Imported toner must be consistent across the cosmetic notification, original label, formula, claims, Invoice – Packing List and HS code. Generic or inconsistent product descriptions may trigger questions on notification, labelling, SDS and classification basis.

This guide sets out the key pre-ETA checks: HS Code, import duty, VAT, C/O, cosmetic notification, labelling, customs documents and risk points that may delay clearance.

Reference translationThis English version follows the Vietnamese legal logic for business reference only. It is not an official legal translation issued by a competent authority.

QUICK FACT

Item	Review point	Operational note
Product	Toner, a finished skin-care cosmetic in liquid/lotion form for external use, not a medicine.	Applies to imported finished products intended for commercial circulation in Viet Nam.
Reference HS	3304.99.30 for other face or skin creams and lotions; review 3304.99.90 if the product description does not fit the primary code.	HS must be determined by function, claim, label and product form.
Duty/VAT	Typical MFN 20%; normal duty reference 30%; VAT planning rate 10%, only review 8% if eligible under the applicable VAT reduction policy.	C/O may reduce import duty only when the certificate, origin criteria and transport route are valid.
Specialized policy	Imported cosmetics require a cosmetic product notification receipt number for import clearance review and before being placed on the market, under Circular 06/2011/TT-BYT and amendments including Circular 34/2025/TT-BYT.	Do not treat it as a generic “import licence”; the core file is cosmetic notification/compliance.
Labelling	Original label and Vietnamese supplementary label must match the notification file and show required cosmetic information.	Check product name, function, ingredients, batch, expiry, origin and responsible party.

SCOPE OF APPLICATION

Legal noteThis article applies only to finished cosmetic toner for external skin care. It does not apply automatically to medicines, disinfectants, medical products, bulk cosmetic liquids, raw materials, testers, R&D samples or cosmetic sets containing different products. Review catalogue, formula, label, claims and actual import purpose.

In scope

Hydrating, soothing, balancing or exfoliating toner within cosmetic claims.
Retail packaged toner under a brand/SKU with compliant cosmetic notification.
New commercial goods imported for sale or distribution.

Separate review required

Acne treatment, antibacterial, anti-inflammatory or disease-treatment claims.
High-alcohol toner or products with dangerous goods risk during transport.
Samples, testers, exhibition goods or research/quality-control products.
Bulk liquid, semi-finished products, empty packaging or mixed cosmetic sets.

CLASSIFICATION & TECHNICAL IDENTIFICATION

The key issue is whether the item is a finished skin-care cosmetic, packed for retail, with cosmetic ingredients, external-use instructions and claims that remain within the cosmetic boundary.

Criterion	Documents to check	Risk if misdescribed	Suggested goods description
Product form	Label, product photo, catalogue, packaging.	May be confused with cleanser, perfume mist, chemical liquid or drug product.	Facial toner/skin toner cosmetic, brand…, SKU…, capacity…
Claims/functions	Label artwork, notification file, website and marketing materials.	Therapeutic claims may move the product outside cosmetics.	Use cosmetic functions: balancing, hydrating, soothing or surface cleansing.
Ingredients	INCI list, formula, CFS, SDS/MSDS if alcohol/fragrance is present.	Ingredient inconsistency may affect notification and post-market inspection.	Use INCI names consistently.
Packaging & shelf life	Packing list, lot/expiry list, carton mark, label.	Quantity, capacity or expiry mismatch may hold the shipment.	State capacity, for example 150 ml/bottle or 200 ml/bottle.

HS CODE – DUTY – C/O

HS code must be determined by the product’s main function, presentation, claims and supporting documents. Do not apply one HS code to all skin-care liquids without review.

