Tiếng Việt
中文 (中国)
COSMETIC PACKAGING / NON-ELECTRIC ACCESSORIES
IMPORT PROCEDURE FOR DROPPER TUBE / PIPETTE / SQUEEZE DROPPER CAP
For dropper tubes, pipettes and squeeze dropper caps, the main customs risk is not the trade name but the structure: plastic, glass, rubber, silicone, or a mixed-material assembly. A generic “dropper cap” description may cause wrong HS code, duty, C/O treatment and documentary requests. This article provides an E2E map to review HS code, duties, C/O, policy, documents and customs decision points before ETA.
QUICK FACTS
| Item | Fast review point | Risk if ignored |
|---|---|---|
| Product | Dropper tube / pipette / squeeze dropper cap for serum bottles, essential oils, cosmetics or liquid ingredients. | Generic description such as “accessories” may trigger questions on material, use and HS classification. |
| Key HS codes | 3923.50.00 for plastic caps/closures; 7010.90.99 for glass tubes/containers for packing; 3926.90.99 for other plastic articles; 4016.99.99 for separate rubber bulbs. | Using one HS code for a mixed-material set may lead to wrong duty, C/O and goods description. |
| Reference base duties | 3923.50.00: MFN 10%, ordinary 15%, VAT 10%/8%; 7010.90.99: MFN 20%, ordinary 30%, VAT 10%/8%; 3926.90.99: MFN 12%, ordinary 18%, VAT 10%/8%. | Material misclassification can materially change import tax payable. |
| Specialized policy | Empty cosmetic packaging components should be reviewed by material, intended use and technical dossier; they are not automatically finished cosmetics. | If actually used for food, pharma, medical or lab purposes, another policy regime may apply. |
| Documents before ETA | Catalogue, material datasheet, product photos, component structure, invoice, packing list, C/O, original label, contract/PO. | Lack of material data makes classification difficult. |
Legal note: This is an operational reference for empty cosmetic packaging/accessory components. HS code and policy must be reviewed against catalogue, datasheet, material, packing condition, intended use and shipment documents.
SCOPE OF APPLICATION
This article applies to dropper tubes, pipettes and squeeze dropper caps imported for serum bottles, essential oils, cosmetic liquids or liquid ingredients. It covers plastic threaded caps, rubber/silicone bulbs, glass tubes, plastic pipettes, assembled droppers and separate components.
It does not automatically apply to laboratory pipettes, medical devices, food-contact packaging, electrical device parts or finished products containing cosmetics. Samples, used goods, warranty goods, EPE/FDI factory imports or medical/pharma/food use cases must be reviewed separately.
CLASSIFICATION & TECHNICAL IDENTIFICATION
Structure
A dropper set may include a plastic/metal cap, threaded ring, rubber or silicone bulb, glass/plastic tube and sometimes a seal or gasket.
Function
If used for cosmetic packaging, documents should state “empty cosmetic packaging component” or “dropper closure for cosmetic bottle”.
Material
Identify PP, PE, ABS, PETG, glass, borosilicate glass, rubber, silicone or aluminium collar because material drives HS classification.
Import condition
Separate components and assembled sets may be classified differently under the General Rules for Interpretation.
| Check item | Documents | Risk if wrong | Suggested declaration wording |
|---|---|---|---|
| Main material | Catalogue, datasheet, material COA, photos | Wrong chapter between plastic, glass and rubber. | Plastic dropper cap with glass pipette, for cosmetic bottle, brand-new. |
| Separate or assembled | Packing list, photos, BOM | Wrong line split or wrong set classification. | Dropper set comprising plastic cap, rubber bulb and glass pipette for serum bottle. |
| Dimensions/capacity | Technical drawing, catalogue | Cannot prove packaging use. | Glass dropper tube, length…, capacity…, for bottle cap assembly. |
| Intended use | PO, contract, product description | May be treated as lab/medical/food use. | Empty packaging component for cosmetic production/packing. |
| Label and origin | Original label, carton mark, C/O | Origin and labeling issues. | Declare origin according to documents and original label. |
HS CODE – DUTY – C/O
Do not lock all shipments under one HS code. Classification must follow the material giving the essential character, separate/assembled condition and packaging function.
