Sample sale items, testers, promotional products and gift-with-purchase cosmetics are often treated as “minor” shipments. In practice, once they are displayed, sold, distributed or given to consumers in Vietnam, their compliance risk can be equivalent to ordinary commercial cosmetics. The importer must control product description on the Invoice, HS Code, cosmetic notification, Vietnamese labelling, C/O and the consistency of SKU, batch, expiry date and formula. This article provides an E2E map for pre-ETA review, customs clearance and post-clearance document retention.

Legal note: “Sample sale” is a commercial/packaging status, not a standalone HS heading. If the goods are cosmetic products placed on the Vietnamese market, the importer should review cosmetic notification, labelling, ingredients, claims, import documents and tax treatment according to the actual product. Review must be based on catalogue, label, formula, volume/weight, set configuration and actual import purpose.

QUICK FACTS

Item	What to check	Risk if missed
Product nature	Tester/sample sale/promotional/gift-with-purchase cosmetics placed on the market.	Incorrectly declaring marketable goods as non-commercial samples.
HS Code	No separate HS for “sample sale”; classify by actual product under 3303, 3304, 3305, 3307 or other relevant headings.	Wrong duty, wrong policy and HS queries.
Cosmetic notification	Imported cosmetics circulated in Vietnam should be reviewed for product notification before circulation.	Market access and post-clearance risks.
Labelling	Original label, Vietnamese supplementary label, batch, expiry date, ingredients, responsible party and origin.	Supplement/rectification requests and market surveillance risks.
VAT and C/O	Baseline VAT review is usually 10%; preferential C/O depends on HS and origin.	Loss of tariff preference and cost deviation.

SCOPE OF APPLICATION

This article applies to cosmetic sample sale items, including testers, mini sizes, trial kits, promotional products and gift-with-purchase cosmetics that are displayed, sold, distributed or provided to consumers in Vietnam.

Applicable to finished cosmetic products with commercial/direct packaging.
Not automatically applicable to lab samples, testing samples, R&D samples or internal-use samples not placed on the market.
Multiple SKUs, formulas, shades, fragrances or volumes must be reviewed separately.
Used, near-expiry, repacked, exhibition or disposal goods may trigger different requirements.

CLASSIFICATION & PRODUCT IDENTIFICATION

Product type

Identify whether the sample sale item is perfume, skincare, make-up, hair care, deodorant, shaving product or a mixed kit.

Market status

Confirm whether the goods are sold, given with purchase, used as testers at counters or used internally only.

Technical file

Check formula/ingredient list, claims, label, volume, batch, expiry, CFS, LOA and notification number.

Criterion	Documents to compare	Risk of wrong description	Suggested goods description
Actual cosmetic type	Catalogue, label artwork, INCI list, notification	Classifying by “sample” instead of actual product	“Cosmetic sample sale – product name, form, volume, brand, SKU”
Market purpose	PO, contract, marketing plan	Confusing internal samples with marketable goods	State sale/promotion/gift-with-purchase purpose where applicable
Volume/weight	Invoice, packing list, labels, carton marks	Labelling and set configuration mismatch	State retail unit and packing specification
Batch and expiry	COA, labels, cartons, batch list	Poor traceability or near-expiry risk	Attach batch/expiry list
Claims	Labels, website, leaflet, ads	Overclaiming beyond cosmetic scope	Avoid therapeutic claims unless legally supported

HS CODE – DUTY – C/O

Classification principle: Sample sale status does not change HS classification. HS must follow the actual cosmetic’s function, composition, dosage/packaging form and intended use. Rates below are for pre-ETA reference and must be verified against the tariff in force on declaration date.

