IMPORT PROCEDURE GUIDE FOR FRAGRANCE OIL USED AS A COSMETIC RAW MATERIAL

COSMETICS – RAW MATERIALS – FRAGRANCE

IMPORT PROCEDURE GUIDE FOR FRAGRANCE OIL USED AS A COSMETIC RAW MATERIAL

Fragrance oil is often declared too generally as “fragrance”, “aromatic oil” or “perfume oil”, while HS classification, duty treatment, chemical controls and technical documentation depend on its formulation basis, intended use, SDS, COA, IFRA statement and actual packaging. 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.

If the shipment is incorrectly classified between 3302.90.00, 3301, 3303.00.00, 3307 or food/beverage flavouring under 3302.10, customs may request additional SDS/catalogue documents, change the inspection channel, reject preferential C/O treatment or delay production. This article provides an E2E review map before ETA.

ItemQuick review information
ProductFragrance oil used as a fragrance raw material in cosmetics/personal care; not automatically applicable to finished perfume or food flavouring.
Reference HS3302.90.00 – other mixtures of odoriferous substances used as industrial raw materials.
Reference taxesMFN: 5%; ordinary import duty: 7.5%; VAT: 10%. Preferential FTA duty may be 0% on many routes if origin requirements are met.
Main policyReview according to actual dossier: cosmetic raw material, dangerous chemical/mixture, DG cargo, chemical/product labeling, SDS/COA/IFRA.
WarningReview against SDS, COA, IFRA, CAS/allergen list, labels, intended use and origin route.
Illustration for IMPORT PROCEDURE GUIDE FOR FRAGRANCE OIL USED AS A COSMETIC RAW MATERIAL
Illustration of the product group and document review before customs clearance.

QUICK SUMMARY

Legal note: This article applies only to fragrance oil imported as a cosmetic raw material. Conclusions must be reviewed against SDS, COA, IFRA, CAS/allergen list, labels, intended use and origin route.

SCOPE OF APPLICATION

This article applies to fragrance oil used as a fragrance raw material in cosmetic and personal-care manufacturing, including soap, shower gel, shampoo, lotion, body mist and similar products at production stage.

  • It does not automatically apply to surfactants, emollients, extracts, preservatives, actives or colorants.
  • It does not apply to finished perfume, food flavouring, single natural essential oils or retail products for direct application on skin.
  • New goods, R&D samples, testing samples, gifts, commercial goods and flammable solvent-based goods may trigger different policies.
  • Review must be made according to catalogue, datasheet, raw-material code and actual import purpose.

CLASSIFICATION & PRODUCT IDENTIFICATION

Identification points

  • Mixture of odoriferous substances or alcoholic/solvent solution based on odoriferous substances.
  • Used as an industrial cosmetic raw material, not a retail finished product.
  • Supported by SDS/COA/IFRA, fragrance code, batch number, shelf life and storage conditions.

Items to lock before ordering

  • Actual use: cosmetic, food, candle/room fragrance or other use.
  • Flash point, UN number and DG class if applicable.
  • CAS/allergen list and ratios of controlled components.
CriteriaDocuments to checkRisk if misdescribedSuggested declaration description
Nature of goodsSDS, COA, TDS, IFRA certificate, ingredient declarationConfusion with essential oil or finished perfume“Fragrance oil for cosmetic manufacturing, HS 3302.90.00, code…, new 100%”
Composition/basisCAS list, allergen statement, carrier solvent, flash pointMay trigger chemical declaration, DG or warehouse safety issuesDescribe as “mixture of odoriferous substances”, not only “oil”
Intended usePO, contract, confirmation for cosmetic manufacturingFood/beverage use may shift to 3302.10 and food policy“Raw material for cosmetics/personal care products, not for retail sale”
PackagingPacking list, photos of drums/cans/bottlesWrong quantity, labels or DG handlingState net weight/volume, number of cans/drums and batch/lot
Goods statusInvoice, packing, label, lot COASamples/promotional/retail goods may have different policiesState sample for testing/R&D if applicable

HS CODE – DUTIES – C/O

For fragrance oil used as cosmetic raw material, HS must be determined by the odoriferous mixture nature, not by trade name. The key is to distinguish it from natural essential oils, finished perfume, food flavouring and room-fragrance preparations.

