Risk: Eyeliner may be declared as a generic “cosmetic pen” or “make-up pencil”, while its regulatory nature is an eye make-up cosmetic. A vague description may lead to wrong HS classification, inconsistent cosmetic notification and incomplete label/ingredient records.

Impact: If the cosmetic notification number, authorization letter, CFS/waiver basis, label claims, C/O or product description do not match, the shipment may be subject to additional document requests, customs channel escalation, delayed clearance and unplanned DEM/DET charges.

Approach: This article provides an E2E (End-to-End) checklist for importers to review HS code, duties, C/O, cosmetic notification, labeling, customs documents and pre-ETA risk controls before shipping eyeliner to Vietnam.

QUICK FACTS

Item	Key review point	Operational note
Product scope	Eyeliner: liquid, gel, pencil, wax/crayon, pen-tip or cake eyeliner used for eye make-up.	Do not automatically apply to mascara, eyebrow pencil, eyeshadow, eyelash glue or eyelash growth products.
Indicative HS	3304.20.00 – eye make-up preparations.	Review actual label, function, composition, retail presentation and product photos.
Indicative taxes	MFN duty around 22%; ordinary duty reference 33%; VAT to be checked at 8%/10%.	Do not finalize tax without checking the tariff at customs declaration date.
Specialized policy	Imported finished cosmetics generally require a valid cosmetic product notification before commercial import/circulation.	Review Circular 06/2011/TT-BYT and Circular 34/2025/TT-BYT.
Main blockage points	Mismatch in notification/CFS/LOA, excessive claims, controlled colorants/preservatives, incomplete labels, C/O discrepancies.	Align product name, shade/SKU, batch, origin and responsible person across all documents.

Legal note: This is an operational reference. HS, duty, VAT, C/O, cosmetic notification, CFS/authorization and labels must be checked against the actual dossier and regulations effective on the declaration date.

SCOPE OF APPLICATION

This article applies only to eyeliner imported for commercial distribution in Vietnam, including liquid eyeliner, gel eyeliner, pencil/wax eyeliner, felt-tip eyeliner, jar eyeliner with brush, cake eyeliner and color/shade variants where the nature is eye make-up cosmetic.

Do not apply automatically to mascara, eyeshadow, eyebrow pencil, eyelash glue, false lashes, empty applicators, brushes or multi-item make-up sets.
Samples, testers, gifts and promotional items placed on the market should still be reviewed for notification, labeling and market-responsible entity obligations.
Claims such as medical eye treatment, eyelash growth stimulation or antibacterial/disinfecting effects may push the product outside ordinary cosmetic treatment.
Review catalogue, datasheet, SKU/shade list, label, formula/INCI and the actual import purpose.

PRODUCT CLASSIFICATION & IDENTIFICATION

Main function Make-up for defining or coloring the eyelid/eye contour.

Presentation Liquid, gel, pencil, wax/crayon, cake/powder, pen-tip or jar with brush.

Technical review Colorants, solvents, film formers, preservatives, packaging, shade, net content and applicator.

Use purpose Eye make-up, not medical treatment, infection prevention or eyelash growth therapy.

Checkpoint	Documents to compare	Risk if misdescribed	Suggested description on documents/declaration
Product nature	Catalogue, label, product photos, INCI/formula, SDS if any.	Generic “cosmetic pen” may lead to wrong HS and policy review.	“Eyeliner cosmetic preparation, brand…, shade…, net content…, for eye make-up”.
Presentation form	Datasheet, packing, product photos.	May be confused with eyebrow pencil, mascara, eyeshadow or empty tools.	State liquid/gel/pencil/crayon/cake eyeliner.
Claims	Artwork, label, website, marketing claims.	Medical or growth claims may exceed cosmetic scope.	State eye make-up function only.
Shade/SKU list	Shade list, invoice, packing list, SKU list.	Mismatch causes difficulties in notification and customs check.	Attach shade/SKU annex when multiple colors exist.
Label and origin	Original label, Vietnamese label, C/O, invoice, packing list.	Origin, batch, expiry and responsible person may not match.	Align goods description and origin across documents.

