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.

Illustration for Import procedure guide for cosmetic testing samples — Illustration of the product group and document review before customs clearance.

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.

Circular 06/2011/TT-BYT Circular 34/2025/TT-BYT Vietnam Trade Portal HS lookup

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.

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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