Tiếng Việt
中文 (中国)
IMPORT PROCEDURE FOR COSMETIC COLORANTS
Cosmetic colorants are often described too generally on invoices, such as “colorant”, “pigment”, “CI powder” or only a commercial shade name. In practice, HS classification may vary depending on organic/inorganic nature, powder/paste/liquid form, CAS, CI No., carrier and actual end use.
If HS Code is misclassified, chemical declaration is missed, SDS/MSDS, COA, CAS/CI No. or ASEAN cosmetic colourant restrictions are not properly reviewed, the shipment may be queried, routed for document/physical inspection, lose C/O preference or incur DEM/DET charges.
This article provides an E2E (End-to-End) map for pre-ETA review: HS, duty, C/O, chemical compliance, technical documents, commercial documents and clearance decision points.
QUICK FACTS
| Item | Information to review |
|---|---|
| Product | Colorant imported as a cosmetic manufacturing raw material; not automatically applicable to food colorants, textile dyes, paints, inks or finished retail cosmetics |
| Reference HS | 3204.17, 3204.19, 3205.00, 3206.11/3206.19/3206.49, and possibly 2821.10 or 3203.00 depending on composition |
| Indicative duty | Many 3204–3206 pigment/colorant lines show indicative MFN 0%, ordinary duty reference 5%; base VAT 10%; verify the tariff at declaration date |
| Specialized policy | Chemical management, SDS/MSDS, hazard classification and chemical declaration may apply if the CAS is controlled; do not assume “no policy” |
| Cosmetic compliance | As a raw material, colorant should be checked against the ASEAN Cosmetic Directive annexes, especially Annex IV on permitted colourants, before use in finished products |
| Caution | Review catalogue, datasheet, SDS, COA, CAS/CI No., lot details and actual import purpose |
This article is for operational reference. For colorants, HS classification and regulatory treatment depend on INCI/CAS, chemical identity, purity, powder/paste/liquid form, cosmetic-use purpose and actual SDS/COA documents.
SCOPE OF APPLICATION
This article applies to colorants used in cosmetics imported as raw materials: organic pigments, inorganic pigments, colour lakes, titanium dioxide pigments, iron oxide pigments, treated mica/pearlescent pigments or colour preparations used in cosmetic manufacturing.
It does not automatically apply to food colorants, textile dyes, paints, inks, plastic masterbatch, non-cosmetic industrial chemicals or finished retail cosmetics. Samples, R&D materials, trial production batches, EPE/FDI/factory imports or CAS-controlled chemicals may require different handling.
Review catalogue, datasheet, SDS/MSDS, COA, CAS/CI No., composition, carrier ratio and actual import purpose.
CLASSIFICATION & PRODUCT IDENTIFICATION
A colorant should not be identified only by a commercial shade name. The dossier should establish INCI name, CAS, CI No., organic/inorganic/natural nature, physical form, purity, carrier if any, particle size, coating/treatment, cosmetic grade standard and intended use in finished formulas.
Generic naming may lead to wrong HS, missed chemical control, improper cosmetic restrictions, incorrect goods labelling and weak explanation under Yellow/Red channel review.
| Checkpoint | Documents to cross-check | Risk if wrongly described | Suggested declaration wording |
|---|---|---|---|
| INCI/CAS and trade name | SDS, COA, TDS, catalogue, specification | Generic “colorant” may lead to wrong chemical nature and HS | Cosmetic colorant, INCI/CAS…, form…, color index…, raw material for cosmetic manufacturing |
| Organic/inorganic/natural nature | COA, MSDS, composition declaration | Confusion between synthetic organic pigment, inorganic pigment, TiO2 or iron oxide | State synthetic organic pigment / inorganic pigment / natural coloring matter |
| Physical form and concentration | Packing list, label, TDS, photo | Powder/paste/liquid or carrier-based preparation may change HS | Declare powder/paste/liquid form and active/carrier ratio where applicable |
| Intended use | PO, contract, raw material standard, formula plan | Confusion with food colorant, textile dye, paint/ink material | State “for cosmetic manufacturing only” if supported |
| ASEAN cosmetic restrictions | Annex II/III/IV/VI/VII, manufacturer statement | Ingredient may be banned or limited when used in finished cosmetics | State CI No. and ASEAN cosmetic compliance statement where available |
HS CODE – DUTY – C/O
HS classification is not determined by the word “colorant” but by chemical nature and preparation form. The same red/black/yellow shade may fall under different codes if it is a synthetic organic pigment, colour lake, titanium dioxide, iron oxide, carbon black or natural colourant. The duty rates below are planning references and must be verified against the current tariff and actual documents at declaration date.
