Problem: A makeup set may include lipstick, cushion/foundation, powder, blush, eyeliner, mascara or concealer in one retail pack. Declaring the whole shipment only as “makeup set” without reviewing each component may lead to incorrect HS classification, duty rate, cosmetic notification and Vietnamese labelling. Agitate: A single unmatched component may trigger customs queries, loss of preferential C/O treatment, storage costs or post-clearance explanation. Solution: This article provides an E2E (End-to-End) map for pre-ETA review: component-based HS classification, duties, C/O, cosmetic notification, labelling, documents and clearance decision points.

QUICK FACTS

Item	Review point	Operational note
Product name	Makeup set sold as a kit/combo under the same owner, containing multiple make-up products.	Do not assume one HS code applies to the entire set if components differ in nature or function.
Reference HS	3304.10.00, 3304.20.00, 3304.91.00, 3304.99.30, 3304.99.90, depending on components.	Prepare a component matrix: SKU, product name, use, form, quantity/volume and value.
MFN duty	20% for 3304.10.00; 22% for 3304.20.00 and 3304.91.00; 18% for 3304.99.30/3304.99.90.	Final duty depends on confirmed HS and tariff schedule at declaration time.
Normal duty	Indicatively 30%, 33% or 27% by HS line.	Usually determined by reference to the normal import duty rules.
VAT	8% if eligible for VAT reduction; otherwise 10%.	Check exclusion appendices and effective policy when opening the declaration.
Specialized policy	Cosmetic product notification, Vietnamese label, PIF.	Each formula/product name/claim in the set should be matched with the relevant notification.

Legal note: Makeup sets carry high classification risk. Do not declare only one generic “cosmetic set” line if the kit contains products with different HS codes or notification dossiers. Review packing list, INCI, labels, notifications, C/O and retail packing evidence.

Illustration for Import procedure for makeup sets — Illustration of the product group and document review before customs clearance.

SCOPE OF APPLICATION

Covered

Makeup sets containing lipstick, cushion, foundation, powder, tint, blush, eyeliner, mascara, concealer or similar make-up products.
Same-owner combos sold as retail kits, gift boxes, travel kits, trial kits or promotion sets.
Imports for distribution, retail, e-commerce or sales promotion.

Not automatically covered

Skincare-only sets without make-up products.
Sets containing non-cosmetic items such as brushes, bags, mirrors or electronic tools.
Samples, testers, non-commercial goods, goods to be split after import, or products with unclear responsible party.
Products bearing medical or treatment claims.

Review the actual catalogue, SKU list, packing list, labels, INCI formula and import purpose. Accessories or non-cosmetic components must be assessed separately.

PRODUCT CLASSIFICATION & IDENTIFICATION

A makeup set must be reviewed at two layers: the retail set layer (packing, owner, retail purpose) and the component layer (use, physical form, application area, ingredients and quantity). Reviewing only the set name may cause incorrect HS, notification or C/O treatment.

Checkpoint	Documents to compare	Risk if described incorrectly	Suggested description
Set components	Detailed packing list, photos, catalogue, SKU list.	Missing component lines, value breakdown or unsupported single-HS declaration.	“Makeup set comprising lipstick…, cushion…, mascara…, powder…, retail pack, brand…”.
Function of each item	Label, claim, notification, brochure.	Misclassification between lip, eye, powder and skin make-up preparations.	State lip make-up, eye make-up, powder or skin make-up cream/lotion.
Physical form	Product photos, texture, SDS/MSDS if any.	Cushion cream may be confused with pressed powder; lip tint may be confused with serum.	State liquid, cream, pressed powder, pencil, stick, tube or jar.
Owner and notification	Notification receipt, authorization letter, CFS where applicable.	Using one notification for different formulas in the set.	Map notification numbers item by item.
Labels	Outer box label and each item label.	Missing ingredients, quantity, expiry, origin or responsible party.	Align set name with component names.

HS CODE – DUTIES – C/O

For a makeup set, the key point is not to assign one generic HS code based only on the trade name “makeup set”. The importer should prepare a component matrix showing each item name, physical form, use, quantity/volume, value, proposed HS code, cosmetic notification number and origin. A set-based declaration should only be considered when there is sufficient basis that the goods are a retail set with an identifiable essential character; otherwise, component-level declaration is safer for HS, duty and C/O control.

