IMPORT PROCEDURES FOR CREAM / SKIN CARE CREAM
Problem: Imported cream is often described generically on invoices while notification dossiers, labels, ingredients, C/O and HS must match by SKU. Agitation: Wrong HS, missing notification, label mismatch or invalid C/O can trigger document requests, channel inspection, clearance delays and DEM/DET. Solution: This article provides an E2E map for pre-ETA review: HS, duties, C/O/FTA, specialized policy, documents, process and risks.
QUICK FACT
| Item | What to verify | Application note |
|---|---|---|
| Product | Cream / skin care cream for face or body care, in cream/emulsion/gel-cream form, retail packed or imported commercially. | Applies only to cream; do not automatically apply to cleanser, toner, serum, essence, lotion, mask, makeup remover or body lotion. |
| Reference HS | 3304.99.30 – other face or skin creams and lotions. | Verify formulation, function, dosage form, label and catalogue before declaration. |
| Reference duties | MFN may be around 18%; ordinary duty may be around 27%; VAT must be checked at 8%/10% depending on timing and VAT reduction policy. | Not a final tax ruling; check the tariff schedule on declaration date. |
| Specialized policy | Imported cosmetics normally require a cosmetic product notification/notification receipt before market circulation. | If claims or ingredients go beyond cosmetics, conduct additional regulatory classification. |
Legal note
This is an operational review framework for cream / skin care cream, not a universal legal conclusion for all SKUs. Review by catalogue, datasheet, formula, label, claim, documents, origin and actual import purpose.
SCOPE OF APPLICATION
Product covered
This article covers skin care cream in cream, gel-cream or emulsion form, for external cosmetic use.
No group-wide assumption
Cleanser, toner, serum, essence, lotion, mask, makeup remover and body lotion may share a personal-care category but must not be treated under one automatic HS/policy conclusion.
Variants requiring separate review
Sunscreen cream, acne-treatment cream, drug-like active claims, samples, gifts, non-commercial imports, refurbished/used goods or sets require separate review.
Document principle
If data is incomplete, state: Review according to catalogue, datasheet, model/SKU and actual import purpose.
PRODUCT CLASSIFICATION & IDENTIFICATION
For cream, the authority may review function, ingredients, dosage form, label, packaging, instructions and product notification, not only the commercial name on the invoice. Generic descriptions such as “skin care product” may be insufficient for HS and regulatory review.
| Technical criterion | Document to compare | Risk if misdescribed | Suggested goods description |
|---|---|---|---|
| Product name and form | Invoice, packing list, label, catalogue, notification | Generic names weaken HS and regulatory evidence. | Skin care cream for external use, brand…, volume…, SKU…, new 100%. |
| Function/claim | Label, artwork, brand website, claim sheet | Therapeutic claims may trigger non-cosmetic review. | Use cosmetic-care wording consistent with the dossier. |
| Ingredients and actives | Formula, ingredient list, COA/SDS if any | Restricted/prohibited ingredients or excessive levels may be questioned. | Cross-check INCI list, label and notification. |
| Pack size/SKU | Packing list, label, carton mark, images | Incorrect quantity/specification affects declaration and inspection. | State tube/jar/bottle, ml/g, quantity by SKU. |
HS CODE – DUTY – C/O
For cream / skin care cream, the HS Code cannot be determined by the trade name alone. The operational review must compare the cosmetic function, product form, ingredients, label, cosmetic notification dossier, packaging and actual description on commercial documents. The section below is a detailed pre-ETA review framework; the final duty rate must still be checked on the declaration date.
Tax control note
The rates below are 2026 reference rates for HS 3304.99.30 based on current tariff data and sectoral tariff compilations. At customs declaration, the importer must re-check the tariff schedule, customs system, actual C/O, country of origin and applicable VAT policy.
