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IMPORT PROCEDURE GUIDE FOR FOUNDATION
Foundation is a facial makeup product, but import documents should not describe it merely as “makeup/cosmetics”. Businesses should confirm the product form, formula, notified claims, HS Code, cosmetic notification number and label content before the shipment arrives.
If cream/liquid foundation is confused with powder foundation, cushion or concealer; if the authorization letter/CFS is missing; if the product name differs across notification, invoice and original label; or if SPF/whitening/acne claims exceed the cosmetic scope, the shipment may be queried, delayed, denied preferential C/O treatment or incur DEM/DET charges.
This guide provides an E2E (End-to-End) review map before ETA, covering HS classification, duties, C/O, cosmetic notification dossier, labeling, PIF and key risk points to control before customs declaration.
Legal note: This guide applies only to foundation in cream, liquid, lotion or stick form for facial makeup. It does not automatically apply to cushion, powder, lipstick, tint, blush, eyeliner, mascara or concealer. Review actual catalogue, formula/INCI, label artwork, claims, SKU and import purpose.
QUICK FACT
| Item | Foundation review point | Pre-ETA control point |
|---|---|---|
| Product | Foundation for facial base makeup, usually in cream, liquid, lotion, stick or pump bottle form. | Do not group with cushion, powder or concealer if the product form/function is different. |
| Reference HS | Main reference: 3304.99.30 – face creams and lotions or other skin preparations. True powder/pressed foundation may require review under 3304.91.00. | Compare trade description, physical form, label, formula and product photos. |
| Tax reference | For 3304.99.30: reference MFN 18%, ordinary import duty 27%, VAT 8%/10% depending on the VAT policy and conditions. | Confirm on the customs declaration date and actual C/O. |
| Specialized management | Imported cosmetics placed on the Vietnamese market require a cosmetic product notification receipt number; the dossier usually includes the notification form, authorization letter and CFS where applicable. | Submit/check notification before commercial shipment planning. |
| Label/PIF | Cosmetic labeling must comply with specialized rules; the responsible company must maintain the PIF (Product Information File). | Product name, batch/lot, INCI, function, warnings and responsible entity must match. |
SCOPE OF APPLICATION
Covered foundation products
- Liquid foundation, cream foundation, serum foundation, foundation stick or facial base lotion.
- Finished products packed for retail or commercial distribution in Vietnam.
- New products with original label, batch number, expiry date, manufacturer/owner and matching notification dossier.
Not automatically covered
- Cushion foundation with sponge/refill/compact case.
- Powder foundation, loose powder or pressed powder, which may fall under 3304.91.00.
- Concealer, primer, BB/CC cream, sunscreen-foundation or products with acne/whitening/therapeutic claims.
Actual catalogue, label artwork, formula/INCI, SKU and import purpose must be reviewed. Samples, testers, gift-with-purchase items, R&D samples or exhibition goods may trigger different requirements from normal commercial imports.
PRODUCT CLASSIFICATION & IDENTIFICATION
Foundation should be identified by product form, application area, primary function and claims. Generic descriptions such as “cosmetics”, “makeup” or “face product” may lead to wrong HS classification, incomplete notification dossier or incorrect labeling.
| Criterion | Documents to compare | Risk if inaccurate | Suggested goods description |
|---|---|---|---|
| Product form | Catalogue, product image, original label, COA/specification if available. | Confusing cream/liquid foundation with powder foundation; incorrect HS and duties. | “Liquid foundation for facial makeup, shade…, net volume…” |
| Claims/function | Label artwork, brand website, marketing materials, notification form. | Acne treatment, melasma treatment or antibacterial claims may exceed cosmetic scope. | Use cosmetic function: base makeup, light coverage, evening skin tone. |
| INCI formula | Formula, ingredient list, PIF, safety assessment, CFS where applicable. | Restricted/prohibited ingredients or mismatched UV filters may be exposed during post-market control. | INCI does not need to be declared fully on customs declaration but must match notification and label. |
| SKU/shades | SKU list, shade list, packing list, invoice. | Mismatch of shade/model between documents and labels complicates physical inspection. | State SKU or shade range where multiple shades are imported. |
HS CODE – DUTY – C/O
Classification principle: Foundation is classified by product nature, not trade name alone. The following HS/duty information is operational reference only and must be verified against the tariff schedule in force on the customs declaration date.
