pressed powder blush, baked powder blush, cream blush, liquid blush, gel blush, balm blush, stick blush or cheek tint.
Not automatically applicable to
Foundation, cushion, face powder, lipstick, lip tint, eyeliner, mascara, concealer, skincare or products making treatment claims.
Cases requiring separate review
Multi-product cosmetic sets, mixed palettes, tester/sample goods, commercial gifts and goods imported by EPE/FDI entities for domestic circulation.
Application principle
Review by catalogue, datasheet, SKU, INCI formula, label artwork, claims and actual import purpose; do not apply one generic conclusion to all makeup products.
PRODUCT CLASSIFICATION & IDENTIFICATION
Product form
Loose powder, pressed powder, baked powder, cream blush, liquid blush, gel blush, stick blush or cheek palette. Physical form is a key HS and declaration factor.
Main function
To add cheek color, makeup effect, glow or highlighting; light moisturizing or shimmer effects may appear but should not be described as treatment without legal basis.
Identification documents
Catalogue, label artwork, INCI list, COA if available, MSDS/SDS if supplied, CFS, authorization letter, product photos, shade list and SKU list.
Description warning
Generic descriptions such as cosmetics/makeup may cause HS misclassification, cosmetic dossier mismatch and labeling issues.
| Check point | Documents to compare | Risk if wrongly described | Suggested goods description |
|---|---|---|---|
| Finished product form | Catalogue, product photos, artwork and manufacturer description | Wrong HS between 3304.91.00 and 3304.99.90; customs may request clarification | Blush/pressed powder cheek makeup, brand…, shade…, SKU… |
| Function/claim | Original label, brand website, notification dossier and marketing material | Acne, whitening, SPF or treatment claims may exceed cosmetic boundaries | Describe makeup/cheek color function; avoid treatment claims in customs documents. |
| INCI ingredients | Formula/INCI list, SDS/MSDS if any | Ingredient names may mismatch between notification dossier, label and PIF | Align INCI names across notification, label and PIF. |
| Shade/SKU set | Shade list, SKU list, Packing List and artwork | Mismatch in number of shades or product names between Invoice and notification | State shade/SKU clearly when multiple colors are imported. |
| Goods condition | Invoice, Packing List, contract and label photos | Tester/sample goods declared as commercial stock may create policy issues | State new cosmetic blush, not pharmaceutical product. |
HS CODE – DUTIES – C/O
HS classification should be determined by product form and principal makeup function. The critical distinction is whether the blush is in powder form or in cream/liquid/gel/stick form.
| Reference HS code | Applicable case | Review basis | Risk if wrong | Documents to compare |
|---|---|---|---|---|
| 3304.91.00 | Blush in powder form, whether or not compressed: pressed blush, loose blush, baked powder blush | Heading 3304 for beauty/makeup preparations; subheading 3304.91 for powders | If actual goods are cream/liquid/stick, this code may be challenged | Catalogue, photos, artwork, physical form, packing list, notification dossier |
| 3304.99.90 | Cream, liquid, gel, balm or stick blush not classifiable as powder | Other preparations under 3304.99; product form and makeup function must be reviewed | Wrongly declaring under powder or skincare may affect duties and description | INCI, texture, usage method, artwork, label, COA if any |
| 3304.99.30 | Only to be reviewed when the product is actually face/skin cream or lotion; not a default code for blush | Depends on goods description, use area, claim and dosage form | Confusing color makeup with face/skin lotion may lead to HS error | Catalogue, claims, use area, directions |
| 3304.10.00 / 3304.20.00 | Not primary blush codes; relevant only where a set includes lip or eye makeup items | Used as warning for mixed palettes/sets | A multi-item set may require line separation or set-classification review | Set BOM, item photos, invoice breakdown |
| Tax item | HS 3304.91.00 – powder blush | HS 3304.99.90 – cream/liquid/stick blush | Condition | Risk control |
|---|---|---|---|---|
| MFN import duty | Reference 22% | Reference 18% | Applies where MFN treatment is used and no special preferential origin is claimed | Check the tariff on the declaration date. |
| Ordinary import duty | Reference 33% | Reference 27% | May apply where MFN/special preferential treatment is not available | Lock HS and origin before ETA. |