| Reference HS code | Application condition | Indicative duty to verify at declaration date | Documents to cross-check |
|---|---|---|---|
| 3204.17.10 / 3204.17.90 | Synthetic organic pigments and preparations; common for organic pigment powder/other forms | Indicative MFN: 0%; ordinary duty reference: 5%; base VAT: 10% | SDS, COA, CAS/CI No., TDS, composition and packaging photos |
| 3204.19.00 | Other synthetic organic colouring matter or mixtures under heading 3204 | Indicative MFN: 0%; ordinary duty reference: 5%; base VAT: 10% | COA, mixture formula, MSDS and cosmetic-use statement |
| 3205.00.00 | Colour lakes and preparations based on colour lakes | Indicative MFN: 0%; ordinary duty reference: 5%; base VAT: 10% | CI No., substrate/base, COA, TDS, SDS |
| 3206.11.10 / 3206.19.10 / 3206.49.90 | Inorganic pigments, TiO2-based pigments or other inorganic colouring preparations | Indicative MFN: 0%; ordinary duty reference: 5%; base VAT: 10% | COA, TiO2/oxide content, particle size, coating/treatment, SDS |
| 2821.10.00 | Iron oxides/hydroxides as separate inorganic chemicals, not mixed pigment preparations | Indicative MFN: 0%; ordinary duty to be verified; base VAT: 10% | CAS, purity, COA, SDS, intended use and surface treatment |
| 3203.00.90 | Colouring matter of vegetable/animal origin, not for food/beverage use | MFN to be checked in the current tariff schedule; base VAT: 10% | Extract source, COA, solvent/carrier and cosmetic use |
Preferential C/O/FTA matrix to check before ETA
| Origin route | C/O or proof of origin | Indicative preferential duty | Conditions/risks to check |
|---|---|---|---|
| ASEAN / ATIGA | Form D | May be 0% if HS and origin rule are satisfied | Check CTH/CTSH/RVC rule, goods description and HS consistency |
| China / ACFTA or RCEP | Form E or RCEP proof | Many 3204/3205/3206 lines are preferential 0%; verify annual tariff schedule | Watch third-party invoice, direct consignment and pigment/colorant description |
| Korea / AKFTA, VKFTA, RCEP | Form AK/VK or RCEP proof | Deep preference often available, many lines at 0% | Cross-check origin criterion, manufacturer and country of origin on COA/label |
| Japan / VJEPA, AJCEP, CPTPP, RCEP | Form VJ/AJ or CPTPP/RCEP proof | Preference may apply if the HS line is committed | Check PSR, tariff shift and invoice chain |
| EU/UK | EUR.1, statement on origin or UKVFTA proof | Preference may apply subject to schedule and rules | Check statement on origin, exporter status and goods description |
| India/Hong Kong | Form AI or AHK | Verify separately by HS and agreement schedule | Do not rely on C/O with only commercial colour name and no CAS/CI No. |
- Correct C/O form and origin criterion WO/RVC/CTH/CTSH
- Goods description, HS, quantity, weight, origin and manufacturer match the documents
- Issue date, stamp/signature, third-party invoice and direct consignment are valid
- Do not rely on C/O based only on commercial shade name without CAS/CI No. or composition documents
APPLICABLE SPECIALIZED POLICIES
| Goods scenario | Potential policy | Documents to check | Agency/portal if identifiable | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Colorant used as cosmetic raw material | Not a finished cosmetic product notification by itself if used internally, but permitted use must be checked for finished products | COA, SDS, TDS, cosmetic grade statement, CI No. | DAV/MOH for finished cosmetic compliance issues | Before PO and before ETA | Do not use materials outside permitted lists/limits in finished cosmetics |
| CAS listed for chemical declaration or dangerous chemicals | Chemical declaration, classification/labelling and SDS obligations under current chemical rules | CAS, SDS, composition, concentration, GHS classification | National Single Window/MOIT if applicable | Before clearance | Missed declaration may suspend the dossier |
