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IMPORT PROCEDURE BY PRODUCT · COSMETIC SAMPLE
IMPORT PROCEDURE GUIDE FOR COSMETIC TESTING SAMPLES
Testing samples are usually small in quantity, low in declared value and not intended for sale. However, a shipment may still be held if the goods are described too generally, declared at zero value, not supported by a clear research or testing purpose, or not accompanied by the proper cosmetic sample import dossier. This article provides an E2E map before ETA: sample nature, HS classification by product type, duties, C/O, sample import order, customs documents and critical risk points.
QUICK FACTS
| Item | Fast review point | Operational note |
|---|---|---|
| Goods | Cosmetic testing samples imported for research, testing or internal quality evaluation. | Not for tester packs, sample-sale goods or promotional items placed on the market. |
| Indicative HS | There is no fixed HS code for “testing sample”; classify by the actual product nature, commonly under 3304, 3305 or 3307. | Review INCI, use, product form, packaging and catalogue. |
| Duties | Common MFN range: 10%–22%; base VAT: 10%; ordinary duty is commonly 150% of MFN if preferential treatment is not available. | Each HS line has its own rate; do not apply one duty rate to all samples. |
| Specialized control | Cosmetics imported for research/testing may fall under a special mechanism and must not be circulated. | Review Article 35 of Circular 06/2011/TT-BYT and applicable amendments. |
| Dossier lock | Import purpose, sample quantity, “not for sale” marking, approved sample order, commercial documents. | Wrong purpose or excessive quantity may cause the shipment to be treated as commercial goods. |
Legal note: This article applies only to cosmetic testing samples used strictly for research, testing or product development. If the samples are sold, bundled as gifts, used for commercial display or placed on the market, the importer must reassess the proclamation and circulation mechanism applicable to commercial cosmetic goods.
SCOPE OF APPLICATION
This article applies to cosmetic testing samples imported for research, testing, formula evaluation, quality assessment or product development preparation. It does not apply to commercial cosmetic goods, retail testers, sample-sale items or promotional goods placed on the market.
- Applies only to cosmetic products under cosmetic management: skincare, make-up, hair care, body care, fragrance, personal deodorant and similar items.
- Does not automatically apply to pharmaceutical samples, food samples, industrial chemicals, essential oil raw materials or cosmetic raw materials not yet formulated.
- Review catalogue, datasheet, formula or INCI, import purpose, sample quantity and actual documents.
- If the sample shipment includes batteries, electrical devices, testing equipment or commercial advertising materials, review those items separately.
CLASSIFICATION & TECHNICAL IDENTIFICATION
Nature of sample
A testing sample is still classified by its actual product nature, not by the fact that it is a sample. The goods description should show cosmetic type, form, packing and non-sale purpose.
Import purpose
The dossier should clearly show research, testing, formula evaluation or internal quality testing; avoid descriptions suggesting commercial trading.
Description risk
Generic names such as cosmetic sample or laboratory sample may be insufficient for HS classification, specialized policy review and customs explanation.
| Technical criterion | Document to review | Risk if wrongly described | Suggested goods description |
|---|---|---|---|
| Cosmetic product type | Catalogue, photos, original label, sample request | Wrong HS between 3304, 3305, 3307 or another heading | Cosmetic testing sample in serum/lipstick/shampoo/deodorant form, not for sale |
| Main function | Claim, INCI, manufacturer description | May be questioned as medicine, chemical or commercial goods | Testing sample for cosmetic quality evaluation, not for sale |
| Quantity per sample | Sample order, packing list, SKU list | Excessive quantity or unclear purpose | State each SKU quantity, small packing and testing purpose |
| Declared value | Invoice, quotation, sample agreement | Zero value may trigger customs valuation query | Declare a reasonable value or value for customs purpose |
| Market circulation status | Label photo, internal note, purpose confirmation | May be treated as sale goods if fully commercial packaging is used | Not for sale / for testing purpose only |
HS CODE – DUTY – C/O
There is no separate HS code for “testing samples”. Customs classification follows the actual product nature. Before ETA, the importer should prepare an SKU-to-HS mapping table and review MFN duty, VAT and C/O eligibility for each sample type.