1. HS CLASSIFICATION TABLE FOR CREAM / SKIN CARE CREAM
| HS code to review | Classification logic | When it may apply | When not to apply automatically | Documents to verify |
|---|---|---|---|---|
| 3304.99.30 | Other face or skin creams and lotions, within cosmetic / skin-care preparations other than medicaments. | Reference code for face cream, hand cream, foot cream, moisturizing cream, gel-cream and external-use skin care cream without therapeutic disease claims. | Do not apply automatically to serum/essence in another form, masks, powders, cleansing preparations, topical medicines or products with therapeutic claims. | Invoice, Packing List, original label, cosmetic notification, ingredient list, catalogue, product photos and SKU specifications. |
| 3304.99.20 | Anti-acne preparations. | Review if the cream is labelled/positioned as anti-acne, acne care or acne prevention and the notification dossier reflects that function. | Not for ordinary moisturizing or skin-care cream with surface-care, softening, moisturizing or cosmetic brightening claims only. | Label, claim sheet, notification, active ingredients, brand website and sales materials. |
| 3304.99.90 | Other preparations within skin-care cosmetics. | Consider for products that are not clearly creams/lotions or anti-acne preparations, such as some essences, sets or special forms. | Do not use to avoid 3304.99.30 where the product is actually a face/skin cream or lotion. | Catalogue, product form, specifications, formula and use purpose. |
| 3304.91.00 | Powders, whether or not compressed. | Only if the product is in powder form. | Not for emulsion/cream/gel-cream products. | Product photos, texture, label and catalogue. |
| 3401.30.00 | Organic surface-active products and preparations for washing the skin, in liquid or cream form, put up for retail sale, whether or not containing soap. | Review if the goods are cleansing cream, cream cleanser, make-up remover or face wash with a washing/surfactant function. | Not for leave-on skin care cream whose main function is moisturizing/care. | Cleansing claim, rinse-off/leave-on instructions, surfactants and label. |
| Pharmaceutical/other headings | May arise outside Chapter 33 if the product is medicinal or carries disease-treatment claims. | Only where label/dossier indicates treatment, prevention, pharmacological action or specially controlled ingredients. | Do not infer this for ordinary cosmetic skin-care cream. | Claims, formula, foreign marketing authorization, medical documents and legal/regulatory opinion. |
2. IMPORT DUTY – VAT TABLE FOR HS 3304.99.30
| Tax item | Specific reference rate | Application condition | Pre-declaration check | Risk if incorrect |
|---|---|---|---|---|
| MFN import duty | 18% | Applies where goods originate from a country/territory enjoying MFN treatment with Viet Nam and no special preferential C/O is used. | Check HS 3304.99.30 in the current preferential import tariff and the customs system on declaration date. | Wrong duty leads to underpayment/overpayment, amendment, recovery or post-clearance explanation. |
| Ordinary import duty | 27% | Reference rate where MFN/FTA conditions are not satisfied or origin does not enjoy preferential treatment. | Verify MFN status, origin evidence, invoice and original label. | Incorrect origin assessment may result in wrong tax liability. |
| Special preferential duty under FTA | Depending on route, may be 0%, 2.5%, 5%, 10%, 10.9% or another scheduled rate. | Only with valid C/O/proof of origin, correct agreement, origin criterion, direct consignment and matching documents. | Compare all available FTAs for the same origin and select the lowest lawful rate that can be supported by documents. | Rejected C/O may lead to MFN duty or post-clearance recovery. |