Reference HS	When applicable	Risk if wrong	Documents to compare
3304.99.30	Skin-care toner/lotion, external use, cosmetic, non-medicinal.	Customs may query HS and cosmetic policy if the description is unclear.	Notification, label, INCI, catalogue, SDS.
3304.99.90	Other skin-care preparations not fitting the specific lotion/cream subheading.	Inconsistent description may affect duty and compliance review.	Claim, artwork, product form, CFS/LOA.
3304.99.20	Only if the product is truly an anti-acne preparation under its real description and claims.	Acne-treatment wording may trigger cosmetic/drug boundary risk.	Formula, claims, notification and marketing materials.
3401.30.00	Review only if the product is actually a wash-off skin cleansing preparation, not ordinary toner.	Confusing cleanser with toner may lead to wrong HS and policy.	Directions for use and surfactant ingredients.

DETAILED DUTY TABLE TO REVIEW BEFORE DECLARATION

Standard skin-care toner

HS3304.99.30

MFN20%

Normal dutyReference 30% under the 150% MFN principle if no preferential/special preferential rate applies.

VATPlan at 10%; review 8% only if eligible and not excluded.

C/OReview Form D, E, RCEP, CPTPP, EVFTA, UKVFTA or other applicable FTAs.

Other skin-care preparation

HS3304.99.90

MFN20%

Normal dutyReference 30% if the 150% principle applies.

VAT10% planning rate; review 8% case by case.

Anti-acne/borderline claim

HSReview 3304.99.20 or other code based on actual file.

Main riskClaim may exceed cosmetic scope and require regulatory review.

FileFormula, notification, label, CFS, LOA and claim substantiation.

Samples/testers/R&D

HSClassified by product nature, usually Chapter 33 if it is cosmetic.

PolicyCannot be sold if imported for research/testing purposes without market circulation compliance.

APPLICABLE SPECIALIZED POLICIES

Scenario	Policy	Documents	Authority/portal	Timing	Risk note
Commercial toner	Cosmetic product notification before circulation.	CFS, LOA/POA, notification form, formula, label.	Drug Administration of Vietnam / relevant public service system.	Before import or market circulation planning.	Missing notification may block market circulation and trigger customs queries.
Alcohol/fragrance toner	Dangerous goods review for transport.	SDS/MSDS, flash point, UN/class if any.	Carrier/airline/shipping line/agent.	Before booking.	Undeclared DG may be rejected or penalized.
Medical/acne/antibacterial claims	Cosmetic boundary review.	Claims, artwork, website, formula.	Health authority/customs depending on case.	Before notification and import.	Claims may move the product outside cosmetics.
Samples/testers	Specific purpose review; no commercial sale unless compliant.	Sample import purpose, quantity and undertaking.	DAV/customs based on case.	Before arrival.	Do not disguise commercial goods as samples.

LEGAL DOCUMENTS TO REVIEW

Group	Document	Issuer	Effective date	Role	Notes
Circular	06/2011/TT-BYT	Ministry of Health	01/04/2011	Cosmetic notification, labelling, PIF, import/export and post-market control.	Review consolidated version and amendments.
Amendment	34/2025/TT-BYT	Ministry of Health	18/08/2025	Amends several provisions of Circular 06/2011/TT-BYT.	Apply by filing date and current guidance.
Labelling	43/2017/NĐ-CP, 111/2021/NĐ-CP	Government	As applicable	Goods labelling and Vietnamese supplementary labels.	Cosmetic-specific labelling still follows cosmetic rules.
Tariff	26/2023/NĐ-CP	Government	15/07/2023	MFN tariff schedule for Chapter 33, heading 3304.	Check amendments at declaration date.
Normal duty	15/2023/QĐ-TTg	Prime Minister	15/07/2023	Normal duty principle, including 150% MFN when relevant.	Use if no preferential treatment applies.
VAT	48/2024/QH15, 204/2025/QH15, 174/2025/NĐ-CP	National Assembly/Government	01/07/2025 to 31/12/2026 for reduction policy	Determine 10% or eligible 8% VAT.	Use 10% for conservative cost planning if uncertain.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises should also verify the document numbers on the official legal document portals or the issuing authorities’ websites before application.

