Powder cosmetics, including loose powder and pressed powder, are often described too generally as “cosmetic”, “make-up powder” or “face powder” on commercial documents. In practice, the customs and compliance file must clearly evidence the product form, cosmetic use, ingredients, label and cosmetic product notification number. If HS Code 3304.91.00 is applied without sufficient basis, or if the product is confused with eye make-up, blush, raw powder ingredients or treatment products, the shipment may be requested for supplementary documents, routed for inspection, lose C/O preferential duty and incur DEM/DET charges. This article provides an E2E (End-to-End) map for pre-ETA review: HS code, duty, C/O, cosmetic notification, labelling, import documents and clearance decision points.

LEGAL NOTE: Powder must be assessed based on the actual file: formula/ingredients, original label, catalogue, product claims, packaging and cosmetic notification dossier. Not every “powder” should automatically be classified under the same HS code or the same policy if the actual product is eye shadow, blush, raw material, medicinal/treatment product or non-commercial sample.

QUICK FACTS FOR POWDER COSMETICS SHIPMENTS

Review group	What to check	Operational note
Product	Powder cosmetic products: loose powder, compact powder, setting powder, finishing powder, face powder or powder foundation where the product is powder.	Do not automatically apply to eye shadow, separate blush, lipstick, raw powder material or treatment products.
Reference HS	3304.91.00 – powders, whether or not compressed.	Check ingredients, use, label, retail packaging and commercial description.
Indicative taxes	MFN: 22%; ordinary duty reference: 33%; base VAT: 10%, review VAT reduction policy if eligible at declaration time.	Do not rely on old tariff or VAT policy.
Specialized policy	Cosmetic product notification; CFS, authorization letter, ingredients, claims, PIF and Vietnamese sub-label.	The notification receipt number is a key document point for imported cosmetics.
Main risks	Wrong HS, missing notification, excessive claims, mismatch in product name/shade/SKU, incorrect C/O form or origin criterion.	Review before ETA instead of supplementing after cargo arrival.

SCOPE OF APPLICATION

This article applies to finished powder cosmetic products in loose or pressed form used for make-up/skin appearance, such as loose powder, compact powder, pressed powder, setting powder, finishing powder, face powder or powder foundation if the product is essentially powder. It should not be automatically applied to liquid/cream foundation, cushion, lipstick, tint, eyeliner, mascara, concealer, eye shadow, raw powder ingredients, pharmaceutical powder, powder supplements or goods not placed on the market as finished cosmetics. New goods, samples, test marketing goods, gifts, warranty goods, EPE/FDI imports or non-commercial imports may require different handling. Review must be based on catalogue, datasheet, model/SKU, formula, label and actual import purpose.

CLASSIFICATION & TECHNICAL IDENTIFICATION

For powder cosmetics, the identification basis includes product form, area of use, claims, mineral/color ingredients, packaging form, shade/SKU and cosmetic notification documents. A generic description such as “powder” may be insufficient to distinguish it from eye make-up, blush, raw powder materials or products with medicinal indications.

TECHNICAL IDENTIFICATION CRITERIA

Technical criterion	Document to compare	Risk if described incorrectly	Suggested description on documents/declaration
Product form	Catalogue, product photos, original label, technical description	May be confused with cream/lotion, eye make-up or raw powder; wrong HS.	“Powder cosmetic, loose/pressed, brand…, shade…, net weight…”
Use/claim	Label, artwork, product brief, website claim	Treatment or medicinal claims may exceed cosmetic scope.	Describe cosmetic use such as make-up, oil control, setting or skin appearance.
Ingredients/INCI	Formula, ingredient list, MSDS/COA if any	Restricted/prohibited substances; mismatch with notification dossier.	Compare label, product notification and PIF.
Shade/SKU/model	Model list, packing list, carton label, photos	Mismatch between Invoice, Packing List, notification and label.	List all shades/SKUs when notification data differ.
Owner/manufacturer	CFS, authorization letter, Invoice, contract	Manufacturer/owner mismatch; notification may be queried.	Names, addresses and country of manufacture must be consistent.
Goods status	Invoice, packing list, contract, import purpose	Samples/gifts may be handled incorrectly as commercial goods or vice versa.	State new finished cosmetic goods and actual purpose.