| Cargo scenario | Reference HS | MFN duty | Ordinary duty | VAT | Application condition | Documents to check |
|---|---|---|---|---|---|---|
| Plastic screw cap / squeeze dropper cap / plastic closure | 3923.50.00 | 10% | 15% | 10%; possible 8% if VAT reduction conditions apply | Main nature is a plastic stopper, lid, cap or closure for packaging. | Photos, catalogue, PP/PE/ABS material, invoice description, label sample. |
| Glass dropper tube / glass pipette used with packaging | 7010.90.99 | 20% | 30% | 10%; review 8% if eligible | Glass article used as container/tube for packing, not a laboratory pipette. | Capacity, diameter, glass material, assembly with cap, use for cosmetic packaging. |
| Glass stopper / glass closure | 7010.20.00 | 20% | 30% | 10%; review 8% if eligible | The item is a glass stopper/lid/closure, not plastic or composite. | Material photos, technical description, separate invoice line if needed. |
| Separate plastic pipette/tube not classifiable as a closure | 3926.90.99 | 12% | 18% | 10%; review 8% if eligible | Other plastic article not meeting the description of 3923.50.00. | Dimensions, plastic material, dispensing function, product photos. |
| Separate vulcanized rubber bulb; silicone bulb must be reviewed separately by material | 4016.99.99 or suitable 4016.99 subheading | 20% reference | 30% reference | 10%; review 8% if eligible | Applies when a vulcanized rubber bulb is imported separately and not assembled as a complete dropper closure. Silicone must not be automatically classified under 4016 unless the material dossier supports it. | Material COA/MSDS, photos, catalogue, separate or assembled condition. |
C/O AND FTA REVIEW TABLE
| Route/origin | Origin document | Preferential duty approach | Conditions | Risk control |
|---|---|---|---|---|
| ASEAN | C/O Form D | Several lines under 3923 / 7010 / 4016 may reach 0% if the ATIGA schedule is satisfied. | Valid origin criterion, direct transport, matching goods description and HS code. | C/O describes only “dropper” while the declaration separates plastic, glass and rubber components. |
| China | Form E or other applicable origin document | May be lower than MFN; the actual rate must be checked by HS code and declaration year. | Check CTH/CTSH/RVC criterion, third-party invoice and transport route. | Wrong HS on C/O or overly generic description such as “cosmetic accessories”. |
| RCEP | RCEP C/O or RCEP origin declaration | The preferential rate depends on member country and the staging schedule for each HS line. | Review exporting country, origin country, 8-digit HS code and applicable year. | RCEP is not always better than MFN; compare rates before declaration. |
| South Korea | Form AK / Form VK | May be 0% or lower than MFN depending on the HS line and applicable schedule. | Check origin criterion, goods description, quantity and value. | Assembled multi-material droppers may be challenged if C/O lists only one generic item. |
| Japan | Form AJ / Form VJ / CPTPP origin document | May reach 0% under certain routes if the origin rule and schedule are met. | Compare the most favorable agreement by HS line. | Goods exported from Japan are not necessarily goods of Japanese origin. |
| EU / UK | EUR.1 / statement on origin | May be eligible for EVFTA/UKVFTA preferential treatment if conditions are met. | Check origin certification mechanism, description, HS and direct transport. | Missing valid origin statement at declaration time may block preferential duty. |
| Australia / New Zealand / CPTPP | Form AANZ / CPTPP origin document | May be lower than MFN and may reach 0% for eligible HS lines. | Review HS-specific schedule and direct transport/consignment conditions. | Using the wrong agreement form or mismatched invoice description may cause rejection. |
| No C/O | Not applicable | Apply MFN where the origin is entitled to MFN treatment; otherwise ordinary duty may apply. | Origin, labels and commercial documents must still be consistent. | No special preferential duty can be claimed, but origin must still be declared accurately. |
PRE-ETA TAX AND C/O CHECKLIST
Decide whether to declare separate components or an assembled dropper set.
Match HS on C/O with customs declaration and invoice description.
Check WO/CTH/CTSH/RVC origin criteria as applicable.
