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IMPORT PROCEDURE FOR SURFACTANT
This guide applies to surfactants imported as raw materials for cosmetics or personal care manufacturing. Before ETA, the importer should lock the INCI/CAS, SDS, TDS, active matter, HS code, duties, C/O, label information and chemical-control status to avoid HS disputes, document supplementation and storage charges. For the product covered in this article, the importer should confirm the model, intended use, construction or composition, new/used condition, and technical documents before concluding the HS code, tax treatment, or specialist policy. The following sections organize the main controls from document receipt, catalogue and label review through dossier preparation, declaration, and coordination at the port of entry.
QUICK FACT TABLE
| ITEM | REVIEW POINT |
|---|---|
| Product | Surfactant used in cleanser, shampoo, shower gel, body wash, toothpaste or personal care formulas. |
| Reference HS | Main heading: 3402. Codes to review include 3402.11.10, 3402.11.90, 3402.12.00, 3402.13.00, 3402.19.00, 3402.90.13, 3402.90.90. |
| Reference MFN duty | 8% for 3402.11.10; 10% for certain preparations such as 3402.90.13. Verify the exact 8-digit HS at declaration date. |
| VAT | Reference data shows 10% for 3402.11.10. Any 8% VAT reduction must be checked against Decree 174/2025/ND-CP and exclusion appendices. |
| Key policy | Not automatically treated as a finished cosmetic product. Check whether the goods are raw materials, hazardous chemicals, R&D samples, retail cosmetic products or skin-cleansing preparations. |
| Sensitive documents | SDS/MSDS, TDS, COA, composition, INCI/CAS, active matter, pH, physical state, original label, origin documents. |
SCOPE OF APPLICATION
This guide applies only to surfactant within the cosmetic raw material group. It does not automatically apply to emollients, extracts, fragrance oils, preservatives, actives or colorants, as each group may have a different HS classification and regulatory trigger.
- Bulk liquid, paste, powder, flake or blended surfactant.
- Imported for cosmetic/personal care manufacturing, R&D, testing, EPE/FDI or factory use.
- Finished retail cleanser/shampoo products must be reviewed separately as finished cosmetics.
- Samples, R&D goods, warranty/returned goods and retail packs may trigger different treatment.
Review must be based on catalogue, datasheet, CAS, INCI and actual import purpose.
CLASSIFICATION & TECHNICAL IDENTIFICATION
Technical identification
- Type: anionic, cationic, non-ionic, amphoteric or blend.
- INCI/CAS: e.g. Sodium Laureth Sulfate, Cocamidopropyl Betaine, Decyl Glucoside.
- Active matter and composition: surfactant content, solvent, water, salt.
- Form: liquid, paste, flake, powder or concentrated solution.
- Use: cleansing, foaming, emulsifying or solubilising in personal care formulas.
Naming risk
Generic descriptions such as “chemical”, “surfactant” or “cosmetic raw material” may not be sufficient for HS, C/O or chemical-policy review. The description should reflect chemical nature, surfactant type, physical form and intended use.
| Criterion | Document to review | Risk if wrong | Suggested customs/commercial description |
|---|---|---|---|
| INCI/CAS and trade name | SDS/MSDS, TDS, COA, specification | Unable to distinguish substance from mixture; wrong chemical policy | Surfactant raw material – Sodium Laureth Sulfate solution, CAS…, for cosmetic manufacturing |
| Surfactant type | TDS, formula, catalogue | Wrong HS branch: anionic/cationic/non-ionic/other | Anionic/non-ionic/amphoteric surfactant, liquid/paste/powder |
| Active matter and solvent | COA, specification, SDS | Incorrect treatment if diluted solution or blend | Surfactant preparation, active matter …%, in aqueous solution |
| Import purpose | PO, contract, production process | Confusion with industrial detergent or finished cosmetic | Raw material for manufacturing cosmetic/personal care products |
| Retail or bulk | Packing list, label photos, catalogue | Retail skin products may trigger finished cosmetic notification | Bulk raw material, not for direct retail use |
HS CODE – DUTY – C/O
HS principle: surfactant should not be fixed under one code without INCI/CAS, SDS, TDS, COA, active matter, physical form and import purpose. Separate single organic surface-active agents from blended preparations or washing/cleaning preparations.
