Tiếng Việt
中文 (中国)
IMPORT PROCEDURE FOR COSMETIC TESTERS PLACED ON THE VIETNAMESE MARKET
Tester is not a separate HS code. When testers, sample-sale items, promotional products or gift-with-purchase cosmetics are made available to consumers in Viet Nam, the risk is not the word “tester” itself but incorrect import purpose, missing cosmetic product proclamation number, non-compliant labelling, invalid C/O and inconsistencies among Invoice, Packing List, catalogue, label and proclamation dossier. This article provides an E2E (End-to-End) map for reviewing HS code, duty, C/O, cosmetic proclamation, label and pre-ETA documents.
QUICK FACT
| Item | What to check | Operational conclusion |
|---|---|---|
| Product name | Cosmetic tester, sample sale, promotional item or gift-with-purchase item placed on the market | Do not classify by the word “tester”; classify by function, composition, dosage form, use area and packaging. |
| Regulatory status | Imported cosmetics placed on the market | A valid cosmetic product proclamation receipt number should be available before circulation. |
| Indicative HS | Depending on the tester: 3303, 3304, 3305, 3307 or 3401 for soap/surfactant products | There is no single HS code if the documents only say “Tester”. |
| Indicative tax | Common MFN range: 15%–22%; VAT: 10%; ordinary duty reference: 150% of MFN | Check the tariff schedule on the declaration date. |
| C/O | Special preferential duty may apply if origin rules and the correct form are met | Do not claim preferential duty if description, HS, origin criterion or direct transport is inconsistent. |
| Label | Original label plus Vietnamese sub-label for goods circulated in Viet Nam | “Tester/Not for sale” does not replace proclamation/labelling obligations. |
Legal note: Cosmetics imported for research, testing, exhibition or non-commercial gift/sample purposes must not be automatically redirected to market circulation. If the goods are placed on the market, they should be handled as commercial finished cosmetics with product proclamation, labelling, commercial customs documents, HS classification and duties.
SCOPE OF APPLICATION
This article applies to cosmetic testers imported as finished products or mini/sample units, including counter testers, sample-sale items, promotional items, gift-with-purchase cosmetics and small sets that are made available to Vietnamese consumers.
- Applies when the goods are used in commercial circulation, customer trials, sample sale, promotion or gift-with-purchase activities.
- Does not automatically apply to research samples, testing samples, exhibition samples, internal samples or temporary import–re-export goods.
- Do not group perfume, skincare, makeup, hair care, shaving and deodorant testers under one HS code.
- Review catalogue, datasheet, SKU, INCI, original label, net content, import purpose and distribution method.
CLASSIFICATION & TECHNICAL IDENTIFICATION
Function-based identification Determine whether the tester is perfume, skincare, lipstick, mascara, shampoo, hair serum, shaving cream or deodorant.
Proclamation-based check Compare product name, brand, manufacturer, formula, capacity, use and proclamation number.
Label-based check Review original label, Vietnamese sub-label, tester/sample wording, batch/lot, MFG/EXP and responsible entity.
TECHNICAL IDENTIFICATION CRITERIA
| Technical criterion | Documents to compare | Risk if wrongly described | Suggested declaration wording |
|---|---|---|---|
| Actual cosmetic type | Catalogue, original label, product photos, proclamation | Wrong HS due to generic “cosmetic tester” wording | “Cosmetic tester – [product type], brand…, capacity…, for…” |
| Import purpose | PO/Contract, promotion plan, email confirmation | Declared as sample but actually circulated | State tester/promotion/gift purpose and market circulation clearly |
| Formula/function | INCI list, CFS/LOA, PIF if available | Claims may exceed cosmetic boundary | Do not state therapeutic claims if the product is only cosmetic |
| Net content | Invoice, Packing List, label, carton mark | Mismatch between label and proclamation | Declare unit capacity and number of units clearly |
| Sets/gifts | Packing list, set photos, combo structure | Multiple HS codes declared as one line | Separate items by HS if functions differ |
HS CODE – DUTY – C/O
Mandatory principle: “Tester” is a commercial/marketing status, not the classification basis. HS classification must follow the nature of the product. If the Invoice only says “Tester”, Customs may request catalogue, labels, composition, product photos and cosmetic proclamation documents.