| Fine powder pigment with dispersion risk | Transport safety, SDS, packaging and hazard labelling | SDS, packing, hazard label, UN if any | Carrier/airline/port/CFS warehouse | Before booking | Shipment may be rejected if SDS or DG classification is missing/wrong |
| Dual use for food/pharma/cosmetics | Food/pharma control may arise; do not apply cosmetic raw material logic automatically | COA, intended use, label, buyer statement | MOH/MOIT depending on scenario | Before contract signing | Same colour index may have different industry policies |
| Import for EPE/FDI/factory | Customs procedure by declaration type, BOM, production purpose | Contract, PO, material code, BOM, investment license if needed | Managing Customs authority | Before declaration | Wrong declaration type or purpose may create post-clearance risk |
LEGAL INSTRUMENTS TO REVIEW
| Document group | Name/number | Issuing authority | Effective date/application | Role in procedure | Articles/appendices to note | Review note |
|---|---|---|---|---|---|---|
| Law | Law on Chemicals No. 69/2025/QH15 | National Assembly | Effective 01/01/2026; replacing Law on Chemicals No. 06/2007/QH12 except transitional cases | Framework for chemicals, chemical activities, chemical information, chemical safety and dangerous chemicals in products/goods | Review provisions on chemical information, classification, labelling, SDS and importer obligations | Applies if the colorant is a chemical/raw chemical under management; review by actual CAS and SDS |
| Decree | Decree 26/2026/ND-CP | Government | Effective 17/01/2026 | Detailed chemical management and dangerous chemicals in goods/products | Check current lists/appendices by actual CAS | Key 2026 reference for chemical review |
| Circular/consolidated text | Circular 06/2011/TT-BYT and consolidated/updated text amended by Circular 34/2025/TT-BYT | Ministry of Health | Circular 34/2025 effective 18/08/2025 | Cosmetic management, ingredients, PIF and finished product notification | ASEAN Annexes II/III/IV/VI/VII, especially Annex IV – permitted colourants | Raw material must be reviewed before use in finished cosmetics |
| DAV updates | Official letters updating ASEAN Cosmetic Agreement annexes | Drug Administration of Vietnam | Applies by update round | Review banned, restricted, colourant, preservative and UV filter lists | Annex II, III, IV, VI, VII | Check the latest version before formula use |
| Decree | Decree 111/2021/ND-CP amending Decree 43/2017/ND-CP | Government | Effective 15/02/2022 | Goods labelling for imports | Original label, Vietnamese supplementary label, responsible entity | Applicable to goods circulating in Vietnam |
| Customs | Decree 167/2025/ND-CP; Circular 121/2025/TT-BTC | Government/Ministry of Finance | Decree 167 effective 15/08/2025; Circular 121 effective 01/02/2026 | Customs procedure, dossier, inspection and supervision | Check at declaration date | Applies to declaration and channel handling |
| Tariff | Consolidated Document 07/VBHN-BTC and current tariff schedule | Ministry of Finance | Issued 22/04/2025, latest updates required | Determine MFN duty and tax policy | Chapters 28, 32 and related HS lines | Do not finalize duty without verified 8/10-digit HS |
VIEW / DOWNLOAD ORIGINAL LEGAL TEXTS
Enterprises may search legal instruments by number on official legal databases, the Government portal or the issuing authority website. Enterprises should cross-check official portals before applying any provision.
CUSTOMS CLEARANCE DOCUMENT SET
Commercial documents
- Commercial Invoice, Packing List, B/L/AWB.
- Sales Contract/Purchase Order if any.
- C/O if preferential duty is claimed.
- Goods photos, original label, packing mark and lot/batch list.
Specialized documents if applicable
- SDS/MSDS, COA, TDS, catalogue/specification.
- CAS/CI No., cosmetic grade statement and use-purpose statement.
- Chemical declaration dossier if applicable.
- ASEAN Annex review documents for finished product use.
