Cosmetic mouthwash is normally positioned as an oral-care/cosmetic product for rinsing, freshening breath and supporting daily oral hygiene. If the product is described too broadly, or if its claims suggest treatment, disinfection or dental therapy, the shipment may face questions on HS code, cosmetic notification, ingredients, labeling and C/O eligibility.

This article provides an E2E (End-to-End) compliance map before ETA: HS code, duties, C/O, cosmetic notification, customs dossier, labeling and key risks to control before cargo arrival.

QUICK FACTS

Item	Review point	Operational note
Product	Cosmetic mouthwash / oral rinse for oral hygiene and breath freshening.	Do not apply this article automatically to therapeutic mouth rinse, antiseptic solution, prescription product, toothpaste or breath spray.
Main HS reference	3306.90.00 – other preparations for oral or dental hygiene.	Finalize based on function, claims, ingredients, packaging and cosmetic notification dossier.
Duty reference	MFN duty: 20%; ordinary duty reference: 30%; standard VAT: 10%.	Preferential FTA rates require valid origin documents, correct HS, matching descriptions and direct consignment conditions.
Specialized policy	Review cosmetic product notification, PIF, LOA and CFS where required by the current dossier/regulations.	Main authority for imported cosmetics: Drug Administration of Vietnam, Ministry of Health.

Legal note

This article covers finished cosmetic mouthwash for normal cosmetic/oral-hygiene use. If the product contains therapeutic claims, antibacterial/antiseptic claims, high-risk active ingredients or medical positioning, classification must be reviewed based on the actual dossier.

SCOPE OF APPLICATION

Covered

Cosmetic mouthwash/oral rinse in bottles, mini bottles or sachets.
Daily-use oral hygiene and breath-freshening products without therapeutic claims.
New commercial goods, samples or marketing goods where the dossier supports the declared purpose.

Not automatically covered

Medicinal mouthwash, antiseptic treatment solution, dental therapeutic products.
Toothpaste, breath spray or dental floss if the form/function differs.
Alcohol-heavy, aerosol or DG-sensitive products. Review by catalogue, datasheet, model and actual import purpose.

PRODUCT IDENTIFICATION

The product should be identified by formula, ingredients, claims, form of use, labeling and instructions, not merely by trade name.

Check point	Documents to review	Risk if misdescribed	Suggested customs description
Product form	Catalogue, artwork, photos, instructions.	Confusion with toothpaste, breath spray, medicine or antiseptic solution.	Cosmetic mouthwash/oral rinse, brand…, variant…, capacity…
Claims	Original label, website, brochure, notification dossier.	Therapeutic claims may move the product outside ordinary cosmetics.	Use oral hygiene/breath freshening description only where supported.
Ingredients	Ingredient list, COA, SDS/MSDS.	Active ingredients or high concentration may trigger classification questions.	Avoid generic “chemical solution”.
Origin and C/O	C/O, invoice, B/L, packing list.	Loss of FTA preference if HS/description/origin mismatch.	Keep C/O wording consistent with invoice and declaration.

HS CODE – DUTY – C/O

For cosmetic mouthwash, the HS code is normally reviewed under heading 3306 – preparations for oral or dental hygiene. The final code must be determined by the product nature, claims, ingredients, form, packaging and notification dossier, not only by the commercial product name.

HS and tax review matrix

Reference HS code	When applicable	MFN import duty	Ordinary duty	VAT	Risk if misclassified	Documents to review
3306.90.00	Cosmetic mouthwash/oral rinse and other oral hygiene preparations, not toothpaste and not dental floss.	20%	30%	10%	Wrong classification if the product is actually toothpaste, dental floss, medicinal mouthwash or therapeutic antiseptic solution.	Ingredient list, artwork, cosmetic notification, label, instructions for use, invoice.
3306.10.10/3306.10.90	Only if the dossier shows a dentifrice/toothpaste product in powder, paste or gel form.	20%	30%	10%	Confusing toothpaste with mouthwash may lead to wrong HS, wrong product description and inconsistent notification dossier.	Product form, use instruction, label, formula and invoice description.
3306.20.00	Only for dental floss, packed for retail sale.	20% reference	30% reference	10%	Not applicable to oral rinse/liquid mouthwash.	Product images, material composition, packing list and retail packaging.
3004 or another heading	Review only if the product is positioned as a medicinal/therapeutic preparation with active pharmaceutical function or disease-treatment claims.	To be checked separately	To be checked separately	To be checked separately	Serious specialized-policy risk if a non-cosmetic product is handled as a cosmetic.	Claims, ingredients, medical/dental use materials, classification opinion and licensing dossier.