Reference HS	Typical sample sale product	Indicative MFN	Indicative ordinary duty	Baseline VAT	Documents to compare
3303.00.00	Perfume, EDP, body spray/fragrance mist with perfuming nature	18%	27%	10%	Label, alcohol/fragrance composition, SDS/MSDS if DG
3304.10.00	Lip make-up, tint, gloss sample/mini	20%	30%	10%	Claims, shade/fragrance, SKU, notification
3304.20.00	Mascara, eyeliner, eye make-up	22%	33%	10%	Eye-area use, warnings, claims
3304.91.00	Powder, pressed powder, blush powder	22%	33%	10%	Powder/pressed form, shade, retail packing
3304.99.20	Anti-acne preparations where claims/nature match	10%	15%	10%	Anti-acne claim, actives, notification
3304.99.30 / 3304.99.90	Cream, lotion, essence, serum, cleanser/skincare or other skin-care preparations	18% reference	27% reference	10%	Usage form, body area, formula, label, cosmetic notification
3305.10.90 / 3305.90.00	Shampoo, conditioner, hair serum, styling cosmetics	15%–20%	22.5%–30%	10%	Hair product type, claims, INCI, label
3307.10.00 / 3307.20.00 / 3307.30.00	Shaving products, deodorants, bath preparations	18%–20%	27%–30%	10%	Deodorant/antiperspirant/shaving/bath claims

C/O and FTA preference review

Origin route	Proof of origin	Preference to verify	Key conditions	Risk
ASEAN	Form D / ATIGA proof	Many cosmetic lines may reach 0% if origin rules are met	WO/RVC/CTH/CTSH, direct consignment, matching description	Preference denial and duty recovery
China	Form E or RCEP proof	Verify by exact HS and tariff schedule	HS, origin, third-party invoice, transport route	Wrong form or vague “samples” description
Korea	AKFTA/VKFTA/RCEP	Deep reduction depending on HS	Actual manufacturing country and origin criterion	Korean brand is not equal to Korean origin
Japan	VJEPA/AJCEP/CPTPP/RCEP	Select the best eligible agreement	Form, origin criterion and direct transport	Wrong agreement selection
EU/UK	EVFTA/UKVFTA origin statement	Phased reduction depending on HS/year	REX/statement, exporter eligibility and shipping docs	Invalid self-certification
Australia/NZ, India, Hong Kong	AANZFTA/CPTPP, AIFTA, AHKFTA	Verify by each HS	Origin rule and proof validity	HS mismatch between C/O and declaration

Pre-ETA C/O checklist

Correct origin proof and agreement.
HS, description, quantity, weight and invoice number match.
Origin criterion such as WO, RVC, CTH or CTSH is properly declared.
Third-party invoice, direct consignment, issue date, seal/signature or self-certification are checked.
Do not rely on a generic “samples” description if the goods are marketable cosmetics.

SPECIALIZED POLICY MATRIX

Goods scenario	Possible policy	Documents	Authority/portal	Timing	Risk note
Marketable sample sale cosmetics	Cosmetic notification before circulation	Notification, CFS, LOA, ingredients, label	Drug Administration of Vietnam/MOH e-portal	Before sale/gift/distribution	Do not assume exemption because it is a sample
Retail counter testers	Notification, labelling and user safety control	Label, batch, expiry, tester control process	Responsible person/company	Before retail display	Testers still contact consumers
Promotional or gift-with-purchase goods	Cosmetic notification, Vietnamese label, commercial documents and trade promotion file where applicable	Invoice, packing list, campaign plan, gift list, promotion terms/records	Customs/market surveillance/trade promotion authority where relevant	Before ETA and promotion launch	Free of charge still needs customs value review and a clear campaign basis
Alcohol/aerosol/flammable goods	DG transport requirements, SDS/MSDS	SDS/MSDS, UN/packing if any	Carrier/airline/warehouse/port	Before booking	Transport refusal if DG is undeclared
Lab/R&D samples not placed on market	Different review route and purpose evidence	Purpose letter, test plan, small quantity, no-sale undertaking	Customs/specialized agency if required	Before declaration	Do not mix with sample sale goods
EPE/FDI/factory import	Import purpose, distribution rights and internal records	Contract, PO, invoice, business scope	Managing customs branch	Before ETA	Wrong purpose may create tax/post-clearance exposure