| Cosmetic sample group | Indicative HS | Indicative MFN | Indicative ordinary duty | VAT | Application condition and documents to review |
|---|---|---|---|---|---|
| Perfume/fragrance sample | 3303.00.00 | 18% | 27% | 10% | Perfume, eau de parfum, body fragrance; review concentration, function, label and invoice. |
| Lip make-up sample | 3304.10.00 | 20% | 30% | 10% | Lipstick, lip tint, lip gloss; review shade/SKU, label, formula and testing purpose. |
| Eye make-up sample | 3304.20.00 | 22% | 33% | 10% | Eyeliner, mascara, eyeshadow; avoid a generic make-up sample description. |
| Nail product sample | 3304.30.00 | 22% | 33% | 10% | Cosmetic nail product; check DG transport if flammable solvents are present. |
| Powder sample | 3304.91.00 | 22% | 33% | 10% | Powder, cushion powder, pressed powder; review pressed or loose form. |
| Skin care cream/serum/lotion sample | 3304.99.30 or 3304.99.90 | 20% | 30% | 10% | Review separately if anti-acne, treatment, anti-inflammatory or medicinal claims appear. |
| Shampoo sample | 3305.10.90 | 15% | 22.5% | 10% | If anti-fungal claims appear, review 3305.10.10 and actual product nature. |
| Hair treatment/conditioner/hair serum sample | 3305.90.00 | 20% | 30% | 10% | Other hair preparations; review function and product form. |
| Personal deodorant/antiperspirant sample | 3307.20.00 | 20% | 30% | 10% | Distinguish from body mist, perfume or room deodorizer preparations. |
| Origin route | Common proof of origin | Potential special preference | Checkpoints | Risk if incorrect |
|---|---|---|---|---|
| ASEAN | Form D or e-Form D | May be substantially reduced; several lines may be 0% if the current ATIGA tariff schedule is met | RVC/CTH, description, HS, invoice, direct consignment | Mismatch in HS or sample description may deny preference. |
| China | Form E or RCEP if eligible | Review ACFTA/RCEP by actual HS | Origin criterion, third-party invoice, transport route | Overly generic cosmetic sample description may trigger query. |
| Korea | Form AK/VK or RCEP | Review AKFTA/VKFTA/RCEP | Manufacturer, origin, 8-digit HS, issue date | Wrong form may deny special preference. |
| Japan | VJ/AJ, CPTPP or RCEP | Review the applicable agreement and exporter proof | CTH/RVC criterion, description, invoice | Confusing agreement mechanisms. |
| EU/UK | EUR.1 or origin declaration under EVFTA/UKVFTA | Review EVFTA/UKVFTA tariff by HS | Proof of origin, direct transport, exporter statement | Invalid origin proof. |
| Australia/New Zealand | AANZFTA or CPTPP | Review AANZFTA/CPTPP | Origin proof and origin criterion | Export country alone does not prove origin. |
| India/Hong Kong | Form AI or AHK | Review AIFTA/AHKFTA | Form, description, HS, direct transport | Wrong form or country of origin. |
| C/O checklist before claiming preference | Requirement | Action |
|---|---|---|
| Form/proof of origin | Correct agreement, route and origin country | Do not claim preference until legal basis is clear. |
| HS and goods description | C/O HS must be consistent with customs HS; description must identify sample type | Prepare catalogue and packing list if the description is broad. |
| Origin criterion | WO, PE, RVC, CTH/CTSH depending on the agreement | Review BOM/process if customs asks. |
| Third-party invoice | Must be indicated correctly where applicable | Wrong invoice information may reject preference. |
| Direct consignment | Review B/L, transit and non-manipulation proof | Missing transit evidence may trigger explanation. |
| Issue date/signature/stamp/e-C/O | Valid and verifiable paper or electronic document | Do not use expired or unverifiable C/O. |
Control point: C/O only supports preferential duty treatment. It does not replace the need to prove testing-sample purpose and does not allow market circulation.
SPECIALIZED POLICY MATRIX
| Goods situation | Possible policy | Documents to review | Agency / portal | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Cosmetic sample for research/testing | Import order for cosmetic research/testing samples; product proclamation may not be required if the special case is properly met | Sample order, purpose, quantity, sample list, manufacturer details | Under current cosmetic management rules; confirm receiving authority at filing date | Before arrival | Samples must not be circulated. |
| Sample looks like commercial goods | May be required to follow commercial cosmetic import/proclamation mechanism | Proclamation, LOA, CFS, PIF, label | Health authority depending on current mechanism | Before declaration | Wrong purpose may lead to additional dossiers. |
| Therapeutic or disease claims | May trigger reassessment outside cosmetic scope | Claim, formula, label, technical documents | Health specialized authority | Before ETA | Claims beyond cosmetic scope may change policy. |
| Alcohol/solvent/aerosol sample | Dangerous goods transport rules may apply | MSDS, UN number, flash point, packing instruction | Carrier, airline, shipping line, port | Before booking | Failure to check DG may cause booking refusal. |
| EPE/FDI/factory use | Customs regime depends on import purpose | Contract, purpose, internal use record, accounting documents | Customs branch | Before declaration | Wrong customs regime affects tax/accounting control. |
SAMPLE IMPORT ORDER DOSSIER FOR COSMETIC RESEARCH/TESTING
Article 35 of Circular 06/2011/TT-BYT provides a special mechanism for cosmetics imported for research/testing. The importer should review the current form, receiving authority and updated procedure under applicable amendments before filing.
