Emollient, a softening and smoothing ingredient used in cosmetic formulations, is often declared too generally as “cosmetic raw material”. In practice, HS Code, chemical declaration, MSDS/SDS, COA, original label and declared use depend directly on INCI/CAS, composition, physical state and technical documents. If HS is fixed only by trade name or chemical-declaration risks are missed, the shipment may be routed for inspection, required to supplement documents, lose C/O preference or incur storage and detention costs. This guide provides an E2E review map before ETA: HS, duties, C/O, chemical policy, document set and clearance decision points.

QUICK FACT

Item	Compliance points
Goods	Emollient used as cosmetic raw material: ester emollients, silicone oils, fatty alcohols, wax/emollient blends, plant/mineral-based softeners.
Reference HS	There is no single fixed code. Common groups: 2915.90.90, 3823.70.90, 3910.00.20/3910.00.90, 3404.90.90; verify by INCI/CAS/MSDS.
Indicative duties	MFN may be 5%, 0% or 3% depending on HS; planning VAT is 10%, review 8% only if the VAT reduction policy is valid and applicable.
Key policy	Review import chemical declaration if the CAS appears in Appendix V of Decree 113/2017/ND-CP or if the mixture is classified as hazardous.
Key documents	Invoice, Packing List, B/L/AWB, C/O if any, MSDS/SDS, COA, TDS, INCI/CAS, specification, original label and cosmetic manufacturing use.

Legal noteEmollient is a formulation function, not an HS classification basis. Verify by INCI, CAS, MSDS/SDS, COA, TDS and actual import purpose; do not conclude that no chemical declaration is required before reviewing the full file.

SCOPE OF APPLICATION

This article applies to emollient imported as a cosmetic formulation raw material, whether as a single substance, technical mixture or commercial blend for factory manufacturing. It does not automatically apply to finished cream, lotion or body oil packed for retail sale, fragrance oil, preservative, active, colorant, surfactant, food additive, pharmaceutical ingredient or industrial chemical used outside the cosmetic scope. New goods, R&D samples, EPE/FDI imports, products with flammable solvent, DG (Dangerous Goods) characteristics or CAS numbers subject to chemical declaration may trigger different policies. Review against catalogue, datasheet, model and actual import purpose.

CLASSIFICATION & TECHNICAL IDENTIFICATION

Goods nature

Match the trade name with INCI, CAS, active content, single substance/mixture status, physical form and use in cosmetic formulation.

Technical documents

MSDS/SDS, COA, TDS, specification, allergen statement if any, botanical/RSPO evidence if required by buyer, original label and packing specification.

Classification risk

“Emollient” is only a functional term. Ester, silicone oil, fatty alcohol and wax-type emollients may fall under different HS chapters.

Suggested description

Use chemical/INCI nature and usage, e.g. “Cosmetic raw material – emollient – [INCI/CAS] – for cosmetic manufacturing”.

Criterion	Documents to check	Risk if wrong	Suggested goods description
INCI/CAS	MSDS/SDS, COA, TDS	Chemical nature is unclear; HS may be wrong	Emollient cosmetic raw material – [INCI/CAS] – for cosmetic manufacturing
Composition/mixture	Composition, concentration, specification	Chemical declaration or DG review may be missed	State the main substance, form and use
Physical form/packing	Original label, goods photo, packing list	Wrong transport condition, unit or customs description	Liquid/paste/wax/powder, net weight, packaging
Intended use	PO, formula BOM, manufacturing explanation	May be treated as finished cosmetics or industrial chemical	Raw material for cosmetic manufacturing, not for direct retail sale

HS CODE – DUTIES – C/O

HS for emollient must be determined by chemical nature, not by marketing name. The table below is a review framework for common scenarios and does not replace official classification based on the shipment file.

