Tiếng Việt
中文 (中国)
COSMETICS – HAIR CARE
IMPORT PROCEDURE GUIDE FOR HAIR TONIC COSMETIC
Importing hair tonic cosmetic is not simply declaring a generic hair-care product. Wrong HS code, over-therapeutic claims, notification mismatch or inconsistent Vietnamese labelling may lead to document supplementation, loss of C/O preference and storage costs. This guide provides an E2E map for reviewing HS code, taxes, C/O, cosmetic dossier, labelling and pre-ETA risk points. For the product covered in this article, the importer should confirm the model, intended use, construction or composition, new/used condition, and technical documents before concluding the HS code, tax treatment, or specialist policy. The following sections organize the main controls from document receipt, catalogue and label review through dossier preparation, declaration, and coordination at the port of entry.
QUICK FACT – EXECUTIVE SUMMARY
| Item | Review direction |
|---|---|
| Product scope | Hair tonic cosmetic in liquid, spray, ampoule or light serum form for external use on hair/scalp, provided the dossier shows cosmetic nature. |
| Reference HS | 3305.90.00 – other preparations for use on the hair. Not applicable if the product is a medicine, health supplement or device bundle. |
| Tax reference | MFN 20%; normal duty reference 30%; planning VAT 10%; valid C/O may change duty under each FTA. |
| Main policy | Review cosmetic product notification, labelling, CFS/LOA, ingredients, claims, PIF and import dossier. |
| Key risk | Claims such as “treats hair loss”, “stimulates hair growth” or “treats scalp disease” may shift the product outside ordinary cosmetics. |
Legal note Hair tonic cosmetic is an external-use cosmetic product for hair/scalp. If the formula, label or claims indicate therapeutic treatment, hair-growth stimulation or disease-related anti-hair-loss effects, the product nature must be reviewed again; cosmetic import procedures should not be applied automatically to every SKU.
SCOPE OF APPLICATION
This article applies only to hair tonic cosmetic – an external-use cosmetic product for hair/scalp, commonly in liquid, spray, ampoule, light serum or scalp-care tonic form. It does not cover conditioner, hair mask, styling wax, therapeutic scalp medicine or oral products.
- Applicable to commercial imports, distribution, retail, samples or project goods where the product nature is cosmetic.
- Not automatically applicable to products with therapeutic, pharmaceutical anti-hair-loss or hair-growth claims.
- Samples, gifts and goods already sold overseas still require dossier-based review.
- Review catalogue, datasheet, formula, original label, claims, CFS/LOA and actual import purpose.
CLASSIFICATION & PRODUCT IDENTIFICATION
Product nature
Hair tonic cosmetic is generally an external-use preparation left on hair or scalp for mild cleansing, soothing, moisturizing or scalp/hair care within cosmetic scope.
Technical documents
Check original label, catalogue, INCI formula, CFS/LOA, MSDS if any, packaging images, instructions, marketing claims and SKU list.
Boundary control
If the dossier says “treatment”, “anti-hair loss”, “hair growth”, “medicine” or “therapeutic scalp treatment”, legal/specialized review is required before declaration.
Goods description
Recommended wording: “hair tonic cosmetic, external-use hair/scalp preparation, liquid/spray form, brand…, volume…, brand-new goods”.
TECHNICAL IDENTIFICATION CRITERIA
| Criteria to check | Documents to compare | Risk if described incorrectly | Suggested customs/commercial description |
|---|---|---|---|
| Product form | Catalogue, packaging images, original label, instructions | May be mistaken as therapeutic serum, medicine or conditioner | Hair tonic cosmetic in liquid/spray form for external use on hair/scalp |
| Use and claims | Original label, brand website, Vietnamese label draft, notification dossier | Therapeutic claims may exceed cosmetic scope | Hair/scalp care, soothing/moisturizing/supporting healthy-looking hair within cosmetic scope |
| INCI ingredients | Formula, COA/MSDS if any, product notification | Ingredient inconsistency affects notification/labelling | Use INCI names and required formula disclosure in the dossier/PIF |
| Volume/packing | Invoice, packing list, original label, carton photos | Mismatch in quantity/value/labelling | Bottle/spray … ml; … pcs/carton |
| Origin/manufacturer | C/O, CFS, LOA, invoice, label | Wrong origin may invalidate FTA preference or labelling | State correct country of origin, manufacturer and brand owner if any |
HS CODE – DUTY – C/O
HS classification must be based on the product nature, hair-use function, application form and claims. The commercial term “tonic” alone is not sufficient because it can refer to cosmetics, medicines, supplements or other preparations.