Reference HSApplicabilityRisk of wrong HSDocuments to check
3302.90.00Fragrance oil is a mixture of odoriferous substances used as cosmetic raw material, not a finished retail productConfusion with finished perfume or food flavouringSDS, COA, IFRA, TDS, PO, intended-use declaration, original label
3301.xxSingle or natural essential oils/resinoids not compounded as fragrance oilWrong HS if the item is a compounded fragrance blendGC/MS if available, COA, botanical origin, extraction method
3302.10.xxMixtures used in food or beverage industriesMay trigger food-safety/flavouring requirementsFood spec, intended use, additive/flavouring standard
3303.00.00Finished perfumes and toilet waters packed for usersMay require cosmetic notification before circulationRetail label, claims, packaging, volume, cosmetic notification
3307.xxOther perfumery, cosmetic or toilet preparations, room perfuming preparationsWrong policy if it is a consumer finished product, not raw materialCatalogue, instructions, labels, claims, sales channel
Tax/duty itemReference rateApplicabilityDocuments/legal basis to review
Ordinary import duty7.5%Reference rate when MFN/FTA conditions are not met, based on 150% of MFN.Decision 15/2023/QD-TTg and tariff at declaration date.
MFN import duty5%Applies when the shipment is eligible for MFN treatment.Current MFN tariff; re-check on Vietnam Trade Portal.
Import VAT10%Applies unless another VAT policy is valid at declaration time.Customs declaration, customs value and current VAT schedule.
Special preferential FTA dutyMay be 0% under several FTAsOnly with valid C/O/origin proof meeting origin criteria, direct transport, description and HS requirements.C/O, origin criterion, invoice, packing, B/L/AWB and transport route.
Other taxesNormally no SCT for fragrance oil raw materialRe-check if actual goods are alcoholic beverages, retail perfume or special goods.Catalogue, import purpose, label, SDS.

SPECIAL PREFERENTIAL C/O & FTA

Even though the MFN rate is not very high, C/O should still be checked to optimize duty and standardize origin documents. Do not use preferential C/O if description, HS or origin criteria are not adequately supported.

Origin routeC/O form or origin proofPossible preferential dutyConditionsDocuments to check
ASEAN / ATIGAForm DMay be 0% if ASEAN origin rules are metCTH/CTSH/RVC according to PSR; direct transportForm D, invoice, packing list, B/L, HS 3302.90.00 description
China / ACFTA or RCEPForm E or RCEP C/OMay qualify for special preferential duty, often 0% depending on scheduleOrigin criterion, third-party invoice, route controlForm E/RCEP, third-party invoice if any, transport documents
Korea / AKFTA, VKFTA, RCEPForm AK/VK or RCEP C/OMay enjoy preferential duty if Korean origin is validRVC/CTH under PSR; description must match fragrance oilC/O, COA, SDS, invoice, packing list
Japan / VJEPA, AJCEP, CPTPP, RCEPForm VJ/AJ, CPTPP origin declaration or RCEP C/OMay enjoy preferential duty; choose the optimal agreement by dossierOrigin criterion and self-certification rules where applicableOrigin proof, B/L, invoice, transport route
EU / EVFTAEUR.1 or valid origin declarationMay enjoy EVFTA preference if origin requirements are metExporter authorization/REX review where relevantEUR.1/origin declaration, invoice, goods description
UK / UKVFTAOrigin declaration or compliant C/OMay enjoy preferential treatment if UK origin is validHS, description, value and issuer must matchOrigin declaration, invoice, B/L
Australia – New Zealand / AANZFTA or CPTPPForm AANZ or CPTPP origin declarationMay enjoy preferential duty if origin is provenDo not confuse export country with origin countryC/O, invoice, transport route, packing list
India / AIFTAForm AIMay enjoy preference if PSR is metRisk of wrong origin criterion or descriptionForm AI, invoice, packing list, B/L
Hong Kong / AHKFTAForm AHKMay enjoy preference if AHKFTA rules are metActual origin must be clear, not only transshipment portForm AHK, transport documents, invoice
C/O checkpointRequirementRisk if incorrectPre-ETA control
C/O form or origin proofCorrect agreement, form or valid origin declarationPreference may be rejectedCheck before customs declaration
HS and goods descriptionMatch the declaration or have a valid HS conversion basis; description must reflect fragrance oilCustoms may question HS or product natureCompare HS 3302.90.00 with invoice, packing list and SDS
Origin criterionWO, CTH/CTSH, RVC or other PSR criterionOrigin rule may not be satisfiedAsk supplier to confirm PSR in advance
Third-party invoicingThird-party invoicing must be declared if applicableC/O may be questioned due to seller/shipper/manufacturer mismatchCompare contract, invoice and C/O
Direct transportB/L/AWB, transit documents, non-manipulation proof if requiredPreference may be denied due to unclear transit routeLock route before ETD/ETA
Issue date and validityC/O must be issued within the allowed period; retrospective issuance must be properly indicatedAdditional explanation may be requestedCheck vessel departure, invoice date and C/O date