| Import VAT | 8% or 10% | During 01/07/2025–31/12/2026, review VAT reduction eligibility if the goods are not excluded; otherwise apply 10%. | Check Decree 174/2025/ND-CP, exclusion appendices, HS/product nature and system guidance at declaration time. | Assuming 8% for every cream shipment may be incorrect if excluded or not accepted by the system. |
3. SPECIAL PREFERENTIAL C/O/FTA TABLE FOR HS 3304.99.30
| Route/origin | C/O form or proof of origin | 2026 reference special preferential duty | Main application condition | Documents to compare | Risk to block |
|---|---|---|---|---|---|
| ASEAN / ATIGA | Form D C/O | 0% | ATIGA origin rules and direct consignment are satisfied. | Form D, invoice, packing list, B/L, goods description, HS, quantity and origin. | Wrong origin criterion, vague cream description or missing direct consignment proof. |
| China / ACFTA | Form E C/O | 0% if valid | Chinese origin under ACFTA; third-party invoice must be handled correctly if any. | Form E, description box, HS, invoice number, B/L, stamp/signature, exporter/manufacturer. | Form E is often challenged on description, third-party invoice, HS or transit route. |
| China / RCEP | RCEP proof of origin | Approx. 10% | Use only if RCEP conditions are met; compare with ACFTA because ACFTA may be more beneficial. | Proof of origin, RCEP criterion, invoice, B/L and route. | Using RCEP while ACFTA is available may increase tax cost. |
| Korea / VKFTA | Form VK C/O | 0% | Prefer to review for Korean-origin goods if VKFTA conditions are met. | Form VK, origin criterion, manufacturer, invoice, B/L and goods description. | Using AKFTA/RCEP instead may be less tax-efficient. |
| Korea / AKFTA | Form AK C/O | 5% | Applies if AKFTA requirements are met; compare with VKFTA. | Form AK, CTH/CTSH/RVC criterion and transport documents. | Failure to choose the optimal agreement increases landed cost. |
| Korea / RCEP | RCEP proof of origin | Approx. 10% | Consider only if VKFTA/AKFTA is unavailable or unsupported. | RCEP proof, invoice, B/L and origin criterion. | RCEP can be higher than bilateral/regional alternatives. |
| Japan / VJEPA | Form VJ C/O | 0% | Japanese-origin goods satisfying VJEPA. | Form VJ, origin criterion, invoice, B/L and cream description. | Wrong form or missing transit proof may deny preference. |
| Japan / AJCEP | Form AJ C/O | 0% | Applies under ASEAN–Japan agreement if conditions are met. | Form AJ, origin criterion, invoice, packing list and B/L. | Select the agreement that the exporter can properly document. |
| Japan / CPTPP or RCEP | CPTPP/RCEP proof | CPTPP may be 0%; Japan RCEP approx. 10.9% | Compare VJEPA/AJCEP/CPTPP/RCEP before finalizing documents. | Proof of origin, criterion, invoice, B/L and direct consignment. | Using RCEP when VJEPA/AJCEP/CPTPP is valid may increase duty. |
| EU / EVFTA | EUR.1 or origin statement if eligible | Approx. 2.5% | Apply according to EVFTA staging; verify EU member state and REX/statement where relevant. | EUR.1/origin statement, invoice, exporter, description, HS and direct consignment. | Incorrect statement or failure to prove EU origin may deny preference. |
| UK / UKVFTA | UKVFTA C/O or origin proof | Approx. 2.5% | Applies to UK-origin goods satisfying UKVFTA rules. | Origin proof, invoice, B/L, goods description and HS. | Confusing UK with EU or using incorrect proof may deny preference. |
| Australia–New Zealand / AANZFTA | Form AANZ C/O | 0% | Applies to Australian/New Zealand or ASEAN origin under AANZFTA if eligible. | Form AANZ, origin criterion, invoice, B/L and transit proof if any. | Missing direct consignment evidence through a third country. |
