Tiếng Việt
中文 (中国)
IMPORT PROCEDURE FOR COSMETIC PACKAGING PUMPS, PRESS PUMPS AND SPRAYERS
For cosmetic packaging pumps and sprayers, the main risk is not the commercial name but the actual construction: scent sprayer heads, spray heads with dip tubes, plastic closures and hand pumps may lead to different HS codes and duty rates. This guide provides an E2E (End-to-End) control map for HS code, duty, C/O, technical documents, labeling and pre-ETA risk control. For the product covered in this article, the importer should confirm the model, intended use, construction or composition, new/used condition, and technical documents before concluding the HS code, tax treatment, or specialist policy. The following sections organize the main controls from document receipt, catalogue and label review through dossier preparation, declaration, and coordination at the port of entry.
QUICK FACT
| Review item | Operational guidance |
|---|---|
| Product | Pumps, press pumps, spray heads and sprayers for cosmetic/personal-care packaging; empty components without filled product. |
| Related product group | Cosmetics and personal-care packaging/components: bottles, jars, tubes, caps, pumps, sprayers, droppers and paper boxes. |
| Indicative HS | Review 9616.10.20, 8424.89.20, 3923.50.00, 8413.20.90 depending on construction. |
| Duty planning | Indicative MFN from 0% to 25%; VAT planning 10%, review 8% only if eligible. |
| Key policy | Focus on HS classification, labeling, origin and material; review separately if used for food, pharma, medical, aerosol or filled liquid goods. |
SCOPE OF APPLICATION
This article applies to standalone pumps, press pumps, spray heads and sprayers used for cosmetic or personal-care bottles and jars. It does not automatically apply to filled cosmetics, aerosol valves, industrial sprayers, medical devices, food-contact packaging, electric pumps, machinery parts or used goods. Review must be based on catalogue, datasheet, model and actual import purpose.
CLASSIFICATION & TECHNICAL IDENTIFICATION
Construction
Press head, spring, piston, valve, dip tube, collar, overcap and material composition.
Function
Mist spraying, lotion pumping, jet spraying, dosage pressing, closure or decorative part.
Evidence
Catalogue, datasheet, exploded photos, drawing, BOM, material COA and model/SKU list.
| Technical criterion | Documents to review | Risk if described incorrectly | Suggested customs description |
|---|---|---|---|
| Main function: pump, spray, press or closure | Catalogue, photos, operation video, drawing | Wrong HS among 9616, 8424, 3923 and 8413 | “Plastic mist sprayer head for cosmetic bottle, empty, model…, material…” |
| Dip tube, spring, piston and valve | Datasheet, exploded view, BOM | Misclassification as a simple closure or a spray appliance | State whether it has dip tube, spring, piston and valve |
| Material composition | COA/TDS/MSDS if available | Wrong duty/policy if metal or composite materials dominate | State PP/PE/PET/ABS/metal/spring materials |
HS CODE – DUTY – C/O
HS code must be determined by principal function, construction, operating mechanism, material and use. The codes below are indicative and do not replace the customs authority’s official classification.
| Indicative HS code | Applicable condition | Risk if misapplied | Documents to review |
|---|---|---|---|
| 9616.10.20 | Spray heads/mounts of scent sprayers or similar toilet sprayers. | May be challenged if the item is an industrial trigger sprayer or a simple plastic closure. | Catalogue, photos, technical drawing, cosmetic/fragrance use. |
| 8424.89.20 | Spray heads with dip tubes. | May conflict with 9616 where the principal use is cosmetic/toilet spraying. | Dip tube construction, spraying mechanism. |
| 3923.50.00 | Plastic caps/closures without independent spray or pump mechanism. | Wrong if the item has spring, piston, valve or dip tube. | Photos, material, closure function. |
| 8413.20.90 | Other hand pumps for liquids. | Wrong if the item is a cosmetic atomizer/sprayer head. | Pump construction, flow, piston mechanism. |
DETAILED DUTY TABLE TO REVIEW BEFORE CUSTOMS DECLARATION
9616.10.20
Mounts and heads for scent sprayers or similar toilet sprayers
9616.10.10
Complete scent sprayers or similar toilet sprayers
8424.89.20
Spray heads with dip tubes
8424.90.94
Parts of spraying/dispersing appliances
3923.50.00
Plastic stoppers, lids, caps and closures without independent spray/pump mechanism
8413.20.90
Other hand pumps for liquids
C/O AND FTA PREFERENTIAL DUTY REVIEW
| Origin route | C/O or origin document | Possible preference | Conditions to check | Risk if incorrect |
|---|---|---|---|---|
| ASEAN | Form D / ATIGA origin document | Potentially 0% depending on HS and schedule | WO/RVC/CTH/CTSH, direct transport, description | Preference denial and duty collection |
| China | Form E or RCEP | ACFTA/RCEP if origin rules are met | HS, description, third-party invoice | C/O may be rejected |
| Korea/Japan/EU/UK/CPTPP | Relevant FTA certificates/statements | Depending on route and special tariff schedule | Check the tariff schedule at declaration date | MFN duty may apply if unprepared |
SPECIALIZED POLICY MATRIX
| Goods scenario | Possible policy | Documents to review | Authority/portal if identifiable | Timing | Risk note |
|---|---|---|---|---|---|
| New empty packaging components | Customs clearance; HS, origin, value and labeling control. | Invoice, packing list, catalogue, photos, material. | Customs; market surveillance if circulated. | Before ETA. | Do not treat empty packaging as finished cosmetics. |
| Imported together with filled cosmetics | Cosmetic product proclamation may apply to the filled finished product. | Proclamation receipt number, label, CFS/LOA. | Drug Administration of Vietnam / public service portal. | Before commercial declaration. | Do not apply empty-packaging policy to filled cosmetics. |
