Import procedures for cosmetic masks

COSMETICS – PERSONAL CARE · MASK

IMPORT PROCEDURES FOR COSMETIC MASKS

Operational risk: “Mask” may refer to a cosmetic skin-care mask, medical/protective mask or LED mask device. A generic description can trigger questions on HS, cosmetic notification, labels and intended use.

Operational impact: Wrong HS, invalid C/O, missing cosmetic notification or label mismatch may lead to document requests, customs channel escalation, loss of FTA duty and DEM/DET costs.

E2E approach: This article provides a practical map for cosmetic mask imports: HS, tax, C/O, cosmetic notification, labels, customs dossier and pre-ETA risk control.

QUICK FACTS

Item Review point
Product scope Cosmetic masks: sheet masks, wash-off masks, sleeping masks, clay/mud masks, eye/lip masks for skin-care purposes, without medical treatment claims.
Reference HS 3304.99.90 for other skin-care masks; consider 3304.99.30 where the product is essentially a face/skin cream or lotion.
Reference duties MFN: 18% for 3304.99.90/3304.99.30; ordinary duty: 27%; VAT: review 8%/10% at declaration date.
Key regulatory point A valid cosmetic product notification receipt is required before market circulation; labels, ingredients, CFS/authorization and PIF must be consistent.
Authorities/portals Drug Administration of Vietnam – Ministry of Health for imported cosmetics; Customs for VNACCS/VCIS declaration.
Warning Do not apply this article to medical/protective masks, LED mask devices, therapeutic/acne-treatment products or research samples without separate review.
Legal note

HS, duty, VAT and FTA data are for planning. Check tariff schedules and product dossier at declaration date.

SCOPE OF APPLICATION

This article applies only to cosmetic masks for external skin care, including sheet, hydrogel, clay/mud, wash-off, peel-off, sleeping, eye and lip masks, where the product is not a drug or medical device.

It does not automatically apply to medical/protective masks, LED mask devices, electric beauty devices, therapeutic products, disinfectant products, samples for research or goods under a different intended use. Review catalogue, datasheet, SKU, ingredient list, label, claims and import purpose.

PRODUCT CLASSIFICATION & IDENTIFICATION

How to identify

  • Sheet/hydrogel/mud/gel/cream/lotion form for skin care.
  • Cosmetic ingredients declared by INCI.
  • External use only and no treatment claim.
  • Label states cosmetic/skincare mask.

Separate review

  • Medical/protective mask.
  • LED mask device.
  • Acne-treatment or antibacterial claims.
  • Dry substrate without cosmetic preparation.
Criteria Documents Risk if wrongly described Suggested customs description
Product form Catalogue, label artwork, product photos, sample if available Generic “mask” may be confused with medical mask or LED mask device “Cosmetic skin-care mask, external use, non-medical/non-therapeutic”
Claims Label, manufacturer website, leaflet, notification form Treatment/antibacterial claims may exceed cosmetic scope State skin-care functions only where supported
Ingredients INCI, COA, SDS/MSDS, formula data for notification Banned/restricted ingredients may trigger rejection or explanation Cosmetic ingredients, retail packed
Substrate/material Non-woven, hydrogel, cellulose, cotton, mud/clay, gel/cream data Dry substrate may not fall under HS 3304 Serum-impregnated sheet mask / wash-off cosmetic mask
Packing unit Packing list, invoice, label, pieces/box data Unit mismatch affects quantity, value and labels Box x sachets x pieces; net content per sachet
Import status Invoice, contract, photos, intended use Samples/testers/promotions may differ New goods for sale/sample/marketing subject to actual purpose

HS CODE – DUTY – C/O

Classification must be based on product function, formulation, claims and use mode, not the trade name “mask”.