LEGAL DOCUMENTS TO REVIEW

Group	Document	Issuer	Effective timing	Role	Key points	Review note
Cosmetics	Circular 06/2011/TT-BYT	MOH	In force as amended	Cosmetic management, notification, PIF, labelling, import	Rules on cosmetic notification, notification dossier, responsible person, product information and PIF	Check the consolidated/amended text before preparing dossiers
Cosmetics amendment	Circular 34/2025/TT-BYT	MOH	18 Aug 2025	Amends Circular 06	Notification dossier/form updates	Apply for new/amended filings after effective date
Labelling	Decree 43/2017/NĐ-CP, amended by 111/2021/NĐ-CP	Government	111/2021 effective 15 Feb 2022	Goods labelling and Vietnamese supplementary labels	Mandatory label contents, origin, responsible entity	Review together with cosmetic labelling rules
Trade promotion	Decree 81/2018/NĐ-CP	Government	Effective 15 Jul 2018; check amendments	Regulates trade promotion, gifts, promotion campaigns and related procedures	Promotion forms, notification/registration of campaigns if applicable	Relevant where sample sale or gift-with-purchase is part of a Vietnam promotion campaign
Promotion value caps	Circular 39/2025/TT-BCT	MOIT	Effective 01 Jul 2025	Maximum value of goods/services used for promotion and maximum discount rates	Promotion value limits and exceptions where applicable	Does not replace cosmetic notification, labelling or customs valuation obligations
Customs	Decree 08/2015/NĐ-CP, amended by 167/2025/NĐ-CP	Government	167/2025 effective 15 Aug 2025	Customs procedures and supervision	Customs dossier, valuation and supervision	Verify at declaration date
Customs circular	Circular 121/2025/TT-BTC	MOF	01 Feb 2026	Amends customs and import/export tax procedures	Dossier and tax administration	Review timing of application
VAT	Decree 174/2025/NĐ-CP	Government	01 Jul 2025	VAT reduction policy under Resolution 204/2025/QH15	Eligible/non-eligible goods and services	Check HS and appendices for each period
Tariff	Current MFN and special preferential tariff schedules	Government/MOF	By year/agreement	MFN, ordinary and FTA duty rates	Chapter 33 and related headings	Do not rely on outdated tariff data

VIEW / DOWNLOAD ORIGINAL LEGAL TEXTS

Companies should cross-check the legal documents on Vietnam’s official legal database or the issuing authority’s website before application.

Circular 06/2011/TT-BYT Circular 34/2025/TT-BYT Decree 111/2021/NĐ-CP Decree 81/2018/NĐ-CP Circular 39/2025/TT-BCT Legal database

CUSTOMS CLEARANCE DOCUMENT SET

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order where applicable.
C/O if tariff preference is claimed.
Catalogue, product photos, original labels, SKU list and batch/expiry list.

Cosmetic compliance file

Cosmetic product notification/receipt number.
CFS.
LOA/POA.
PIF.
Ingredient/INCI list, claims, label artwork, Vietnamese label.
SDS/MSDS if alcohol/aerosol/flammable content exists or carrier requires it.

File group	Documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB	Customs declaration, value, transport	Shipper/Importer/Forwarder	Generic “sample” description, missing SKU/volume	Match each line to label and packing
Notification	Notification, CFS, LOA, formula	Market access	Importer/RA/Legal	No notification before circulation	Check product name and responsible person
Labelling	Original and Vietnamese labels, artwork	Clearance/post-clearance/market circulation	Brand/Importer	Name, batch, expiry, origin mismatch	Take photos of actual labels
Duty/C/O	C/O, transport docs, invoice	Preferential duty claim	Shipper/Exporter/Importer	C/O describes goods only as “samples”	Check form, HS, description, quantity and date
DG/transport	SDS/MSDS, booking note, packing declaration	International booking	Shipper/Forwarder	Alcohol/aerosol not declared	Review flash point/UN if applicable

CLEARANCE DECISION POINTS

Decision point	Question	Evidence	Consequence if unclear	Recommended action
Market placement	Sold/gifted/promotional or internal use only?	PO, campaign plan, purpose letter	Wrong cosmetic policy	Confirm purpose from booking stage
HS basis	Perfume, skincare, makeup, hair care or deodorant?	Catalogue, label, ingredient list	Wrong duty/C/O and HS queries	Classify each SKU before ETA
Cosmetic notification	Does receipt match name, brand and responsible person?	Notification, CFS, LOA	Goods not ready for circulation	Do not circulate before completion
Labelling	Do labels match batch, expiry and origin?	Label artwork, actual photos	Supplement/rectification requests	Prepare Vietnamese label before distribution
C/O validity	Do form, HS, description and origin match?	C/O, invoice, B/L, packing list	Loss of preference	Review C/O draft before issue
Alcohol/aerosol	Is DG declaration needed?	SDS/MSDS, flash point	Transport refusal or delay	Declare DG before booking

PRACTICAL E2E PROCESS

1. Pre-ETA review

Confirm import purpose, SKU grouping, HS, duty, C/O, notification, labelling and DG status.