| Australia/New Zealand / CPTPP or RCEP | CPTPP/RCEP proof | CPTPP may be 0%; RCEP approx. 10% | Compare AANZFTA/CPTPP/RCEP according to exporter documents. | Proof of origin, invoice, B/L and origin criterion. | Using RCEP when AANZFTA/CPTPP is valid may not be optimal. |
| India / AIFTA | Form AI C/O | 5% | Applies if AIFTA origin requirements are met. | Form AI, origin criterion, invoice, packing list and B/L. | Failure to prove RVC/CTH or matching description may deny preference. |
| Chile / VCFTA or CPTPP | Form VC or CPTPP proof | May be 0% if eligible | Check which agreement the exporter can support. | Form VC/CPTPP proof, invoice, B/L and origin criterion. | Wrong proof format or direct consignment issue. |
| EAEU / VN-EAEU FTA | Form EAV C/O | May be 0% | Applies to EAEU-origin goods satisfying the agreement. | Form EAV, origin criterion, B/L and invoice. | Incorrect HS or description makes preference difficult to support. |
| Hong Kong / AHKFTA | Form AHK C/O | Approx. 20%; compare with MFN 18% | Use only if legally and commercially beneficial; transit via Hong Kong does not create Hong Kong origin. | Form AHK, manufacturer, origin criterion, B/L and invoice. | Applying AHKFTA when higher than MFN may increase tax cost; select the lowest lawful rate. |
4. PRE-ETA C/O CHECKLIST
| C/O item to check | Control requirement | Common error | Pre-ETA action |
|---|---|---|---|
| C/O form | Correct agreement form: D, E, VK, AK, VJ, AJ, AANZ, AI, VC, AHK, EAV, EUR.1 or corresponding self-certification. | Wrong form for the route/origin; using RCEP although another FTA is lower. | Ask shipper to confirm the form at PO/booking stage. |
| Origin criterion | Check WO, RVC, CTH, CTSH or agreement-specific criterion. | Criterion does not match product-specific rule or lacks material explanation. | Request origin calculation/production flow for high-value shipments. |
| Goods description | C/O description must match the cream, label, invoice and packing list. | C/O states only “cosmetics” and does not match SKU/pack size. | Request clear description: skin care cream/face cream, brand, SKU or key specification. |
| HS Code | HS on C/O should match at least 6 digits; if 8 digits are shown, compare with Viet Nam HS. | Export-country HS differs from Viet Nam HS without explanation. | Prepare an HS explanation memo if needed. |
| Third-party invoice | If third-party invoicing exists, it must be shown according to the relevant FTA. | Missing tick/statement or wrong invoice-issuing country. | Check draft C/O before original issuance. |
| Direct consignment | Prove direct consignment or compliant transit. | Transit via a third country without through B/L or non-manipulation evidence. | Obtain through B/L or non-manipulation certificate where needed. |
| Quantity – weight – value | Must match invoice, packing list, B/L and actual goods. | Gross/net weight, carton count or SKU quantity differs. | Cross-check before shipment departure. |
| Stamp, signature, issue date | Correct issuing authority, specimen stamp/signature, valid issue date and submission period. | Retroactive C/O not marked where required; invalid signature. | Check color scan before ETA and keep original/electronic proof as required. |
5. OPERATIONAL CONCLUSION FOR CREAM SHIPMENTS
- If the product is an ordinary external-use skin care cream, not a medicine, the first reference code to review is 3304.99.30.
- The base tax scenario for cost planning should include 18% MFN, 27% ordinary duty, and 8%/10% VAT depending on the declaration-date policy.
- With valid C/O, compare applicable FTAs. For several origins such as ASEAN, China under ACFTA, Korea under VKFTA, Japan under VJEPA/AJCEP/CPTPP, Australia–New Zealand under AANZFTA/CPTPP, the special preferential rate may reach 0%.
- Do not finalize landed cost until draft C/O, invoice, packing list, label and cosmetic notification match each other.