| Reference HS | When applicable | Risk if misclassified | Documents to check |
|---|---|---|---|
| 3305.90.00 | Other preparations for use on the hair; generally applicable to external-use cosmetic hair tonic. | Wrong classification as medicine/therapeutic product may lead to customs queries or amendment. | Catalogue, label, INCI formula, notification, CFS/LOA, MSDS if any. |
| 3305.10.00 | Only if the actual product is shampoo/wash-off product. | Misidentifying hair tonic as shampoo changes HS and policy. | Use instruction, wash-off/rinse-off claims. |
| 3305.90.00 or other heading | If sold as hair serum/lotion/tonic but still a hair preparation. | Failure to determine product nature may trigger wrong specialized policy. | Product description, actual photos, label draft. |
| Heading 3004 or other policy | Only if claims/formula show medicinal treatment. | Cosmetic procedure cannot be used for medicinal products. | Claims, active ingredients, manufacturer legal dossier. |
DETAILED TAX TABLE TO REVIEW BEFORE CUSTOMS DECLARATION
Hair tonic cosmetic – HS 3305.90.00
MFN
20% reference according to Vietnam Trade Portal for 3305.90.00.
Normal duty
Reference 30% if MFN/FTA is not applicable and no separate normal rate is provided; based on 150% of MFN.
VAT
Planning VAT 10%; consider 8% only if eligible and not excluded.
C/O
Special preferential duty may apply if a valid C/O meets the relevant FTA rules; check form, origin criterion, description, HS and direct transport.
Potential reclassification
HS
If claims indicate treatment/medicine, do not automatically apply 3305.90.00.
Duty
Duty and policy follow the final HS classification.
VAT
Applied according to final product nature and current VAT policy.
Control
Lock claims, formula, label and notification dossier before ETA.
Samples/gifts/marketing goods
HS
Classify by product nature; usually review 3305.90.00 if cosmetic hair tonic.
Duty
Do not assume duty exemption; check value and import purpose.
VAT
Plan 10% unless a clear basis says otherwise.
Dossier
Invoice, packing list, import purpose, product photos and explanation if required.
Hair-care set with other products
HS
If imported as a set, review set classification or split lines by product.
Duty
May differ by each product.
VAT
According to actual HS/product situation.
Risk
Generic “hair care set” wording may trigger HS, quantity and notification questions.
SPECIAL PREFERENTIAL C/O/FTA REVIEW
| Route/origin | C/O form/origin document | Special preferential duty to verify | Conditions & risks |
|---|---|---|---|
| ASEAN/ATIGA | Form D | May be 0% If the ATIGA form for the corresponding HS code has been committed and the C/O is valid. | Check WO/RVC/CTH/CTSH, product description, HS, direct shipping. |
| Trung Quốc | Form E hoặc RCEP | Verify ACFTA/RCEP level at the time of opening the declaration; Not automatically applied if C/O does not meet criteria. | Risk of third party invoice, wrong description “cosmetic hair tonic”, wrong HS. |
| Hàn Quốc | Form AK/VK hoặc RCEP | Verify according to AKFTA/VKFTA/RCEP; Select agreements with good tax rates and appropriate records. | Compare origin, manufacturer, invoice, and direct shipping. |
| Nhật Bản | VJEPA/AJCEP/CPTPP/RCEP | Verify commitments according to each agreement; Do not mix documents between mechanisms. | Wrong form or origin criteria may result in loss of incentives. |
| EU/UK | EUR.1, EVFTA/UKVFTA self-certification document of origin if eligible | Verify EVFTA/UKVFTA levels and self-certification conditions. | Need to check the exporter’s eligibility, product description, HS, document issuance date. |
| Úc/New Zealand/Ấn Độ/Hong Kong | AANZFTA/CPTPP/RCEP, AIFTA, AHKFTA | Verify each route according to actual documents. | Do not use this C/O route for goods of origin or transportation that do not meet the conditions. |
Pre-ETA C/O checklist
- Correct C/O form/origin document for the selected route.
- Origin criterion WO/RVC/CTH/CTSH matches the product-specific rule.
- Goods description, HS, quantity, weight and origin match invoice/packing list.