APPLICABLE SPECIALIZED POLICIES

Goods scenarioPossible policyDocuments to checkAuthority/portalRecommended timingRisk note
Fragrance oil imported as a cosmetic raw materialNot treated as a finished cosmetic retail product; technical raw-material files must be retained for finished-product PIFSDS, COA, IFRA, allergen list, INCI/fragrance declarationCustoms; factory QA/R&DBefore ETD and ETAA cosmetic product notification is not automatically required if the raw material is not circulated as a finished product, but intended use must be clear.
Fragrance oil in retail packaging or directly used on the bodyMay be considered finished perfume/cosmetic; cosmetic notification and cosmetic labeling may be requiredLabel, claims, function, retail packaging, formula, LOA/CFS if notification is requiredCosmetic authority / Department of Health according to dossierBefore market circulationDo not apply raw-material logic if the goods are consumer finished products.
Flavouring for food or beverage useMay shift to food-safety/flavouring policy and HS 3302.10Food specification, standards, intended use, COAFood-safety competent authorityBefore orderingThis article must not be used as a final conclusion for food flavouring.
Mixture with flammable solvent / DG cargoIMDG/IATA, SDS, hazard labels and suitable warehouse handling may applySDS, UN number, class, flash point, packing groupCarrier/airline, warehouse, port, customsBefore bookingMissing DG data may cause booking rejection or transport mode change.
Contains controlled chemical, precursor or hazardous chemical componentsReview Decree 26/2026/ND-CP and relevant lists; declaration/control/safety conditions may ariseCAS list, ratio, English/Vietnamese SDS, intended useNational Single Window or chemical database if applicableBefore customs declarationDo not conclude “no chemical declaration” without CAS and concentration data.
Samples, R&D or testing goodsPolicy may differ from commercial shipments; purpose and quantity must be clearly statedProforma invoice, packing list, sample confirmation letter, SDS, COACustoms; R&D/QA teamBefore ETASamples imported for testing/R&D must not be automatically circulated commercially.