Reference HS	Covered component in the set	MFN import duty	Normal import duty	VAT	Conditions and documents to compare
3304.10.00	Lipstick, lip tint, lip gloss, lip balm with lip make-up function.	20%	30%	8%/10%	Label, claim, ingredients, cosmetic notification, photos and C/O. Do not use this code automatically for lip-care products with different nature or claims.
3304.20.00	Mascara, eyeliner, eyeshadow, eye primer, eye pencils or other eye make-up preparations.	22%	33%	8%/10%	Compare eye-area use, original label, notification dossier, ingredients and commercial description. Generic “makeup item” descriptions are risky.
3304.91.00	Powder, pressed powder, blush powder, contour powder, whether or not compressed.	22%	33%	8%/10%	Use only where the product is genuinely powder. Cushion/foundation in cream or liquid form should not be automatically classified here.
3304.99.30	Foundation, cushion, concealer, cream/lotion for face or other skin application.	18%	27%	8%/10%	Check texture, application area, claims, INCI, notification and label. This is commonly considered for cream/lotion/cushion base products.
3304.99.90	Other make-up or skin preparations under heading 3304 not evidenced under the above lines.	18%	27%	5%/8%/10%	Use cautiously. Confirm product nature, use, VAT treatment and exclusion appendices at declaration time.
3926 / 4202 / 9603…	Non-cosmetic accessories such as bags, mirrors, brushes, sponges or separate cases with independent value/nature.	Depends on HS	Depends on HS	Depends on policy	Do not automatically include independent accessories under HS 3304.

C/O and FTA preferential duty review

Origin/route	Origin document	2026 preferential duty to compare by HS	Conditions	Risk if incorrect
ASEAN	Form D / ATIGA	Generally 0% for key 3304 lines if origin rules are met.	WO/RVC/CTH/CTSH as applicable; direct transport; item description matching Invoice/Packing.	A generic “makeup set” C/O may be questioned when the declaration is split by HS.
China	Form E / ACFTA or RCEP	ACFTA is often 0%; 2026 RCEP is around 10% for 3304.10/3304.99 and 11% for 3304.20/3304.91.	Check origin criterion, third-party invoice, item descriptions and direct transport.	Using RCEP while ACFTA is available may increase duty; poor descriptions may lead to rejection.
Korea	Form AK / VK or RCEP	AKFTA/VKFTA may be 5% for 3304.10/3304.20; VKFTA may be 0% for 3304.91/3304.99; RCEP around 10%–11%.	Compare each agreement by HS and choose the lowest valid rate.	Wrong form or ineligible origin criterion may remove preference.
Japan	VJ / AJ / CPTPP / RCEP	AJCEP/VJEPA/CPTPP are often 0%; Japan RCEP 2026 around 10.9%–12%.	Compare HS per item, invoice, packing list and direct transport.	Simple packaging/packing operations may not create preferential origin.
EU / UK	EVFTA / UKVFTA	Indicative 2026 rates: 2.7% for 3304.10; 3.1% for 3304.20/3304.91; 2.5% for 3304.99.	Use the required origin statement/certificate under the relevant agreement; description and HS must match.	Incorrect statement, HS or third-party invoice can create post-clearance queries.
Australia/New Zealand, CPTPP	AANZFTA / CPTPP	Often 0% if origin conditions are satisfied.	Origin rules, transport documents and item-level descriptions must be consistent.	Multiple origins in one set may prevent a single preferential treatment.
India	Form AI / AIFTA	Often around 5% for key 3304 lines in 2026.	Review origin criterion, HS, description, quantity and weight.	Even with C/O, compare against other available treatments before claiming preference.
Hong Kong	AHKFTA	For several 3304 lines, the rate may remain equivalent to MFN, e.g. 20%/22% or similar.	Use only where the tariff schedule and evidence support a benefit or origin-management purpose.	Claiming a non-beneficial preference adds dossier complexity.
United States / no FTA	Non-preferential C/O if available	Usually MFN: 20%, 22% or 18% depending on HS.	C/O supports origin evidence but does not create preferential duty.	No special preferential C/O means no import-duty reduction.

C/O checklist for makeup sets: C/O form; origin criterion WO/RVC/CTH/CTSH; description of each set component; HS on C/O; quantity/weight/value; third-party invoice; direct transport; issue date; stamp/signature; consistency among C/O – Invoice – Packing List – customs declaration.

Operational conclusion: before ETA, prepare a component matrix showing item – HS – MFN duty – intended FTA – notification number – label – value. This controls HS, C/O and notification risks before customs declaration.