Circular 06/2011/TT-BYT Circular 34/2025/TT-BYT HS 3304.99.30 Decree 26/2023/NĐ-CP

CUSTOMS CLEARANCE DOCUMENT SET

Commercial documents

Commercial Invoice, Packing List, B/L or AWB.
Sales Contract/PO if any.
C/O if claiming preferential duty.
Catalogue, product photos, original label and SKU list.

Cosmetic compliance file

Cosmetic product notification receipt number.
CFS, LOA/POA, formula/ingredient list.
Original label, Vietnamese supplementary label and PIF.
SDS/MSDS for alcohol/fragrance or transport requirement.

OPERATIONAL DOCUMENT CHECKLIST

File group	Documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO	Declaration and valuation	Importer/supplier	Product name/capacity mismatch	Match against label and notification.
Transport	B/L or AWB, arrival notice, pre-alert	Cargo release and customs	Forwarder/carrier	Generic goods description	Review draft transport documents.
Cosmetic	Notification, CFS, LOA, formula	Specialized compliance	Regulatory/importer	Different product name or manufacturer	Check against label and SKU list.
DG if any	SDS/MSDS and flash point	Booking and transport safety	Supplier/forwarder	Alcohol risk not declared	Review before booking.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question	Evidence	Consequence	Recommended action
HS	Is 3304.99.30 supported?	Label, claims, formula.	HS query or channel change.	Prepare classification note.
Notification	Is the exact product notified?	Notification, CFS, LOA.	Compliance query.	Match product name/SKU.
Claims	Any therapeutic claim?	Artwork, website.	Boundary risk.	Review before import.
C/O	Correct form and origin?	C/O, invoice, B/L.	Loss of preference.	Check draft C/O.

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review

Confirm HS, duty, VAT, C/O, notification, label and DG status.

Step 2 – Lock documents

Finalize Invoice, Packing List, B/L/AWB, product label and SKU list.

Step 3 – Compliance file

Check notification, CFS, LOA, formula, PIF and Vietnamese label.

Step 4 – Customs declaration

Handle Green/Yellow/Red channel and respond to HS, value, origin and cosmetic file queries.

Step 5 – Release and delivery

Pay taxes, release cargo, deliver to warehouse, apply labels if required.

Step 6 – Post-clearance file

Archive import documents, C/O, label and PIF for post-market/post-clearance control.

PRE-ETA RISK CHECKLIST

Risk	Impact	Prevention	Document
Wrong notification	Market circulation issue	Check exact product/SKU	Notification, label
Name mismatch	Customs query	Lock naming convention	Invoice, label, notification
Wrong C/O	No duty preference	Review draft C/O	C/O, B/L, invoice
Borderline claims	Non-cosmetic risk	Review artwork and marketing	Claims, formula
Alcohol/DG issue	Booking rejection	Check SDS/MSDS	SDS, flash point

FAQ

1. Does toner require an import licence?

It is more accurate to review cosmetic product notification, not a generic licence. The product must comply before circulation.

2. What is the main HS code?

3304.99.30 is the main reference, subject to actual documents.

3. Is VAT 10% or 8%?

Plan 10%; apply 8% only if eligible.

4. Can C/O reduce duty?

Yes, if the C/O, origin criteria and shipment route are valid.

5. Is alcohol toner dangerous goods?

It depends on SDS/MSDS, flash point and transport rules.

6. Are testers handled like sale goods?

No. Samples/testers require separate purpose review and cannot be sold unless compliant.

IMPLEMENTATION SUPPORT FROM TGIMEX

For toner shipments, enterprises should not wait until cargo arrival to review HS, tax, C/O, cosmetic notification and labels. TGIMEX can support pre-ETA review, document control, international freight coordination, customs declaration, delivery and post-clearance file retention.

Relevant capacity

Agency network in more than 60 countries.
Membership in WCA, WCA China Global, VLA, HNLA.
Ocean, air, road/rail freight and customs clearance.

Work scope

Pre-ETA HS, duty, C/O, notification and label review.
Invoice, Packing List, B/L/AWB, C/O, label and notification cross-check.
Customs declaration and Green/Yellow/Red channel support.

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