| Reference HS | When applicable | Identification basis | Risk if misapplied | Documents to check |
|---|---|---|---|---|
| 3304.99.30 | Cream, liquid, lotion or stick foundation used for facial makeup. | Heading 3304; “other”; face creams and lotions/other skin preparations. | If the product is a true powder, customs may reclassify and reassess duty. | Catalogue, product photo, label, packing, formula/INCI, notification. |
| 3304.91.00 (exclusion/review) | Only for true powder or pressed powder foundation. | Powder/pressed form rather than cream/lotion. | Not applicable to liquid foundation merely because the marketing says “powdery finish”. | Product photo, texture, formula and label. |
| 3304.99.90 (fallback review) | Other makeup/skin preparations not fitting 3304.99.30 or 3304.91.00. | Requires case-by-case classification review. | Should not be used as a blanket code for all cosmetics. | Technical dossier, sample, function and claims. |
| Tax item | Reference rate | Condition | Operational note |
|---|---|---|---|
| MFN import duty | 18% | Origin eligible for MFN and no special preferential C/O used. | Check the tariff decree in force on declaration date. |
| Ordinary import duty | 27% | Where MFN/FTA conditions are not satisfied. | Use as contingency in import cost review when origin documents fail. |
| VAT | Standard 10%; possible 8% if eligible under current VAT reduction policy. | VAT reduction under Decree 174/2025/ND-CP applies uniformly across import, production, processing and trade if not excluded. | Check excluded appendices and customs system treatment before declaration. |
| Special consumption/environmental protection tax | Usually not applicable to finished foundation. | Recheck if product/packaging/transport conditions are unusual. | MSDS should still be reviewed for flammable solvents or aerosol forms. |
| FTA/C/O | Market | Reference rate | Conditions to check | Common risk |
|---|---|---|---|---|
| ATIGA – Form D/e-Form D | ASEAN | 0% | ASEAN origin, valid origin criterion, matching goods description. | Wrong origin criterion or mismatch with invoice/declaration. |
| ACFTA – Form E | China | 0% reference; RCEP China may be higher. | Select the most beneficial FTA but meet its rules of origin. | Using RCEP when ACFTA is more favorable; Form E discrepancies. |
| VKFTA/AKFTA | Korea | VKFTA 0%; AKFTA 5% reference. | Check form, origin criterion, exporter/manufacturer and transport documents. | Confusing VKFTA and AKFTA; manufacturer mismatch. |
| VJEPA/AJCEP | Japan | 0% reference. | Japan origin and direct transport conditions. | Third-party invoice not reflected properly. |
| EVFTA/UKVFTA | EU/UK | Approx. 2.5% reference for 2026. | Valid proof of origin and threshold requirements. | Insufficient proof for post-clearance audit. |
| CPTPP/AANZFTA/VCFTA/VN-EAEU | CPTPP, AU/NZ, Chile, EAEU | Many cases 0%. | Correct agreement, proof of origin and transport route. | Preferential duty denied due to transport or document defects. |
Quick tax treatment matrix
| Document scenario | Import duty treatment | VAT treatment | Items to lock before ETA |
|---|---|---|---|
| No special preferential C/O but MFN condition is met | Reference MFN 18% for 3304.99.30. | Standard 10% or 8% if VAT reduction remains applicable and goods are not excluded. | Origin, goods description, HS code and declaration date. |
| Valid special preferential C/O available | Apply the corresponding FTA rate only when rules of origin and document conditions are satisfied. | VAT is handled independently under VAT rules. | C/O form, origin criterion, direct transport, third-party invoicing and goods description. |
| C/O rejected or submitted later | Duty may revert to MFN/ordinary treatment or require later adjustment/refund procedures. | VAT base may need to be checked after duty adjustment. | C/O submission timeline, customs record and explanation letter. |
| Powder foundation wrongly declared under cream/lotion HS | Possible reclassification to 3304.91.00 and reassessment. | VAT follows the applicable code/policy at processing time. | Sample/photo, texture, formula, packing and invoice description. |
Pre-ETA tax lock checklist: finalize HS, VAT treatment, country of origin, applicable FTA/C/O, and cross-check product name, form, shade count and packing across Invoice, Packing List, label and cosmetic notification.