| Indicative HS code | Typical tester type | MFN duty | Ordinary duty reference | VAT | Documents to check |
|---|---|---|---|---|---|
| 3303.00.00 | Perfume/body spray/fragrance mist tester | 18% | 27% | 10% | Fragrance label, use, capacity, SDS if alcohol/flammable |
| 3304.10.00 | Lipstick/lip tint/lip balm makeup tester | 20% | 30% | 10% | Shade, INCI, label, lip product proclamation |
| 3304.20.00 | Eye makeup tester | 22% | 33% | 10% | Eye-area use, colour, formula, warning if any |
| 3304.30.00 | Nail product tester | 22% | 33% | 10% | Solvent composition, SDS, warning label |
| 3304.99.30 | Cream/lotion/skincare tester | 20% | 30% | 10% | Skin-care function, label, formula |
| 3304.99.90 | Other skincare/beauty preparation | 20% | 30% | 10% | Catalogue, use area, claims |
| 3305.10.90 | Ordinary shampoo tester | 15% | 22.5% | 10% | Hair-use label and proclamation |
| 3305.90.00 | Hair serum/mask/styling tester | 20% | 30% | 10% | Hair product function and label |
| 3307.10.00 | Shaving/after-shave tester | 18% | 27% | 10% | Pre/during/after-shave function |
| 3307.20.00 | Deodorant/antiperspirant tester | 20% | 30% | 10% | Deodorant/antiperspirant claims |
Tariff source note: The MFN/VAT rates are used as operational references for common Chapter 33 HS lines on the Vietnam Trade Portal. Before declaration, the importer must re-check the current tariff schedule, applicable FTA and C/O dossier against the final HS code.
Classification warning: If one shipment includes lipstick testers, serum testers, perfume testers and shampoo testers, each product line should be mapped by SKU – HS – proclamation – duty. “Assorted cosmetic testers” is not a safe declaration.
SPECIAL PREFERENTIAL C/O/FTA TABLE TO BE CHECKED BY FINAL HS CODE
| Origin/route | C/O or origin document | Preferential duty to check | Condition | Key risk |
|---|---|---|---|---|
| ASEAN | Form D / ATIGA proof | Many Chapter 33 cosmetic lines may be 0% if eligible | Origin rule, direct transport, matching description and HS | Generic “tester” description may cause refusal |
| China | Form E or ACFTA/RCEP proof | Check by finalized HS; may be lower than MFN | Third-party invoice, transit, description and quantity | Form E box errors or HS mismatch |
| Korea | Form AK/VK or RCEP proof | Depending on HS: 0%–5% or staged rate | Compare AKFTA/VKFTA/RCEP and choose a valid beneficial route | Wrong form or failed origin criterion |
| Japan | Form VJ/AJ, CPTPP or RCEP | Depending on HS; many cosmetic lines have deep reductions | Check product-specific rule and manufacturer | C/O not matching brand/manufacturer/HS |
| EU | EUR.1 or EVFTA origin statement | Check EVFTA schedule by year and HS | REX/statement, direct transport, invoice | Invalid origin statement |
| UK | UKVFTA proof | Check UKVFTA schedule by year and HS | Same logic as EVFTA | Confusing EVFTA and UKVFTA |
| Australia/New Zealand | AANZFTA or CPTPP proof | Many lines may be 0% if eligible | Actual origin and origin criterion | Insufficient origin evidence |
| India | Form AI | Not automatically better than MFN | Check AIFTA by HS | Claiming preference without valid form |
| Hong Kong | AHKFTA proof | Check carefully; may not always be better than MFN | Actual Hong Kong origin | Confusing port of loading with origin |
C/O checklist before claiming preferential duty
- Correct C/O form or origin document for the route.