HS CODE – DUTY – C/O

Powder cosmetics are generally reviewed under heading 33.04 for beauty/make-up and skin-care preparations. Where the product is powder, whether or not compressed, the reference HS code is 3304.91.00. However, if the actual goods are eye make-up, lip preparations, nail preparations, creams/lotions, raw powder ingredients or treatment products, HS classification may change.

Reference HS code	Applicable condition	Indicative duty	Risk if misclassified	Documents to check
3304.91.00	Powders, whether or not compressed, for make-up/skin appearance, packed as cosmetic products.	MFN 22%; ordinary reference 33%; base VAT 10%.	Wrong HS if actually eye make-up, blush, raw powder, medicinal or treatment product.	Catalogue, label, formula, notification, CFS/LOA, product photos.
3304.20.00	Only where the goods are eye make-up preparations rather than face powder.	Indicative MFN 22%.	Confusing powder with eye make-up can create HS and notification issues.	Use area, artwork, product brief.
3304.99.90 / other 33.04 codes	Only where the product is not powder but remains skin-care/make-up cosmetics.	Depends on the actual subheading.	Using “other” when a specific powder code exists may be challenged.	Ingredients, form, use, packaging.
3004 / pharmaceutical heading	Only if the product is a medicine or has disease treatment claims.	Not covered by this article.	High risk: permit, classification and clearance may change.	Claims, intended use, medical documents if any.

DUTY AND C/O/FTA REVIEW TABLE

Route/origin	Origin document	Duty to review	Application conditions	Risk if incorrect
No preferential C/O	Not available or only commercial origin evidence	Indicative MFN 22% if origin is from an MFN partner; ordinary reference 33% if MFN/FTA conditions are not met.	Correct HS, customs value and origin consistency.	Higher duty cost; origin may be queried if documents are unclear.
ASEAN/ATIGA	C/O Form D or accepted origin document	Special preferential duty may apply; many cosmetic tariff lines are low/0% subject to the effective tariff schedule.	Origin criterion, direct consignment, goods description and HS must match.	Wrong form, origin criterion or description may lead to rejection.
China/ACFTA or RCEP	C/O Form E or RCEP C/O	Review ACFTA/RCEP tariff schedule for the declaration year; do not automatically assume 0%.	Check origin criterion, third-party invoice, direct transport and country of origin.	Form E mismatches in description, HS or exporter often trigger explanation.
Korea/VKFTA, AKFTA or RCEP	C/O Form VK, AK or RCEP	Review each FTA and select the valid and most suitable treatment.	Goods must satisfy origin rules and transport/commercial documents must align.	Wrong form or agreement can deny preferential duty.
Japan/VJEPA, AJCEP, CPTPP or RCEP	C/O under the relevant agreement	Review the tariff schedule by agreement and actual origin.	Check PSR, invoice, transport route, export country and origin country.	Failure to prove origin or direct consignment.
EU/EVFTA, UK/UKVFTA	EUR.1 or origin statement where eligible	Review phase-down rate by year; some lines reduce gradually.	Eligible exporter, proper description and HS, valid origin statement.	Incorrect REX/statement content may invalidate the preference.
Australia–New Zealand/AANZFTA or CPTPP	Agreement C/O or accepted origin document	Review AANZFTA/CPTPP schedule by origin country and year.	Origin criterion, transport documents, invoice and packing list must match.	Confusing export country with origin country may cause wrong preference.

Pre-ETA C/O checklist

Check whether the C/O form or self-certification mechanism matches the selected FTA.
Check HS code, goods description, quantity, weight and value against Invoice/Packing List.
Check origin criteria such as WO, RVC, CTH or CTSH against the applicable PSR.
Check third-party invoice, back-to-back C/O or transit through a third country, if any.
Check issue date, signature/seal, country of origin and transport route.

