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.

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.

QUICK SUMMARY

Item Quick review information
Product Fragrance oil used as a fragrance raw material in cosmetics/personal care; not automatically applicable to finished perfume or food flavouring.
Reference HS 3302.90.00 – other mixtures of odoriferous substances used as industrial raw materials.
Reference taxes MFN: 5%; ordinary import duty: 7.5%; VAT: 10%. Preferential FTA duty may be 0% on many routes if origin requirements are met.
Main policy Review according to actual dossier: cosmetic raw material, dangerous chemical/mixture, DG cargo, chemical/product labeling, SDS/COA/IFRA.
Warning Review against SDS, COA, IFRA, CAS/allergen list, labels, intended use and origin route.
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.
Criteria Documents to check Risk if misdescribed Suggested declaration description
Nature of goods SDS, COA, TDS, IFRA certificate, ingredient declaration Confusion with essential oil or finished perfume “Fragrance oil for cosmetic manufacturing, HS 3302.90.00, code…, new 100%”
Composition/basis CAS list, allergen statement, carrier solvent, flash point May trigger chemical declaration, DG or warehouse safety issues Describe as “mixture of odoriferous substances”, not only “oil”
Intended use PO, contract, confirmation for cosmetic manufacturing Food/beverage use may shift to 3302.10 and food policy “Raw material for cosmetics/personal care products, not for retail sale”
Packaging Packing list, photos of drums/cans/bottles Wrong quantity, labels or DG handling State net weight/volume, number of cans/drums and batch/lot
Goods status Invoice, packing, label, lot COA Samples/promotional/retail goods may have different policies State 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 HS Applicability Risk of wrong HS Documents to check
3302.90.00 Fragrance oil is a mixture of odoriferous substances used as cosmetic raw material, not a finished retail product Confusion with finished perfume or food flavouring SDS, COA, IFRA, TDS, PO, intended-use declaration, original label
3301.xx Single or natural essential oils/resinoids not compounded as fragrance oil Wrong HS if the item is a compounded fragrance blend GC/MS if available, COA, botanical origin, extraction method
3302.10.xx Mixtures used in food or beverage industries May trigger food-safety/flavouring requirements Food spec, intended use, additive/flavouring standard
3303.00.00 Finished perfumes and toilet waters packed for users May require cosmetic notification before circulation Retail label, claims, packaging, volume, cosmetic notification
3307.xx Other perfumery, cosmetic or toilet preparations, room perfuming preparations Wrong policy if it is a consumer finished product, not raw material Catalogue, instructions, labels, claims, sales channel
Tax/duty item Reference rate Applicability Documents/legal basis to review
Ordinary import duty 7.5% 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 duty 5% Applies when the shipment is eligible for MFN treatment. Current MFN tariff; re-check on Vietnam Trade Portal.
Import VAT 10% Applies unless another VAT policy is valid at declaration time. Customs declaration, customs value and current VAT schedule.
Special preferential FTA duty May be 0% under several FTAs Only 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 taxes Normally no SCT for fragrance oil raw material Re-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 route C/O form or origin proof Possible preferential duty Conditions Documents to check
ASEAN / ATIGA Form D May be 0% if ASEAN origin rules are met CTH/CTSH/RVC according to PSR; direct transport Form D, invoice, packing list, B/L, HS 3302.90.00 description
China / ACFTA or RCEP Form E or RCEP C/O May qualify for special preferential duty, often 0% depending on schedule Origin criterion, third-party invoice, route control Form E/RCEP, third-party invoice if any, transport documents
Korea / AKFTA, VKFTA, RCEP Form AK/VK or RCEP C/O May enjoy preferential duty if Korean origin is valid RVC/CTH under PSR; description must match fragrance oil C/O, COA, SDS, invoice, packing list
Japan / VJEPA, AJCEP, CPTPP, RCEP Form VJ/AJ, CPTPP origin declaration or RCEP C/O May enjoy preferential duty; choose the optimal agreement by dossier Origin criterion and self-certification rules where applicable Origin proof, B/L, invoice, transport route
EU / EVFTA EUR.1 or valid origin declaration May enjoy EVFTA preference if origin requirements are met Exporter authorization/REX review where relevant EUR.1/origin declaration, invoice, goods description
UK / UKVFTA Origin declaration or compliant C/O May enjoy preferential treatment if UK origin is valid HS, description, value and issuer must match Origin declaration, invoice, B/L
Australia – New Zealand / AANZFTA or CPTPP Form AANZ or CPTPP origin declaration May enjoy preferential duty if origin is proven Do not confuse export country with origin country C/O, invoice, transport route, packing list
India / AIFTA Form AI May enjoy preference if PSR is met Risk of wrong origin criterion or description Form AI, invoice, packing list, B/L
Hong Kong / AHKFTA Form AHK May enjoy preference if AHKFTA rules are met Actual origin must be clear, not only transshipment port Form AHK, transport documents, invoice
C/O checkpoint Requirement Risk if incorrect Pre-ETA control
C/O form or origin proof Correct agreement, form or valid origin declaration Preference may be rejected Check before customs declaration
HS and goods description Match the declaration or have a valid HS conversion basis; description must reflect fragrance oil Customs may question HS or product nature Compare HS 3302.90.00 with invoice, packing list and SDS
Origin criterion WO, CTH/CTSH, RVC or other PSR criterion Origin rule may not be satisfied Ask supplier to confirm PSR in advance
Third-party invoicing Third-party invoicing must be declared if applicable C/O may be questioned due to seller/shipper/manufacturer mismatch Compare contract, invoice and C/O
Direct transport B/L/AWB, transit documents, non-manipulation proof if required Preference may be denied due to unclear transit route Lock route before ETD/ETA
Issue date and validity C/O must be issued within the allowed period; retrospective issuance must be properly indicated Additional explanation may be requested Check vessel departure, invoice date and C/O date

