A toothpaste shipment is often delayed not because the customs procedure is inherently complex, but because the importer uses a generic goods description, applies the wrong HS code, lacks a cosmetic product notification receipt, uses claims beyond cosmetic scope, or has inconsistencies among Invoice, Packing List, label and INCI formula. This article provides an E2E map for reviewing HS code, duty, specialized policy, dossier, clearance process and pre-ETA risks.

QUICK FACTS

Review item	Practical note for toothpaste
Product scope	Toothpaste – tooth-cleaning preparation in paste, gel or powder form, packed for retail sale and used for oral/dental hygiene.
Primary HS to review	3306.10.10 – toothpastes/powders for preventing dental diseases; classification must be checked against ingredients, form, label and actual claims.
Alternative HS to review	3306.10.90 for other tooth-cleaning preparations; 3306.90.00 is not the default code for ordinary toothpaste and should only be considered for mouthwash, breath spray or other oral/dental preparations.
Reference duties	MFN duty 20%; ordinary import duty for reference 30%; base VAT 10%.
Specialized policy	Imported cosmetic products must obtain the cosmetic product notification receipt number before being placed on the Vietnamese market, where the product falls under cosmetic management.
Key risks	Wrong HS code, therapeutic claims beyond cosmetic scope, missing cosmetic notification, incorrect label, and C/O discrepancies in form/origin criteria.

Legal note: This content applies to ordinary cosmetic toothpaste. It does not automatically apply to mouthwash, cosmetic breath spray, medicinal dental products, medical devices or products with therapeutic claims. Review by formula, label, claims, notification dossier, origin and actual shipment documents.

SCOPE OF APPLICATION

This article covers only toothpaste in the group “toothpaste, cosmetic mouthwash and cosmetic breath spray”. Toothpaste for children, fluoride toothpaste, whitening toothpaste, sensitive toothpaste, herbal toothpaste, charcoal toothpaste, samples, gifts or oral-care sets may require separate review by SKU and claim.

PRODUCT CLASSIFICATION & IDENTIFICATION

By use

Toothpaste is normally a paste, gel or powder used with a toothbrush for oral/dental hygiene and cosmetic oral care.

By technical dossier

Review brand, variant, product form, net weight, INCI formula, fluoride content if any, label claims and usage instructions.

By packaging

Tube, carton, travel pack or set packaging. If packed with toothbrush, mouthwash or breath spray, review each component separately.

By claims

Cleaning, fresh breath, enamel protection or cosmetic whitening claims may be acceptable; treatment or cure claims require separate legal review.

Criteria to check	Documents to compare	Risk if wrongly described	Suggested goods description
Product form	Catalogue, label, product photos, formula	Wrong HS or specialized policy	Toothpaste, paste/gel/powder, brand, variant, net weight, new goods.
Main use	Label, claims, website, leaflet	Therapeutic claim risk	Oral/dental hygiene preparation; avoid unverified treatment wording.
INCI ingredients	Formula, PIF, COA/SDS if any	Mismatch with notification	Declare the finished product, not individual ingredients.
Sets/SKU	Packing list, SKU list, set photos	Combining different goods under one HS	Separate toothpaste from mouthwash, breath spray or toothbrush.

HS CODE – DUTIES – C/O

The HS basis is that toothpaste is an oral/dental hygiene preparation under heading 3306, and should first be reviewed under subheading 3306.10. Final classification depends on actual form, composition, claims, packaging and technical dossier.

Reference HS code	Application conditions	Reference duty / VAT	Risk if misclassified	Documents to check
3306.10.10	Toothpaste in paste/gel/powder form, packed for retail sale and used for dental hygiene or cosmetic oral care claims.	MFN 20%; ordinary duty reference 30%; base VAT 10%.	Incorrectly using 3306.90.00 or 3306.10.90 may trigger classification explanation and duty adjustment.	Catalogue, label artwork, INCI formula, COA if any, cosmetic notification, invoice, packing list and C/O draft.
3306.10.90	Other tooth-cleaning preparations when technical dossier does not fit 3306.10.10.	MFN 20%; ordinary duty reference 30%; base VAT 10%.	If the actual goods are toothpaste in paste/powder form, Customs may request further justification.	Product form, retail packaging, usage instructions, claims, sample photos and SKU list.
3306.90.00	Not the primary code for toothpaste. Consider only for mouthwash cosmetic, breath spray cosmetic or other oral/dental hygiene preparations outside 3306.10.	MFN 20%; base VAT 10% as shown on the trade portal for this line.	Using this code for toothpaste may cause wrong subheading and inconsistent cosmetic/label dossier.	Catalogue, label, product form, intended use and SKU breakdown.

