Scrub products are often declared under generic descriptions such as “body scrub”, “exfoliating cream”, “sugar scrub” or “cleansing scrub”. If the importer does not distinguish whether the product is a skin-care cosmetic preparation or a surface-active skin-washing preparation, the shipment may face wrong HS classification, incorrect tax, missing cosmetic notification number, incorrect Vietnamese label or loss of C/O preferential duty. 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.

This guide provides an E2E (End-to-End) checklist for importing scrub into Viet Nam: product identification, HS code, duties, C/O, cosmetic notification, labeling, customs dossier, decision points and risks to control before ETA.

QUICK FACTS

Item	What to verify	Operational note
Product scope	Scrub / exfoliating cosmetic for face or body skin	Applies to cosmetics only; not automatically applicable to medicinal, therapeutic or industrial chemical products.
Reference HS	3304.99.90 for skin-care/exfoliating scrub; 3401.30.00 where the product is primarily a retail skin-washing surface-active preparation; 3304.99.30 where it is clearly a skin cream/lotion.	Verify catalogue, formula, claim and actual use.
Reference duty	3304.99.90: MFN 18%, ordinary 27%, VAT 10% standard, possibly 8% if eligible; 3401.30.00: MFN 27%, ordinary approx. 40.5%, VAT 10% standard, possibly 8% if eligible.	Do not finalize taxes before confirming HS at declaration date.
Specialized policy	Imported cosmetics require a Cosmetic Product Notification Receipt Number before being placed on the market.	The responsible person is liable for safety, efficacy, quality and labeling.
Key dossier	Invoice, Packing List, B/L/AWB, C/O, cosmetic notification, CFS, authorization letter, formula/INCI, label, catalogue/datasheet.	Product name, form, function, ingredients, origin and batch information must match across all records.

Legal note

Tax rates and policies are for operational planning. The importer should re-check the tariff schedule, cosmetic rules and actual product documents at the declaration date.

Illustration for Import procedure guide for scrub / exfoliating cosmetic — Illustration of the product group and document review before customs clearance.

SCOPE OF APPLICATION

Covered scrub products

Body scrub, face scrub, sugar scrub, salt scrub, exfoliating gel/cream/paste.
Cosmetic products applied externally to clean, exfoliate, smooth or care for skin.
New retail-packed goods imported for trading, samples, display or spa/salon use.

Not automatically covered

Ordinary shower gel, soap, body mist, deodorant, antiperspirant cosmetic and shaving cream.
Products making therapeutic, medicinal, disinfectant or disease-treatment claims.
Raw materials, semi-finished goods, kits with multiple HS headings or non-cosmetic goods.

Actual catalogue, datasheet, SKU, ingredient list, claims and import purpose must be reviewed.

PRODUCT CLASSIFICATION & IDENTIFICATION

Product form

Cream, gel, paste, oil, powder or mixed preparation with sugar, salt, cellulose, silica or other exfoliating particles.

Main function

Determine whether the main function is skin care/exfoliation or skin washing based on surface-active agents.

Claims & ingredients

Review AHA/BHA/PHA, enzymes, microbeads, essential oils, preservatives, colourants and claims such as acne treatment or antibacterial.

Criteria	Documents to check	Risk if wrongly described	Suggested declaration wording
Trade name and product type	Catalogue, label, brand website, COA if any	A generic “cosmetic” or “cream” description may cause wrong HS and policy.	“Exfoliating body scrub cosmetic, brand…, SKU…, capacity…, new 100%”.
Main function	Claims, directions for use, packaging description	Confusion between skin care and skin-washing preparation.	State “for skin exfoliating/care” or “skin washing preparation”.
Physical form	Photos, catalogue, MSDS/SDS, formula	Powder, cream, gel and oil forms may require different HS review.	“gel scrub / cream scrub / sugar scrub / powder scrub”.
Exfoliating ingredients	INCI/ingredient list	Acids or microbeads may trigger safety or claim questions.	Mention key ingredient if needed for explanation.
Notification and label	Cosmetic notification, original label, Vietnamese label draft	Mismatch may lead to supplementary dossier requests.	Product name should match notification and label.

HS CODE – DUTIES – C/O

1. Reference HS classification

Reference HS	When applicable	Risk if misclassified	Documents to compare
3304.99.90	Main route for cosmetic scrub used for skin care/exfoliation and not primarily a washing preparation.	If it is actually a cleansing scrub/shower scrub, Customs may review HS 3401.30.00.	Catalogue, label, directions, formula, cosmetic notification.
3304.99.30	Where the product is clearly a face/skin cream or lotion.	Relying only on the word “cream” may be inaccurate.	Texture, claim, ingredients, label and invoice.
3401.30.00	Where the scrub is a retail liquid/cream skin-washing surface-active product, with or without soap.	Higher MFN duty; wrong HS may cause tax adjustment.	Surfactants, “wash/cleanse” claim and directions.
3304.91.00	Only where the scrub is a powder cosmetic.	Not suitable for cream/gel scrub.	Product photos and physical form.