Reference HS Application condition Import duty & VAT reference Documents to compare
3304.99.90 Other skin-care masks: sheet mask with serum, mud/clay mask, sleeping mask, gel mask, hydrogel/eye mask where the essential character is cosmetic skin care. Ordinary duty 27%; MFN 18%; VAT to be checked at 8%/10%. INCI list, label, claims, catalogue, SDS/COA if available, product photos and notification dossier.
3304.99.30 Consider only where the product is essentially a face/skin cream or lotion, such as sleeping mask in cream/lotion texture. Ordinary duty 27%; MFN 18%; VAT 8%/10% subject to review. Texture, use instruction, label claims, ingredient list and package artwork.
3304.99.20 Only where the product falls under anti-acne cream description; treatment claims may create boundary risk. Ordinary duty 15%; MFN 10%; VAT subject to actual classification. Claims, active ingredients, label, marketing material and regulatory classification file.
3401.30.00 Not the default code for masks; review only if it is a surfactant-based skin-cleansing preparation in liquid/cream form for retail sale. Ordinary duty 40.5%; MFN 27%; VAT subject to tariff review. Cleansing function, surfactant composition, rinse-off mechanism and label.

Special preferential C/O/FTA review

Route/origin C/O or origin proof Indicative preferential duty Conditions and risks
ASEAN / ATIGA Form D Indicative 0% for 3304.99.90/3304.99.30 if origin rules and direct transport are met. Check origin criterion, third-party invoice, description, HS and quantity.
China / ACFTA Form E Indicative 0%, subject to annual tariff schedule and exceptions. Check description, origin criterion, quantity, through B/L and third-party invoice.
Korea / AKFTA, VKFTA, RCEP Form AK / VK / RCEP proof AKFTA around 5%; VKFTA often 0%; RCEP around 10% for 3304.99.90 in 2026 indicative schedules. Choose the most beneficial FTA only where the goods truly qualify.
Japan / AJCEP, VJEPA, CPTPP, RCEP Form AJ / VJ / CPTPP declaration / RCEP AJCEP/VJEPA/CPTPP may be 0%; Japan RCEP around 10.9%. Check exporter eligibility, PSR, date and validity.
EU / EVFTA and UK / UKVFTA EUR.1 or origin statement Indicative around 2.5% for 3304.99.90 in 2026. Check REX/origin statement, HS, origin country and direct transport.
Australia – New Zealand AANZ / CPTPP / RCEP proof AANZFTA/CPTPP may be 0%; RCEP around 10%. Compare schedules before declaration.
India / AIFTA Form AI Indicative around 5%. Check RVC/CTH origin rule and transport evidence.
Hong Kong / AHKFTA AHK proof of origin May remain high, e.g. 20% indicative for 3304.99.90. Do not assume AHKFTA is better than MFN.
C/O checklist
  • Correct FTA form/proof and valid origin.
  • Origin criterion WO/RVC/CTH/CTSH matches product-specific rule.
  • Description, HS, quantity and weight match the declaration set.
  • Check third-party invoice, direct transport, issue date and signature/stamp where applicable.

SPECIALIZED MANAGEMENT POLICIES

Situation Possible policy Documents Authority/portal Timing Risk note
Finished cosmetic masks for sale Cosmetic notification, label control and PIF Notification receipt, CFS/authorization, formula, label, PIF DAV/MOH; Customs Before ETA and market release Do not wait until arrival to review notification.
Sheet/hydrogel/wash-off masks Managed as cosmetics if skin-care and non-medicinal Catalogue, label, INCI, usage DAV/MOH; Customs Before HS finalization Separate from medical masks and LED devices.
Acne/antibacterial/therapeutic claims Boundary review for cosmetic vs drug/medical product Label, claims, ingredients, advertising DAV/MOH; classification may be needed Before contract/label printing Do not include therapeutic claims in cosmetic notification.
Alcohol/solvent/fragrance risk Dangerous goods review for transport if relevant SDS/MSDS, flash point, composition Carrier/airline/forwarder Before booking Wrong DG declaration may block booking.
Samples/testers/gifts Purpose-based review; notification may still be required for market placement Invoice, purpose, label Customs/DAV where circulated Before ETA Do not assume samples are exempt.
EPE/FDI/factory import Review use purpose and domestic circulation Contract, invoice, warehouse plan, notification where applicable Customs managing EPE/FDI Before declaration Domestic sale requires separate review.