APPLICABLE SPECIALIZED POLICIES

Goods scenario Possible policy Documents to check Authority/portal Recommended timing Risk note
Fragrance oil imported as a cosmetic raw material Not treated as a finished cosmetic retail product; technical raw-material files must be retained for finished-product PIF SDS, COA, IFRA, allergen list, INCI/fragrance declaration Customs; factory QA/R&D Before ETD and ETA A 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 body May be considered finished perfume/cosmetic; cosmetic notification and cosmetic labeling may be required Label, claims, function, retail packaging, formula, LOA/CFS if notification is required Cosmetic authority / Department of Health according to dossier Before market circulation Do not apply raw-material logic if the goods are consumer finished products.
Flavouring for food or beverage use May shift to food-safety/flavouring policy and HS 3302.10 Food specification, standards, intended use, COA Food-safety competent authority Before ordering This article must not be used as a final conclusion for food flavouring.
Mixture with flammable solvent / DG cargo IMDG/IATA, SDS, hazard labels and suitable warehouse handling may apply SDS, UN number, class, flash point, packing group Carrier/airline, warehouse, port, customs Before booking Missing DG data may cause booking rejection or transport mode change.
Contains controlled chemical, precursor or hazardous chemical components Review Decree 26/2026/ND-CP and relevant lists; declaration/control/safety conditions may arise CAS list, ratio, English/Vietnamese SDS, intended use National Single Window or chemical database if applicable Before customs declaration Do not conclude “no chemical declaration” without CAS and concentration data.
Samples, R&D or testing goods Policy may differ from commercial shipments; purpose and quantity must be clearly stated Proforma invoice, packing list, sample confirmation letter, SDS, COA Customs; R&D/QA team Before ETA Samples imported for testing/R&D must not be automatically circulated commercially.