2. Reference import taxes

VAT review note

For cosmetic scrub, do not default to 5% VAT. Use 10% as the standard VAT rate; 8% may only be considered where the product is eligible for the VAT reduction policy at the customs declaration date and is not excluded.

HS	Description	MFN	Ordinary duty	VAT	Note
3304.99.90	Other cosmetic/skin-care preparations	18%	27%	8/10%	Common route for skin-care scrub.
3304.99.30	Other face/skin creams and lotions	18%	27%	8/10%	Only if the dossier supports cream/lotion nature.
3401.30.00	Retail skin-washing surface-active preparations	27%	40.5%	8/10%	For cleansing scrub/shower scrub.
3304.91.00	Powders, whether or not compressed	22%	33%	8/10%	Only for powder cosmetics.

3. Preferential C/O by route

Origin/route	C/O form or origin document	Indicative preferential rate for HS 3304.99.90/3304.99.30	Conditions	Risk
ASEAN	Form D / ATIGA origin document	0%	Origin rule, direct transport, matching description and HS.	Wrong form or transport evidence may cause rejection.
China	Form E or RCEP document	ACFTA may be 0%; RCEP must be checked by year.	Actual Chinese origin and correct origin criterion required.	Third-party invoice or HS mismatch risk.
Korea	Form AK / VK / RCEP	Indicative AKFTA 12%, VKFTA 10%, RCEP 8%.	Choose the most beneficial valid form.	Wrong criterion leads to MFN.
Japan/CPTPP	AJ, VJ, CPTPP or RCEP	Often around 0–5% depending on year and agreement.	Check origin and year-specific schedule.	Self-certification or document mismatch.
EU/UK	EUR.1 or origin statement	Preferential duty subject to EVFTA/UKVFTA schedule.	Origin rule and transport evidence required.	Without valid origin evidence, MFN applies.
India/Hong Kong/EAEU	AI / AHKFTA / EAEU C/O	AIFTA around 5%; AHKFTA around 2.5%; VN-EAEU many lines may be 0%.	Check each market and HS.	Do not apply 3304 rates if HS changes to 3401.

4. C/O pre-ETA checklist

Correct form or origin document under the chosen FTA.
Origin criterion: WO, RVC, CTH/CTSH or product-specific rule.
Description, HS, quantity, weight, invoice and parties must match.
Check third-party invoice, direct transport, transshipment, issue date, stamp/signature or e-verification.

APPLICABLE SPECIALIZED POLICIES

Goods scenario	Possible policy	Documents	Authority/portal	When to do	Risk note
Imported cosmetic scrub for trading	Cosmetic product notification before circulation.	Notification, CFS, authorization, formula, label.	Drug Administration of Viet Nam / National Single Window depending on process.	Before ETA, preferably before booking.	No notification number creates market circulation risk.
Scrub with AHA/BHA/PHA/enzyme	Ingredient limits, warnings and cosmetic claims.	Formula, COA, SDS, label, PIF.	DAV and post-market surveillance bodies.	Before label finalization.	Treatment claims may require revision.
Cleansing/shower scrub	Potential HS 3401.30.00 review.	Surfactants, directions, washing claims.	Customs.	Before declaration.	Wrong HS causes tax exposure.
Samples/testers/gifts	Cosmetic policy, label and import purpose review.	Invoice, sample label, purpose letter if any.	Customs and authorities if required.	Before ETA.	Do not assume exemption automatically.

LEGAL DOCUMENTS TO REVIEW

Document group	Document	Authority	Effective timing	Role	Key points	Review note
Circular	Circular 06/2011/TT-BYT and consolidated/amending documents	Ministry of Health	Effective from 01/04/2011; use latest consolidated version.	Cosmetic notification, PIF, safety, labeling and post-market control.	Articles on notification dossier, notification validity, labels and PIF.	Use consolidated version to capture amendments.
Decree	Decree 26/2023/ND-CP	Government	Effective from 15/07/2023.	MFN import tariff schedule.	Appendix II.	Check at declaration date.
Decree	Decree 174/2025/ND-CP	Government	Effective from 01/07/2025; VAT reduction until 31/12/2026.	Determines 8% VAT possibility.	Article 1 and exclusion list.	Not automatic if excluded.
Circular	Circular 31/2022/TT-BTC	Ministry of Finance	Effective from 01/12/2022.	Vietnam nomenclature for HS description.	Chapter 33 and 34.	Classify by tariff description, not trade name.

VIEW / DOWNLOAD ORIGINAL LEGAL TEXTS

Enterprises may look up documents by number on official legal databases or authority websites. Enterprises should additionally verify the documents on the official legal database or the issuing authority’s website before application.