Reference HS	Condition of use	Risk if wrong	Documents to check
2915.90.90	Ester emollients such as isopropyl myristate/palmitate or other fatty acid esters when chemistry supports this heading	Misclassified as 3824/3404 if it is a blend or formulated wax	MSDS, COA, CAS, TDS, percentage composition
3823.70.90	Other industrial fatty alcohols used as emollient/consistency agents	Confusion with pure fatty alcohols in Chapter 29 or blends in Chapter 38	MSDS, COA, origin, purity
3910.00.20/3910.00.90	Silicone oil/emollient such as dimethicone, cyclomethicone or silicone dispersion/solution/other form	May be treated as finished cosmetics if packed and claimed as retail product	INCI, CAS, polymer type, viscosity, application
3404.90.90	Artificial wax or prepared waxy emollient not classified elsewhere	Confusion with oils, esters or other chemical preparations	TDS, melting point, composition, MSDS

DETAILED DUTY TABLE TO REVIEW BEFORE DECLARATION

2915.90.90

Condition:Ester emollient; documents show a suitable carboxylic acid derivative.

MFN: Reference 5%; verify against the current tariff at declaration time.

Ordinary duty: Reference 7.5% if the 150% MFN principle applies and no separate rate is listed.

VAT: 10%; review 8% only if the VAT reduction policy is valid and the goods are not excluded.

C/O: Form D/E/RCEP/CPTPP/EVFTA/UKVFTA… only if HS, origin criterion and direct transport are valid.

3823.70.90

Condition:Other industrial fatty alcohols used as emollient/consistency agents.

MFN: Reference 5%.

Ordinary duty: Reference 7.5% if the 150% MFN principle applies.

VAT: 10%; review 8% only if eligible.

C/O: Check RVC/CTH/CTSH, goods description and third-party invoice if any.

3910.00.20 / 3910.00.90

Condition:Primary-form silicone, dispersed/solution form or other form.

MFN: Reference 0%; verify by detailed HS code.

Ordinary duty: Review Decision 15/2023/QD-TTg if no separate ordinary duty is listed.

VAT: 10%; apply 8% only if eligible.

C/O: Even where MFN is 0%, C/O may still be needed for origin evidence or internal compliance.

3404.90.90

Condition:Other artificial or prepared wax.

MFN: Reference 3%.

Ordinary duty: Reference 4.5% if the 150% MFN principle applies.

VAT: 10%; review 8% only if eligible.

C/O: C/O must match wax/preparation description and HS code.

C/O AND FTA PREFERENCE REVIEW TABLE

Origin route	C/O form or origin document	Preference to review	Conditions/documents to check	Risk if wrong
ASEAN	Form D / ATIGA	May be 0% depending on HS and ATIGA schedule	WO/RVC/CTH/CTSH, direct transport, goods description	Preference may be rejected if form or description is wrong
China	Form E / ACFTA or RCEP	Review the special preferential schedule by detailed HS	Invoice, packing, HS, origin criterion, third-party invoice if any	Wrong HS or value may invalidate preference
Korea/Japan	AKFTA/VKFTA/RCEP; VJEPA/AJCEP/CPTPP/RCEP	Review by country of origin and selected FTA	C/O, chemical description, tariff-shift or regional-value criterion	A different HS may change preference conditions
EU/UK/CPTPP	EVFTA/UKVFTA/CPTPP	Review by proof of origin and reduction schedule	Statement/Certificate of Origin, direct transport, purchase file	Missing valid origin proof removes preference

SPECIALIZED POLICY MATRIX

Goods scenario	Policy possibly applicable	Documents to check	Authority/portal if identifiable	Timing	Risk note
Ordinary emollient chemical not in Appendix V	Customs procedure, goods label and technical file	MSDS, COA, TDS, original label, Invoice, Packing List	Customs / importer keeps file	Before ETA	Do not conclude “no policy” without CAS and MSDS.
CAS listed for chemical declaration	Import chemical declaration before customs clearance	MSDS, COA, CAS, composition, intended use	National Single Window / Ministry of Industry and Trade	Before declaration or clearance	Missing declaration may cause supplementary request.
Flammable goods, solvent-based goods or DG	Dangerous goods transport review	MSDS Section 14, flash point, UN number, packing group	Carrier/airline/port/warehouse	Before booking	Wrong DG status may cause rejection or surcharge.
Raw material for cosmetic manufacturing	Support file for finished-product PIF/QA	COA, specification, INCI, supplier profile, origin	Importer/QA/Compliance	Before import and production	Raw material is not automatically subject to finished cosmetic product proclamation.
Special botanical/animal origin	Quarantine/CITES review if evidence exists	Certificate, botanical/animal origin, CITES statement	Specialized authority if applicable	Before ETA	Only applies when documents show regulated origin.

