Cosmetic laboratory samples are often underestimated because the quantity is small; however, customs risks may still arise around import purpose, HS classification, declared value, C/O, sample labelling and the research/testing dossier. If the shipment is described as commercial goods, lacks the approved research/testing import order or exceeds the permitted quantity, customs may request additional documents, route the shipment for inspection, delay clearance and trigger DEM/DET costs. This article provides an E2E (End-to-End) pre-ETA review map covering import purpose, HS Code, duties, C/O, specialized dossiers, customs documents and key risks to control before arrival.

QUICK FACT TABLE

Category	Content needs closing	Records/test scores	Rủi ro nếu sai
Mặt hàng	Cosmetic lab test sample import for research and internal testing; not put on the market.	Catalog, model description, ingredients, intended use, quantity of each SKU.	It is considered a commercial cosmetic if the documents do not indicate testing purposes.
Key policy	According to Article 35 Circular 06/2011/TT-BYT: cosmetic samples imported for research/testing are in special cases and are not required to be announced as circulated goods but must have an approved order.	Import orders for research and testing according to Appendix 14-MP; copy stamped “Send to enterprise”.	Without these documents, clarification of import conditions may be required.
Quantity	Tối đa 10 mẫu/sản phẩm according to regulations for cosmetics imported for research and testing.	Invoice, Packing List, model/SKU list, order approval.	Exceeding the quantity may be considered no longer a research/test sample.
HS Code	There is no separate HS code for “lab test sample”; Apply according to the actual product nature: skin care, hair care, makeup, perfume, personal hygiene…	Ingredients, dosage form, uses, location of use, original label.	Wrong application of HS leads to wrong taxes, wrong specialized policies and wrong C/O.
Thuế/VAT	Apply according to actual students; Goods marked “sample/no commercial value” are not automatically exempt from tax if there is no basis for exemption.	Customs value, tax exemption/reduction conditions if any, C/O if applying for incentives.	Declaring a value of 0 or a symbolic value with no basis may be subject to value consultation.

Legal note: This English version is for reference and is not an official legal translation. The article applies only to cosmetic lab test samples Used for research/testing, not for sale, not given as a gift, not distributed to the market. If the goods are testers, sample sales, promotional goods or complimentary goods that are still put on the market, they must be handled according to another group of procedures.

Illustration for Import Procedure Guide for Cosmetic Laboratory Samples — Illustration of the product group and document review before customs clearance.

SCOPE OF APPLICATION

Apply for

Lab test sample of cream, lotion, serum, toner, shampoo, hair treatment, makeup, fragrance or other personal care product.
Samples are imported for R&D, sensory evaluation, internal testing, claim testing, packaging compatibility testing or stability testing.
Small batch, clearly intended for testing, not released for circulation.

Does not apply automatically

Mẫu kiểm nghiệm requested by the testing agency/unit according to separate records.
Mẫu phát triển sản phẩm Enter raw materials/bulk/compound for processing or formula research.
Tester/sample sale/promotional goods/complementary goods brought to market.
Goods with claims of treatment, antiseptic, sterilization, beauty drink or beauty equipment.

Need to review according to catalog, datasheet, model/SKU, ingredients, actual import purpose and content on documents. Do not group all types of cosmetic samples into one policy conclusion.

CLASSIFICATION & GOODS IDENTIFICATION

Lab samples are not an independent “goods” in the tariff schedule. Customs will look in product nature: ingredients, dosage form, main uses, locations of use on the body, original label, direct packaging, quantity and import purpose.