Consolidated cosmetics regulation Decree 26/2023/ND-CP Decree 174/2025/ND-CP Lookup HS 3304.99.90 Lookup HS 3401.30.00

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
C/O if preferential duty is claimed.
Catalogue, photos, original label and SKU list.

Cosmetic compliance documents

Cosmetic Product Notification Receipt Number.
CFS if required.
Authorization letter.
INCI formula, PIF, original label and Vietnamese label.
Claim substantiation and safety data where needed.

Dossier group	Required document	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB, contract/PO	Customs declaration and valuation	Importer, shipper, forwarder	Incorrect goods name or quantity	Freeze final documents and reconcile SKU.
HS – Tax	Catalogue, label, ingredient list, function	HS classification and tax calculation	Importer, broker, compliance	Using 3304 instead of 3401 or vice versa	Review main function and surfactants.
Cosmetics	Notification, CFS, authorization, PIF	Cosmetic compliance	Responsible person	Wrong product name or invalid authorization	Match product, manufacturer and responsible person.
Label	Original label and Vietnamese label	Clearance/post-market control	Importer, brand owner	Missing ingredients, batch, expiry, origin	Check before printing/affixing.
C/O	FTA C/O or origin statement	Preferential duty	Exporter/importer	Wrong criterion or HS	Check before claiming preference.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question	Proof	Consequence if unclear	Recommended handling
HS code	Is the scrub under 3304 or 3401?	Catalogue, label, formula	Tax and classification dispute	Analyze main function before declaration.
Notification number	Is the cosmetic notification valid and matching?	Notification, CFS, authorization	Supplementary request or circulation risk	Finalize before ETA.
Label	Does the label contain all required items?	Artwork and translation	Post-market or clearance risk	Review before printing.
Ingredients/claims	Any acids, enzymes, microbeads or treatment claims?	Formula, PIF, label	Additional explanation or claim revision	Remove non-cosmetic claims.
C/O	Is the C/O eligible?	C/O, invoice, B/L	Preference denied	Check form, criterion and direct transport.

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review

Confirm HS, duties, VAT and C/O route.
Review cosmetic notification, label, ingredients and claims.

Step 2 – Lock documents

Freeze Invoice, Packing List and B/L/AWB.
Match product name across notification, label, C/O and declaration.

Step 3 – Complete cosmetic dossier

Prepare/check notification, CFS, authorization and PIF.
Do this before ETA.

Step 4 – Customs declaration

Green lane: system-based release under conditions.
Yellow lane: document check.
Red lane: document and physical inspection.

Step 5 – Release and post-clearance

Pay taxes, take delivery and affix Vietnamese label if required before circulation.
Archive all records by shipment.

Step 6 – Post-market readiness

Maintain PIF and claim substantiation.
Monitor formula/label/manufacturer changes.

PRE-ETA RISK CHECKLIST

Risk	Impact	How to block before ETA	Documents
Wrong HS 3304/3401	Tax adjustment and delayed clearance	Review main function and surfactants	Catalogue, formula, label
Missing notification	Compliance risk	Finalize notification before arrival	Notification, CFS, authorization
Invalid C/O	No preference	Check C/O before declaration	C/O, invoice, B/L
Overstated claim	Regulatory explanation	Remove therapeutic claims	Label and marketing material
Label mismatch	Post-market risk	Check Vietnamese label	Artwork, notification
Controlled ingredient concern	Safety questions	Review INCI and limits	Formula, SDS, PIF

FAQ

Does imported scrub need cosmetic notification?

Yes, if it is a cosmetic product for circulation in Viet Nam.

Which HS should be used?

It depends on the main function: skin-care/exfoliating scrub usually under 3304.99.90; cleansing/shower scrub may require 3401.30.00.

Is VAT 8% or 10%?

The standard VAT is generally 10%; 8% may apply if the product is eligible under the current VAT reduction policy.

Can C/O reduce duty?

Yes, provided that the form, origin criterion, direct transport and documents are valid.

Are samples/testers exempt?

Do not assume exemption. Review cosmetic policy, labeling and import purpose.

What if the label says “acne treatment”?

Review the claim carefully because therapeutic claims may go beyond cosmetics.

IMPLEMENTATION SUPPORT FROM TGIMEX

This guide provides a procedural map for scrub imports. In actual shipments, the importer still needs to review catalogue, formula, label, C/O, transport 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.
Customs clearance, C/O, permits, warehouse and domestic delivery.

Support scope

Pre-ETA review: HS, policy, C/O, duty, label and cosmetic notification.
Compliance dossier control: Invoice, Packing List, B/L/AWB, C/O, label and PIF.
International logistics coordination and customs declaration.
Post-clearance record keeping.

TGIMEX can support an E2E import plan: pre-ETA policy review, document check, international transport coordination, customs clearance, domestic delivery and post-clearance record retention.

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