LEGAL DOCUMENTS TO REVIEW

Document groupDocument name/numberIssuing authorityEffective/application timeRole in procedureNotable article/appendixReview note
TariffDecree 26/2023/ND-CP and Decision 15/2023/QD-TTgGovernment / Prime MinisterDecision 15/2023 effective from 15 July 2023Basis for MFN and ordinary import duty reviewHS 3302.90.00 in Chapter 33; ordinary duty generally follows the 150% MFN rule unless separately listedRe-check at customs declaration date.
ChemicalsDecree 26/2026/ND-CPGovernmentEffective 17 January 2026Regulates chemical activities and hazardous chemicals in products/goodsReview declaration/control obligations by component, CAS number, concentration and applicable lists; do not conclude based only on the commercial name “fragrance oil”Use Decree 26/2026/ND-CP as the current primary basis; cite Decree 113/2017/ND-CP and Decree 82/2022/ND-CP only when reviewing old dossiers or transitional periods.
CosmeticsCircular 06/2011/TT-BYT and Circular 34/2025/TT-BYTMinistry of HealthCircular 34/2025 effective 18 August 2025Basis for cosmetics management, notification, PIF, labeling and claimsApplicable when the goods are finished cosmetics or when raw-material data support finished cosmetic dossiersFor fragrance oil raw material, IFRA/INCI/SDS data should be retained for quality files.
Goods labelingDecree 43/2017/ND-CP and Decree 111/2021/ND-CPGovernmentDecree 111/2021 effective 15 February 2022Basis for import labels, supplementary labels and mandatory informationProduct name, origin, responsible entity, quantity and warnings if anyFor chemical/DG goods, hazard labeling under SDS must be reviewed separately.
Foreign trade and customsLaw on Foreign Trade Management 2017; Customs Law; applicable customs decreesNational Assembly / GovernmentReview effective status at time of importGeneral framework for import and customs proceduresHS, customs value, origin and specialized policyDo not invent articles; review against actual dossier.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises should additionally verify documents on the official legal document portal or the issuing authority’s website before application.

CUSTOMS CLEARANCE DOCUMENT SET

Commercial documents

Technical/specialized documents

  • Complete SDS with flash point and GHS classification
  • COA by batch/lot
  • IFRA statement and allergen list
  • Original label/packaging photos
  • Declaration of import purpose as raw material

OPERATIONAL DOSSIER CHECKLIST

Dossier groupRequired documentsUsed forPrepared byCommon errorsPre-ETA check
Commercial dossierCommercial Invoice, Packing List, B/L or AWB, Sales Contract/POCustoms declaration, value, quantity and partiesImporter / Docs / ProcurementGeneric product name such as “oil” or “fragrance” is insufficientCompare goods description with SDS/COA/IFRA before ETA
Raw-material technical dossierSDS, COA, TDS, IFRA certificate, allergen list, INCI/fragrance declarationHS classification, physical inspection, DG review and QA/R&D recordSupplier / QA / R&DMissing flash point, CAS, batch number or shelf lifeRequest lot-specific documents before booking
Origin dossierC/O Form D/E/AK/VK/VJ/AJ/EUR.1/UKVFTA/AANZ/AI/AHK/RCEP/CPTPP declarationClaim special preferential import dutySupplier / Exporter / DocsWrong form, HS, description or missing third-party invoice indicationCompare C/O with invoice, packing list and B/L/AWB
Label and safety dossierOriginal label, planned supplementary label, hazard pictogram if any, storage instructionsLabel review, DG handling, warehouse and post-clearance auditImporter / QA / WarehouseOrigin, batch, warning or storage condition not shownObtain label photos before shipment leaves origin
Intended-use dossierConfirmation letter for cosmetic raw material use, R&D/sample purpose if applicableClarify that goods are not finished retail products or food flavouringImporter / R&D / ProductionCustoms asks for explanation due to sensitive goods namePrepare before ETA, especially first shipments or samples

KEY DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision pointQuestion to answerEvidenceConsequence if unclearRecommended action
Is HS sufficiently supported?Is it a mixture of odoriferous substances for raw-material use, or an essential oil/finished perfume?SDS, COA, IFRA, TDS, labelHS consultation or channel changeStandardize goods description and technical dossier before declaration
Is it subject to chemical control?Do CAS/concentrations fall under controlled lists, precursors or DG classification?SDS, CAS list, GHS classificationChemical declaration/explanation may be requestedReview under Decree 26/2026/ND-CP, SDS, CAS list and updated applicable lists
Is C/O valid for preference?Are form, origin criterion, description, HS and route correct?C/O, invoice, B/L, packing listNo preference, tax adjustmentCheck C/O before customs transmission
Are label and safety data sufficient?Does the original label show name, origin, batch, warning/storage data?Label photos, SDS, packing listSupplementary label or DG clarification may be requestedObtain label photos and SDS before booking
Is the import purpose clear?Raw material, R&D sample or retail finished product?PO, intended-use letter, catalogueWrong specialized policyAvoid generic names; state intended use clearly

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review: finalize HS, SDS/IFRA/COA, taxes, C/O, labeling and DG status.
Step 2: Lock documents: Invoice, Packing List, B/L/AWB, PO, description, batch, origin and quantity.
Step 3: Review chemical/DG/cosmetic policies: CAS, GHS, flash point, intended use and raw-material versus finished-product status.
Step 4: Declare customs: prepare explanations on HS, value, origin, intended use and technical documents for yellow/red channel.
Step 5: Clearance and record retention: label if required, retain SDS/COA/IFRA/C/O by lot and hand over to QA/R&D for finished-product PIF.