Criteria to check	Documents need to be compared	Rủi ro nếu mô tả sai	Suggestions on how to record goods names on documents/declarations
Dạng sản phẩm	Catalog, COA/MSDS, sample photos, original labels	Mistaken student group between 3304, 3305, 3303, 3307 or another group	“Cosmetic laboratory sample – [product name] – not for sale – for research/testing only”
Import purpose	Research/testing orders, sample request emails, internal test plans	It is considered a commercial product if it only says “cosmetics” in general	Clearly state “research/test sample, not marketed”
Quantity of each SKU	Invoice, Packing List, SKU list, order approval	Vượt giới hạn 10 mẫu/sản phẩm according to research/test records	Separate each product, capacity, quantity, batch number if any
Trị giá khai báo	Proforma/Commercial Invoice, shipping documents, reference price documents	A value of 0 or “no value” is easily required for explanation	Record reasonable value for customs declaration, including free goods
Sample label/packaging	Label photo, artwork, “not for sale” label if available	Mistaken for commercial retail	Ghi “sample pack / lab sample / not for commercial distribution”

HS CODE – DUTIES – C/O

For lab samples, students should not be selected based on the phrase “sample”. Students must follow complete product nature. Below is a reference table for businesses to orient their documents; Tax rates must be compared on the tax table and customs system at the time of declaration registration.

Nhóm mẫu	HS tham khảo	Applicable conditions	Thuế tham khảo	Records need to be compared
Mẫu chăm sóc da: cream, lotion, serum, toner, cleanser, mask	3304.99.90 hoặc mã chi tiết phù hợp	Beauty/skin care preparations, not drugs	MFN thường khoảng 20%; Normally approx 30%; Basic VAT 10% or reduced level if policy conditions are met from time to time	Ingredients, uses, label, catalog, invoice
Mẫu phấn/trang điểm dạng bột	3304.91.00 hoặc mã chi tiết phù hợp	Powder makeup products; Need to distinguish from skincare	Need to look up according to the detailed code on the date of opening the declaration	Texture, uses, usage locations, labels
Samples of hair products: hair serum, hair mask, hair tonic cosmetic	3305.90.00	Products used on hair, not shampoo/hair straightener/hair lacquer	MFN tham khảo 20%; usually 30%; Basic VAT 10%	Catalog, uses, ingredients, labels
Mẫu uốn/duỗi tóc	3305.20.00	Chế phẩm uốn tóc hoặc làm duỗi tóc	MFN tham khảo 15%; usually 22,5%; Basic VAT 10%	Instructions for use, safety warnings, ingredients
Perfume/fragrance samples	3303.00.00 hoặc mã phù hợp	Perfume, toilet waters or finished fragrances	It is necessary to compare the current tax schedule and special consumption policy if there is a specific alcohol element	MSDS, alcohol content, shipping label, DG if available
Mẫu khác	Students follow their practical nature	Not enough data to pin a unique code	Do not give an absolute tax rate if the code has not been determined	Catalog/datasheet, photos, labels, COA/MSDS

SPECIAL PREFERENTIAL C/O – FTA TABLE

Route/origin	Form/proof of origin	Applicable conditions	Records need to be compared	Rủi ro nếu sai
ASEAN	Form D / chứng từ ATIGA	Goods meet rules of origin and ship directly	C/O, invoice, packing list, B/L, tiêu chí RVC/CTH/CTSH	Do not enjoy special tax incentives if the form is incorrect or the product description is incorrect
Trung Quốc	Form E hoặc RCEP	Apply according to ACFTA/RCEP if it meets the rules of origin	C/O, third party invoice if any, goods description, HS	It’s easy to be questioned if the C/O states “cosmetic samples” does not match the actual goods
Hàn Quốc	AK/VK/RCEP	Choose beneficial and qualified FTA	Origin criteria, direct shipping, date of issue	Offers will not be accepted if they meet the wrong criteria or are expired
Nhật Bản	VJ/AJ/CPTPP/RCEP	Compare each agreement and HS code	C/O or self-certified documents if the agreement allows	Nhầm form làm mất ưu đãi
EU/UK	EVFTA/UKVFTA	Proof of origin according to agreement regulations	Statement on origin, invoice, routing	The sample is small but still must prove origin if applying for incentives
Úc–New Zealand/Ấn Độ/Hong Kong	AANZFTA/CPTPP, AIFTA, AHKFTA	Applicable if there is a corresponding route of origin and sufficient documents	C/O, origin criteria, bill of lading	Discounts will not be given without proof of direct shipping