| Technical scenario | Reference HS | Classification description | When to review | Documents to cross-check |
|---|---|---|---|---|
| Anionic surfactant – sulphated fatty alcohols | 3402.11.10 | Anionic organic surface-active agent, sulphated fatty alcohols. | Possible for SLS/SLES-type materials if SDS/TDS supports the chemistry. | SDS, CAS, INCI, active matter, TDS, COA. |
| Other anionic surfactant | 3402.11.90 | Other anionic organic surface-active agents. | When the product is anionic but not sulphated fatty alcohols. | SDS/TDS, chemical name, CAS, active content. |
| Cationic surfactant | 3402.12.00 | Cationic organic surface-active agents. | Conditioning or surface-modifying raw materials with cationic nature. | SDS, CAS, function, COA. |
| Non-ionic surfactant | 3402.13.90 | Other non-ionic organic surface-active agents. | Glucoside, ethoxylated or other non-ionic surfactants. | INCI/CAS, TDS and composition. |
| Amphoteric/other surfactant | 3402.19.90 | Other organic surface-active agents. | Betaine/amphoteric or other charge-type products. | SDS, CAS, charge type, pH, active matter. |
| Anionic washing/cleaning preparation | 3402.90.13 | Anionic washing or cleaning preparations, including bleaching, cleansing or degreasing preparations. | Only where the product is a preparation/mixture with a clear cleaning function. | Formula, SDS, label, catalogue and import purpose. |
| Retail skin cleansing product | 3401.30.00 | Organic surface-active products for washing the skin, liquid/cream, retail packed. | Retail cleanser/body wash/shower gel, not bulk raw material. | Retail label, claims, packing and cosmetic notification review. |
| Reference HS | Use case | MFN duty | Ordinary duty reference | Import VAT | Operational note |
|---|---|---|---|---|---|
| 3402.11.10 | Sulphated fatty alcohols / relevant anionic surfactant | 8% | 12% if no separate ordinary rate applies and 150% of MFN is used | 10% | Vietnam Trade Portal shows MFN 8% and VAT 10%. Check measures for specific CAS/chemical restrictions. |
| 3402.90.13 | Anionic washing/cleaning preparation | 10% | 15% if no separate ordinary rate applies and 150% of MFN is used | 10% | Do not use this code for every single surfactant raw material. |
| 3402.11.90 / 3402.12.00 / 3402.13.90 / 3402.19.90 | Other anionic, cationic, non-ionic or amphoteric surfactants | Check the official tariff by 8-digit code at declaration date | Do not calculate before MFN is confirmed | Cross-check by current tariff | Use where SDS/TDS does not support 3402.11.10 or 3402.90.13. |
| Origin route | C/O or origin document | Special preferential duty review for HS 34.02 | Conditions | Common risk |
|---|---|---|---|---|
| ASEAN | Form D / ATIGA origin document | ATIGA is often 0% for many HS 3402 lines, subject to exact 8-digit code and year. | ASEAN origin, origin criteria and direct consignment. | Generic description or HS mismatch. |
| China | Form E / RCEP | ACFTA may reach 0% for many HS 3402 lines; compare with RCEP by year and route. | CTH/RVC/PSR, third-party invoice and transport route. | Form E discrepancy, HS mismatch or weak description. |
| Korea | Form AK / VK / RCEP | AKFTA/VKFTA may be 0% for many HS 3402 lines; compare agreement by actual HS. | Origin criteria, manufacturer, third-party invoice, direct transport. | Wrong form or origin criterion. |
| Japan | AJ/VJ/CPTPP/RCEP | Many surfactant lines may reach 0% under AJCEP/VJEPA/CPTPP after staging. | PSR, chemical description and direct transport. | Using a less suitable agreement. |
| EU | EUR.1 / EVFTA statement | EVFTA must be checked by HS and year; older references for 3402.90.13 showed about 6.2%, requiring 2026 update. | Qualified exporter/origin statement and matching HS. | Invalid origin statement or exporter status. |
| UK | UKVFTA origin document | Check the UKVFTA schedule separately; do not use EU documents for UK origin. | Valid UK origin and origin statement. | EU/UK document confusion. |
| Australia/New Zealand | AANZFTA / CPTPP / RCEP | AANZFTA/CPTPP may be 0% for many HS 3402 lines; compare against RCEP. | Correct form/origin evidence and PSR. | Wrong agreement or missing direct transport proof. |
| India | Form AI | Older AIFTA schedules show several HS 3402.11/3402.12/3402.13 lines at 0%; some other lines may still remain around 5%. | AIFTA origin criteria and consistent goods description. | Wrong CTH/RVC or generic “chemical” description. |
| No preferential C/O | Not applicable | MFN applies if MFN conditions are met; otherwise ordinary duty may be considered. | Commercial origin evidence must be consistent. | Wrong landed-cost estimate if expected C/O is rejected. |
C/O pre-ETA checklist
- Correct C/O form or origin document for the chosen FTA.