HS CODE – DUTIES – C/O

For finished eyeliner used as eye make-up, the key HS code to review is usually 3304.20.00 – eye make-up preparations. The classification basis is main function, cosmetic composition, application area, retail presentation and label/catalogue description. Sets, empty tools or products with medical claims require separate review.

Indicative HS code	Application condition	Risk if misclassified	Documents to check
3304.20.00	Finished eyeliner for eye make-up in liquid, gel, pencil/wax, pen-tip, cake or jar format.	Wrong HS may affect duty, notification and C/O description.	Label, INCI/formula, catalogue, photos, cosmetic notification, invoice/packing list.
3304.99.xx	Only if the item is not eye make-up but another skin/eye-area cosmetic.	Misstating eye make-up may trigger HS consultation.	Claims, instructions, product form and use area.
9603/9616 or other headings	Only for empty brushes/applicators, packaging or accessories without cosmetic preparation.	Combining tools and cosmetics under one code may be incorrect.	Detailed packing list, structure, set composition and values.

Tax/C/O line	Indicative level for HS 3304.20.00	Application condition	Operational risk
MFN import duty	Around 22%.	For eligible MFN origin/territory where FTA is not claimed.	Check if FTA C/O can provide a better rate.
Ordinary import duty	Reference 33%.	May apply if MFN/FTA conditions are not met.	Review Decision 15/2023/QD-TTg and current tariff.
VAT	Check 8%/10%.	Reduced VAT applies only when the product is not excluded and the policy is still effective.	Do not assume 8% without checking the annexes and declaration system.
Special preferential duty	May be reduced under FTA if C/O/origin proof is valid.	ATIGA, ACFTA, AKFTA, VKFTA, AJCEP, VJEPA, AANZFTA, AIFTA, RCEP, EVFTA, UKVFTA, CPTPP, etc.	Wrong form, origin criterion, description, HS, third-party invoice or transit proof may lead to rejection.

Origin route	C/O or origin proof to review	Documents to compare	Risk if incorrect
ASEAN/ATIGA	Form D or applicable origin proof.	C/O, invoice, packing list, B/L/AWB, origin criterion.	Loss of preferential duty if direct consignment or criterion fails.
China/ACFTA or RCEP	Form E or RCEP proof.	Description, HS 3304.20.00, exporter, third-party invoice if any.	Form E is often sensitive to description and third-party invoicing.
Korea/AKFTA/VKFTA/RCEP	Form AK, VK or RCEP proof.	Origin criterion, exporting country, transport route.	Choosing the wrong FTA may lose the better preferential rate.
Japan/AJCEP/VJEPA/CPTPP/RCEP	Form AJ, VJ, CPTPP or RCEP proof.	C/O, transport documents, invoice, packing list, catalogue.	Incorrect origin criterion or late issuance issues may cause rejection.
EU/EVFTA, UK/UKVFTA	EUR.1 or origin statement where applicable.	Origin proof, invoice, exporter reference if any, direct consignment.	Invalid statement or inconsistent description can be rejected.

APPLICABLE SPECIALIZED POLICIES

Goods situation	Potential policy	Documents to check	Authority/portal if identifiable	Recommended timing	Risk note
Finished eyeliner for commercial import	Cosmetic product notification and cosmetic management.	Notification number, LOA, CFS/waiver, label, ingredient list, PIF.	Drug/cosmetic authority or public service portal depending on current procedure.	Before shipment/ETA.	Missing notification can block clearance/circulation.
Multiple shades/SKUs	Each trade name/shade/SKU must match notification and label dossier.	Shade list, SKU, artwork, invoice, packing list.	Importer/compliance team.	Before PO and invoice finalization.	Mismatch may lead to dossier rejection.
Borderline claims	May require regulatory reclassification/claim review.	Claims, labels, website, brochure, composition.	Health/regulatory authorities during inspection.	Before label approval.	Medical/growth claims are high risk.
Samples/testers/promotional goods	Notification/label obligations depend on market placement.	Import purpose, quantity, tester label, internal documents.	Customs and health authority depending on case.	Before booking/declaration.	Do not assume samples are exempt.
Flammable solvent formulation	May trigger DG transport requirements.	SDS/MSDS, flash point, UN number if any.	Carrier/forwarder/DG specialist.	Before booking.	Missing SDS may delay booking.