APPLICABLE SPECIALIZED POLICIES
| Goods situation | Possible policy | Documents to check | Authority / portal if identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Finished cosmetic cream for trading | Cosmetics management, product notification, labeling. | Notification, label, ingredients, CFS/authorization if required, invoice, packing list. | Drug Administration / health authority and customs. | Before arrival and before circulation. | Do not conclude eligibility if notification, label or ingredients do not match. |
| Cream with therapeutic/drug-like claims | Potential non-cosmetic classification review. | Claim sheet, label, formula, product dossier. | Health/specialized authority depending on classification. | Before ordering or ETD. | Therapeutic claims may change regulatory treatment. |
| Samples/testing/exhibition goods | Different treatment may apply depending on purpose and quantity. | Purpose letter, non-commercial invoice, quantity, label. | Customs and competent authority if requested. | Before ETA. | Commercial procedure cannot be assumed. |
| Gift set including other products | Each product may need separate HS, label and notification review. | SKU list, packing specification, labels, notifications. | Customs/health authority if relevant. | Before final invoice. | Incorrect grouping may distort HS/policy. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Name / number | Issuing body | Effective time | Role in procedure | Articles / appendices to note | Review note |
|---|---|---|---|---|---|---|
| Cosmetics regulation | Circular 06/2011/TT-BYT and amendments, including Circular 34/2025/TT-BYT. | Ministry of Health | Circular 34 effective 18/08/2025. | Cosmetics notification and circulation management. | Review notification, ingredients, labels and post-notification responsibility. | Check consolidated/latest text. |
| Foreign trade management | Decree 69/2018/ND-CP. | Government | Effective from 15/05/2018. | Foreign trade management framework. | Check restrictions/conditions if any. | Review by actual composition and claim. |
| Customs | Circular 38/2015/TT-BTC as amended by Circular 39/2018/TT-BTC. | Ministry of Finance | Circular 39 effective 05/06/2018. | Customs dossier, declaration and inspection. | Review customs dossier and amendment rules. | Check current system guidance. |
| Origin | Decree 31/2018/ND-CP. | Government | Effective from 08/03/2018. | Origin management and proof of origin. | FTA origin criteria. | C/O must match goods description and transport. |
| Labeling | Decree 43/2017/ND-CP and Decree 111/2021/ND-CP. | Government | 43: 01/06/2017; 111: 15/02/2022. | Goods labels and Vietnamese supplementary labels. | Mandatory label contents. | Label must match notification and import docs. |
| Import-export tariff | Decree 26/2023/ND-CP and Decree 108/2025/ND-CP. | Government | 108 effective 19/05/2025. | Tariff and duty reference. | Tariff appendices by HS. | Check on declaration date. |
| VAT | Decree 174/2025/ND-CP. | Government | Effective from 01/07/2025. | VAT reduction review. | Article 1, Article 2 and exclusions. | Verify system and tax guidance at import time. |
VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS
Enterprises may search the document numbers on the legal document portal, Government portal or the issuing authority website.
Enterprises should additionally verify documents on the legal document portal or issuing authority website before application.
CUSTOMS CLEARANCE DOCUMENT SET
Commercial documents
Commercial Invoice, Packing List, Bill of Lading/Air Waybill, Sales Contract/Purchase Order if any, C/O if claiming preference, catalogue/datasheet, product images, original label and SKU list.
Specialized documents if applicable
Cosmetic product notification, labeling file, ingredient documents, CFS if required, manufacturer/owner authorization if any, technical and claim-support documents.
100% matching rule
Goods name, quantity, SKU, pack size, origin, lot number, expiry, ingredients and label must match commercial documents, notification dossier, C/O and customs declaration.
Post-clearance archive
Keep notification, import documents, label photos, C/O, transport docs, payment and explanation files for post-clearance or cosmetics post-market review.
| Document group | Required document | Used for | Usually prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO | Customs, value, payment | Supplier, Procurement, Docs | Generic name, wrong SKU/spec. | Match each SKU with label and catalogue. |
| Transport | B/L or AWB, arrival notice, pre-alert | D/O, declaration, delivery | Forwarder/carrier | Wrong consignee, missing pre-alert. | Check before ETA. |
| Origin | C/O or proof of origin | Preferential duty | Exporter/issuing body | Wrong form/criterion/description. | Compare with invoice, B/L, packing list. |
| Cosmetics | Notification, label, ingredients, CFS/authorization if any | Compliance and circulation | Importer/legal/supplier | Notification does not match imported SKU. | Check product name, label, ingredients and responsible entity. |
CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended handling |
|---|---|---|---|---|
| HS Code | Is HS 3304.99.30 well supported? | Catalogue, label, ingredients, notification, photos | Explanation or duty adjustment. | Prepare a short classification memo before ETA. |
| Cosmetic notification | Does the notification match product name/label/SKU? | Notification, label, ingredient list | Supplementary dossier request. | Map notification against the shipment before declaration. |
| Vietnamese label | Does the supplementary label contain mandatory information? | Artwork, label photos, checklist | Cannot circulate properly. | Approve labels before market release. |
| C/O | Correct form, criterion, description and direct consignment? | C/O, B/L, invoice, packing list | Preference denied. | Check C/O before submission. |
| Product claim | Does claim exceed cosmetic scope? | Label, website, marketing material | Additional regulatory review. | Align claims with notification and cosmetic rules. |
PRACTICAL E2E PROCESS
Step 1 – Pre-ETA review
Confirm HS, policy, duty, C/O, labeling, notification, claim and any specialized dossier risk.