PRE-ETA RISK CHECKLIST

RiskConsequencePre-ETA controlDocuments to check
Overly generic product name: “fragrance oil/perfume oil”Wrong HS, SDS/IFRA request and clearance delayUse “mixture of odoriferous substances for cosmetic manufacturing”SDS, COA, IFRA, TDS
Missing SDS or SDS without flash point/DG dataBooking rejection, transport mode change or additional costRequest updated SDS with GHS, flash point and UN data if anySDS/MSDS, IMO/IATA declaration if DG
C/O with wrong HS or descriptionPreference rejected; MFN/ordinary duty payablePre-check C/O before ETAC/O, invoice, packing list, B/L
Confusing cosmetic raw material with finished cosmeticMissing cosmetic notification or wrong policyDetermine packaging, claims, sales channel and intended useLabel, catalogue, PO, intended-use declaration
No CAS/component control reviewChemical/DG/warehouse requirements may arise unexpectedlyRequest CAS/allergen/IFRA and review Decree 26/2026/ND-CP based on actual compositionCAS list, SDS, IFRA, COA

FAQ – COMMON BUSINESS QUESTIONS

Does fragrance oil require cosmetic product notification?

If imported as a raw material for cosmetic manufacturing, it is not automatically treated as a finished cosmetic for circulation. If it is packaged/claimed for direct body use or retail sale, review cosmetic notification requirements.

What is the reference HS code for fragrance oil?

For mixtures of odoriferous substances used as cosmetic raw materials, the common review direction is 3302.90.00. Separate it from natural essential oils under 3301, finished perfume under 3303 and food flavouring under 3302.10.

What are the reference import taxes?

For 3302.90.00, this file uses reference rates: MFN 5%, ordinary duty 7.5%, VAT 10%. Re-check the tariff on the customs declaration date.

Can C/O reduce duty?

Yes. Many FTAs may reduce the special preferential duty to 0%, but only if valid origin proof, origin rules and direct transport requirements are satisfied.

Is chemical import declaration required?

Do not conclude without CAS and concentration data. Review Decree 26/2026/ND-CP, SDS, controlled chemical lists, GHS classification and DG status for each product.

Is COA enough without SDS/IFRA?

High risk. COA confirms lot quality parameters; SDS supports safety, transport and chemical review; IFRA/allergen data supports cosmetic quality files and finished-product PIF.

Are samples handled the same as commercial goods?

Not automatically. Samples should show testing/R&D purpose, reasonable quantity, value and no automatic commercial circulation.

IMPLEMENTATION SUPPORT FROM TGIMEX

This article provides the HS, tax, document and compliance map for fragrance oil. For actual shipments, documents must still be checked against SDS, COA, IFRA, CAS/allergen list, commercial documents, origin and intended use.

Pre-ETA review

HS, duty, C/O, labels, SDS/IFRA/COA, DG and technical documents.

Compliance control

Cross-check Invoice, Packing List, B/L/AWB, C/O, SDS, COA, IFRA, labels and technical documents.

Freight & customs

Coordinate agents, carriers/airlines, DG review, ETA tracking, customs declaration and channel handling.

Post-clearance file

Keep lot-based records and transfer QA/R&D documents for finished cosmetic PIF.

For fragrance oil with possible chemical, DG, C/O or labeling issues, businesses should not wait until arrival to review the dossier. A minor mismatch among Invoice, Packing List, SDS, COA, IFRA, C/O or label may lead to additional document requests, clearance delay or unplanned storage costs.

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