LEGAL DOCUMENTS TO REVIEW

Document group	Document number/name	Issuing body	Effective date / timing	Role in procedure	Key provisions/annexes to note	Review note
Cosmetics circular	Circular 06/2011/TT-BYT	Ministry of Health	Effective from 2011, as amended	Core regulation for cosmetic notification, PIF, safety, labeling and import.	Notification, LOA, CFS, labeling, PIF.	Check consolidated/amended text.
Amending circular	Circular 34/2025/TT-BYT	Ministry of Health	Effective 18 Aug 2025	Updates cosmetic notification dossier, CFS and filing mechanism.	Electronic/paper submission, CFS/waiver rules.	Apply based on filing time.
Labeling decree	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Decree 111 effective 15 Feb 2022	General labeling/origin rules for imported goods.	Mandatory label and Vietnamese supplemental label.	Coordinate with cosmetic labeling rules.
MFN tariff	Decree 26/2023/ND-CP	Government	Effective 15 Jul 2023	MFN import duty schedule.	Heading 33.04; HS 3304.20.00.	Check on declaration date.
Ordinary tariff	Decision 15/2023/QD-TTg	Prime Minister	Effective 15 Jul 2023	Ordinary import duty basis.	Ordinary duty application rule.	Use only where MFN/FTA is not applicable.
VAT	Decree 174/2025/ND-CP	Government	Effective 01 Jul 2025	VAT reduction policy.	Excluded goods/services annexes.	Check current validity and customs system.
Sanctions	Decree 117/2020/ND-CP and amendments	Government	Effective 15 Nov 2020	Administrative penalties in health sector including cosmetics.	Notification, circulation, labeling, quality violations.	Check amendments before application.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Circular 06/2011/TT-BYT
Circular 34/2025/TT-BYT
Decision 2393/QD-BYT
Decree 26/2023/ND-CP
Decision 15/2023/QD-TTg
Decree 174/2025/ND-CP
Decree 111/2021/ND-CP

Businesses should cross-check the official legal database or issuing authority website before application.

CUSTOMS CLEARANCE DOCUMENT SET

Commercial documents

Commercial Invoice.
Packing List showing SKU/shade/quantity.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
C/O if preferential duty is claimed.
Catalogue, original label, product photos and shade/SKU list.

Cosmetic regulatory documents

Valid cosmetic product notification number.
Authorization letter from manufacturer/owner.
CFS or exemption basis where applicable.
Ingredient/INCI list, original label and proposed Vietnamese label.
PIF retained for post-market inspection.

Document group	Required document	Used for	Usually prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO, B/L/AWB.	Declaration, value, quantity, transport.	Importer, shipper, forwarder.	Vague product name or missing shade/SKU.	Compare SKU/shade against notification and packing list.
HS classification	Catalogue, label, ingredients, photos.	HS, duty and policy review.	Importer/compliance/broker.	Confusion with mascara, eyeshadow or empty tools.	Review use and retail presentation.
Cosmetic notification	Notification, LOA, CFS/waiver, responsible person information.	Import/circulation condition.	Regulatory/Legal/QA.	Product name mismatch.	Compare trade name, variant, manufacturer/owner.
C/O	C/O/origin proof, invoice, B/L/AWB.	Special preferential duty.	Shipper/importer.	Wrong form or origin criterion.	Check form, HS, description, quantity, issue date and direct consignment.
Label	Original label, Vietnamese label, artwork.	Clearance/circulation/post-market check.	Importer/brand owner.	Missing ingredients, batch, MFG/EXP or warning.	Checklist under labeling and cosmetic rules.

CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended action
HS code	Is the product truly an eye make-up preparation?	Catalogue, label, ingredients, notification.	HS consultation, tax adjustment, clearance delay.	Finalize HS before ETA and keep classification rationale.
Cosmetic notification	Does the notification match product/brand/shade?	Notification, LOA, CFS.	Additional regulatory documents requested.	Align notification with invoice and label before shipping.
Product claims	Any medical/growth/antibacterial claims?	Artwork, claim list, website.	Possible regulatory reclassification.	Review claims before label/marketing approval.
C/O	Is FTA eligibility established?	C/O, invoice, B/L/AWB, origin criterion.	Preferential duty denied.	Check draft C/O before declaration.
Vietnamese label	Is the supplemental label complete?	Original and Vietnamese labels, notification dossier.	Post-market/circulation risk.	Prepare label before arrival.
Samples/testers	Will the goods be placed on the market?	Import purpose, quantity, internal documents.	Wrong customs type or missing regulatory obligations.	Clarify purpose and applicable procedure.