C/O and FTA preferential duty matrix

Origin route	C/O form / origin document	Preferential duty note for HS 3306.90.00	Conditions to apply	Documents to compare	Risk if incorrect
ASEAN	Form D / ATIGA origin document	0% reference where conditions are satisfied.	ASEAN origin, valid origin criterion and direct consignment.	C/O, invoice, packing list, B/L, goods description and HS.	Loss of preference if description or HS differs.
China	Form E – ACFTA or RCEP origin document	ACFTA may need to be checked for 0%; RCEP must be reviewed by annual schedule.	Select the applicable FTA based on actual origin and available origin document.	C/O, third-party invoice if any, direct transport evidence.	Wrong FTA choice, wrong origin criterion or wrong issuing country.
Korea	Form AK, Form VK or RCEP	AKFTA/VKFTA/RCEP should be compared; some cosmetic lines may be 0% if eligible.	Check manufacturer, RVC/CTH/CTSH criterion and origin supporting documents.	C/O, invoice, B/L, BOM if required.	Using a non-optimal form or failing origin criteria.
Japan	Form AJ, Form VJ, CPTPP or RCEP	Review the applicable schedule; do not assume 0% without a valid origin document.	Determine the best FTA route according to origin and shipment route.	C/O/origin certification, transport documents, goods description.	Wrong form or insufficient proof of direct consignment.
EU / UK	EVFTA / UKVFTA origin proof	Preferential duty must be checked under the relevant schedule at the declaration date.	Valid exporter/origin declaration or C/O, compliant product description and direct transport.	Origin statement, invoice, packing list, transport documents.	Unsupported origin statement or mismatch with customs declaration.
Australia / New Zealand	Form AANZ, CPTPP or RCEP	Compare AANZFTA/CPTPP/RCEP to choose the lawful and best route.	Origin, shipment route and documentary evidence must match.	C/O, invoice, B/L, origin criterion.	Wrong FTA route may cause denial of preference.
India	Form AI – AIFTA	Check AIFTA rate at the declaration date.	Must satisfy AIFTA origin criterion and direct transport rules.	C/O, invoice, transport documents.	Invalid origin criterion or inconsistent goods description.
Hong Kong	Form AHK – AHKFTA	Compare with MFN because not every case is more beneficial.	Only if goods satisfy AHKFTA rules of origin.	C/O, invoice, B/L.	Preference may be lower than expected or C/O may be rejected.

C/O checklist before ETA

Check at least: C/O form, origin criterion WO/RVC/CTH/CTSH, third-party invoice, direct consignment, goods description, HS code, quantity, weight, origin country, stamp/signature, issue date, validity period and consistency across C/O – Invoice – Packing List – B/L – cosmetic notification – label.

SPECIALIZED POLICY MATRIX

Situation	Possible policy	Documents	Authority / portal	Timing	Risk note
Finished cosmetic mouthwash for commercial import	Cosmetic product notification.	Notification number, LOA, CFS if required, ingredient list, label.	Drug Administration of Vietnam.	Before ETA and distribution.	Missing or inconsistent notification may delay clearance.
Antiseptic/therapeutic claims	Review cosmetic versus medicinal/medical classification.	Claims, formula, active concentration.	MOH/DAV and customs if queried.	Before notification submission.	Claims may change regulatory pathway.
Alcohol or flammable components	Transport DG review.	SDS/MSDS, flash point, UN data if any.	Carrier/airline/forwarder.	Before booking.	Wrong DG declaration may block shipment.

LEGAL DOCUMENTS TO REVIEW

Document group	Document	Issuing authority	Effective timing	Role in the procedure	Key sections to note	Review note
Cosmetics regulation	Circular 06/2011/TT-BYT on cosmetics management	Ministry of Health	Effective from 01/04/2011	Core legal basis for cosmetic notification, PIF, product safety, labeling and import management.	Articles 4–10 on notification; Articles 11–12 on PIF; Article 13 on product safety.	Must be read together with amendments and consolidated/updated guidance.
Amending regulation	Circular 34/2025/TT-BYT	Ministry of Health	Issued 03/07/2025, effective 18/08/2025	Amends and supplements Circular 06/2011/TT-BYT; updates cosmetic notification dossier handling.	Article 1 amending relevant provisions and appendices.	Apply to notification dossiers submitted after its effective date.
Import tariff	Decree 26/2023/ND-CP and Decree 108/2025/ND-CP	Government	Decree 26 effective 15/07/2023; Decree 108 effective 19/05/2025	Basis for MFN tariff, ordinary duty and tariff schedule review.	Chapter 33, heading 3306.	Tariff must be checked at the customs declaration date.
VAT	Decree 174/2025/ND-CP	Government	Effective from 01/07/2025	VAT reduction policy under Resolution 204/2025/QH15.	Check excluded goods/services list if any.	Do not automatically apply 8%; verify HS and current VAT policy.
HS nomenclature	Circular 31/2022/TT-BTC	Ministry of Finance	AHTN 2022	Vietnam import-export goods nomenclature for HS classification.	Chapter 33 and general classification rules.	Use to determine the 8-digit HS code.
Labeling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Check current validity	Rules on goods labels and Vietnamese supplementary labels.	Mandatory label contents for imported goods/cosmetics.	Review original label and Vietnamese supplementary label before market circulation.

