If an import shipment is described only as “soap”, Customs and compliance teams may need to verify whether it is toilet soap, cosmetic soap, medicated soap, antibacterial product or a skin-washing preparation. Misdescription may result in wrong HS classification, missing cosmetic notification, labeling issues, loss of C/O preference or DEM/DET. This guide provides an E2E (End-to-End) control map covering HS code, duties, C/O, cosmetic notification, customs documents and pre-ETA risk controls.

QUICK FACTS

Item	Review point for soap	Operational note
Scope	Soap for personal hygiene, bath soap, beauty soap, facial soap, body soap and handmade cosmetic soap in retail packaging.	Not automatically applicable to laundry soap, industrial soap, disinfectant products or pharmaceuticals.
Main HS reference	3401.11.20 – Bath soap.	For bars/cakes/moulded pieces used for personal hygiene.
Alternative HS to review	3401.11.10 medicated products; 3401.11.90 other; 3401.30.00 liquid/cream skin-washing preparations.	Confirm form, formula, claim, label and intended use.
Duties	3401.11.20: MFN 20%, normal import duty reference 30%, standard VAT 10%.	Final duty depends on the declared HS, origin, valid C/O and tariff schedule at declaration time.
Main policy	Cosmetic product notification, cosmetic labeling and product information file requirements.	Claims such as antibacterial, disinfecting or therapeutic require separate regulatory review.

Legal note

This guide treats soap as a cosmetic soap for body/skin cleansing. If the product has therapeutic, disinfecting, strong antibacterial or medical-use claims, it should not be handled as an ordinary cosmetic without dossier review.

SCOPE OF APPLICATION

Applicable to

Bath soap in bars, cakes, pieces or moulded shapes.
Facial soap, body soap, beauty soap and handmade cosmetic soap.
Retail-packed soap for personal hygiene or skin cleansing.
New goods, samples, display goods or commercial imports.

Not automatically applicable to

Laundry soap, industrial soap or household detergents.
Disinfectants, hand/burface sanitizers or medical products.
Products with therapeutic acne/skin-disease claims.
Liquid soap or shower gel, which may need HS 3401.30.00.

Actual catalogue, datasheet, SKU, INCI formula, label, claims and import purpose must be reviewed.

CLASSIFICATION & PRODUCT IDENTIFICATION

The decisive factors are product form, intended use, cosmetic claims and technical dossier. The same commercial name “soap” may lead to different HS and regulatory paths if it is liquid, solid, medicated, antibacterial or therapeutic.

Criteria	Documents to check	Risk if misdescribed	Suggested goods description
Product form	Photos, label, catalogue, packing specification.	Confusion between 3401.11.20 and 3401.30.00.	“Cosmetic bath soap in bar form, brand…, SKU…, net weight…”
Main function	Label, claim, product website, notification dossier.	Therapeutic/disinfecting claims may move it outside ordinary cosmetics.	State skin/body cleansing; do not add unsupported medical claims.
INCI formula	Formula, COA, SDS/MSDS if any.	Mismatch with cosmetic notification or restricted ingredients.	Refer to the notified INCI list.
Label	Original label, Vietnamese sub-label, artwork.	Missing batch, expiry, responsible person or directions.	Brand, product name, SKU, origin, batch/lot.

HS CODE – DUTIES – C/O

HS classification for soap must be based on form and intended use. Bath soap in bar/cake/moulded form is primarily reviewed under 3401.11; liquid or cream skin-washing preparations should be reviewed separately under 3401.30.00.