E2E IMPORT PROCEDURE FOR EYELINER

Step 1: Pre-ETA review

Confirm HS 3304.20.00 where applicable, MFN/FTA/VAT, cosmetic notification, label and C/O.

Step 2: Lock documents

Finalize invoice, packing list, B/L/AWB, shade/SKU list, original label, INCI/formula and notification dossier.

Step 3: Complete regulatory dossier

Check notification number, LOA, CFS/waiver, PIF and Vietnamese label. Resolve gaps before ETA.

Step 4: Customs declaration

Green channel allows conditional clearance; Yellow checks documents; Red checks documents and physical goods. Key questions: HS, value, C/O, description, notification and label.

Step 5: Clearance and post-clearance control

Deliver to warehouse, control label placement, archive shipment records, PIF and origin documents for post-market checks.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents to check
Notification number mismatch	Additional documents or explanation.	Compare notification with invoice, packing list, label and SKU list.	Notification, label, invoice, packing list.
Claims exceed cosmetic scope	Regulatory reclassification risk.	Approve claims before import and sale.	Artwork, website, brochure, label claim.
C/O error	Loss of preferential duty.	Review draft C/O before arrival.	C/O, invoice, B/L/AWB, origin criterion.
Vague description	Wrong HS and policy risk.	State eyeliner, form, brand, shade and net content.	Catalogue, label, invoice.
Incomplete label	Market inspection risk.	Prepare Vietnamese label in line with notification and label rules.	Original label, Vietnamese label, notification.
Unclear SDS for solvent-based product	Air/sea booking delay.	Obtain SDS/MSDS and transport classification.	SDS/MSDS, flash point, packing instruction if any.

FAQ – COMMON BUSINESS QUESTIONS

1. Does imported eyeliner require cosmetic notification?

Yes, where imported for commercial circulation in Vietnam. A valid cosmetic product notification should be available before commercial shipment/circulation.

2. Is HS 3304.20.00 always correct?

No absolute conclusion should be made without reviewing the actual dossier. It is the key reference for eye make-up preparations.

3. Is quality inspection/certification required?

Ordinary finished cosmetics are generally managed through notification and post-market control, but special claims or unusual composition require separate review.

4. Can C/O reduce duty?

Yes, if the origin proof is valid and matches the FTA rules, HS and goods description.

5. Are testers or gifts exempt?

Not automatically. If placed on the market or provided to consumers, notification/label obligations should be reviewed.

6. What if invoice name differs from the notification?

Correct or align documents before declaration; mismatch in trade name, shade, SKU or manufacturer may delay clearance.

7. Is pencil eyeliner stationery?

No, if it contains cosmetic preparation for eye make-up. Pencil form does not change its cosmetic nature.

IMPLEMENTATION SOLUTIONS FROM TGIMEX

This article sets out the HS, tax, cosmetic notification and specialized policy map for eyeliner. For actual shipments, each dossier must be checked against catalogue, label, ingredients, shade/SKU list, documents, origin and import purpose.

Pre-ETA review

HS, duties, C/O, notification, labels, catalogue, INCI and shade/SKU list.

Compliance control

Invoice, Packing List, B/L/AWB, C/O, LOA, CFS, notification, label and PIF cross-check.

International logistics

Agent coordination, carrier booking, pre-alert, ETA and transport documents.

Customs and post-clearance

Declaration preparation, channel handling, record retention and post-market label review.

For shipments with cosmetic notification, C/O or labeling requirements, businesses should not wait until cargo arrival to review documents. Small discrepancies may cause additional document requests, clearance delay or unplanned storage costs.

TGIMEX supports an E2E import plan: pre-ETA policy review, document control, international logistics coordination, customs declaration, clearance handling, domestic delivery and post-clearance record keeping.

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