Checklist C/O: Check form, WO/RVC/CTH/CTSH criteria, third party invoice, direct shipping, item description, HS, quantity, weight, country of origin, stamp/signature, date of issue and validity. Sample/no commercial value goods still need valid documents of origin if the business applies for tax incentives.

APPLICABLE SPECIALIZED POLICY

Commodity situation	Policies may apply	Documents to check	Processing authority/gateway	Time to do it	Ghi chú rủi ro
Cosmetic samples for research/testing	Orders to import cosmetics for research and testing; It is not required to declare the product as circulating goods	Order Appendix 14-MP, testing purpose, quantity ≤ 10 mẫu/sản phẩm	Drug Administration – Ministry of Health; customs upon customs clearance	Before ETA	Missing approval may result in a shipment being held
Sample for sale/tester/sample sale	Not within the scope of this article; Cosmetic product declaration form and circulation label may be required	Announcement slip, secondary label, PIF, distribution documents	Drug Administration/Department of Health/customs	Before entering and before circulating	Do not use the lab sample mechanism to bring products to market
The model has a treatment/antiseptic/beauty drink claim	May no longer be ordinary cosmetics	Claim, ingredients, instructions for use, label	Specialized management agencies by commodity group	Before ordering	Need to review according to actual records
Mẫu chứa cồn, aerosol, dễ cháy	Dangerous goods (DG) regulations may apply	MSDS, UN number, packing instruction, airline/forwarder acceptance	Airline/shipping company, forwarder, customs	Before booking	Transportation may be refused if the DG declaration is incorrect
Entry form for EPE/FDI/factory	Customs policy by type, internal use purpose, quota/storage management if any	Contracts, test plans, warehouse receipts, internal documents	Customs Department manages	Before opening the declaration	Wrong type may result in explanation after customs clearance

LEGAL INSTRUMENTS TO REVIEW

Text group	Name/number	Issuing authority	Effectiveness/time of application	Role in procedure	Articles/clauses/appendixes that need attention	Review notes
Specialized circulars	Circular 06/2011/TT-BYT	Ministry of Health	It is necessary to compare the validity and the amended text at the time of application	Regulations on cosmetic management, announcement, import, research/test samples	Điều 35, Appendix 14-MP; maximum regulations 10 mẫu/sản phẩm	Based on the focus of the article
Luật	Customs Law 2014	National Assembly	Being a customs clearance platform	Principles of declaration, inspection, and customs clearance	Need to review according to actual records	Do not replace the instructions of the customs department
Customs Decree/Circular	Decree 08/2015/ND-CP, Decree 59/2018/ND-CP; Circular 38/2015/TT-BTC, Circular 39/2018/TT-BTC	Government/Ministry of Finance	It is necessary to compare the consolidated and amended versions	Documents, value, declaration, customs inspection	Need to review according to type of import	Apply according to actual declaration
Goods labeling	Decree 43/2017/ND-CP, Decree 111/2021/ND-CP	Government	Need to compare when goods have circulation labels or sample labels	Regulations on product labels/sub-labels	Required content on the label	Lab samples should clearly state “not for sale/not for market circulation” if appropriate
Biểu thuế	Current import and export tariff schedule	Ministry of Finance/Government	At the date of registration of the declaration	Determination of MFN tax, regular, special incentives	Mã HS chi tiết của mẫu	Do not use a single HS for every sample
VAT	Decree 174/2025/ND-CP and related documents	Government	Từ 01/07/2025 đến hết 31/12/2026 according to the scope of application	Determine the possibility of reducing VAT if the goods do not belong to the exclusion group	Phụ lục loại trừ	Does not apply automatically 8%; Must review according to HS and appendix

VIEW / DOWNLOAD ORIGINAL LEGAL TEXTS

Enterprises can look up documents by number on the Legal Document Portal, the Government Electronic Information Portal or the website of the issuing agency. Enterprises should further compare on the Legal Document Portal or the issuing agency’s website before applying.