Review third-party invoice, direct transport, issue date and signature/stamp.
Compare MFN against special preferential duty before declaration.
Check 8%/10% VAT by declaration date and exclusion annex.
APPLICABLE SPECIALIZED POLICY
| Cargo situation | Possible policy | Documents to check | Authority/portal | Timing | Risk note |
|---|---|---|---|---|---|
| Empty cosmetic packaging/accessory | Ordinary customs, labeling, HS and material policy review. | Catalogue, datasheet, photos, material, intended use. | Customs authority. | Before ETA. | Not a finished cosmetic notification if empty. |
| Food-contact packaging | Food-contact policy may apply. | Use purpose, contract, material standard. | Food safety authority if applicable. | Before purchase order. | Do not use cosmetic logic for food use. |
| Medical/pharma/lab pipette | Medical, pharmaceutical or laboratory policy may apply. | Claims, manual, intended use. | MOH/specialized authority if applicable. | Before booking. | Lab pipette is not the same as cosmetic dropper packaging. |
| EPE/FDI factory import | Import type, production purpose and records. | Contract, BOM, investment file if needed. | Managing customs authority. | Before ETA. | Wrong import type affects audit/settlement. |
| Mixed metal/silicone/rubber parts | HS by material or set classification. | COA/MSDS, sample photos, material ratio. | Customs/classification authority if needed. | Before PO. | Generic “dropper” is insufficient. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Legal instrument | Issuing body | Effective/applicable time | Role | Key point | Review note |
|---|---|---|---|---|---|---|
| Law | Law on Customs 2014 | National Assembly | Current, subject to amendments | Customs declaration and supervision framework. | Declarant responsibility for accurate information. | Check latest consolidated text. |
| Decree | Decree 08/2015/ND-CP, amended by 59/2018/ND-CP | Government | Applicable as amended | Detailed customs procedures. | Documents, channeling, physical inspection. | Review by customs regime. |
| Circular | Circular 38/2015/TT-BTC, amended by 39/2018/TT-BTC | Ministry of Finance | Applicable as amended | Customs declaration guidance. | Goods description, HS, value and attachments. | Review by import type. |
| Decree | Decree 69/2018/ND-CP | Government | Effective from 15 May 2018 | Foreign trade management. | Check if the item is for pharma, medical, food or special chemical use. | Do not conclude no permit without actual dossier review. |
| Decree | Decree 26/2023/ND-CP | Government | Effective from 15 July 2023 | MFN import tariff schedule. | Check exact 8-digit HS code. | Review current tariff at declaration date. |
| Decree | Decree 43/2017/ND-CP and 111/2021/ND-CP | Government | 111/2021 effective from 15 Feb 2022 | Goods labeling. | Product name, origin, manufacturer and mandatory label fields. | Application depends on circulation/use status. |
| VAT | Decree 174/2025/ND-CP | Government | From 01 Jul 2025 to 31 Dec 2026 | Basis for considering 8% VAT if eligible. | Check exclusion annex and declaration date. | Do not default to reduced VAT. |
VIEW / DOWNLOAD OFFICIAL DOCUMENTS
Enterprises should look up documents by number on official legal portals, the Government portal or the issuing authority website before applying them.
CUSTOMS DOCUMENT SET
Commercial documents
Commercial Invoice, Packing List, B/L or AWB, contract/PO, C/O if claiming preferential duty, catalogue, photos and material list.
Technical documents
Plastic/glass/rubber/silicone material information, drawings, COA/MSDS if available, component photos and packaging use.
Specialized documents if triggered
Evidence that the item is not a medical/lab/food/pharma item if the description is ambiguous.