| Document / item | Content to prepare | Checkpoint | Risk if missing |
|---|---|---|---|
| Sample import order | Product list, dosage/form, packing, main function, composition, unit, quantity, manufacturer and country | Quantity limit under current rules and clear research/testing purpose | Customs may request specialized dossier. |
| Purpose explanation letter | State testing, formula evaluation, stability testing or product development purpose | No sale, marketing or gift purpose | May be treated as commercial goods. |
| SKU / shade / sample list | Product name, sample code, batch, volume, quantity per item | Must match invoice, packing list, label and photos | Mismatch may trigger query. |
| Not-for-sale indication | Label photo, marking, supplier confirmation | Should show sample for testing or not for sale where possible | Commercial packaging may raise questions. |
| Technical file | INCI, MSDS where needed, catalogue, product photos | Enough for HS and claim review | Insufficient basis for classification/policy. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Name / number | Issuing body | Effective timing | Role | Key article / appendix | Review note |
|---|---|---|---|---|---|---|
| Circular | Circular 06/2011/TT-BYT on cosmetic management | Ministry of Health | Effective from 01/04/2011; review amendments | Cosmetic management, import, proclamation, label, research/testing samples | Articles 3, 4, 35, 36, Appendix 14-MP | Review consolidated/current version. |
| Amending circular | Circular 34/2025/TT-BYT | Ministry of Health | Issued 03/07/2025, effective 18/08/2025 | Amends Circular 06/2011/TT-BYT | Relevant updated forms and procedures | Review sample form and receiving authority. |
| Labeling decrees | Decree 43/2017/ND-CP and Decree 111/2021/ND-CP | Government | Decree 111 effective 15/02/2022 | Goods labeling framework | Mandatory label content and origin | Not-for-sale samples should still be identifiable. |
| Tariff instruments | MFN tariff, ordinary duty tariff and FTA tariff schedules | Government / Ministry of Finance | At declaration date | Determine import duty, VAT and C/O preference | Decision 15/2023/QD-TTg and FTA schedules | Do not use a single duty rate for all samples. |
| Customs law | Customs law and implementing regulations | National Assembly / Government / Ministry of Finance | Current version | Customs declaration, inspection, valuation, post-clearance | Customs dossier, HS, value, origin | Review customs regime by import purpose. |
VIEW / DOWNLOAD ORIGINAL LEGAL SOURCES
Businesses should additionally verify the document number on the official legal document portal or the issuing authority’s website before applying it.
CUSTOMS CLEARANCE DOCUMENT SET
Commercial documents
Commercial Invoice, Packing List, B/L or AWB, contract/PO if any, sample letter and value basis.
Technical documents
Catalogue, photos, label, INCI, MSDS if DG risk exists, SKU/shade/sample list.
Specialized dossier
Research/testing sample import order, approval if applicable and non-circulation commitment.