- Correct origin criterion: WO, PE, RVC, CTH/CTSH or product-specific rule.
- Description, HS, quantity, weight and origin match Invoice, Packing List, B/L/AWB and declaration.
- Issue date, signature/stamp, third-party invoice and direct transport evidence checked.
- No preferential claim before the actual HS of each tester type is finalized.
SPECIALIZED POLICY MATRIX
| Goods scenario | Possible policy | Documents to check | Authority/platform | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Cosmetic testers placed on the market | Cosmetic product proclamation before circulation | Proclamation, LOA, CFS if required, label, ingredients | Public service/NSW or competent health authority system | Before arrival or before distribution | Tester status does not remove proclamation obligation |
| Research/testing samples | Special sample/testing purpose; no market circulation | Sample order, purpose, quantity | Relevant authority by actual case | Before import | Market circulation would breach import purpose |
| Promotional/gift-with-purchase items | Treat as circulated cosmetics if consumers receive/use them | Promotion plan, label, proclamation, commercial docs | Customs + health/market surveillance authorities | Before ETA and promotion launch | May be considered non-compliant circulating goods |
| Alcohol/aerosol testers | DG review for transport | SDS/MSDS, UN number if any, flash point | Carrier/airline/shipping line; IATA/IMDG logic | Before booking | Misdeclared DG can be rejected by carrier |
| Multi-product tester set | Apply policy per item | Detailed packing list, set photo, proclamation per SKU | Customs and specialized authority | Before declaration | Multiple HS/proclamation lines may be required |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document | Issuing authority | Effective timing | Role | Key points | Review note |
|---|---|---|---|---|---|---|
| Circular | Circular 06/2011/TT-BYT on cosmetics management | Ministry of Health | Effective from 01/04/2011 | Basis for cosmetic proclamation, management and labelling | Article 3, Article 18 and special sample/testing provisions | Check current amended version |
| Amending circular | Circular 34/2025/TT-BYT | Ministry of Health | Effective 18/08/2025 | Updates cosmetics management rules | Review changes for dossier submission | Apply at submission time |
| Decree | Decree 43/2017/ND-CP on goods labels | Government | Effective 01/06/2017 | General labelling framework | Mandatory label contents | Read with Decree 111/2021 |
| Amending decree | Decree 111/2021/ND-CP | Government | Effective 15/02/2022 | Updates goods labelling rules | Original label/sub-label/importer responsibility | Check actual artwork |
| Tariff | Decree 26/2023/ND-CP and amendments | Government | Effective from 15/07/2023; later amendments exist | MFN tariff basis | HS and MFN duty | Check on declaration date |
| Origin | Decree 31/2018/ND-CP and Circular 33/2023/TT-BTC | Government/Ministry of Finance | As per each document | Origin and C/O verification | Origin rules, C/O check, preferential claim | Check each FTA |
VIEW / DOWNLOAD OFFICIAL DOCUMENTS
Businesses should cross-check the applicable documents on the official legal document portals or authority websites before applying them.
CUSTOMS DOCUMENT SET
Commercial documents Commercial Invoice, Packing List, B/L or AWB, Contract/PO, C/O if preference is claimed, catalogue, product photos, labels, SKU list.
Cosmetic dossier Cosmetic proclamation receipt number, LOA, CFS if required, INCI composition, label and PIF/product information file for post-market control.
Transport dossier SDS/MSDS for alcohol/aerosol/DG risk, booking, pre-alert, arrival notice and delivery order.