SPECIALIZED POLICY MATRIX

Goods scenario	Policy that may apply	Documents to check	Authority/portal if identifiable	Recommended timing	Risk note
Finished powder imported for sale	Cosmetic product notification and labelling review.	Notification, CFS, authorization letter, formula, label, PIF.	Drug Administration of Vietnam – Ministry of Health; relevant public service portal.	Before ETA, preferably before booking.	Missing notification number may cause document queries.
Powder with special claims	Review cosmetic scope; avoid treatment/disease-prevention claims without basis.	Artwork, label, marketing content, product brief.	Drug Administration/Ministry of Health if clarification is needed.	Before finalizing label and notification.	Excessive claims may affect notification and classification.
Multiple shades/SKUs	Each variant should be checked against notification and ingredient/color data.	Shade list, color formula, label per SKU, packing list.	Cosmetic notification receiving authority.	Before supplier issues Invoice.	Mismatch between shades/SKUs and notification may trigger supplement request.
Samples/test marketing/gifts	May require different handling from commercial goods; cosmetic policy and label still need review.	Invoice, purpose letter, sample quantity, label, ingredients.	Customs; specialized authority if relevant.	Before ETA.	“Sample” used for commercial sale may be treated as wrong purpose.
EPE/FDI/factory import	Review purpose, import/distribution rights, internal file and post-clearance management.	Contract, PO, import purpose, business license if relevant.	Managing customs authority.	Before declaration.	Wrong regime or import purpose may affect taxes and post-clearance management.
Packaging/sub-label	Imported goods labelling and mandatory Vietnamese information for circulation.	Original label, Vietnamese sub-label, ingredients, lot, expiry, origin, responsible entity.	Market surveillance/customs when inspected.	Before clearance or before circulation depending on case.	Incorrect label may require correction or incur penalties.

LEGAL DOCUMENTS TO REVIEW

Document group	Document name/number	Issuing body	Effective date/application time	Role in the procedure	Key article/clause/appendix if any	Review note
Law	Customs Law 54/2014/QH13	National Assembly	In force; check amendments if any.	Basis for declaration, inspection and customs supervision.	Review rules on customs dossier, inspection, clearance and post-clearance.	Does not replace guidance of customs authorities at declaration time.
Decree	Decree 08/2015/ND-CP, 59/2018/ND-CP, 167/2025/ND-CP	Government	Decree 167/2025/ND-CP effective 15 Aug 2025.	Detailed customs procedures and supervision.	Review customs dossier, declaration and physical inspection rules.	Check consolidated/current version.
Customs circular	Circular 38/2015/TT-BTC, 39/2018/TT-BTC, 121/2025/TT-BTC	Ministry of Finance	Circular 121/2025/TT-BTC effective 01 Feb 2026.	Guidance on dossiers, declaration and import tax administration.	Review e-dossier and declaration indicators.	Apply by declaration date.
Cosmetic circular	Circular 06/2011/TT-BYT and 34/2025/TT-BYT	Ministry of Health	Circular 34/2025/TT-BYT effective 18 Aug 2025.	Cosmetic management, notification, PIF and market responsibility.	Review notification number, PIF and amended forms.	Use the form effective at submission time.
Goods labelling	Decree 43/2017/ND-CP, 111/2021/ND-CP	Government	Decree 111/2021/ND-CP effective 15 Feb 2022.	Imported/circulated goods labelling.	Language, name, origin, responsible party, quantity, ingredients.	Cosmetic label must match notification dossier.
HS nomenclature	Circular 31/2022/TT-BTC	Ministry of Finance	Effective 01 Dec 2022.	Vietnam import-export nomenclature and HS basis.	Heading 33.04 and subheading 3304.91.00.	Final HS depends on actual dossier and customs ruling if any.
Tariff	Decree 26/2023/ND-CP; Decision 15/2023/QD-TTg; FTA tariff decrees	Government/Prime Minister	Apply by declaration year/time.	Determine MFN, ordinary and special preferential duty.	Check HS, origin, C/O form and phase-down schedule.	Do not use absolute duty without checking current tariff.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

The company may search the document number on Vietnam’s legal document portal, the Government portal or the website of the issuing authority. Companies should cross-check the applicable document on official legal databases or authority websites before applying it.