VIEW / DOWNLOAD ORIGINAL LEGAL TEXTS

Enterprises may search documents by number on the Government legal document portal, the official legal database or the issuing authority’s website. Enterprises should re-check official legal texts before applying them.

Circular 06/2011/TT-BYT Circular 34/2025/TT-BYT Decree 26/2023/ND-CP Decree 108/2025/ND-CP Chapter 33 tariff reference

CUSTOMS 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, artwork, original label and ingredient list.

Specialized documents

Cosmetic product notification receipt number.
LOA and CFS where required under the current notification dossier/regulations.
PIF, formula, product specification and COA where required.
MSDS/SDS if alcohol content or DG review is relevant.
Vietnamese supplementary label dossier.

CUSTOMS DOSSIER CHECKLIST BY OPERATION

Dossier group	Required documents	Used for which step	Usually prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO.	Value, quantity and goods description declaration.	Importer, supplier, docs team.	Generic product name, missing capacity/variant, wrong quantity.	Match each SKU with label and packing details.
Transport	B/L or AWB, arrival notice, pre-alert.	Cargo release, customs declaration and direct consignment review for C/O.	Forwarder, carrier, airline.	Wrong consignee, wrong package count, missing routing details.	Compare B/L/AWB with invoice, packing list and C/O.
Cosmetic notification	Notification receipt, LOA, CFS if required, ingredient list.	Proof of import/market circulation eligibility.	Importer, regulatory affairs/legal, product owner.	Notification not matching product name, brand, manufacturer, variant or capacity.	Compare notification against artwork, label and commercial documents.
C/O	FTA C/O or origin document.	Claiming special preferential duty.	Supplier/exporter.	Wrong HS, wrong description, missing third-party invoice note, late issue date.	Review C/O before vessel/flight arrival.
Labeling	Original label, Vietnamese supplementary label, artwork.	Market circulation and customs explanation when required.	Importer, brand owner, compliance team.	Claims exceed cosmetic scope or mandatory Vietnamese contents are missing.	Review label against notification, ingredient list and advertising claims.

Control rule: product name, quantity, capacity, variant, origin, manufacturer, ingredients and claims should be consistent across commercial documents, cosmetic notification, label, C/O and customs declaration.

CLEARANCE DECISION POINTS

Decision point	Question	Evidence	Consequence	Recommended action
Product classification	Cosmetic oral hygiene product or medicinal/antiseptic product?	Claims, ingredient list, artwork.	Regulatory challenge.	Review claims before filing.
HS code	Is 3306.90.00 sufficiently supported?	Catalogue, label, usage instructions.	Wrong duty and C/O risk.	Finalize HS based on substance over trade name.
Notification	Does the notification match product/variant/manufacturer?	Notification dossier, LOA, label.	Supplement request or delay.	Lock dossier before ETA.
C/O	Does C/O match form, HS, description, origin and direct shipment?	C/O, invoice, B/L.	Loss of FTA duty.	Check draft C/O before issuance.

E2E OPERATIONAL FLOW

Step 1 · Pre-ETA review

HS, duty, C/O, notification, label, claims and DG risk.

Step 2 · Lock documents

Invoice, PL, B/L/AWB, artwork, label and notification consistency.

Step 3 · Specialized dossier

Notification, LOA/CFS where required and PIF readiness.

Step 4 · Customs declaration

Green/Yellow/Red channel response and explanation dossiers.

Step 5 · Clearance & post-clearance

Delivery, VN label check and lot-based file retention.

Pre-ETA risk control

Do not wait until cargo arrival to review notification, C/O and labels.

PRE-ETA RISK CHECKLIST

Overstated claims: check label, website and brochure.

Wrong HS: verify heading 3306 and actual function.

Notification mismatch: product name, brand, manufacturer and variant.

C/O error: form, HS, description, origin and direct consignment.

Labeling issue: original label and Vietnamese supplementary label.

DG issue: SDS/MSDS if alcohol or flammable composition exists.

FAQ

Question	Short answer
Does cosmetic mouthwash require cosmetic notification?	Usually yes if classified as a cosmetic/personal care product for the Vietnam market; review the actual dossier.
What is the main HS?	3306.90.00, subject to actual product form and claims.
What is the MFN duty?	20% reference; standard VAT 10%.
Can C/O reduce duty?	Yes if valid and compliant with the selected FTA.
Does “antibacterial” affect classification?	It may; antiseptic/therapeutic claims must be reviewed carefully.
Are samples treated like commercial goods?	Not automatically; review purpose, quantity and non-commercial use evidence.

EXECUTION SUPPORT FROM TGIMEX

This article provides the compliance map for cosmetic mouthwash. For real shipments, the importer should still review the actual catalogue, ingredient list, artwork, notification dossier, documents, origin and import purpose.

Pre-ETA control

Review HS, policies, C/O, duty, label and claims.
Check consistency across commercial and compliance documents.

Operational execution

Coordinate overseas agents, carriers and pre-alerts.
Prepare customs declaration and post-clearance file retention.

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