| Dossier group | Required document | Used for | Usually prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, B/L/AWB | Customs declaration, value, transport | Shipper, buyer, forwarder | Zero invoice, generic goods name | Reasonable value and clear testing purpose. |
| Technical | Catalogue, photos, INCI, label | HS and policy review | Manufacturer/R&D/QA | No INCI or vague claims | Prepare SKU mapping before ETA. |
| Specialized | Sample order and purpose letter | Prove sample import mechanism | Importer/compliance | No non-circulation purpose | Prepare before arrival. |
| Origin | C/O or proof of origin if preference is claimed | Preferential duty declaration | Supplier/exporter | Wrong form, HS or description | Check form, origin criterion and direct consignment. |
| Label/purpose | Label photos, not-for-sale marking, commitment letter | Explain sample purpose | Shipper/importer | Commercial-looking packaging | Add sample for testing indication where appropriate. |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Impact if unclear | Recommended action |
|---|---|---|---|---|
| HS code | Does the sample fall under 3304, 3305, 3307 or another heading? | Catalogue, INCI, use, photos | Reclassification or duty adjustment | Prepare HS mapping by SKU. |
| Sample purpose | Can research/testing purpose be proven? | Sample order, purpose letter, lab/R&D record | May be treated as commercial goods | Lock purpose on invoice and dossier. |
| Quantity | Does quantity exceed the sample basis/current rules? | Packing list, sample order | Dossier rework | Check each SKU and unit. |
| Customs value | Is the customs value reasonable? | Invoice, quote, supplier note | Valuation query | Avoid unsupported zero value. |
| C/O | Is preference fully supported? | C/O, B/L, invoice, proof of origin | Preference denied | Claim only when documents match. |
PRACTICAL E2E PROCESS
| Step | Action | Locked output | Risk to prevent |
|---|---|---|---|
| 1. Pre-ETA review | Confirm sample purpose, HS by SKU, duty, C/O, special sample policy | SKU – HS – duty – dossier mapping | Generic description and unclear purpose. |
| 2. Document lock | Finalize invoice, packing list, transport document, sample list, value and not-for-sale marking | Consistent document set | Mismatch across documents. |
| 3. Specialized dossier | Prepare sample order, purpose letter and approval if applicable | Explanation dossier | Late preparation after ETA. |
| 4. Customs declaration | Declare correct HS, value, regime and purpose; prepare Green/Yellow/Red lane explanation | Declaration and supporting file | HS, value, purpose queries. |
| 5. Clearance and record retention | Receive goods, transfer to lab/R&D, avoid circulation and retain records | Post-clearance file and usage log | Wrong use or missing records. |
PRE-ETA RISK CHECKLIST
| Risk | Impact | Pre-ETA prevention | Document to check |
|---|---|---|---|
| Generic goods name | Insufficient HS/policy basis | State cosmetic type and testing purpose | Invoice, packing list, catalogue |
| Zero-value invoice | Customs value query | Use reasonable value or value for customs purpose | Invoice, quote, sample letter |
| No sample order | Cannot prove sample mechanism | Prepare sample order before arrival | Order and purpose letter |
| Excessive quantity/purpose mismatch | May be treated as commercial goods | Check quantity by product/SKU | Packing list, SKU list |
| Wrong C/O form/description | Preference denied | Review form, HS, description, date and direct consignment | C/O, B/L, invoice |
| Claims beyond cosmetic scope | Policy reassessment | Review disease/treatment claims before import | Label, catalogue, INCI |
FAQ
| Question | Practical answer |
|---|---|
| Does a cosmetic testing sample require product proclamation? | If it is truly imported for research/testing and meets the special mechanism, it may not require the same proclamation as market circulation goods; prepare sample order and purpose evidence. |
| Can testing samples be sold or gifted to customers? | No. Research/testing samples must be used for the declared purpose and must not be circulated. |
| What is the HS code for testing samples? | There is no separate HS for sample status. HS is determined by actual product nature: lipstick, serum, shampoo, deodorant, nail product, etc. |
| Is duty payable even if the goods are samples? | Possibly yes. Duty depends on HS, customs value, C/O and any applicable exemption/reduction; sample status alone does not automatically mean duty-free. |
| Can C/O reduce duty? | Possibly, if the C/O form, origin criterion, HS, description and direct consignment are valid. C/O does not replace the specialized sample dossier. |
| How should the invoice description be written? | State product type, form, quantity, testing purpose and not-for-sale status; avoid only writing cosmetic sample. |
| What if the sample contains alcohol or aerosol? | Review MSDS, dangerous goods requirements and transport acceptance before booking. |
RELATED ARTICLES
EXECUTION SUPPORT FROM TGIMEX
This guide provides the map for HS, duty, C/O, testing-sample dossier and specialized policies. In actual shipments, the importer still needs to review catalogue, INCI, quantity, value, origin, label and import purpose.
Pre-ETA review
Review HS by SKU, research/testing sample policy, duty, C/O, label and technical documents.
Compliance control
Cross-check invoice, packing list, B/L/AWB, sample order, explanation letter, catalogue, INCI, MSDS and labels.
E2E execution
Coordinate international freight, customs declaration, lane handling, domestic delivery and post-clearance record retention.
For sample shipments that may trigger specialized review, C/O or customs valuation explanation, businesses should not wait until arrival to prepare documents. Minor inconsistencies between invoice, packing list, catalogue, INCI, C/O or labels may cause additional document requests, clearance delay and unplanned costs.
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