SPECIALIZED MANAGEMENT MATRIX
| Scenario | Possible policy | Documents | Authority/portal | Timing | Risk note |
|---|---|---|---|---|---|
| Commercial imported foundation | Cosmetic product notification, label, PIF and customs dossier. | Notification, authorization letter, CFS if required, INCI, label. | Drug Administration of Vietnam via National Single Window. | Before ETA, preferably before booking. | No notification or mismatched product name may delay clearance/distribution. |
| SPF foundation | Cosmetic rules plus review of UV filters, efficacy evidence and mandatory warnings. | Formula, SPF/PA test if available, PIF, label. | DAV/post-market control. | Before notification and label printing. | Wrong sunscreen claim or restricted filter issue. |
| Acne/whitening/antibacterial claims | Regulatory borderline review; do not assume cosmetic status if therapeutic claims exist. | Artwork, claims, active ingredients, evidence dossier. | DAV and relevant authorities. | Before notification and marketing. | May require claim revision or different regulatory pathway. |
| Samples/testers/gifts | If placed on the market, control as commercial cosmetics; R&D/testing has separate rules. | Purpose, quantity, “not for sale” label if applicable. | Provincial health authority/DAV depending on case. | Before import. | Tester sold or gifted without notification is high risk. |
| Flammable solvent/aerosol/set | Transport DG review and item-by-item policy for sets. | MSDS/SDS, packing instruction, set composition. | Carrier/forwarder/customs. | Before booking. | Improper DG declaration may cause refusal or penalty. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document | Issuer | Effective timing | Role | Key articles/appendices | Review note |
|---|---|---|---|---|---|---|
| Cosmetics regulation | Circular 06/2011/TT-BYT as amended; consolidated version including Circular 34/2025/TT-BYT. | Ministry of Health | Circular 06 effective from 01/04/2011; amendments follow each document. | Notification, label, PIF, safety and post-market control. | Articles 5, 6, 10, 11, 12, 17, 18, 19, 35, 48; Appendices 01-MP, 02-MP, 07-MP. | Check the current consolidated text before dossier submission. |
| Administrative procedure | Procedure for issuing cosmetic product notification receipt for imported cosmetics. | MOH/DAV | Applied via National Single Window. | Dossier components, processing timeline and fee. | Notification, authorization letter, CFS, 03/05 working days. | Check latest DAV/NSW instructions. |
| Labeling | Decree 43/2017/ND-CP amended by Decree 111/2021/ND-CP. | Government | Decree 111 effective from 15/02/2022. | General labeling requirements in addition to cosmetic label rules. | Mandatory content, origin and supplementary label. | Cosmetics must also comply with specialized cosmetic labeling rules. |
| Tariff | Decree 26/2023/ND-CP and amendments if any. | Government/MOF | Effective from 15/07/2023; update if amended. | MFN tariff basis. | Chapter 33, heading 3304, subheading 330499. | Do not rely on outdated duty rates. |
| VAT | Decree 174/2025/ND-CP. | Government | Effective 01/07/2025. | Review possible 8% VAT application. | Article 1 and exclusion appendices. | Verify the excluded list at declaration date. |
VIEW / DOWNLOAD ORIGINAL DOCUMENTS
Businesses should verify legal documents by number through official legal databases or the issuing authority’s website before application.
Consolidated cosmetics regulation
Imported cosmetics notification procedure
National Single Window
Decree 26/2023/ND-CP – MFN tariff schedule
Decree 174/2025/ND-CP
Imported cosmetics notification procedure
National Single Window
Decree 26/2023/ND-CP – MFN tariff schedule
Decree 174/2025/ND-CP
CUSTOMS CLEARANCE DOCUMENT SET
Commercial documents
- Commercial Invoice.
- Packing List with SKU/shade/quantity/unit.
- Bill of Lading/Air Waybill.
- Sales Contract/Purchase Order if any.
- C/O if claiming preferential duty.
- Catalogue, product photos, original label, shade/SKU list.
Cosmetics specialized documents
- Cosmetic product notification receipt number.
- Valid authorization letter from manufacturer/product owner.
- CFS if required or exemption basis if applicable.
- Formula/INCI, PIF, label, COA/specification, MSDS/SDS when needed.
- Evidence for SPF, waterproof, whitening or oil-control claims if any.