Circular 06/2011/TT-BYT VAT policy 2025–2026 HS/tariff lookup

CUSTOMS CLEARANCE DOCUMENT SET

Set of commercial documents

Commercial Invoice, even free goods, should still have a reasonable declared value.
Packing List (Phiếu đóng gói) tách từng SKU/mẫu.
Bill of Lading/Air Waybill (Sea/air waybill).
Sales Contract/Purchase Order or sample request letter if available.
C/O if the business applies for tax incentives.
Catalog, datasheet, COA/MSDS, product photos, original labels.

Specialized profile

Orders for importing cosmetics for research and testing according to Appendix 14-MP.
The approval copy is stamped “Send to enterprise” for presentation to customs.
Sample usage plan: research, testing, formula evaluation, stability testing.
Commitment not to release samples to the market.
MSDS/DG declaration if sample contains alcohol, aerosol or is flammable.

Profile group	Documents required	Which step to use?	Who usually prepares	Common errors	How to check ETA in advance
Thương mại	Invoice, Packing List, AWB/B/L, PO/email sample request	Open declaration, determine value and quantity	Importer, supplier, forwarder	It says “no value” but has no customs value	Compare unit price, quantity, SKU, delivery conditions
Kỹ thuật	Catalogue, COA, MSDS, thành phần, nhãn gốc	Student division, policy, DG	Supplier/R&D/QA	Missing ingredients or uses	Finalize product groups before declaring HS
Specialized in cosmetics	Research/testing order approved	Chứng minh điều kiện mẫu đặc biệt	Importer/Regulatory	There is no stamp submitted to customs	Complete before ETA, save scanned copies and originals
Origin	C/O or documents of origin if applying for incentives	Apply special preferential taxes	Supplier/importer	C/O does not match the sample description	Check form, HS, description, quantity, invoice

Test rules: Product name, quantity, SKU/model, origin, technical specifications, ingredients and import purpose must match commercial documents, specialized records, sample labels and customs declarations.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Điểm quyết định	Questions to answer	Tài liệu chứng minh	Consequences if unknown	Recommended treatment
Import purpose	Is it true that it is a research/testing lab sample?	Order Appendix 14-MP, test plan	Required to be declared as circulating goods	Clearly state “not for sale / for lab testing only” on the voucher
Quantity	There is overtaking 10 mẫu/sản phẩm không?	Invoice, Packing List, order approval	Suspected of entering business	Separate the SKU and quantity of each model
HS Code	Have students followed the nature of the product?	COA/MSDS, nhãn, catalogue	Sai thuế và sai C/O	Finalize HS for each group of samples before ETA
Trị giá	Do free goods have a reasonable declared value?	Proforma invoice, giá tham khảo	Consult on value or additional documents	Do not declare 0 if there is no basis
Vận chuyển	Does the sample contain alcohol/aerosol/flammable?	MSDS, DG declaration	Airline/ship refuses to transport	Check DG before booking

PRACTICAL E2E PROCEDURE

Step 1 – Review ETA in advance: Determine sample purpose, quantity of each product, HS according to product nature, tax/VAT, C/O, sample label and request for research/testing orders.

Step 2 – Lock the set of documents: Check Invoice, Packing List, AWB/B/L, catalog, COA/MSDS, label image, SKU list; Make sure the sample name and quantity match the approval documents.

Step 3 – Complete specialized documents: Prepare orders to import cosmetics for research and testing; Receive approval to submit to customs; If there is a DG, lock the shipping records.