HS reference	When applicable	Duty reference	Risk	Documents
3401.11.20	Bath soap in bar/cake/moulded form for personal hygiene.	MFN 20%; normal duty reference 30%; standard VAT 10%.	Wrongly classifying liquid/cream cleansing products.	Label, photos, catalogue, INCI, notification, COA.
3401.11.10	Medicated products within the toilet-use soap line.	MFN 20%; normal duty reference 30%; VAT 10%.	Not a default code for ordinary cosmetic soap; if the label/claims refer to medicated, treatment, antiseptic or therapeutic effects, review the cosmetic–drug–disinfectant boundary before ETA.	Claims, formula, label, regulatory dossier and corresponding notification/registration documents.
3401.11.90	Other toilet-use soap not falling under 3401.11.10 or 3401.11.20.	MFN 20%; normal duty reference 30%; VAT 10%.	Using “other” when bath soap is clearly applicable.	Catalogue, sample photo, product description.
3401.30.00	Organic surface-active skin-washing preparation in liquid/cream form, retail-packed.	MFN 27%; normal duty reference 40.5%; VAT 10%.	Review only when the goods are actually liquid/cream; do not apply to bar/cake/moulded bath soap where the dossier clearly shows solid form.	Form, volume, label, formula, catalogue.

SPECIAL PREFERENTIAL TARIFF UNDER C/O/FTA

Route/origin	C/O form	Preferential duty	Conditions	Risk
ASEAN	Form D / ATIGA proof of origin	Do not rely on isolated old preferential-rate rows; verify Decree 126/2022/ND-CP and the 2022–2027 ATIGA schedule by HS code, declaration year and C/O conditions.	Origin criteria, direct consignment, HS and description match.	Wrong HS/description may lead to rejection.
China	Form E / ACFTA or RCEP proof	Check the official ACFTA/RCEP schedule by HS and year.	Verify CTH/CTSH/RVC if applicable.	Commercial origin is not the same as preferential origin.
Korea	AK/VK or RCEP	Check AKFTA/VKFTA/RCEP schedules.	C/O must match invoice, packing list and B/L.	Wrong FTA route may trigger duty recovery.
EU/UK	EUR.1 or origin declaration under EVFTA/UKVFTA	Check EVFTA/UKVFTA schedules.	Exporter status, direct transport and product description.	Insufficient transport evidence may affect preference.

Pre-ETA C/O checklist:

Correct C/O form or self-certification document.
Correct origin criterion: WO, RVC, CTH/CTSH as applicable.
Description, HS, quantity, weight and origin match commercial documents.
Third-party invoice and direct transport requirements are checked.
Issue date, signature/stamp and validity are reviewed.

APPLICABLE SPECIALIZED POLICIES

Situation	Possible policy	Documents	Authority/portal	Timing	Risk note
Ordinary cosmetic soap	Cosmetic product notification before market circulation.	Notification, LOA, CFS if applicable, INCI and label.	Health regulatory authority.	Before import/market launch.	No notification may delay selling plan.
Therapeutic/disinfecting claims	Review cosmetic–drug–disinfectant boundary.	Claims, test reports, formula, marketing materials.	Relevant health authority.	Before PO placement.	Do not treat as ordinary cosmetic without review.
Samples/testing goods	Review import purpose and circulation plan.	Invoice, sample declaration, internal use statement.	Customs and relevant authorities.	Before ETA.	Samples sold commercially may create compliance risk.

LEGAL DOCUMENTS TO REVIEW

Group	Document	Issuer	Effectiveness	Role	Key points	Review note
Circular	Circular 06/2011/TT-BYT	Ministry of Health	Effective from 01 Apr 2011, as amended.	Cosmetic management, notification, PIF and labeling.	Label requirements and cosmetic dossier.	Check the latest consolidated/amended version.
Amending Circular	Circular 34/2025/TT-BYT	Ministry of Health	Effective 18 Aug 2025.	Amends Circular 06/2011/TT-BYT.	Notification dossier and submission method.	Apply according to submission date.
Labeling	Decree 43/2017/ND-CP and 111/2021/ND-CP	Government	Currently applicable, subject to amendments.	General goods labeling.	Original label, Vietnamese sub-label and origin.	Use with cosmetic-specific labeling rules.
Tariff/VAT	Import tariff schedules and Decree 174/2025/ND-CP	Government/MOF	Depends on declaration date.	MFN, normal duty, special preference and VAT.	HS 3401.11.20 and alternatives.	Standard VAT remains 10%; 8% only if eligible.