| Dossier group | Required documents | Used for | Prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Cosmetic notification | Notification, authorization letter, CFS/exemption basis, formula. | Specialized management compliance. | Importer/Regulatory/Legal. | Product name, brand, manufacturer mismatch. | Compare with invoice, label and packing list. |
| Labeling | Original label, Vietnamese supplementary label, artwork, INCI. | Market circulation/post-market control. | Brand/Importer/Compliance. | Missing responsible entity, warning or expiry data. | Check cosmetic labeling rules and general goods labeling rules. |
| HS–tax–C/O | Catalogue, C/O, invoice, transport document. | Customs declaration and preferential duty. | Docs/CUS/Forwarder. | Wrong C/O form, origin criterion or HS. | Check draft C/O before issuance. |
| Transport | MSDS/SDS and packing instruction if flammable/aerosol risk exists. | Booking and DG declaration. | Shipper/Forwarder/Carrier. | DG not declared correctly. | Request MSDS before booking, especially for air freight. |
CLEARANCE DECISION POINTS
| Decision point | Question | Evidence | Consequence if unclear | Recommended action |
|---|---|---|---|---|
| Notification number | Has commercial foundation been notified? | Notification receipt/NSW result. | Delayed clearance/distribution risk. | Complete notification before ETA. |
| HS suitability | Is it liquid/cream or powder foundation? | Catalogue, photo, label, formula. | Duty reassessment and C/O denial. | Document classification basis. |
| Claims | Any therapeutic, acne, melasma or antibacterial claim? | Artwork, website, PIF, evidence. | Regulatory query/post-market risk. | Review claims before notification and label. |
| C/O eligibility | Does C/O form, origin criterion and invoice match? | C/O, invoice, packing list, B/L/AWB. | No FTA duty benefit. | Check draft C/O before original issuance. |
| Label | Are product name, function, INCI, batch, expiry and warnings sufficient? | Original/supplementary label, notification. | Post-market control issue. | Complete labeling checklist before printing. |
PRACTICAL E2E PROCESS
Step 1: Pre-ETA review
Lock product form, HS, tax, C/O, cosmetic notification, label, PIF and MSDS/SDS where needed.
Step 2: Freeze documents
Finalize invoice, packing list, B/L/AWB, shade list, quantity, net content, origin and manufacturer.
Step 3: Complete cosmetics dossier
Check notification number, authorization letter, CFS/exemption basis, label and PIF before arrival.
Step 4: Customs declaration
Green Lane: system-based clearance; Yellow Lane: document inspection; Red Lane: document and physical inspection.
Step 5: Clearance and delivery
Deliver to warehouse, manage supplementary label if required, count lots/shades and archive documents.
Step 6: Post-clearance control
Maintain PIF, notification, import documents, label, C/O and quality records for inspection.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | How to prevent | Documents to check |
|---|---|---|---|
| No/mismatched cosmetic notification | Clearance/distribution delay. | Check notification before booking. | Notification, label, invoice, SKU list. |
| Wrong HS between 3304.99.30 and 3304.91.00 | Wrong duty, reassessment or C/O denial. | Confirm physical form and product photos. | Catalogue, sample, photo, formula. |
| C/O defects | Preferential duty denied. | Review draft C/O against invoice/declaration. | C/O, invoice, packing, B/L/AWB. |
| Claims exceed cosmetic scope | Dossier/label/advertising risk. | Revise or substantiate claims before notification. | Artwork, PIF, claim evidence. |
| Supplementary label incomplete | Post-market control issue. | Review label before printing. | Original label, supplementary label, notification. |
FAQ
Does foundation need cosmetic notification?
Yes, if imported for circulation/business in Vietnam. A notification receipt number is required before market placement.
Does foundation need a separate import license?
The main control is cosmetic notification, label and customs dossier. Special claims, samples or unusual formula must still be reviewed.
What is the HS for foundation?
Cream/liquid foundation is usually reviewed under 3304.99.30. Powder foundation may require 3304.91.00.
Can C/O reduce duty?
Yes, if the proof of origin is valid and origin rules are satisfied.
Is SPF foundation sunscreen?
Claims, UV filters and supporting evidence must be reviewed. Do not conclude by trade name alone.
Do testers or mini sizes need notification?
If placed on the market or gifted for consumer use, they should be controlled as circulating cosmetics.
RELATED ARTICLES
IMPLEMENTATION SUPPORT FROM TGIMEX
This guide provides a regulatory map for foundation imports. Actual shipments still require review against catalogue, formula/INCI, label artwork, documents, origin and import purpose.
Pre-ETA review
HS, notification, C/O, tax, label, PIF, catalogue, formula/INCI and MSDS/SDS.
Compliance dossier control
Cross-check invoice, packing list, B/L/AWB, C/O, notification, authorization letter, CFS and label.
International logistics
Coordinate agents, carriers, ETA, pre-alert and transport documents.
Customs and post-clearance
Prepare declaration dossier, manage customs lanes, support HS/origin/value explanation and archive records.
For foundation shipments involving cosmetic notification, C/O, labeling or sensitive claims, businesses should not wait until cargo arrival to review dossiers. Minor inconsistencies may result in additional document requests, clearance delay or unplanned storage costs.
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.
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