Step 4 – Open customs declaration: Clearly explain the type of import, value, HS code, sample purpose; Monitor the Green/Yellow/Red stream and prepare answers when asked.

Step 5 – Customs clearance, goods receipt and post-clearance control: Enter sample warehouse, label/record non-circulation status, save batch records, test results and record of sample use/destruction if any.

PRE-ETA RISK CHECKLIST

Rủi ro	Hậu quả	How to block ETA in advance	Documents to check
There are no research/testing orders	Required to be restocked or treated as commercial goods	Prepare documents Appendix 14-MP before ETA	Order approval, test plan
Exceeding 10 models/product	Suspected of being imported for sale/circulation	Divide SKUs clearly, check the quantity of each product	Invoice, Packing List, orders
Product names are too general	Sai HS, sai policy, sai thuế	Name by nature: skincare/haircare/fragrance/makeup sample	Catalogue, nhãn, COA/MSDS
Khai trị giá 0	Tham vấn trị giá	Use fair value for customs purposes	Invoice/proforma, email supplier
No DG check	Unable to book air/sea or kept in warehouse	Check MSDS and DG classification before booking	MSDS, SDS, packing declaration
Use the following form for the wrong purpose	Post-inspection risks and violations of cosmetic management	Save the sample import – export – use/cancel book	Warehouse receipt, test record, cancellation record

FAQ – COMMON BUSINESS QUESTIONS

1. Do lab test samples need a cosmetic declaration form?

If it is true that cosmetics are imported for research/testing, Article 35 Circular 06/2011/TT-BYT stipulates that this is a special case that is not required to be declared as circulated goods, but must have an import order for research and testing.

2. Can I enter more than 10 samples?

The research/test sample mechanism should not be applied if exceeded 10 mẫu/sản phẩm. In case a larger quantity is needed, the purpose and import mechanism must be reviewed.

3. Do “no commercial value” goods have to pay tax?

You may still have to declare value and pay tax according to regulations if you are not exempt. “No commercial value” does not automatically mean tax exemption.

4. Do lab samples need C/O?

C/O is only needed if the business wants to enjoy special tax incentives or requires sales documents. C/O must match goods description, HS code, quantity, and origin.

5. Are lab samples given to customers to try?

No. Samples imported under the research/testing mechanism must be used for their intended purpose and must not be released into the market.

6. If the sample is fragrance/aerosol, what should I pay attention to?

Must check MSDS, alcohol content, dangerous goods risk (DG) and transportation conditions before booking.

IMPLEMENTATION SOLUTION FROM TGIMEX

The article provides a map of HS codes, taxes, records and specialized policies; However, when deploying actual shipments, businesses still need to review catalogs, datasheets, SKUs, documents, origin and import purposes.

Năng lực phối hợp

Dealer network in over 60 quốc gia.
Thành viên WCA, WCA China Global, VLA, HNLA.
Shipping by sea, air, road/rail.
Customs clearance, C/O, import license, warehousing and domestic transportation.

Support work group

Review before ETA: HS, policy, C/O, tax, label, catalog/datasheet.
Control compliance documents: Invoice, Packing List, AWB/B/L, C/O, label, COA/MSDS.
Coordinate with agents, shipping lines/airlines, ETA tracking, pre-alert.
Customs declaration, Green/Yellow/Red channel processing, explanation support.
Save records in batches and control after customs clearance.

For shipments that are likely to incur specialized inspections, licenses, C/O or label requirements, businesses should not wait until the goods arrive to begin reviewing documents. Every small discrepancy between Invoice, Packing List, catalog, datasheet, C/O or brand can lead to a request for additional documents, delay in customs clearance or incur unplanned storage costs.

TGIMEX supports businesses in establishing E2E import plans: reviewing policies before ETA, checking documents, coordinating international transportation, customs declaration, customs clearance processing, domestic delivery and post-customs clearance records.

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