2. Lock documents

Cross-check Invoice, Packing List, B/L/AWB, SKU list, batch/expiry list, catalogue and original labels.

3. Review cosmetic file

Check notification, CFS, LOA, PIF, ingredient list, claims and Vietnamese labelling.

4. Customs declaration

Prepare HS, value, sample sale purpose, C/O and specialized policy explanation for Yellow/Red lanes.

5. Clearance and delivery

Deliver to warehouse, tally, apply supplementary labels if needed, segregate near-expiry/non-compliant goods.

6. Post-clearance file

Retain notification, import documents, C/O, batch, distribution and promotion/sales records.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents
Generic “sample” description	Wrong HS/policy	Describe actual cosmetic product	Invoice, label, catalogue
No notification	Not ready for market	Complete/check notification before sale/gift	Notification, CFS, LOA
SKU/batch/expiry mismatch	Traceability risk	Request batch/expiry list	Packing list, labels, COA if any
C/O mismatch	Preference denial	Review C/O draft before issue	C/O, invoice, B/L
Alcohol/aerosol not reviewed	Booking refusal or route change	Obtain SDS/MSDS at booking stage	SDS/MSDS, packing
Late Vietnamese label	Market surveillance risk	Prepare label before distribution	Original label, Vietnamese label

FAQ

1. Do cosmetic sample sale items need notification?

If placed on the Vietnamese market for sale, promotion, gift-with-purchase or consumer use, cosmetic notification should be reviewed as for ordinary circulation goods.

2. Is there a separate HS for sample sale?

No. HS follows the actual product: perfume, skincare, makeup, hair care, deodorant, shaving product or other goods.

3. Does “not for sale” exempt the goods?

No automatic conclusion should be made. If goods are displayed, used by consumers or distributed commercially, review the actual file.

4. Can C/O reduce duty?

Yes, if the proof of origin is valid, the agreement is correct and the HS/description/origin match.

5. Is Vietnamese labelling required?

Usually it must be reviewed for marketable cosmetics according to goods labelling and cosmetic labelling rules.

6. Can mini sizes under one brand be notified together?

It depends on product name, formula, shade/fragrance, set configuration and notification rules. Review each SKU.

7. Do free promotional goods need customs value?

A proper customs value should still be supported by commercial records, even if the consumer does not pay separately.

8. What if invoice name differs from notification?

Correct or explain before declaration. Name/brand/SKU mismatch is a major operational risk.

IMPLEMENTATION SOLUTION FROM TGIMEX

This article outlines HS code, duty, cosmetic compliance, C/O, labelling and transport risks for cosmetic sample sale items placed on the market. For real shipments, companies still need to review catalogue, labels, ingredients, SDS/MSDS, documents, origin and import purpose.

60+ countries

WCA / WCA China

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Pre-ETA review

HS, C/O, duty and cosmetic notification.
Labels, catalogue, SKU, batch/expiry.
DG/SDS/MSDS where alcohol/aerosol exists.

Compliance control

Cross-check Invoice, Packing List and B/L/AWB.
Review CFS, LOA, PIF, claims and labels.
Identify mismatches between documents and notification.

Logistics & customs execution

Coordinate agents, carriers and airlines.
Customs declaration and Green/Yellow/Red lane handling.
Domestic delivery and post-clearance file retention.

For sample sale, tester, promotional and gift-with-purchase cosmetics placed on the market, companies should not wait until cargo arrival to start compliance review. Small mismatches among Invoice, Packing List, catalogue, label, C/O and notification can lead to document supplementation, clearance delay and unplanned storage costs.

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