Step 2 – Lock documents and product files
Finalize Invoice, Packing List, B/L/AWB, catalogue/datasheet, SKU list, labels, notification and ingredient documents.
Step 3 – Complete specialized dossier if any
Review notification, CFS/authorization if needed, label and claim-support materials before arrival.
Step 4 – Customs declaration
Green channel may clear under conditions; Yellow checks documents; Red checks documents and physical goods. Common questions: value, HS, goods name, C/O, notification, label and catalogue.
Step 5 – Clearance, delivery and post-clearance
Pick up/deliver goods, verify supplementary labels, archive shipment dossier and prepare explanations for post-clearance review.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA control | Document to check |
|---|---|---|---|
| Wrong C/O form or origin criterion | No preferential duty or duty recovery. | Check form, criterion, description, HS and direct consignment. | C/O, B/L, invoice, packing list. |
| Mismatch among invoice, notification and label | Supplementary explanation request. | Prepare SKU mapping. | Invoice, notification, label, packing list. |
| Claim beyond cosmetic scope | Additional regulatory review. | Approve claims against notification. | Label, artwork, website, formula. |
| Incomplete Vietnamese label | Market circulation risk. | Approve supplementary label before delivery. | Original label, VN label, labeling rules. |
| Overly generic goods description | HS/policy uncertainty. | State cream, use, volume, SKU and brand. | Invoice, packing list, catalogue. |
FAQ
| Question | Answer |
|---|---|
| Does imported cream require a license? | Do not conclude absolutely. For finished cosmetic cream, the focus is usually notification, labeling and customs documents; special claims/ingredients require further review. |
| Is quality inspection/certification required? | Cream cosmetics are not treated like ICT group-2 goods; however, cosmetics compliance and labels must be reviewed under applicable health rules. |
| Is Vietnamese supplementary labeling required? | Yes, where the original label does not contain required Vietnamese content for circulation in Viet Nam. |
| Can C/O reduce duty? | Possibly, if C/O/proof is valid under the relevant FTA and matches goods, HS and transport. |
| Are samples handled like commercial goods? | Not automatically; purpose, quantity, value and documents must be reviewed. |
| What if invoice name differs from notification? | Review and correct before declaration; mismatches among invoice, notification, label and goods are high-risk. |
RELATED ARTICLES
Suggested internal links for further dossier review:
TGIMEX EXECUTION SOLUTION
This article provides a map of HS code, duty, documents and specialized policy. In real shipments, enterprises still need to review catalogue, datasheet, SKU, documents, origin and actual import purpose.
TGIMEX has an agency network in more than 60 countries and is a member of WCA, WCA China Global, VLA and HNLA, with capabilities in sea, air, road/rail transport, customs clearance, C/O, import permits, warehousing and inland delivery.
Pre-ETA review
HS, specialized policy, C/O, duties, label, catalogue/datasheet/SKU.
Compliance file control
Cross-check Invoice, Packing List, B/L/AWB, C/O, catalogue, cosmetics notification, label and technical documents.
International logistics
Coordinate agents, carriers/airlines, ETA, pre-alert and transport documents.
Customs declaration
Prepare declaration file, handle Green/Yellow/Red channels and support explanations on HS, value, origin and policy.
Post-clearance archive
Maintain shipment files and label/compliance evidence for post-clearance review.
For shipments that may involve specialized inspection, permits, C/O or labeling requirements, enterprises should not wait until arrival to start document review. Even a small mismatch among Invoice, Packing List, catalogue, datasheet, C/O or label may lead to document requests, clearance delays or unexpected storage costs.
TGIMEX supports an E2E import execution approach: pre-ETA policy review, document checking, international freight coordination, customs declaration, clearance handling, inland delivery and post-clearance archiving.
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