OPERATIONAL DOCUMENT CHECKLIST
| Document group | Required documents | Used for | Prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO | Customs declaration, valuation, quantity | Importer/Exporter/Docs | Generic “tester” without product type/capacity/SKU | Request itemized SKU mapping |
| Transport | B/L/AWB, Arrival Notice, Pre-alert | Cargo release and declaration | Forwarder/Carrier | Wrong consignee or package/weight mismatch | Compare booking – B/L – PL |
| Cosmetic proclamation | Proclamation number, LOA, CFS if any | Market eligibility | Importer/Regulatory | Tester label differs from proclamation | Compare name, brand, manufacturer, function |
| Label | Original label, Vietnamese sub-label, packaging photos | Customs and circulation | Importer/Brand owner | Missing net content, batch, expiry, responsible entity | Check label artwork before shipment |
| C/O | Form D/E/AK/VK/EUR.1… | Preferential duty | Exporter/Importer | HS/description mismatch | Check C/O before declaration |
| DG if any | SDS/MSDS, flash point, UN number if applicable | International booking | Shipper/Forwarder | Alcohol/aerosol declared as ordinary cargo | DG review before booking |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question | Evidence | Consequence if unclear | Recommended action |
|---|---|---|---|---|
| Import purpose | Will the testers be placed on the market? | PO, promotion plan, distribution contract | Wrong regulatory route | Confirm purpose before shipment |
| HS code | What cosmetic type is each tester? | Catalogue, label, photo, proclamation | Wrong duty/C/O/declaration amendment | Separate lines by product type |
| Cosmetic proclamation | Is a matching proclamation available? | Proclamation receipt, LOA, label | Ineligible circulation | Complete proclamation before distribution |
| Label | Does the tester label contain required information? | Original/sub-label | Label correction request | Review before ETA |
| C/O | Does C/O match HS, description and origin? | C/O, Invoice, B/L | Preference denied | Validate form and criterion |
| DG transport | Alcohol/aerosol/flammable? | SDS/MSDS, packing info | Booking rejection or penalty | DG check before booking |
Step 1 – Pre-ETA review Confirm purpose, map SKU, HS, proclamation, label, C/O and DG risk.
Step 2 – Lock documents Standardize Invoice, Packing List, B/L/AWB, catalogue, label photos, SKU list and draft C/O.
Step 3 – Cosmetic dossier Check proclamation number, product name, function, responsible entity and sub-label.
Step 4 – Customs declaration Declare by actual tester type; prepare explanation for HS, value, proclamation, C/O and label.
Step 5 – Clearance and delivery Pay duties, release goods, check quantity and packaging, and segregate SKUs.
Step 6 – Circulation and post-market file Verify labels, retain import documents, proclamation dossier, C/O and promotion records.
E2E OPERATIONAL PROCEDURE
PRE-ETA RISK CHECKLIST
- Risk 1: Goods described only as “Tester” → require product type, function, capacity, brand, SKU and label photos.
- Risk 2: Imported as samples but used commercially → determine import purpose and proclamation route first.
- Risk 3: Multiple tester types declared under one HS → build SKU – HS – proclamation – duty mapping.
- Risk 4: “Not for sale” label while consumers receive/use the product → review promotion/gift-with-purchase compliance and labelling.
- Risk 5: Invalid C/O → check form, origin criterion and description before claiming preference.
- Risk 6: Alcohol/aerosol DG risk not declared → require SDS/MSDS before booking.
FAQ
| Question | Answer |
|---|---|
| Do imported cosmetic testers need proclamation? | If testers are made available to consumers, used at counters, gifted or sold as sample sale, they should be handled as circulating cosmetics and reviewed for proclamation. |
| Is there a specific HS code for testers? | No. HS depends on the actual product type. |
| Does “Not for sale” exempt the product from proclamation? | Not by itself. If consumers access/use the product in commercial activities, proclamation and labelling should be reviewed. |
| Do gift-with-purchase items need Vietnamese sub-label? | If circulated in Viet Nam, goods labelling requirements should be reviewed. |
| Can a multi-tester set be declared in one line? | Not recommended if items have different HS codes or policies. |
| Can C/O reduce import duty? | Yes, if the C/O/origin document, origin criterion, HS and direct transport are valid. |
| Are counter testers considered market circulation? | If consumers can access/use them in commercial settings, prepare the compliance dossier accordingly. |
| Can a full-size proclamation cover a mini tester? | Review name, formula, use, manufacturer, packaging and authority guidance; do not assume automatically. |
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
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