SPECIAL PREFERENTIAL C/O – FTA MATRIX

Origin / route	C/O form or origin document	Preferential rate to review	Conditions to apply	Risks
ASEAN	Form D / ATIGA origin document	May be 0% if the HS line is covered by the current ATIGA tariff schedule and origin rules are met.	Check Decree 126/2022/NĐ-CP, origin criterion, direct consignment and third-party invoice if any.	Wrong form, HS, goods description or transport document may lead to rejection of preferential duty.
China	Form E – ACFTA	Check Decree 118/2022/NĐ-CP and the ACFTA tariff schedule applicable in the declaration year.	Correct origin criterion, goods description, quantity/weight, origin country, signature and stamp.	Form E is often questioned for third-party invoicing, goods description and origin criteria.
Korea	Form AK / VK or RCEP origin document where applicable	Check AKFTA, VKFTA or RCEP schedule.	Correct FTA route, exporter, RVC/CTH/CTSH or applicable origin criterion.	Choosing the wrong FTA may lose preference even when the goods are of Korean origin.
EU / UK	EUR.1 or approved origin statement under EVFTA/UKVFTA	Check EVFTA/UKVFTA schedule for the relevant year.	Qualified exporter/origin statement, direct transport and matching commercial documents.	Invalid statement or missing origin evidence may lead to MFN duty.
Japan, CPTPP, RCEP, Australia/NZ, India	Origin document under VJEPA, AJCEP, CPTPP, RCEP, AANZFTA, AIFTA as applicable	Do not assume a common rate; check each FTA schedule by HS and year.	Member country, origin rule, transport route and invoice structure must match.	Multiple FTAs may be available, but not all provide the best rate or meet dossier conditions.

PRE-ETA HS – TAX CHECKLIST

Finalize whether the product is toothpaste under 3306.10.10 or other tooth-cleaning preparation under 3306.10.90.
Check MFN 20%, ordinary duty reference 30%, base VAT 10%.
Only consider VAT 8% if the reduction policy is valid, not excluded and supported at declaration date.
Review C/O draft: form, HS, description, origin criterion, third-party invoice and direct transport.

SPECIALIZED REGULATORY POLICY

Goods situation	Possible policy	Documents to check	Authority / processing channel	When to do	Risk note
Ordinary cosmetic toothpaste	Cosmetic notification before market circulation and import customs procedures.	Notification receipt, LOA/authorization, CFS if any, INCI formula, label and catalogue.	Cosmetic management portal/authority by competence; Customs when declaring.	Before ETA, preferably before shipment leaves origin.	Without a valid notification receipt, goods may not be legally circulated.
Fluoride, whitening, sensitive or gum-care toothpaste	May remain cosmetic if claims do not exceed cosmetic scope; claims must be reviewed.	Label, claims, safety file, PIF, test/COA if any.	Cosmetic authority and Customs where explanation is needed.	Before label approval and booking.	Treatment claims may trigger non-cosmetic regulations.
Samples / testing goods	Different handling may apply depending on purpose, quantity and non-commercial use.	Purpose statement, sample invoice, packing list, product technical file.	Customs and specialized authority if requested.	Before ETA.	Samples declared for testing should not be sold if the declared purpose is not commercial circulation.
Toothpaste packed in an oral-care set	HS and policy may need to be separated by component or assessed as a set if legally qualified.	BOM, detailed packing list, labels for each item, SKU values.	Customs and specialized authority.	Before invoice issuance.	Generic “oral care set” descriptions may cause HS and notification errors.