APPLICABLE SPECIALIZED POLICIES

Goods scenario	Potential policy	Documents to check	Authority/portal	Recommended timing	Risk note
Standard makeup set imported for business	Cosmetic product notification before market circulation.	Notification receipt, authorization letter, CFS where applicable, ingredients and labels.	Cosmetics authority/Department of Health under the applicable mechanism.	Before distribution; ideally reviewed before ETA.	Different formulas/items may require separate notification review.
Set with multiple products in one outer box	Outer-box label and item-level labels; responsible entity information.	Original label, Vietnamese label, packing layout and SKU list.	Market surveillance/post-clearance authorities; customs may review documents.	Before import and before Vietnamese labelling.	Outer-box label does not automatically replace mandatory item-level information if items are sold/split separately.
Set containing non-cosmetic accessories	Separate HS classification and policy for accessories.	Accessory photos, value, material and intended use.	Customs and specialized authority if applicable.	Before customs declaration.	Brushes, mirrors, bags or electronic tools are not automatically classified under HS 3304.
Sample/tester set	Policy depends on import purpose and whether goods will circulate in the market.	Invoice, packing list, intended use, “tester/sample” label.	Customs/specialized management authority.	Before booking or before ETA.	Do not assume exemption from notification if the goods will be put on the market.
Products with treatment or medical claims	May fall outside cosmetic scope and require separate policy review.	Label, brochure, website, claims and ingredients.	Ministry of Health/specialized authority as relevant.	Before finalizing label and notification.	Acne treatment, anti-inflammatory, deep regeneration or disease-related claims may trigger explanation.

LEGAL DOCUMENTS TO REVIEW

Document group	Name/number	Issuing authority	Effective status/timing	Role in procedure	Relevant points	Review note
Circular	Circular 06/2011/TT-BYT	Ministry of Health	Must be read together with amendments.	Cosmetic management, notification and responsibilities of the market-responsible entity.	Notification dossier, PIF, labels and market circulation management.	Check the consolidated/amended version at application time.
Amending circular	Circular 34/2025/TT-BYT	Ministry of Health	Effective from 18/08/2025.	Amends and supplements Circular 06/2011/TT-BYT.	Updated cosmetic management points to review when preparing dossiers.	Do not use old templates/guidance if they have been amended or replaced.
Specialized HS list	Circular 09/2024/TT-BYT	Ministry of Health	Check effective status at declaration time.	List of import/export cosmetics with commodity codes.	List 14, heading 33.04 for make-up and skin-care preparations.	Useful for HS cross-checking by cosmetic description.
Decree	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Currently applicable; check further amendments if any.	Goods labelling and Vietnamese supplementary label.	Mandatory label contents, origin, quantity and responsible entity.	Critical for sets with both outer box and inner items.
Tariff schedules	MFN tariff, normal tariff and FTA tariff schedules	Government/Ministry of Finance	Apply at customs declaration time.	Determine MFN, normal duty and preferential duty under C/O.	Chapter 33, heading 3304 and ATIGA/ACFTA/AKFTA/VKFTA/VJEPA/EVFTA schedules.	Do not lock a rate before HS and origin are confirmed.
VAT	Decree 174/2025/ND-CP	Government	Effective from 01/07/2025 to 31/12/2026.	VAT reduction from 10% to 8% where eligible.	Exclusion appendices and application conditions.	Must be checked when opening the declaration.

VIEW / DOWNLOAD SOURCE DOCUMENTS

Circular 34/2025/TT-BYT Decree 174/2025/ND-CP Cosmetics HS list Decree 26/2023/ND-CP – MFN tariff

Businesses should cross-check official portals or the issuing authority website before applying any rule.

CUSTOMS DOCUMENT SET

Commercial documents

Commercial Invoice with component value breakdown.
Packing List with SKU and quantity by product.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
C/O if preferential duty is claimed.
Catalogue, photos, labels and SKU list.

Specialized documents

Cosmetic notification for each relevant component.
Authorization letter, CFS and PIF where applicable.
INCI ingredients and Vietnamese label.
SDS/MSDS if transport requires it.
Brand/owner evidence for same-owner sets.

File group	Documents required	Used for	Usually prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO, B/L or AWB.	Customs declaration, value and quantity control.	Importer, seller, forwarder.	Invoice shows one “makeup set” line without component breakdown.	Request detailed packing list per SKU.
Cosmetics	Notification receipt, INCI ingredients, label, authorization letter/CFS if applicable.	Market-circulation and post-clearance compliance.	RA holder/importer, brand owner.	Notification does not match label or one set item is missing.	Map each SKU to its notification number.
Origin	C/O, invoice, transport documents, value breakdown.	Claiming preferential FTA duty.	Supplier/importer.	C/O description is too generic and does not match item-level HS.	Review draft C/O before declaration.
Labels	Outer-box label, item labels and Vietnamese supplementary label.	Clearance/post-clearance/market circulation.	Importer/brand owner.	Outer box does not show item-level mandatory information.	Approve Vietnamese label before cargo arrival.
Accessories	Accessory photos, material, value and use.	Separate HS determination if required.	Supplier/importer.	Brush/bag/mirror is incorrectly grouped under cosmetic HS.	Separate line where accessory has material value or independent nature.

