Import procedure for perm/straightening cream

IMPORT PROCEDURE FOR PERM/STRAIGHTENING CREAM

COSMETICS – HAIR CARE | HS 3305.20.00

IMPORT PROCEDURE FOR PERM/STRAIGHTENING CREAM

This guide applies only to perm/straightening cream – a topical cosmetic preparation for curling or straightening hair, subject to review against formula, label, catalogue and actual import purpose.

ProblemThe product is often described too generally as “hair cream”, “salon treatment” or “hair chemical”, creating HS and cosmetic compliance risks.
ImpactThe shipment may face requests for cosmetic notification, label/use clarification, C/O rejection or DEM/DET charges.
SolutionThis article provides an E2E map for reviewing HS, duties, C/O, cosmetic dossier, labeling and pre-ETA risks.

QUICK FACT TABLE

Item Review notes
Product Perm/straightening cream – a cosmetic hair waving/straightening preparation if used externally on hair only and without therapeutic/medical claims.
Main reference HS 3305.20.00 – Preparations for permanent waving or straightening.
Reference taxes MFN 15%; ordinary import duty reference 22.5%; standard VAT 10%; do not automatically apply 8% without checking exclusion appendices and customs/tax guidance at declaration date.
Specialized policy A valid cosmetic product proclamation receipt number is required before placing the product on the Vietnamese market; import documents must be consistent with the proclamation, labels, formula and actual use.
Key risks Wrong classification between 3305.20.00 and 3305.90.00; excessive repair/treatment claims; missing CFS/authorization; incorrect C/O form; label inconsistent with proclamation.
Application note Review catalogue, datasheet, formula, original label, model/SKU and SDS/MSDS when chemical irritancy or professional salon packaging is relevant.

LEGAL NOTE

Legal noteThis article is an operational guide for import dossier preparation. Enterprises must verify import tariff, VAT policy, cosmetic product proclamation status, labelling rules and applicable legal documents at the declaration date. It does not replace official classification rulings or competent authority opinions.

SCOPE OF APPLICATION

This article applies solely to perm/straightening cream used externally on hair for waving, straightening or hair-shape control in cosmetic procedures.

Covered products

Cream, lotion, gel or emulsion preparations for hair waving/straightening, in retail or professional salon packs, where the declared use is cosmetic hair care.

Not automatically covered

Hair dyes, bleaching products, hair masks, hair serum, salon treatment without waving/straightening function, nail products or medicinal scalp/hair treatments.

Separate review required

Samples, warranty goods, used/refurbished goods, EPE/FDI/factory imports, professional formulas or repair/treatment claims beyond cosmetic scope.

Review must be based on catalogue, datasheet, model/SKU, formula, original label and actual import purpose.

CLASSIFICATION & PRODUCT IDENTIFICATION

The key classification element is not merely the word “cream” but the permanent waving or straightening function shown on labels, instructions, active formula and cosmetic proclamation dossier.

Primary function

External hair-use product for waving, straightening or hair-shape control; it should not be presented as a medicinal treatment for hair or scalp diseases.

Technical documents

Catalogue, product specification, ingredient list, CFS, LOA, original label, product photos, user instructions and SDS/MSDS where transport safety is relevant.

Document description

Recommended description: “Hair perm/straightening cream, cosmetic use, brand…, model/SKU…, packing…, origin…”. Avoid generic “hair cream” when the actual use is waving/straightening.

Criteria to check Documents to compare Risk if misdescribed Suggested description on documents/declaration
Waving/straightening function Original label, catalogue, instructions Misclassification under 3305.90.00 or other treatment groups Hair perm/straightening cream – cosmetic preparation for hair waving/straightening
Product form and packing Packing List, product photos, labels, SKU list Quantity/packing mismatch or inconsistency with proclamation Cream/gel/lotion, retail/professional salon pack, net weight/volume
Formula and safety warnings Ingredient list, SDS/MSDS, PIF if applicable Request for explanation on claims, restricted substances or safety warning Cosmetic preparation; ingredients as declared on label
Goods condition Invoice, PO, contract, product photos Samples/promotional/used goods may require different handling New cosmetic product for import and distribution / sample for proclamation review
Label and proclamation Cosmetic proclamation, original/Vietnamese label Incorrect responsible company, proclamation number or function Product name and use must match proclamation and label
Operational warningGeneric product descriptions may lead to wrong HS code, incorrect cosmetic policy review, inconsistent proclamation dossier, labelling issues and post-clearance explanations.

HS CODE – DUTY – C/O

The HS code should be determined by main use, composition, preparation form and label/proclamation description. For products specifically used for permanent waving or straightening, the reference code is generally 3305.20.00.