LEGAL DOCUMENTS TO REVIEW

Document group	Document	Issuing authority	Effective/application timing	Role in procedure	Key article/annex	Review note
Cosmetics circular	Circular 06/2011/TT-BYT on cosmetic management	Ministry of Health	Applicable with later amendments.	Basis for cosmetic notification, labeling, responsible person and post-market surveillance.	Article 18 on cosmetic labeling; annexes on notification and claims.	Treatment claims need separate review.
Amending circular	Circular 34/2025/TT-BYT	Ministry of Health	Issued 03 July 2025, effective 18 August 2025.	Amends/supplements Circular 06/2011/TT-BYT, especially notification form and filing guidance.	Notification form and filing instructions.	Use the current form at the filing date.
Goods labeling	Decree 43/2017/NĐ-CP and Decree 111/2021/NĐ-CP	Government	Check validity at import date.	Basis for imported goods labeling and Vietnamese supplementary label.	Mandatory label information and importer responsibility.	Cosmetic label must also comply with Ministry of Health rules.
MFN/VAT tariff	Import tariff, VAT regulations and Customs trade portal data	Government / Ministry of Finance / Customs	At customs declaration date.	Determine MFN duty, ordinary duty, VAT and relevant tax lines.	HS 3306.10.10, 3306.10.90, 3306.90.00.	Do not finalize duty without checking current tariff and actual dossier.
VAT reduction policy	Decree 174/2025/ND-CP	Government	Effective from 01 July 2025, subject to the policy period stated in the document.	Basis to review whether VAT may be reduced from 10% to 8% if the goods are not excluded and the policy is valid at declaration time.	Excluded goods/services list and implementation rules under Resolution 204/2025/QH15.	Do not apply 8% by default; verify HS, product nature and policy validity.
FTA tariff	Decrees 126/2022/NĐ-CP, 118/2022/NĐ-CP, 116/2022/NĐ-CP and other FTA schedules	Government	2022–2027 or treaty-specific period.	Basis for special preferential duty when C/O/origin document is valid.	FTA conditions, tariff schedule and origin rules.	Check route, form, HS, origin criterion and direct consignment.

VIEW / DOWNLOAD SOURCE DOCUMENTS

Enterprises should cross-check the official texts on the Government legal database, the legal document portal or the issuing authority’s website before application.

Check HS 3306.10.10 View Circular 34/2025/TT-BYT View Circular 06/2011/TT-BYT View Decree 126/2022/NĐ-CP View Decree 174/2025/ND-CP

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/PO if any.
C/O if preferential duty is claimed.

Cosmetic regulatory dossier

Cosmetic product notification receipt.
LOA/authorization and CFS if applicable.
INCI formula, PIF and safety information.
Original label and Vietnamese supplementary label.

Dossier group	Required documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Sales Contract/PO, B/L/AWB.	Customs declaration, value, quantity and origin review.	Supplier, importer, Docs/Forwarder.	Goods name too generic, e.g. “cosmetic” or “oral care”.	Describe toothpaste, form, brand, variant, net weight and new goods.
Technical/product	Catalogue, original label, product photos, INCI formula, COA/SDS if any.	HS classification, cosmetic notification and label review.	Manufacturer/exporter and importer QA/RA.	INCI on label differs from notification dossier.	Check ingredient names, order and claims.
Cosmetic regulatory	Cosmetic notification, LOA, CFS if applicable, PIF retained by responsible person.	Market circulation and post-market inspection.	Importer/responsible person/regulatory team.	Product name on notification differs from invoice/label.	Lock product name, brand, variant and size before import.
Origin	C/O Form D/E/AK/VK/EUR.1/RCEP/CPTPP or equivalent origin document.	Special preferential duty.	Supplier/exporter/importer/forwarder.	Wrong HS, description, stamp/signature or third-party invoice declaration.	Check C/O draft before shipment arrival.

CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended handling
HS basis	Is it 3306.10.10 or 3306.10.90?	Catalogue, label, claims, product form and formula.	Classification review and duty adjustment.	Lock HS pre-ETA and write a clear goods description.
Cosmetic scope	Are claims still cosmetic/oral hygiene, or therapeutic?	Label, leaflet, website and notification dossier.	Additional policy may apply.	Regulatory review before importing.
Notification	Does the product have a valid cosmetic notification receipt?	Notification, LOA, CFS and PIF.	Cannot legally circulate.	Complete notification before market release.
C/O validity	Is the C/O form, HS, description and origin criterion correct?	C/O draft, invoice, packing list and B/L.	Preferential duty may be rejected.	Review C/O draft before ETA.
Label consistency	Do product name, ingredients, lot, expiry and net weight match?	Original label, Vietnamese label, invoice and notification.	Supplementary explanation or label correction.	Approve label artwork before shipment.