- Origin criterion clearly shown: WO, RVC, CTH, CTSH or PSR-specific rule.
- HS on C/O matches the declaration or is explainable if the exporting country uses a different HS version.
- Description should not only state “chemical”; it should reflect surfactant type, CAS/INCI or key trade name.
- Check third-party invoice, direct consignment, quantity, weight, issue date, stamp/signature and validity.
APPLICABLE SPECIALIZED POLICIES
| Scenario | Possible policy | Documents | Authority/portal | Timing | Risk note |
|---|---|---|---|---|---|
| Bulk surfactant as raw material | Customs clearance, goods label review, chemical policy check if triggered. | Invoice, PL, B/L/AWB, SDS, TDS, COA, label. | Customs; National Single Window if specialized procedure applies. | 5–7 days before ETA. | Not automatically a finished cosmetic notification case. |
| CAS/substance under chemical control | Possible chemical declaration/control under current chemical regulations. | CAS, SDS in Vietnamese if needed, GHS classification. | National Single Window / Ministry of Industry and Trade. | Before declaration if applicable. | Decree 26/2026/ND-CP should be checked for current imports. |
| Retail pack with direct cosmetic use | Possible finished cosmetic notification. | Label, claims, instruction, composition. | Drug Administration / Health authority depending on case. | Before commercial import. | Raw material scope may not apply. |
| DG/hazardous goods | Dangerous goods transport, GHS labels, SDS, UN number. | SDS sections 2 and 14. | Carrier, airline/shipping line, warehouse/port. | Before booking. | Booking may be rejected if DG is not declared. |
LEGAL DOCUMENTS TO REVIEW
| Group | Document | Issuer | Effective date/status | Role | Key review point | Note |
|---|---|---|---|---|---|---|
| Law | Customs Law 2014; Import/Export Duty Law 2016; Foreign Trade Management Law 2017 | National Assembly | Check current amendments | Customs, duty and import management. | Shipment-specific review. | Do not quote provisions without file review. |
| Decree | 26/2026/ND-CP | Government | Effective 17 Jan 2026 | Chemical activity and hazardous chemical management. | Chemical import declaration and safety documentation. | Priority current basis for post-effective-date imports. |
| Decree | 24/2026/ND-CP | Government | Effective 17 Jan 2026 | Lists of chemicals under the Chemical Law. | CAS and controlled chemical lists. | Check each CAS. |
| Decree | 25/2026/ND-CP | Government | Effective 17 Jan 2026 | Chemical safety/security, storage and incident response. | Warehouse, training, emergency measures. | Applies by scale and hazard. |
| Circular | 34/2025/TT-BYT amending 06/2011/TT-BYT | Ministry of Health | Effective 18 Aug 2025 | Cosmetic management if goods become finished cosmetic products. | Cosmetic notification scope. | Bulk raw materials are different from finished cosmetics. |
| Tariff/VAT | 108/2025/ND-CP; 174/2025/ND-CP | Government | 2025–2026 depending on document | MFN tariff and VAT reduction policy. | Check HS and VAT exclusions at declaration date. | Do not automatically apply 8% VAT. |
VIEW / DOWNLOAD SOURCE DOCUMENTS
Enterprises should cross-check the legal document number on the official legal database or the issuing authority website before application.
CUSTOMS DOCUMENT SET
Commercial set
- Commercial Invoice.
- Packing List.
- Bill of Lading/Air Waybill.
- Contract/PO if any.