LEGAL DOCUMENTS TO REVIEW

Document group Document name/number Issuing authority Effective/application time Role in procedure Notable article/appendix Review note
Tariff Decree 26/2023/ND-CP and Decision 15/2023/QD-TTg Government / Prime Minister Decision 15/2023 effective from 15 July 2023 Basis for MFN and ordinary import duty review HS 3302.90.00 in Chapter 33; ordinary duty generally follows the 150% MFN rule unless separately listed Re-check at customs declaration date.
Chemicals Decree 26/2026/ND-CP Government Effective 17 January 2026 Regulates chemical activities and hazardous chemicals in products/goods Review 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.
Cosmetics Circular 06/2011/TT-BYT and Circular 34/2025/TT-BYT Ministry of Health Circular 34/2025 effective 18 August 2025 Basis for cosmetics management, notification, PIF, labeling and claims Applicable when the goods are finished cosmetics or when raw-material data support finished cosmetic dossiers For fragrance oil raw material, IFRA/INCI/SDS data should be retained for quality files.
Goods labeling Decree 43/2017/ND-CP and Decree 111/2021/ND-CP Government Decree 111/2021 effective 15 February 2022 Basis for import labels, supplementary labels and mandatory information Product name, origin, responsible entity, quantity and warnings if any For chemical/DG goods, hazard labeling under SDS must be reviewed separately.
Foreign trade and customs Law on Foreign Trade Management 2017; Customs Law; applicable customs decrees National Assembly / Government Review effective status at time of import General framework for import and customs procedures HS, customs value, origin and specialized policy Do 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

  • Commercial Invoice
  • Packing List
  • Bill of Lading/Air Waybill
  • Sales Contract/Purchase Order
  • C/O if claiming preferential duty
  • Catalogue/TDS/SDS/COA/IFRA

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 group Required documents Used for Prepared by Common errors Pre-ETA check
Commercial dossier Commercial Invoice, Packing List, B/L or AWB, Sales Contract/PO Customs declaration, value, quantity and parties Importer / Docs / Procurement Generic product name such as “oil” or “fragrance” is insufficient Compare goods description with SDS/COA/IFRA before ETA
Raw-material technical dossier SDS, COA, TDS, IFRA certificate, allergen list, INCI/fragrance declaration HS classification, physical inspection, DG review and QA/R&D record Supplier / QA / R&D Missing flash point, CAS, batch number or shelf life Request lot-specific documents before booking
Origin dossier C/O Form D/E/AK/VK/VJ/AJ/EUR.1/UKVFTA/AANZ/AI/AHK/RCEP/CPTPP declaration Claim special preferential import duty Supplier / Exporter / Docs Wrong form, HS, description or missing third-party invoice indication Compare C/O with invoice, packing list and B/L/AWB
Label and safety dossier Original label, planned supplementary label, hazard pictogram if any, storage instructions Label review, DG handling, warehouse and post-clearance audit Importer / QA / Warehouse Origin, batch, warning or storage condition not shown Obtain label photos before shipment leaves origin
Intended-use dossier Confirmation letter for cosmetic raw material use, R&D/sample purpose if applicable Clarify that goods are not finished retail products or food flavouring Importer / R&D / Production Customs asks for explanation due to sensitive goods name Prepare before ETA, especially first shipments or samples

KEY DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point Question to answer Evidence Consequence if unclear Recommended 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, label HS consultation or channel change Standardize 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 classification Chemical declaration/explanation may be requested Review 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 list No preference, tax adjustment Check 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 list Supplementary label or DG clarification may be requested Obtain label photos and SDS before booking
Is the import purpose clear? Raw material, R&D sample or retail finished product? PO, intended-use letter, catalogue Wrong specialized policy Avoid 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

Risk Consequence Pre-ETA control Documents to check
Overly generic product name: “fragrance oil/perfume oil” Wrong HS, SDS/IFRA request and clearance delay Use “mixture of odoriferous substances for cosmetic manufacturing” SDS, COA, IFRA, TDS
Missing SDS or SDS without flash point/DG data Booking rejection, transport mode change or additional cost Request updated SDS with GHS, flash point and UN data if any SDS/MSDS, IMO/IATA declaration if DG
C/O with wrong HS or description Preference rejected; MFN/ordinary duty payable Pre-check C/O before ETA C/O, invoice, packing list, B/L
Confusing cosmetic raw material with finished cosmetic Missing cosmetic notification or wrong policy Determine packaging, claims, sales channel and intended use Label, catalogue, PO, intended-use declaration
No CAS/component control review Chemical/DG/warehouse requirements may arise unexpectedly Request CAS/allergen/IFRA and review Decree 26/2026/ND-CP based on actual composition CAS 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.

RELATED ARTICLES

Import procedure for cosmetic raw materials
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What is HS Code and how to control classification risk
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What is C/O and common errors in preferential duty claims
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Imported cosmetic notification: dossier and key review points
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Import labeling and Vietnamese supplementary labels
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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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