LEGAL DOCUMENTS TO REVIEW

Document group	Document number/name	Issuing authority	Effective date/application time	Role in procedure	Key article/clause/appendix to check	Review note
Customs law/decree	Customs Law 2014; Decree 08/2015/ND-CP and amendments	National Assembly/Government	According to current validity	Basis for customs declaration, dossier inspection and physical inspection	Provisions on customs dossier, customs inspection and channeling	Check validity at declaration time.
Tariff schedule	Decree 26/2023/ND-CP	Government	Effective 15/07/2023	MFN import duty schedule by HS	Appendix II – preferential import tariff	Check amendments/supplements if any.
Ordinary duty	Decision 15/2023/QD-TTg	Prime Minister	Effective 15/07/2023	Determine ordinary import duty where MFN/FTA is not applied	150% MFN principle if no separate ordinary rate is listed	Do not calculate manually if the HS has a separate listed rate.
VAT	VAT Law 48/2024/QH15; Resolution 204/2025/QH15 if applicable	National Assembly/Government	Resolution 204 applies 01/07/2025–31/12/2026	Determine VAT 10% or 8% if eligible	Applicable and excluded groups under the VAT reduction policy	Check exclusion appendices.
Chemicals	Decree 113/2017/ND-CP; Decree 82/2022/ND-CP	Government / Ministry of Industry and Trade	According to current validity	Chemical declaration, hazardous chemicals, Appendix V	Appendix V; declaration before clearance and exemption rules if any	Check CAS, concentration, mixture classification and exemptions.
Goods labeling	Decree 43/2017/ND-CP; Decree 111/2021/ND-CP	Government	Decree 111 effective 15/02/2022	Original label and Vietnamese supplementary label	Mandatory label contents for imported goods	Check goods name, origin, manufacturer and quantity.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Businesses should cross-check official legal databases or issuing authority websites before application. The buttons below are for original legal texts or official procedures.

Decree 26/2023/ND-CP Decision 15/2023/QD-TTg Chemical declaration Resolution 204/2025/QH15

CUSTOMS DOCUMENT SET

Commercial documents

Commercial Invoice, Packing List, Sales Contract/PO.
Bill of Lading/Air Waybill.
C/O if tariff preference is claimed.
Goods photos, original label and packing specification.

Technical/specialized documents

MSDS/SDS, COA, TDS and specification.
INCI/CAS, percentage composition and cosmetic manufacturing use.
Chemical declaration/DG declaration if applicable.
Supplier file supporting finished-product QA/PIF.

OPERATIONAL DOCUMENT CHECKLIST

Goods name, quantity, model/lot, origin, CAS/INCI and technical specifications must match 100% across commercial documents, labels, MSDS/COA/TDS, specialized files and customs declaration.

File group	Documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO, B/L/AWB	Customs declaration, valuation, transport	Supplier/Buyer/Docs	Wrong goods name, quantity or Incoterms	Match emollient name, net/gross weight, Incoterms, POL/POD.
Technical	MSDS/SDS, COA, TDS, specification, INCI/CAS	HS, chemical policy, DG review	Supplier/QA/Compliance	Missing CAS or percentage composition	Request latest version and lot number where relevant.
Origin	C/O, invoice, transport document	Special preferential duty	Exporter/Forwarder/Docs	Wrong HS, description, origin criterion or third-party invoice	Check form, issue date, signature/stamp, direct transport.
Label	Original label, packaging photos, label artwork if any	Label review and goods identification	Supplier/Importer	Missing chemical name, batch, origin or safety warning	Compare with MSDS/COA/Invoice before ETA.
Chemical/DG if any	Chemical declaration, DG declaration, UN number, flash point	Clearance/transport	Importer/Forwarder/Compliance	Prepared after ETA, delaying clearance/booking	Review MSDS sections 2, 3, 9 and 14 before booking.