- Check third-party invoice if any.
- Check direct transport, issuance date, signature/stamp or electronic mechanism.
APPLICABLE SPECIALIZED POLICY MATRIX
| Goods situation | Possible policy | Documents to check | Authority/portal if identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Ordinary cosmetic hair tonic | Cosmetic product notification, labelling and import dossier. | Notification, CFS/LOA, formula, original label, Vietnamese label, invoice/packing list. | Cosmetic notification authority and customs. | Before declaration/circulation. | Do not wait until arrival to correct claims. |
| Treatment or hair-growth claims | Review cosmetic vs medicine/product treatment boundary. | Claims, ingredients, scientific evidence, label, website. | Relevant authority after product nature is determined. | Before booking or ETA. | Do not treat as cosmetic if dossier shows therapeutic nature. |
| Hair-care set | Review each SKU; separate cosmetic notification may be required. | SKU list, formula, claims, volume, label. | Notification authority/customs. | Before invoice finalization. | SKU mismatch affects notification and declaration. |
| Samples/test/marketing goods | Review import purpose, value, label and notification obligations. | Invoice, purpose, photos, contract/explanation. | Customs/specialized authority if required. | Before ETA. | Samples are not automatically exempt from specialized obligations. |
| EPE/FDI/factory use | Review customs type and whether for internal use or circulation. | Contract, invoice, packing list, use/storage process. | Customs office managing the type. | Before declaration. | Wrong type affects tax and audit. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Name/number | Issuing body | Effective date/application | Role | Key clauses/appendices to check | Review note |
|---|---|---|---|---|---|---|
| Cosmetics circular | Circular 06/2011/TT-BYT | Ministry of Health | Check consolidated/amended version | Cosmetics management, notification, labels, PIF. | Cosmetic notification dossier and responsible organization obligations. | Not sufficient if product is non-cosmetic. |
| Amending circular | Circular 34/2025/TT-BYT | Ministry of Health | Issued 03/07/2025, effective 18/08/2025 | Amends Circular 06/2011/TT-BYT. | Changes to notification form/dossier and filing method. | Apply by effective date. |
| Labelling decree | Decree 43/2017/NĐ-CP and 111/2021/NĐ-CP | Government | Check current validity | Imported goods labelling and Vietnamese supplementary label. | Mandatory label contents, origin, responsible party. | Vietnamese label must match notification and original label. |
| Tariff schedule | Decree 26/2023/NĐ-CP and amendments | Government | Effective 15/07/2023 | MFN import duty basis. | Chapter/heading 3305. | Always re-check at declaration date. |
| Normal duty | Decision 15/2023/QĐ-TTg | Prime Minister | Effective 15/07/2023 | Normal import duty basis. | 150% of MFN if no separate rate and no MFN/FTA applies. | Does not replace FTA preference. |
| Customs | Customs Law and guiding decrees/circulars | National Assembly/Government/Ministry of Finance | By document validity | Declaration, inspection and post-clearance audit. | Value, HS, origin, specialized policy. | Check by customs type. |
VIEW / DOWNLOAD ORIGINAL LEGAL SOURCES
Companies should cross-check legal documents on official legal databases or issuing authorities’ websites before application. These buttons are quick references only and do not replace validity checks at the declaration date.
CUSTOMS CLEARANCE DOSSIER
Commercial documents
- Commercial Invoice.
- Packing List.
- Bill of Lading/Air Waybill.
- Sales Contract/Purchase Order if any.
- C/O if claiming preferential duty.
- Catalogue, product photos, original label, SKU list.
Cosmetics specialized dossier
- Cosmetic product notification receipt number.
- CFS/LOA or authorization documents depending on dossier.
- Ingredient/INCI formula, original label, Vietnamese label.
- PIF for retention and explanation.
- Claims/website/brochure materials to control cosmetic boundary.