| Import VAT | Standard 10%; may be 8% if eligible and not excluded | Standard 10%; may be 8% if eligible and not excluded | Review Decree 174/2025/ND-CP and exclusion appendices at import time | Do not assume 8% without checking the current VAT policy. |
| Special preferential duty under C/O | May be lower than MFN under the applicable FTA tariff | May be lower than MFN under the applicable FTA tariff | Valid C/O/origin document, origin criteria, direct consignment and matching documents | Wrong form, HS, description or third-party invoice may lead to rejection. |
| Origin route | C/O form or origin document | Special preferential duty handling | Conditions | Documents to compare | Risk |
|---|---|---|---|---|---|
| ASEAN | Form D / ATIGA origin document if applicable | Check ATIGA tariff for the actual HS; may be lower than MFN if origin rules are met | WO/RVC/CTH/CTSH as applicable; direct consignment | C/O, Invoice, Packing List, B/L, HS, description | Wrong origin criterion or goods description may deny preference. |
| China | Form E or RCEP C/O | Check ACFTA/RCEP tariff for the actual HS | Correct agreement form and third-party invoice declaration if any | C/O, third-party invoice if any, B/L, packing | Wrong Form E/RCEP or weak direct consignment evidence. |
| Korea | Form AK, Form VK or RCEP C/O | Compare AKFTA/VKFTA/RCEP and select only when rules are met | Origin criteria and direct shipment under the chosen FTA | C/O, commercial documents, manufacturer declaration if needed | Wrong form or HS on C/O. |
| Japan | Form AJ, Form VJ, CPTPP or RCEP | Check AJCEP/VJEPA/CPTPP/RCEP tariff by HS | Depends on route and origin rule of each agreement | C/O/origin statement, B/L, invoice | Unsupported origin or transit inconsistency. |
| EU / UK | EUR.1 or origin statement under EVFTA/UKVFTA | Check EVFTA/UKVFTA tariff by HS | Exporter/origin statement must meet agreement requirements | Origin statement/EUR.1, invoice, B/L | Wrong origin text or goods description. |
| Australia – New Zealand / CPTPP | Form AANZ or CPTPP origin document | Check AANZFTA/CPTPP tariff by HS | Origin rule and transport documents must match | C/O, invoice, B/L, packing | Mismatch between origin, export country and transport route. |
| India / Hong Kong / EAEU | Form AI, Form AHK or EAV where applicable | Check each agreement by HS and actual origin | Only use where origin and route fall under the agreement | C/O, commercial and transport documents | Wrong agreement or form may deny preference. |
| C/O check item | What must match | Pre-ETA check method |
|---|---|---|
| Form and agreement | The form must match the route and origin | Confirm country of manufacture, country of export, transport route and most suitable FTA. |
| Origin criterion | WO, RVC, CTH, CTSH or the applicable criterion | Review product-specific rules of origin by HS; do not check form only. |
| Description and HS | Blush name, product form, HS, quantity and weight must match the document set | Compare C/O with Invoice, Packing List, B/L and notification dossier. |
| Third-party invoice | Must be properly declared where used | Check remarks, invoice issuing country and transaction structure. |
| Issue date and validity | C/O must be valid, correctly signed/stamped and within the required timeline | Review issue date, stamp, signature and reference number before originals are dispatched. |
APPLICABLE SPECIALIZED POLICIES
| Goods situation | Possible policy | Documents to check | Authority/portal if identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Commercially imported blush | Cosmetic notification, labeling control and PIF retention | Notification form, CFS, authorization letter, INCI, artwork | Drug Administration of Vietnam / National Single Window | Before market circulation; review before ETA | Missing or mismatched notification creates post-clearance risk. |
| Multiple shades/SKUs | Review notification scope and product naming | Shade list, SKU list, label artwork | Cosmetic notification system | Before finalizing documents | Mismatch between Packing List and notification may trigger questions. |
| Claims such as SPF/whitening/acne/treatment | Review cosmetic claim boundary and advertising compliance | Artwork, website, claim sheet, supporting data if any | Relevant cosmetic/advertising authority | Before label printing and import | Treatment or sunscreen claims may complicate dossier review. |
| Sample/tester/commercial gift | Review import purpose, label and circulation plan | Invoice, packing, purpose explanation | Customs and specialized authority if relevant | Before ETA | Do not declare samples if goods will be sold commercially. |