| Document group | Required documents | Used for which step | Usual preparer | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, B/L or AWB, contract/PO | Declaration, valuation and quantity check | Importer/Docs/Supplier | Goods named only “colorant” or “pigment” | Cross-check name, CAS/CI No., form and packing before ETA |
| Technical | SDS/MSDS, COA, TDS, catalogue, specification | HS finalization, chemical and transport safety review | Supplier/QA/Compliance | Missing CAS, composition or carrier ratio | Require clear English/bilingual composition and hazard classification |
| Cosmetic | Cosmetic grade statement, ASEAN Annex compliance, CI No. | Review permitted use in finished cosmetic formula | QA/R&D/Regulatory | Ingredient not allowed under Annex IV or used in the wrong application area | Check Annex II/III/IV and intended formula |
| Chemical | Chemical declaration if listed/applicable | Before clearance where controlled | Importer/Compliance | Missed declaration may block clearance | Check CAS against lists and hazard classification |
| C/O | Valid C/O or proof of origin | Claim preferential duty | Supplier/Forwarder/Docs | Wrong form, HS or goods description | Check form, origin criterion and direct consignment before ETA |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Supporting document | Consequence if unclear | Recommended action |
|---|---|---|---|---|
| Is HS sufficiently supported? | Do CAS/CI No., composition, form and organic/inorganic nature exist? | SDS, COA, TDS, catalogue | Possible analysis/classification request and delay | Finalize technical description before declaration |
| Is chemical declaration required? | Is the CAS listed in chemical control lists/appendices? | SDS, CAS list, composition | Declaration may be suspended for missing specialized dossier | Check CAS before ETA and prepare portal account if needed |
| Cosmetic use or other industry? | Is import purpose consistent across PO, label and COA? | PO, contract, statement, factory use plan | Wrong specialized policy or use-purpose query | State “raw material for cosmetic manufacturing” if supported |
| Is C/O eligible? | Do form, origin criterion, goods description and HS match? | C/O, Invoice, Packing List, B/L | Preference denied and duty adjusted | Check draft C/O before shipment |
| Are label and packing sufficient? | Do they show goods name, lot, manufacturer, origin and hazard label if needed? | Label photo, packing mark, SDS | Possible explanation or relabelling request | Request supplier label photos before ETA |
| Is the cargo DG? | Does SDS show UN number, class, packing group or transport condition? | SDS section 14, MSDS, booking note | Carrier/airline may reject cargo | Check DG before booking and cut-off |
PRACTICAL E2E PROCEDURE
Finalize HS, chemical policy, duty, C/O, labelling, SDS and transport conditions before arrival.
Cross-check Invoice, Packing List, B/L/AWB, SDS, COA, TDS, CAS/CI No., label photos and packing marks.
If the CAS is controlled, prepare the portal dossier before clearance; do not wait until arrival.
Green channel is system-based clearance under conditions; Yellow checks documents; Red checks documents and physical goods.
Pay duties, release cargo, archive shipment dossier, SDS/COA/C/O and post-clearance explanation data.
Before use in finished cosmetics, check ASEAN annexes, limits, application area and finished-product PIF.
PRE-ETA RISK BLOCKING CHECKLIST
| Risk | Consequence | How to block before ETA | Documents to check |
|---|---|---|---|
| Invoice says only “colorant/pigment” | Insufficient HS support and high query risk | Add INCI/CAS/CI No., form and use to documents | Invoice, COA, SDS, TDS |
| Missing SDS/MSDS or no CAS in SDS | Chemical/DG review impossible, booking or clearance delay | Request complete SDS with sections 2/3/14/15 | SDS/MSDS |
| Confusion among 3204 – 3206 – 2821 | Wrong duty and policy; possible classification analysis | Confirm organic/inorganic nature, preparation or single compound | COA, CAS, composition, TDS |
| Missed ASEAN Annex IV | Raw material may be unusable or limited in finished cosmetics | Check CI No. against ASEAN Cosmetic Directive before purchase | CI No., statement, Annex |
| C/O with wrong description or HS | Preference denied and duty adjusted | Check draft C/O before ETA | C/O, Invoice, B/L |
| Wrong import purpose | May be treated as food, pharma, paint or ink material | Align PO, label, COA and declaration with cosmetic purpose | PO, contract, label, buyer statement |
FAQ – COMMON BUSINESS QUESTIONS
If it is only an internal manufacturing raw material, it is not handled as a notified finished cosmetic product. However, use in finished products must comply with cosmetic ingredient restrictions.
It may be required if the CAS/composition is listed or controlled under current chemical rules. Check SDS, CAS and concentration before ETA.
There is no single HS. Common review areas are 3204, 3205, 3206; sometimes 2821, 2803 or 3203 depending on nature.
Yes, if HS, goods description, origin criterion and direct consignment are valid.
If goods circulate in Vietnam or are domestically transferred, labelling rules should be reviewed. For raw materials, lot label, name, code, manufacturer, origin and warning remain important.
Not automatically. Customs documents, HS, policy, SDS and use purpose must still be clear.
Not always as a declaration field, but for cosmetic colorants it is critical for Annex IV review and use-purpose explanation.
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
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