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. |
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. |
- 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?
What is C/O and how to check origin documents?
Cosmetic import procedures: notification, labeling and customs dossier
Import labeling errors that can hold cargo
DEM/DET and logistics cost risks
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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