| EPE/FDI/factory import | Review import regime, use purpose and domestic circulation | Contract, use plan, internal documents | Customs office managing the relevant regime | Before declaration | Domestic sale may trigger additional obligations. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document name/number | Issuing authority | Effective timing | Role in the procedure | Key articles/appendices | Review note |
|---|---|---|---|---|---|---|
| Circular | Circular 06/2011/TT-BYT on cosmetic management, as amended including Circular 34/2025/TT-BYT | Ministry of Health | Circular 34/2025/TT-BYT effective from 18 Aug 2025 | Cosmetic notification, PIF, labeling and import management | Provisions on notification, PIF, labeling and import | Check the consolidated/current version at dossier time. |
| Decree | Decree 26/2023/ND-CP | Government | Effective from 15 Jul 2023 | MFN import tariff schedule | Appendix II, heading 33.04 | Used for MFN review; does not replace FTA tariff schedules. |
| Decree | Decree 174/2025/ND-CP | Government | Effective from 01 Jul 2025 to 31 Dec 2026 | VAT reduction policy if eligible | Exclusion appendices and conditions | Do not assume 8% VAT without HS/policy review. |
| Decree | Decree 43/2017/ND-CP and Decree 111/2021/ND-CP | Government | Check current validity at circulation time | Imported goods labeling | Mandatory label contents and Vietnamese supplementary label | Must be read together with cosmetic labeling rules. |
| Origin regulations | Regulations implementing ATIGA, ACFTA, AKFTA, VKFTA, AJCEP, VJEPA, EVFTA, UKVFTA, CPTPP, RCEP… | MOIT/Government | By each agreement | Special preferential duty under C/O | Origin rules, direct consignment, third-party invoice | Review by actual route and documents. |
VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS
Businesses should search the official document number on the Government e-document portal, legal document database or the issuing authority’s website 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 claiming preference, catalogue, product photos and shade/SKU list.
Cosmetic regulatory documents
Cosmetic product notification, CFS, authorization letter, label artwork, INCI list, PIF, COA/SDS if available and Vietnamese label dossier.
| Document group | Required documents | Used for | Usually prepared by | Common errors | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, B/L/AWB, Contract/PO | Declaration, duty calculation and cargo release | Importer, seller, forwarder | Generic product name, missing shade/SKU | Compare against notification dossier and label. |
| Origin | C/O or origin document | Special preferential duty | Seller, exporter, importer | Wrong form, HS or origin criterion | Check form, HS, description, issue date and direct shipment. |
| Cosmetic notification | Notification form, CFS, authorization letter, product documents | Market circulation and specialized review | Brand owner, importer, regulatory team | Product/manufacturer name mismatch | Check every product name, shade/SKU and brand. |
| Label/PIF | Artwork, supplementary label, INCI, PIF, COA/SDS if any | Post-clearance and circulation control | Importer, brand owner | Missing ingredients, batch, expiry or warnings | Review mandatory content and claims before ETA. |
100% matching rule: product name, quantity, shade/SKU, origin, manufacturer, batch, expiry date and ingredients should match across commercial documents, notification dossier, label, PIF and customs declaration.
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended handling |
|---|---|---|---|---|
| HS Code | Is the blush powder or cream/liquid/stick? | Catalogue, photos, artwork, INCI | Wrong duty and HS challenge | Lock HS before ETA and prepare form explanation. |
| Cosmetic notification | Is the notification number valid and for the right product? | Notification, authorization letter, CFS | Insufficient circulation basis or dossier supplement | Compare product name, brand, manufacturer and shade/SKU. |
| Labeling | Are original/supplementary labels complete? | Artwork, supplementary label, product photos | Label supplement or explanation request | Approve label before shipment. |
| C/O | Is special preferential duty supported? | C/O, invoice, B/L | Preference denial and duty adjustment | Review form, origin criterion and direct consignment. |
| Claim | Does it contain treatment, SPF, whitening or acne claims? | Label, website, marketing material | Claim may exceed cosmetic boundary | Review claim before notification and import. |
PRACTICAL E2E PROCEDURE
Step 1 – Pre-ETA review
Lock product form, HS, duty, C/O, notification dossier, label and claim risks. Prepare a shade/SKU list for multi-shade shipments.