| Aerosol, flammable liquid or pressurized goods | DG, chemical and transport safety review. | SDS/MSDS, UN number, class, packaging. | Carrier/airline/shipping line/customs. | Before booking. | Separate from ordinary empty sprayers. |
| Branded/logo-printed parts | IP and authorization review. | Authorization letter, PO, brand artwork. | Customs / rights holder if inspected. | Before arrival. | Risk of detention for suspected IP infringement. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document name/number | Issuing body | Effective timing | Role in procedure | Articles/annexes to note | Review note |
|---|---|---|---|---|---|---|
| Customs law | Customs Law 2014; Decree 08/2015/ND-CP as amended | National Assembly / Government | Review current validity | Customs dossier and inspection basis. | Dossier, inspection and clearance provisions. | Review by customs regime. |
| MFN tariff | Decree 26/2023/ND-CP | Government | Effective 15/07/2023 | MFN duty reference by HS. | Chapters 39, 84, 96. | Recheck at declaration date. |
| Ordinary duty | Decision 15/2023/QD-TTg | Prime Minister | Effective 15/07/2023 | Ordinary duty when MFN/FTA does not apply. | 150% rule where no separate rate is provided. | Use only where applicable. |
| VAT | Law 48/2024/QH15; Resolution 204/2025/QH15; Decree 174/2025/ND-CP | National Assembly / Government | 01/07/2025–31/12/2026 for reduction policy | VAT planning. | Eligibility and exclusion list. | Do not apply 8% without checking exclusions. |
| Goods labeling | Decree 43/2017/ND-CP; Decree 111/2021/ND-CP | Government | Review current validity | Labeling basis for circulation. | Mandatory label contents and origin. | Different control may apply for production inputs. |
VIEW / DOWNLOAD SOURCE DOCUMENTS
Businesses should also verify the documents on the official legal document portal or the issuing authority’s website before applying them.
CUSTOMS CLEARANCE DOCUMENT SET
Commercial documents
- Commercial Invoice
- Packing List
- Bill of Lading/Air Waybill
- Sales Contract/Purchase Order
- C/O if claiming preferential duty
Technical/specialized files if any
- Catalogue, datasheet, drawing and photos
- BOM/material list and COA/MSDS if required
- Original label and model/SKU list
- Authorization if logo/brand is shown
OPERATIONAL DOCUMENT CHECKLIST
| Document group | Required document | Used for | Usual preparer | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO | Declaration, value and quantity check | Buyer/Supplier | Description too generic. | Specify pump/sprayer type, material, model and use. |
| Transport | B/L or AWB, arrival notice, pre-alert | Cargo tracking and customs preparation | Forwarder/agent/shipper | Mismatch in packages/weight. | Compare with packing list and booking. |
| Technical | Catalogue, drawing, photos, BOM | HS review and customs explanation | Supplier/R&D/QA | No dip tube/spring/piston details. | Request exploded view or detailed photos. |
| Origin | C/O if claiming preferential duty | FTA duty application | Supplier/export team | Wrong HS or goods description. | Check form, origin criterion and direct transport. |
100% matching rule: goods name, quantity, model/SKU, material, origin, photos and technical description must match across commercial documents, catalogue, labels, C/O and customs declaration.
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended action |
|---|---|---|---|---|
| HS basis | Is it a toilet sprayer head, spray head with dip tube, closure or hand pump? | Catalogue, photos, drawings | HS consultation, red/yellow channel, duty adjustment. | Lock technical description before invoice issuance. |
| Material | Which material dominates: plastic, metal, spring, rubber gasket? | COA/TDS/material list | Wrong HS and value risk. | Request material breakdown. |
| Filled or empty | Is the product empty or filled with cosmetic/chemical liquid? | Invoice, photos, packing details | Cosmetic/DG/chemical policy may apply. | Separate empty components from filled products. |
PRACTICAL E2E PROCESS
Pre-ETA review
Confirm HS, duty, C/O, material, use and labeling/logo risks.
Lock documents
Match Invoice, Packing List, B/L/AWB, catalogue, model/SKU and photos.
Review special policy
Check filled liquids, aerosol/DG, food/pharma/medical use or branded components.
Customs declaration
Prepare HS explanation, value, C/O and technical dossier for green/yellow/red channel.
Clearance and archive
Deliver goods and retain lot dossier, label, C/O and technical files.
PRE-ETA RISK CHECKLIST
Wrong HS code
Control with catalogue, technical drawings and clear function description.
Invalid C/O
Check form, origin criterion, goods description, HS and direct transport before ETA.
Over-generic product name
Avoid “plastic accessories”; state pump/sprayer type and cosmetic-packaging use.
Prepare PO, authorization or brand-use evidence.
Filled liquid or DG confusion
Separate empty components from filled cosmetic/chemical goods.
FAQ – COMMON BUSINESS QUESTIONS
| Question | Answer |
|---|---|
| Do empty cosmetic pumps/sprayers require cosmetic proclamation? | Usually no, if they are empty packaging components. If imported together with filled cosmetics, the finished cosmetics must be reviewed separately. |
| Is 9616.10.20 always correct? | No. HS depends on construction, function and use; review 8424, 3923 or 8413 where relevant. |
| Can C/O reduce duty? | Yes, if the C/O is valid, the HS/description matches and origin criteria are met. |
| Can lotion pumps and fragrance sprayers share the same HS? | Not automatically. Pumping mechanism, atomizing function and dip tube may change classification. |
| Is Vietnamese labeling required? | Review labeling if the goods are circulated commercially; production inputs may be managed differently. |
| Are samples handled like commercial goods? | Not always. Clarify purpose, value, quantity and supporting documents. |
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.
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