- C/O for preferential duty.
- SDS/MSDS, TDS, COA, specification.
- Original label, lot/batch information if needed.
Specialized documents if triggered
- Chemical declaration file if applicable.
- Vietnamese SDS/GHS label if hazardous.
- Evidence that the goods are raw materials, not finished cosmetics.
- Cosmetic notification if classified as finished cosmetic product.
- DG and warehouse safety documents if needed.
| Document group | Required documents | Used for | Prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, PL, B/L/AWB, contract/PO | Customs declaration and valuation | Supplier, importer, forwarder | Generic product name | Match all documents and label. |
| Technical | SDS, TDS, COA, INCI/CAS | HS, policy, DG, chemical safety | Supplier, QA/R&D, compliance | No CAS or active matter | Request before booking. |
| Origin | C/O, direct transport proof | Preferential duty | Supplier/importer/forwarder | Wrong form/HS/description | Check draft C/O. |
| Label | Original label, auxiliary label draft, GHS warning if any | Market circulation/storage | Importer, QA, compliance | Missing origin/safety warning | Check against label and SDS rules. |
KEY CLEARANCE DECISION POINTS
| Decision point | Question | Evidence | Consequence if unclear | Recommended handling |
|---|---|---|---|---|
| HS code | Substance, blend or preparation? | SDS, TDS, COA, CAS | HS challenge and duty adjustment | Classify before ETA. |
| Chemical control | Is the CAS under a controlled list? | SDS, CAS list, Decree 24/2026, Decree 26/2026 | Missing specialized document | Review all CAS components. |
| Cosmetic/raw material | Is it for direct retail cosmetic use? | Label, packing, claims, PO | Cosmetic notification may be requested | State raw material purpose clearly. |
| C/O | Is the C/O form/HS/origin criterion correct? | Draft C/O, invoice, B/L | Loss of preferential duty | Check before ETA. |
| DG/hazard | UN number/packing group/flash point? | SDS section 14 | Booking rejection or extra charges | Check before booking. |
END-TO-END OPERATING PROCESS
- Pre-ETA review: HS, chemical policy, VAT, C/O, label, SDS and DG.
- Document lock: invoice, PL, B/L/AWB, SDS, TDS, COA, INCI/CAS, active matter and label.
- Specialized procedure if triggered: chemical declaration, Vietnamese SDS, finished cosmetic notification review.
- Customs declaration: manage green/yellow/red channels and explain HS, valuation, C/O and policy.
- Clearance and delivery: D/O, customs clearance, warehouse safety and inland delivery.
- Post-clearance file: keep C/O, SDS, labels, technical file and production-use records.
PRE-ETA RISK CHECKLIST
| Risk | Impact | Prevention | Documents |
|---|---|---|---|
| No SDS/TDS/COA | Insufficient HS and policy basis | Request technical file before booking | SDS, TDS, COA |
| Generic name | Wrong HS and policy | Use technical description | Invoice, PL, TDS |
| No CAS review | Missing chemical procedure | Prepare CAS table | SDS, composition |
| Wrong C/O | Preference rejected | Check draft C/O | C/O, invoice, B/L |
| Raw material vs finished cosmetic unclear | Missing cosmetic notification if applicable | Confirm packaging and use | Label, packing, PO |
| No DG check | Booking delay or rejection | Check SDS section 14 | SDS, UN number |
FAQ
| Question | Answer |
|---|---|
| Does surfactant require cosmetic product notification? | Bulk raw material is not automatically a finished cosmetic product. Retail packs or direct-use cosmetic claims must be reviewed separately. |
| Is HS always 3402.11.10? | No. It depends on anionic/cationic/non-ionic/amphoteric type and whether it is a substance or preparation. |
| Is chemical declaration required? | It depends on CAS, HS chapter, SDS, controlled lists and import purpose under current chemical regulations. |
| Can C/O reduce duty? | Yes, if the origin document is valid and matches HS, description, origin criterion and transport conditions. |
| VAT 8% or 10%? | Reference data shows 10%; any reduction must be checked against Decree 174/2025/ND-CP and exclusions. |
| Are R&D samples treated the same as commercial goods? | They still require correct HS, value, purpose and technical documents; treatment may differ by purpose and quantity. |
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.
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