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review

Finalize HS 3306.10.10/3306.10.90.
Check cosmetic notification, claims, C/O, VAT and label.

Step 2 – Lock documents

Lock Invoice, Packing List and B/L/AWB.
Lock INCI formula, label, catalogue and SKU list.

Step 3 – Complete cosmetic dossier

Check notification, LOA, CFS and PIF.
Prepare Vietnamese supplementary label if required.

Step 4 – Customs declaration

Green: conditional release by system.
Yellow: document check.
Red: document and physical inspection.

Step 5 – Clearance and post-clearance

Delivery to warehouse.
Label compliance before circulation.
Retain shipment dossier for post-clearance review.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA prevention	Documents to check
Wrong HS between 3306.10.10 and 3306.10.90	Duty/explanation issue and possible declaration amendment.	Classify by form, use and claim.	Catalogue, label, formula, invoice.
Claims beyond cosmetic scope	Possible non-cosmetic policy or dossier rejection.	Screen “treat, cure, antibacterial treatment, disease” claims.	Label, website, leaflet, marketing file.
Missing cosmetic notification	Market circulation risk and post-market compliance issue.	Complete notification before distribution.	Notification, LOA, CFS, PIF.
Invalid C/O	Loss of special preferential duty.	Review C/O draft before issuance.	C/O, invoice, B/L, packing list.
Mismatch between documents and label	Supplementary document request and clearance delay.	Align product name, brand, variant and size across all documents.	Invoice, packing list, label, notification, catalogue.

FAQ

Question	Answer
Does toothpaste need an import license?	Do not answer with a generic yes/no. For ordinary cosmetic toothpaste, cosmetic notification and labeling are the main issues; therapeutic claims require separate review.
Does toothpaste need cosmetic notification?	Yes, where it is a cosmetic product placed on the Vietnamese market.
Which HS code is used?	Usually review 3306.10.10 first; 3306.10.90 may apply depending on the actual dossier.
Is VAT 10% or 8%?	Base VAT is 10%; 8% only if the reduction policy applies at declaration date.
Can C/O reduce duty?	Yes, if the origin document is valid, correct in form, HS, description and origin criterion.
What if the label says “treats tooth decay”?	Review the boundary between cosmetics and therapeutic products before import.

IMPLEMENTATION SOLUTION FROM TGIMEX

This article provides a legal and operational map; however, each actual toothpaste shipment should be reviewed against INCI formula, label, notification, documents, origin and import purpose.

Pre-ETA compliance review

HS, cosmetic policy, C/O, VAT, label and INCI formula.
Cross-check Invoice, Packing List, B/L/AWB, C/O, label and notification.

E2E operation

Coordinate agents, carriers/airlines, ETA, pre-alert and transport documents.
Customs declaration, channel handling, inland delivery and post-clearance dossier retention.

Enterprises should not wait until cargo arrival to review dossier risks. Small discrepancies may lead to additional document requests, delayed clearance or unexpected storage charges.

ELECTRICAL – ELECTRONICS – IT EQUIPMENT

F&B

MACHINERY

HOUSEHOLD GOODS

COSMETICS – PERSONAL CARE

ELECTRICAL – ELECTRONICS – IT EQUIPMENT

F&B – FOOD & BEVERAGE

MACHINERY

HOUSEHOLD GOODS

COSMETICS – PERSONAL CARE

IMPORT PROCEDURES FOR TOOTHPASTE

QUICK FACTS

SCOPE OF APPLICATION

PRODUCT CLASSIFICATION & IDENTIFICATION

By use

By technical dossier

By packaging

By claims

HS CODE – DUTIES – C/O

SPECIAL PREFERENTIAL C/O – FTA MATRIX

PRE-ETA HS – TAX CHECKLIST

SPECIALIZED REGULATORY POLICY

LEGAL DOCUMENTS TO REVIEW

VIEW / DOWNLOAD SOURCE DOCUMENTS

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Cosmetic regulatory dossier

CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review

Step 2 – Lock documents

Step 3 – Complete cosmetic dossier

Step 4 – Customs declaration

Step 5 – Clearance and post-clearance

PRE-ETA RISK CHECKLIST

FAQ

RELATED ARTICLES

HS Code for cosmetics

C/O and preferential duty

Cosmetic notification

Imported goods labeling

IMPLEMENTATION SOLUTION FROM TGIMEX

Pre-ETA compliance review

E2E operation

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