Step 2 – Freeze commercial and technical documents
Compare Invoice, Packing List, B/L/AWB, catalogue, artwork, INCI, notification and authorization/CFS.
Step 3 – Complete notification/label where required
Prepare cosmetic notification before market circulation; review Vietnamese label and PIF readiness.
Step 4 – Open customs declaration
Green channel: system-based release. Yellow channel: document inspection. Red channel: document and physical inspection.
Step 5 – Clearance and post-clearance control
Move goods to warehouse, apply supplementary labels where required, file lot documents and prepare explanation dossier.
Step 6 – Circulation control
Control commercial claims, advertising, expiry, batch, storage condition and distribution documents.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA control | Documents to check |
|---|---|---|---|
| Generic “cosmetics/makeup” description | Customs requests catalogue/HS explanation | State blush, product form and shade/SKU clearly | Invoice, Packing List, catalogue |
| Wrong HS between 3304.91.00 and 3304.99.90 | Wrong duty, C/O issue and clearance delay | Confirm finished product form before declaration | Artwork, photos, INCI |
| Missing or wrong cosmetic notification | Post-clearance/circulation risk | Check notification number and product name | Notification, CFS, authorization |
| Wrong C/O form or origin criterion | No special preferential duty | Review C/O before shipment departure | C/O, invoice, B/L |
| Claim exceeding cosmetic boundary | Label/notification/advertising correction | Review claims before label printing and import | Artwork, website, marketing material |
| Shade/SKU mismatch | Dossier supplement and delay | Prepare shade/SKU reconciliation table | Packing List, SKU list, notification |
FAQ
1. Does blush require an import license?
Blush is a cosmetic product. The importer must review cosmetic notification and circulation requirements; do not conclude no license/dossier is needed without checking actual documents.
2. What is the main HS for blush?
Powder blush is commonly reviewed under 3304.91.00; cream/liquid/stick blush may require 3304.99.90 or another suitable code based on actual nature.
3. Can C/O reduce duty?
Yes, if the C/O/origin document is valid and the HS line is eligible under the applicable FTA tariff schedule.
4. Is Vietnamese supplementary labeling required?
Imported goods circulated in Vietnam should be reviewed for Vietnamese labeling under general labeling rules and cosmetic-specific rules.
5. Are tester/sample goods handled the same as commercial goods?
It depends on purpose and quantity, but cosmetic policy, labeling, customs documents and circulation risk still need review.
6. What if the invoice name differs from the notification dossier?
Review immediately before ETA; if product nature, brand, shade or manufacturer differs, commercial or notification documents may need correction.
RELATED ARTICLES
IMPLEMENTATION SUPPORT FROM TGIMEX
This article provides the HS, duty, cosmetic notification, C/O, labeling and risk-control map for blush imports. In real shipments, businesses should still review catalogue, INCI, artwork, documents, origin and import purpose.
Coordination capacity
- Agent network in more than 60 countries.
- Membership in WCA, WCA China Global, VLA and HNLA.
- Sea, air, road and rail logistics capability.
Support scope
- Pre-ETA HS, duty, C/O and cosmetic policy review.
- Cross-check Invoice, Packing List, B/L/AWB, notification dossier, label and PIF.
- Customs declaration, Green/Yellow/Red channel handling and post-clearance filing.
For shipments involving cosmetic notification, C/O or labeling requirements, businesses should not wait until cargo arrival to review documents. Even a small mismatch between Invoice, Packing List, catalogue, artwork, C/O or label can cause document supplement requests, clearance delays or unplanned storage charges.
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