LEGAL DOCUMENTS TO REVIEW

Group Document Issuing authority Effective date/timing Role Articles/annexes to review Review note
Law Customs Law 54/2014/QH13 National Assembly Effective 01 Jan 2015 General customs basis Customs dossier, inspection and clearance Review with implementing documents.
Law Law on Export and Import Duties 107/2016/QH13 National Assembly Effective 01 Sep 2016 Basis for MFN/ordinary/special preferential duty Duty-rate provisions Check tariff at declaration date.
Customs regulations Decree 08/2015/ND-CP, Decree 59/2018/ND-CP, Circular 38/2015/TT-BTC, Circular 39/2018/TT-BTC Government/MOF Check consolidated validity Customs procedures, value, HS and origin review Relevant dossier provisions Use consolidated versions where available.
HS nomenclature Circular 31/2022/TT-BTC MOF Effective 01 Dec 2022 Vietnam import-export nomenclature Chapter 33, heading 3304 Classification depends on product nature.
MFN tariff Decree 26/2023/ND-CP and amendments Government Effective 15 Jul 2023 MFN import tariff Appendix II Recheck before filing.
Ordinary tariff Decision 15/2023/QD-TTg Prime Minister Effective 15 Jul 2023 Ordinary import duty Appendix / 150% principle Applies if MFN/FTA not available.
VAT Decree 174/2025/ND-CP Government Effective 01 Jul 2025 VAT reduction policy Eligible/excluded goods Review 8%/10%.
Cosmetics Circular 06/2011/TT-BYT and Circular 34/2025/TT-BYT Ministry of Health 01 Apr 2011 / 18 Aug 2025 Cosmetic notification, PIF, safety and labeling Articles 4, 5, 10, 11, 13 and annexes Imported cosmetics are notified with DAV/MOH.
Labeling Decree 43/2017/ND-CP and Decree 111/2021/ND-CP Government Check consolidated validity Goods labeling and Vietnamese supplementary label Mandatory labeling contents Cosmetic labels must match notification.
Cosmetic notification dossier Circular 34/2025/TT-BYT amending Circular 06/2011/TT-BYT; Decree 69/2018/ND-CP Ministry of Health/Government Circular 34 effective from 18 Aug 2025 Notification form, power of attorney, CFS and CFS exemption mechanism Amended Articles 4, 5 and 7; Article 36 of the Law on Foreign Trade Management; Article 10.3 of Decree 69/2018/ND-CP CFS may be exempt in specific CPTPP-related cases; if CFS has no expiry date, check whether it was issued within 24 months.
Sanctions/post-clearance Decree 117/2020/ND-CP and Decree 124/2021/ND-CP Government Check current validity at inspection date Administrative sanctions for non-compliant cosmetic notification, labelling and dossier Article 68 of Decree 117/2020/ND-CP and relevant amendments Include this in post-clearance and market-surveillance readiness, not only customs clearance.

VIEW / DOWNLOAD ORIGINAL DOCUMENTS

Enterprises should verify documents on official legal databases or issuing authorities’ websites before applying them.

CUSTOMS DOSSIER

Commercial set

  • Commercial Invoice.
  • Packing List.
  • B/L or AWB.
  • Contract/PO if any.
  • C/O if claiming FTA duty.
  • Catalogue, product photos and label.

Cosmetic compliance set

  • Cosmetic notification receipt.
  • CFS, authorization and ingredient dossier where applicable.
  • PIF kept by responsible person/company.
  • Original label and Vietnamese supplementary label.
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 check Importer/Docs/Supplier Generic product name, missing product form/origin Match product name, packing unit, weight and Incoterms.
Product technical Catalogue, label, photos, INCI, use instruction HS, cosmetic policy, label Supplier/Regulatory Mismatch between label and notification Compare SKU, variants, volume and formula.
Cosmetic notification Notification receipt, CFS, authorization, PIF Market circulation and explanation Responsible person/company Expired or wrong notification Check 5-year validity, name, manufacturer and origin.
C/O FTA C/O or origin declaration Special preferential duty Exporter/Importer Wrong form or origin criterion Check form, date, WO/RVC/CTH/CTSH and direct transport.
Label Original label, Vietnamese supplementary label Clearance/market surveillance Importer/Regulatory Label not matching notification Lock label artwork before ETA.