VIEW / DOWNLOAD OFFICIAL DOCUMENTS

Enterprises should cross-check official legal documents on the Government legal database or the issuing authority’s website before application.

HS 3401.11.20 Circular 06/2011 Circular 34/2025 Decree 174/2025

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/PO if any.
C/O for preferential duty.
Catalogue, product photos, original label and SKU list.

Cosmetic compliance dossier

Cosmetic notification number.
LOA, CFS if applicable.
INCI formula, label, PIF and COA.
SDS/MSDS if transport risk exists.
Claim support documents if needed.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question	Evidence	Consequence	Recommended action
HS classification	Bar bath soap or liquid/cream skin cleanser?	Photos, label, catalogue.	Query or channel change.	Fix HS and product description before ETA.
Cosmetic notification	Does the notification match the imported product?	Notification, LOA, CFS.	Delay in market circulation.	Review before ordering.
Product claims	Any therapeutic/disinfecting claims?	Label, website, marketing material.	Potential reclassification.	Legal/compliance review.
C/O	Does C/O match HS, description and origin?	C/O, invoice, B/L.	Loss of preference.	Check C/O draft early.

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Confirm HS, duties, C/O, claims, label, cosmetic notification and VAT treatment.

Step 2: Lock documents

Finalize invoice, packing list, B/L/AWB, catalogue, label and SKU list.

Step 3: Complete compliance dossier

Review notification, LOA, CFS, INCI, PIF, claims and labeling.

Step 4: Customs declaration

Green channel: system-based clearance; Yellow: document inspection; Red: document and physical inspection.

Step 5: Clearance and post-clearance

Deliver goods, complete sub-labeling, retain shipment dossier and prepare explanations if audited.

PRE-ETA RISK CHECKLIST

Risk	Impact	Control	Documents
Wrong C/O form/origin criterion	Loss of preferential duty.	Review draft C/O.	C/O, invoice, B/L, ROO.
Name mismatch with notification	Clarification and delay.	Align product name, brand and SKU.	Invoice, notification, label.
Overstated claims	Different regulatory path.	Review label and marketing claims.	Label, website, catalogue.
Wrong HS	Wrong duty and declaration data.	Confirm bar/solid/liquid/cream form.	Photos, catalogue, packing.

FAQ

Does imported soap need cosmetic notification?

If it is marketed as a cosmetic for skin/body cleansing, notification should be reviewed before circulation.

Main HS for soap?

For bath soap in bar/cake form, the main reference is 3401.11.20.

Is VAT 8% applicable?

Standard VAT is 10%. 8% is considered only if the reduction policy applies and the product is not excluded.

Can C/O reduce duty?

Yes, if the C/O is valid and the relevant FTA schedule grants preference for the actual HS.

Is handmade soap treated differently?

It depends on formula, label, manufacturer, notification dossier and import purpose.

What if the label says “medicated”?

Review the cosmetic/pharmaceutical boundary before shipment.

EXECUTION SUPPORT FROM TGIMEX

This guide provides a control map for HS, duties and compliance; however, actual soap shipments must still be reviewed against INCI formula, labels, notification dossier, origin and import purpose.

Pre-ETA review

HS, cosmetic policy, C/O, duties, VAT, label and notification dossier.

Compliance dossier control

Invoice, Packing List, B/L/AWB, C/O, notification, LOA, CFS, INCI and label.

International logistics

Agent coordination, carrier/airline follow-up, ETA, pre-alert and transport documents.

Customs & post-clearance

Declaration preparation, channel handling, delivery and post-clearance record retention.

For shipments involving cosmetic notification, C/O or labeling, enterprises should not wait until arrival to start dossier review. Minor inconsistencies may lead to additional documents, delayed clearance or unplanned storage costs.

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