CLEARANCE DECISION POINTS

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended handling
HS basis	Are INCI/CAS and chemical nature clear?	MSDS, COA, TDS, CAS	Wrong duty or customs query	Classify by main substance; function is supplementary information.
Chemical declaration	Is the CAS in Appendix V or hazardous mixture scope?	MSDS, percentage composition, CAS	Supplementary declaration request	Review before ETA; prepare National Single Window account if required.
DG status	What are flash point, UN number and packing group?	MSDS Section 14, DG declaration	Carrier/airline may reject shipment	Confirm DG/non-DG before booking.
C/O validity	Do form, origin criterion, description and HS match?	C/O, Invoice, BL/AWB	Loss of tariff preference	Check C/O draft before shipment or immediately when available.
Intended use	Cosmetic manufacturing or another industrial use?	PO, BOM, end-use explanation	Wrong policy or weak explanation	State import purpose in internal file and documents where needed.

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review

Fix HS, chemical policy, DG, duties, C/O, labeling and technical files.

Step 2 – Lock documents

Ensure Invoice, Packing List, B/L/AWB, label, MSDS, COA, TDS and INCI/CAS match 100%.

Step 3 – Handle specialized requirements if any

Submit chemical declaration or prepare DG declaration if triggered by documents.

Step 4 – Customs declaration

Prepare HS, value, origin, C/O and chemical-policy explanation if queried.

Step 5 – Clearance and archive

Archive declaration, transport documents, MSDS/COA/TDS, C/O and compliance evidence by lot.

PRE-ETA RISK CHECKLIST

Risk	Consequence	How to prevent before ETA	Documents to check
Goods declared only as “emollient”	Insufficient HS basis	Request INCI/CAS/MSDS/COA at purchase stage	MSDS, COA, TDS
Chemical declaration not reviewed	Document supplement and clearance delay	Check CAS against Appendix V and hazardous mixture rules	CAS list, MSDS, composition
Incorrect C/O or origin criterion	Preference denied	Check form, HS, description, issue date and direct transport	C/O, Invoice, B/L/AWB
Wrong DG/non-DG status	Transport rejection or surcharge	Review flash point, UN number and packing group before booking	MSDS sections 2, 9, 14
No raw-material QA/PIF archive	Difficult post-clearance or production explanation	Keep COA, specification and supplier file by lot	COA, TDS, supplier file

FAQ

Does emollient raw material need cosmetic product proclamation?

If imported only as manufacturing raw material, it is not automatically treated like a finished cosmetic product. Keep raw-material files for QA/PIF of finished products.

Is there a fixed HS for emollient?

No. HS depends on chemical nature: ester, silicone, fatty alcohol, wax or blend.

Is import chemical declaration required?

It may be required if the CAS or hazardous mixture classification falls within the regulated scope. Review MSDS and composition.

Can C/O reduce duty?

Possibly, if the C/O form, origin criterion, goods description, HS and direct transport are valid.

Should VAT be planned at 10% or 8%?

Plan at 10%; use 8% only when the goods are eligible and not excluded at declaration time.

Are R&D samples handled differently?

Samples still require HS, value, purpose and technical documents. Policy may vary by customs regime and purpose.

IMPLEMENTATION SOLUTION FROM TGIMEX

This article provides a review map for HS, duties, documents and specialized policies; however, each actual emollient shipment must still be checked against INCI/CAS, MSDS, COA, TDS, documents, origin and import purpose.

Pre-ETA review

Check HS, C/O, duties, chemical policy, DG, labeling and technical documents.

Compliance file control

Cross-check Invoice, Packing List, B/L/AWB, C/O, MSDS, COA, TDS and original label.

International logistics & clearance

Coordinate agents, carriers/airlines, pre-alert, customs declaration and channel handling.

Post-clearance archive

Keep lot-based files and support HS, value, origin and chemical-policy explanations if needed.

For shipments that may involve chemical declaration, DG, C/O or labeling requirements, businesses should not wait until cargo arrival to start document review. Small mismatches among Invoice, Packing List, MSDS, COA, TDS, C/O or labels may lead to document supplementation, delayed clearance or unplanned storage costs.

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