CLEARANCE DECISION POINTS

Decision point Question Proof Consequence Recommended handling
HS basis Is it skin-care mask, cream/lotion, anti-acne or cleansing preparation? Catalogue, INCI, label, use mode Wrong duty, C/O and classification questions Finalize technical description before filing.
Notification validity Is the SKU properly notified? Notification receipt and dossier Market-release risk Check product name, manufacturer, origin and validity.
Claims Any treatment, antibacterial or medical claim? Label, website, leaflet Regulatory boundary risk Clean up claims before printing.
C/O Which FTA is valid and beneficial? C/O, invoice, B/L Preferential duty denied Check form, criterion, direct transport and date.
Supplementary label Does Vietnamese label match original label and notification? Artwork and notification Held goods or market issue Review before ETA.

E2E IMPORT PROCEDURE

Step 1

Pre-ETA review: HS, duty, C/O, cosmetic notification, label, claims and DG risk.

Step 2

Lock commercial and technical documents: invoice, packing list, B/L/AWB, label, SKU, INCI and notification.

Step 3

Handle cosmetic compliance: verify notification validity; update or re-notify where product data changed.

Step 4

Open customs declaration: respond to Green/Yellow/Red channel queries on value, HS, C/O, label and notification.

Step 5

Complete clearance, delivery and post-clearance file retention.

PRE-ETA RISK CHECKLIST

Risk Consequence Pre-ETA control Documents
Generic “mask” description Confusion with medical mask/LED device; wrong HS Specify cosmetic skin-care mask, product form and use Invoice, packing list, catalogue, label
Missing/wrong notification Cannot safely release to market Check notification, SKU, manufacturer and 5-year validity Notification dossier and PIF
Therapeutic claims Possible reclassification and label issues Review label and marketing before shipment Label, website, ingredients
Wrong C/O Preferential duty denied Check form, origin criterion and direct transport C/O, invoice, B/L
SKU/name mismatch Document supplementation and delays Build SKU matching table before ETA Invoice, PL, label, notification
No SDS for risky formula Booking or transport issue Ask supplier for SDS early SDS/MSDS and composition

FAQ

Do cosmetic masks require an import permit?

They generally require a valid cosmetic product notification before market circulation. Avoid saying “no permit” without reviewing formula, label, claims and purpose.

What is the HS code for cosmetic masks?

Commonly 3304.99.90; consider 3304.99.30 if the product is essentially face/skin cream or lotion.

Is a sheet mask the same as a medical mask?

No. A sheet mask is a cosmetic if impregnated with skin-care preparation; medical/protective masks follow a different HS and policy.

Can C/O reduce import duty?

Yes, if valid. Check form, origin criterion, HS, description and direct transport.

Can acne-treatment masks be notified as cosmetics?

Needs careful review. Therapeutic claims may exceed cosmetic scope.

Are samples/testers exempt?

Not automatically. If placed on the market, promoted or sold, notification and labeling may still apply.

What if label and notification names differ?

Resolve before ETA because mismatched product names/SKU/manufacturer/formula can trigger questions.

Is PIF submitted at customs clearance?

PIF is normally kept by the responsible person/company and produced upon authority request, but key data must be ready.

Is CFS mandatory for imported cosmetic masks?

It depends on the country of manufacture/export and the exemption case. From 18 Aug 2025, Circular 34/2025/TT-BYT clarifies CFS exemptions and CFS requirements; if a CFS does not state its validity period, verify that it was issued within 24 months.

RELATED ARTICLES

What is HS Code and why it determines import duty?

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What is C/O and how to check origin documents?

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Cosmetic import procedures: notification, labeling and customs dossier

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Import labeling errors that can hold cargo

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DEM/DET and logistics cost risks

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IMPLEMENTATION SUPPORT FROM TGIMEX

This article maps HS, duties, C/O, cosmetic notification, label and customs dossier requirements. For actual shipments, each SKU must still be reviewed against catalogue, formula, claims, documents, origin and import purpose.

Operational capability

  • Agent network in more than 60 countries.
  • WCA, WCA China Global, VLA and HNLA membership.
  • Ocean, air, road/rail, warehouse and domestic delivery capability.

Support scope

  • Pre-ETA review of HS, C/O, duties, labels and notification.
  • Compliance check of invoice, packing list, B/L/AWB, C/O, labels and PIF.
  • Customs declaration, channel handling and post-clearance file retention.

For masks involving cosmetic notification, C/O, labeling or sensitive claims, document review should start before cargo arrival to reduce clearance delays and unplanned storage costs.

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