| Document group | Required document | Used for | Prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO, B/L/AWB | Declaration and value/quantity check | Importer, seller, forwarder | Generic description, missing material. | Ask supplier to state plastic cap/glass pipette/rubber bulb. |
| Technical | Catalogue, datasheet, photos, material, dimensions | HS and policy review | Buyer, supplier, compliance | No material data. | Obtain catalogue before booking. |
| Origin | C/O, B/L, invoice, packing list | Preferential duty claim | Supplier, importer, forwarder | Different HS or description on C/O. | Check HS, description, quantity, weight and issue date. |
| Label | Original label, carton mark, origin data | Labeling review | Supplier, importer | Missing origin/manufacturer. | Review carton photos before shipment. |
| Import type | Contract, purpose, EPE/FDI files if any | Import regime selection | Importer, customs broker | Wrong import type. | Confirm use purpose before declaration. |
CUSTOMS HOLD DECISION POINTS
| Decision point | Question | Proof | Consequence if unclear | Recommended action |
|---|---|---|---|---|
| HS by material | Is the essential character plastic, glass or rubber? | Catalogue, photos, COA | Classification consultation. | Split lines or prepare set-classification reasoning. |
| Use purpose | Cosmetic, food, medical or lab? | PO, description, manual | Unexpected specialized policy. | State empty cosmetic packaging if true. |
| C/O | Does C/O match HS, description, quantity and weight? | C/O, invoice, packing list | No preferential duty. | Check C/O before transmission. |
| Label | Does carton label show origin and manufacturer? | Original label photos | Label explanation request. | Get label photos before shipment. |
| Separate or set | Invoice declares set or separate parts? | Packing list, BOM, photos | Wrong quantity/unit/HS. | Split lines when necessary. |
PRACTICAL E2E PROCESS
| Step | Task | Control objective | Output |
|---|---|---|---|
| 1. Pre-ETA review | Confirm material, separate/set condition, HS, VAT, C/O and labels. | No late HS/policy issue. | HS and document checklist. |
| 2. Lock documents | Match invoice, packing list, B/L/AWB, catalogue, photos and C/O. | 100% consistency. | Declaration-ready dossier. |
| 3. Specialized policy screening | Check whether food, medical, pharma or lab policy is triggered. | Avoid wrong policy logic. | Policy note by actual dossier. |
| 4. Customs declaration | Declare HS, value, origin and description; handle Green/Yellow/Red channels. | Ready explanation for HS/material/C/O. | Customs declaration and attachments. |
| 5. Clearance and post-clearance | Release cargo and retain shipment records. | Ready for post-clearance audit. | Complete shipment file. |
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA control | Documents |
|---|---|---|---|
| Generic goods name | Document request and delay. | State material and packaging use. | Invoice, catalogue, photos. |
| Mixed materials under one HS | Wrong duty and C/O. | Split line or prepare classification reasoning. | Packing list, BOM, datasheet. |
| C/O mismatch | Preferential duty rejected. | Check C/O before declaration. | C/O, invoice, B/L. |
| Confused with lab/medical pipette | Different policy regime. | Prove cosmetic packaging use. | PO, manual, catalogue. |
| Wrong VAT 8%/10% | Tax adjustment. | Check VAT policy at declaration date. | Tariff, VAT annex, declaration. |
| Missing origin label | Label explanation request. | Request label/carton photos. | Original label photos. |
FAQ
| Question | Answer |
|---|---|
| Is cosmetic product notification required for empty droppers? | Normally no if they are empty packaging components, but actual use and dossier must be reviewed. |
| Can all items be declared under 3923.50.00? | No. It fits plastic closures; glass tubes, rubber bulbs and separate plastic pipettes may fall under other codes. |
| Can C/O reduce duty? | Yes if form, HS, description, origin criterion and transport conditions are valid. |
| Is Vietnamese sub-label required? | Review labeling rules depending on circulation and use status. |
| Is separate rubber bulb different from assembled set? | Yes, it may be classified under rubber if imported separately. |
| Is “cosmetic accessories” enough on invoice? | No. Specify item, material, use and condition. |
RELATED ARTICLES
IMPLEMENTATION SUPPORT FROM TGIMEX
This article provides a map of HS, duty, C/O, documents and policy for dropper/pipette/squeeze caps. For real shipments, review must be based on catalogue, datasheet, materials, documents, origin and import purpose.
Pre-ETA review
HS, duty, C/O, label, catalogue, material and separate/set condition.
Compliance dossier control
Invoice, Packing List, B/L/AWB, C/O, catalogue, labels and technical documents.
E2E logistics execution
International transport, pre-alert, customs declaration, clearance, domestic delivery and post-clearance recordkeeping.
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