OPERATIONAL DOSSIER CHECKLIST
| Dossier group | Required documents | Used for | Prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, B/L/AWB, contract/PO | Declaration, value and quantity | Importer, seller, forwarder | Mismatch in name/volume/quantity/value | Cross-check 100% with label, notification and catalogue. |
| Product technical | Catalogue, product photo, original label, INCI formula | HS and cosmetic policy | Manufacturer/brand owner | Therapeutic claims or vague description | Lock label and claims before document release. |
| Cosmetic notification | Notification, CFS/LOA and related dossier | Circulation/import condition evidence | Legal/Compliance/responsible party | Different product name/SKU/volume | Match name, form, ingredients and responsible party. |
| Origin | C/O, direct transport document, third-party invoice if any | Preferential duty | Shipper/exporter/importer | Wrong form/criterion/HS | Check form, HS, description, date and signature/stamp. |
| Labelling | Original label, Vietnamese supplementary label, packaging photos | Circulation/post-clearance | Importer/brand/compliance | Vietnamese label inconsistent with notification | Compare label with notification and labelling rules. |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended action |
|---|---|---|---|---|
| HS code | Is there sufficient basis for 3305.90.00? | Label, catalogue, formula, claims | Customs HS query or amendment | Prepare classification explanation. |
| Cosmetic nature | Does the product make therapeutic claims? | Claims, website, brochure, label | May not be ordinary cosmetic | Review claims before notification and labelling. |
| Notification | Does the notification match imported goods? | Notification, label, invoice | Supplementation/explanation request | Lock SKU, name, volume and ingredients before ETA. |
| C/O | Is preferential duty valid? | C/O, invoice, B/L, transport documents | Loss of preference or tax adjustment | Check C/O before declaration. |
| Vietnamese label | Does it match original label and notification? | Vietnamese label draft, original label, notification | Post-clearance/circulation risk | Approve Vietnamese label before arrival. |
PRACTICAL E2E WORKFLOW
Step 1 – Pre-ETA review
- Confirm cosmetic hair tonic nature and reference HS 3305.90.00.
- Review cosmetic notification, label, claims, C/O, duty and VAT.
- Check cosmetic vs medicine boundary for sensitive claims.
Step 2 – Lock documents
- Finalize Invoice, Packing List and B/L/AWB.
- Lock catalogue, original label, INCI formula and SKU list.
- Ensure product name, quantity, volume and origin match 100%.
Step 3 – Complete specialized dossier
- Check cosmetic product notification receipt number.
- Prepare CFS/LOA/PIF/Vietnamese label as applicable.
- Do not wait until ETA to correct claims or ingredients.
Step 4 – Customs declaration
- Prepare explanation for Green/Yellow/Red channel if required.
- Prepare HS, value, C/O, cosmetic notification and label evidence.
- Monitor any request for additional documents.
Step 5 – Clearance and post-clearance
- Deliver goods to warehouse and check label, lot/date/expiry if any.
- Archive declaration, documents, notification, C/O and labels.
- Prepare explanation dossier for post-clearance/circulation inspection.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA prevention | Documents to check |
|---|---|---|---|
| Over-therapeutic claims | Product may be challenged as non-cosmetic | Review label and marketing claims | Label, website, brochure, formula |
| Notification mismatch | Document supplementation/explanation | Match notification with invoice/packing/label | Notification, invoice, label |
| Invalid C/O | Loss of preferential duty | Check form, criterion, HS and description | C/O, invoice, B/L |
| Generic “hair product” description | HS/policy query | Describe as hair tonic cosmetic with form and volume | Catalogue, label, declaration |
| Incomplete Vietnamese label | Circulation/post-clearance risk | Approve Vietnamese label before arrival | Original label, Vietnamese label, notification |
| No PIF/quality file | Hard to explain during inspection | Set product and lot dossier | PIF, COA/MSDS if any, formula |
FAQ – COMMON BUSINESS QUESTIONS
Does imported hair tonic cosmetic need cosmetic notification?
Yes, if determined as cosmetic and placed on the Vietnamese market, the cosmetic product notification must be reviewed according to the actual dossier.
What is the HS code?
Reference HS is 3305.90.00 for other preparations for use on the hair. Final HS depends on nature, claims, ingredients and documents.
What are the taxes?
For reference HS 3305.90.00, MFN 20%, normal duty reference 30%, planning VAT 10%.
Can C/O reduce duty?
Possibly, if the C/O is valid and the relevant FTA provides preference for the HS code.
Can “anti-hair-loss treatment” still be cosmetic?
Do not assume. Therapeutic or hair-growth claims require product nature review before applying cosmetic procedure.
Do samples follow the same procedure?
They must still be declared by product nature and import purpose. Notification/labelling/tax obligations depend on actual use and circulation.
What if invoice name differs from notification?
Resolve before declaration; mismatch in name, SKU, volume or label may trigger supplementation or explanation.
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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