Circular 06/2011/TT-BYT Circular 34/2025/TT-BYT Goods labelling

CUSTOMS CLEARANCE DOCUMENT SET

The powder import file should be locked simultaneously between commercial documents and cosmetic regulatory documents. Goods name, quantity, shade/SKU, lot number, expiry date, origin, manufacturer, label, ingredients and cosmetic notification number must be consistent throughout the file.

OPERATIONAL DOCUMENT CHECKLIST

Document group	Required documents	Used for which step	Usually prepared by	Common error	Pre-ETA checking method
Commercial documents	Commercial Invoice, Packing List, Sales Contract/PO, B/L or AWB.	Declaration, customs value, quantity and origin check.	Buyer, seller, forwarder, docs team.	Goods name too generic; missing shade/SKU; wrong quantity.	Compare each line with packing list, carton label and product notification.
Origin documents	C/O Form D/E/VK/AK/EUR.1/RCEP or valid origin statement, if any.	Claiming special preferential duty.	Seller/exporter or manufacturer.	Wrong form, HS, description or origin criterion.	Check form, origin criterion, issue date and direct consignment.
Cosmetic regulatory file	Cosmetic product notification, CFS, authorization letter, formula/ingredients, PIF.	Specialized policy review and customs explanation.	Importer/RA, brand owner, manufacturer.	Expired CFS/LOA, product name mismatch, missing PIF.	Check notification number, product name, manufacturer, ingredients and validity.
Labelling file	Original label, Vietnamese sub-label, artwork, product photos, lot/expiry information.	Clearance, circulation and post-clearance review.	Importer, marketing, QA/RA.	Missing responsible entity, origin, ingredients or net quantity.	Compare label with notification, Invoice and packing list.
Technical documents	Catalogue, product brief, product-form photos, shade/SKU list.	HS classification, product use and policy determination.	Supplier, brand owner, importer.	Insufficient evidence that goods are powder, whether or not compressed.	Standardize goods description before documents are issued.

CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Evidence document	Consequence if unclear	Recommended handling
HS code	Is the product truly powder, whether or not compressed, under 3304.91.00?	Catalogue, photos, label, formula, use.	HS explanation, inspection routing or tax adjustment may arise.	Prepare an HS classification memo before ETA.
Cosmetic notification	Is there a valid notification receipt matching product name/shade?	Notification, CFS, LOA, PIF.	Import/circulation conditions may be insufficient; supplement request may occur.	Check notification before booking.
Goods labelling	Do original label and Vietnamese sub-label match notification and commercial documents?	Artwork, labels, product photos.	Cargo may be held for label correction or violation handling.	Review labels together with notification dossier.
C/O	Does the C/O have correct form, criterion, HS, description and direct consignment?	C/O, B/L/AWB, Invoice, Packing List.	Preference may be rejected and additional duty incurred.	Pre-check draft C/O before original issuance.
Product claims	Do product claims stay within cosmetic scope?	Label, website, product brief, marketing materials.	The product may be suspected as medicinal/treatment goods.	Remove unsuitable claims before notification/import.
Goods status	Is the shipment commercial goods, samples or test goods?	Invoice, PO, purpose letter, quantity.	Wrong customs regime or import purpose.	State the purpose and prepare corresponding documents.

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Confirm HS 3304.91.00 where supported; check MFN/ordinary/FTA duty; review notification, label, C/O and claim risks.

Step 2: Lock documents and technical file

Finalize Invoice, Packing List, B/L/AWB, catalogue, label, shade/SKU list, notification number, CFS/LOA/PIF.