Data-matching rule: Product name, quantity, SKU, net content, origin, ingredients, claims, notification number and C/O description must match across all documents.

CLEARANCE DECISION POINTS

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended action
Declare as one line or split lines?	Is there enough basis to treat the goods as a retail set with essential character?	Packing, item value, catalogue, contract.	Customs may require HS splitting, amendment and additional documents.	Prepare a component breakdown before ETA.
Is each item HS correct?	Is the item lip, eye, powder, cream/lotion or other preparation?	Label, ingredients, photos and notification.	Incorrect duty and C/O policy.	Confirm HS item by item before declaration.
Are cosmetic notifications complete?	Does each component have a suitable notification record?	Notification receipt, CFS/authorization and PIF.	Market-circulation and post-clearance risk.	Compare item list with notification list.
Is the C/O sufficiently detailed?	Does the C/O describe the set or each component? Does HS match the declaration?	C/O, Invoice, Packing List, B/L.	Loss of FTA preference.	Check draft C/O before issuance.
Are labels compliant?	Do outer-box and item labels contain mandatory information?	Original label, Vietnamese label and product photos.	Post-clearance/market inspection risk.	Approve Vietnamese labels before distribution.

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review

Confirm components, HS, duties, C/O, notifications, labels and accessories.

Step 2 – Lock documents

Check invoice, packing list, transport document, catalogue, labels, INCI and value matrix.

Step 3 – Specialized compliance

Review cosmetic notifications, authorization/CFS, PIF and Vietnamese labels.

Step 4 – Customs declaration

Green: system-based release; Yellow: document check; Red: document and physical inspection.

Step 5 – Release and post-clearance

Deliver goods, label properly, archive dossiers and prepare explanations.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA prevention	Documents to check
Declaring the set as one line without breakdown	Explanation, line splitting or clearance delay.	Prepare item, HS, value, quantity and notification matrix.	Invoice, Packing List, catalogue.
Incorrect C/O form or mismatched description	Loss of preferential duty.	Check form, HS, description, quantity, origin and third-party invoice.	C/O, Invoice, B/L.
Missing notification for one item	Market-circulation and post-clearance risk.	Map each SKU with notification receipt.	Notification, label, INCI.
Accessory grouped under wrong HS	Incorrect duty and policy.	Separate brush/bag/mirror if material or independent nature is significant.	Accessory photos, value, material.
Outer-box and item labels are inconsistent	Label correction or additional compliance request.	Approve original and Vietnamese-label artwork before cargo arrival.	Labels, packing, notification dossier.
Claims exceed cosmetic scope	Policy may need re-review.	Remove or correct treatment claims if not properly supported.	Label, brochure, website, e-commerce listing.

FAQ

1. Can one HS code cover the makeup set?

Not automatically. Component-based review is usually required unless retail-set classification is sufficiently supported.

2. Is cosmetic notification required?

Yes for circulation in Vietnam. Each different formula/product should be reviewed against its notification.

3. Can C/O reduce duty?

Yes, if the C/O matches the HS, description, quantity and origin of the components.

4. Are accessories classified as cosmetics?

Not by default. Brushes, pouches and mirrors may need separate HS assessment.

5. Is a promotional gift set different?

Review purpose, value, tax, labels and circulation. Do not assume exemption.

6. What if one item has no notification?

Do not rely on another item’s notification. Review before import or circulation.

IMPLEMENTATION SUPPORT FROM TGIMEX

This article provides a map for HS, duties, documents and specialized policy for makeup sets. In real shipments, businesses still need a component-by-component review against documents, labels, notifications, origin and import purpose.

Coordination capability

Agent network in over 60 countries.
Member of WCA, WCA China Global, VLA and HNLA.
International freight, customs clearance, C/O, permits, warehousing and domestic delivery.

Support scope

Pre-ETA review: component HS, duties, C/O, label, notification and accessories.
Document control: invoice, packing list, transport document, C/O, catalogue and item matrix.
Customs declaration, Green/Yellow/Red channel handling and dossier archiving.

For makeup sets with multiple components, businesses should not wait until arrival to separate the compliance matrix. Small mismatches among invoice, packing list, item list, notification, C/O or labels may lead to document requests, delayed clearance and unplanned storage costs.

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