Step 3: Complete cosmetic regulatory file

Review product notification, CFS, authorization letter, PIF, ingredients and sub-label before cargo arrival.

Step 4: Lodge customs declaration

Prepare explanations for customs value, HS, goods name, use, C/O, notification and label. Green channel is system-based clearance; Yellow channel checks documents; Red channel checks documents and physical goods.

Step 5: Clearance, delivery and post-clearance retention

Deliver to warehouse, check Vietnamese sub-label before sale, retain lot-based files and prepare for post-clearance or market inspection.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents to check
Generic goods name “cosmetic powder”	Insufficient basis for HS/policy; supplementary documents may be requested.	Standardize product name by form, use, brand, shade and net weight.	Invoice, packing list, label, catalogue.
Missing/incorrect cosmetic notification	Regulatory file may be insufficient; clearance/sale may be delayed.	Check notification number, product name, manufacturer, ingredients and validity.	Notification, CFS, LOA, PIF.
Incorrect C/O form or origin criterion	Special preferential duty may be rejected.	Pre-check draft C/O before issuance.	C/O, Invoice, B/L, PSR.
Mismatch in shade/SKU	Customs may request SKU/model explanation.	Lock shade list before Invoice issuance.	Model list, label, packing list, notification.
Claims exceeding cosmetic scope	Product may be considered treatment/pharmaceutical.	Review claims on label, website and sales materials.	Artwork, product brief, formula.
Vietnamese sub-label missing mandatory information	Risk of penalty or corrective action before sale.	Prepare sub-label under Decree 43/2017 and 111/2021, aligned with notification.	Original label, sub-label, notification.

FAQ – COMMON BUSINESS QUESTIONS

Does imported powder need cosmetic notification?

If powder is a finished cosmetic product imported for circulation in Vietnam, the company should review cosmetic product notification under Circular 06/2011/TT-BYT and current amendments.

What HS code is commonly used for powder?

Reference HS is 3304.91.00 for powders, whether or not compressed. Final classification depends on actual documents.

What is the import duty?

Indicative MFN is 22%; ordinary reference is 33%; base VAT is 10%. Check the tariff and VAT policy at declaration time.

Can C/O reduce duty?

Yes, if the C/O or origin document is valid and meets the selected FTA conditions.

Are samples handled like commercial goods?

Not automatically. Purpose, quantity, label and cosmetic policy should be reviewed based on the actual file.

What if the label says “treat acne” or “medical powder”?

The cosmetic scope must be reviewed. Treatment claims may trigger a different policy.

Is Vietnamese sub-labelling required?

Goods circulated in Vietnam must meet Vietnamese labelling requirements; the sub-label must align with original label and notification.

Does a shipment with many shades need separate checking?

Yes. Compare each SKU/shade against the notification and ingredient/label data.

TGIMEX EXECUTION SOLUTION

This article provides a map of HS code, duty, C/O, cosmetic notification dossier and key risks for importing powder cosmetics. For an actual shipment, the company should still review catalogue, datasheet, label, ingredient list, product notification, commercial documents, origin and import purpose.

Pre-ETA review: HS, cosmetic policy, C/O, duty, labelling, catalogue/datasheet/model/shade.

Compliance file control: Invoice, Packing List, B/L/AWB, C/O, notification, CFS, authorization letter, PIF and labels.

International logistics: agent/carrier coordination, ETA tracking, pre-alert and transport documents.

Customs declaration: dossier preparation, Green/Yellow/Red channel handling, HS/value/origin explanation.

Post-clearance: lot-based file retention, sub-label review, notification dossier and origin evidence.

For powder shipments that may involve cosmetic notification, C/O or labelling requirements, companies should not wait until cargo arrival to start document review. A small discrepancy between Invoice, Packing List, catalogue, notification dossier, C/O or label may trigger supplementary document requests, delayed clearance or unplanned storage charges. TGIMEX supports an E2E import approach: pre-ETA policy review, document checking, international freight coordination, customs declaration, clearance handling, domestic delivery and post-clearance file retention.

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