Reference HS code Goods description Application condition Risk if wrongly applied Documents to compare
3305.20.00 Preparations for permanent waving or straightening Main use is hair waving/straightening; cosmetic external use Generic “hair cream” may trigger questions why not 3305.90.00 Catalogue, label, instructions, ingredient list, cosmetic proclamation
3305.10.90 Other shampoos Only for hair cleansing products Incorrect if product is not a shampoo Label, function, usage form
3305.90.00 Other hair preparations For hair mask, treatment, serum, tonic not specifically waving/straightening May be challenged if label states permanent waving/straightening Catalogue, label claims, proclamation
3305.30.00 Hair lacquers Only for hair spray/lacquer products Incorrect if product is cream/gel for waving/straightening SDS/MSDS, packaging form, label
3004/pharmaceutical headings Medicinal products Only when therapeutic claims, active pharmaceutical ingredients or medicinal mechanism exist High risk if cosmetic makes disease-treatment claims Marketing claims, proclamation, formula, instructions
Tax / obligation Reference level for HS 3305.20.00 Basis / application note Check before ETA
MFN import duty 15% Vietnam Trade Portal shows Customs Duty (MFN) 15% for 33052000; verify at declaration date. Check HS, goods description, origin, customs value and tariff schedule.
Ordinary import duty Reference 22.5% Often calculated as 150% of MFN unless a separate ordinary tariff applies; verify current legal schedule. Do not use where valid preferential C/O applies.
VAT Standard 10%; possible 8% review under VAT reduction policy if eligible Decree 174/2025/NĐ-CP provides a VAT reduction policy by period; verify exclusions and declaration date. Check HS, exclusion appendices, declaration timing and tax/customs guidance; do not self-lower VAT on the declaration.
Special preferential duty under C/O May be 0% or reduced under applicable FTA if origin rules are met Depends on agreement, C/O form, origin criterion, direct transport and third-party invoicing. Lock C/O before ETA; compare HS on C/O with declaration, Invoice, Packing List and catalogue.
Route/origin C/O form or proof of origin Reference preferential level Application condition Documents to compare Risk if incorrect
ASEAN Form D – ATIGA Reference if ATIGA conditions are met ASEAN origin, direct transport, HS/description consistent across documents Form D, Invoice, Packing List, B/L, catalogue Wrong RVC/CTH, incorrect description or missing direct transport proof may deny preference.
China Form E – ACFTA; RCEP proof if RCEP is chosen ACFTA reference ; RCEP usually around depending on schedule group Meet PSR, direct transport and proper third-party invoicing disclosure where applicable Form E/RCEP proof, Invoice, B/L, origin criteria worksheet Incorrect Form E boxes, missing third-party invoice note or HS mismatch.
Korea Form AK – AKFTA; Form VK – VKFTA; RCEP where applicable AKFTA/VKFTA reference around ; RCEP around Choose the agreement with the best combined duty rate and origin rule fit C/O, origin criteria worksheet, Invoice, B/L Wrong form or origin criterion may deny preference.
Japan Form AJ/VJ; CPTPP; RCEP where applicable CPTPP reference ; RCEP around ; AJCEP/VJEPA must be checked by schedule Compare AJCEP, VJEPA, CPTPP and RCEP requirements C/O or self-certification where allowed, Invoice, B/L Missing direct transport proof or inconsistent description.
EU EUR.1 or EVFTA origin statement EVFTA reference around Meet EVFTA origin rules and valid origin documentation EUR.1/origin statement, Invoice, B/L Wrong origin-statement wording or exporter eligibility issue.
UK EUR.1 or UKVFTA origin document UKVFTA reference around Meet UKVFTA origin rules and documentation requirements C/O/origin proof, Invoice, B/L Using EVFTA documentation incorrectly for UK shipments or vice versa.
Australia – New Zealand Form AANZ; CPTPP/RCEP where suitable AANZFTA/CPTPP reference ; RCEP around Select the agreement matching actual origin and transport route C/O, B/L, Invoice, Packing List Failure to prove direct transport or actual origin.
India Form AI – AIFTA AIFTA reference around Meet AIFTA origin rules and documentary requirements Form AI, Invoice, B/L, origin criteria Incorrect criterion or overly generic goods description.
EAEU VN–EAEU FTA origin document where eligible VN–EAEU FTA reference Meet origin rules and transport conditions C/O, Invoice, B/L, transport documents Origin or direct-transport proof not acceptable.
Hong Kong (China) AHKFTA C/O where eligible AHKFTA: check schedule at declaration date Meet AHKFTA origin rules C/O, Invoice, B/L Confusing Hong Kong origin with Mainland China origin.
C/O checkpoint Review requirement Common risk
C/O form Correct form by route: D, E, AK, VK, AJ, VJ, AI, AANZ, EUR.1 or permitted proof Wrong form or form outside the intended agreement.
Origin criterion Compare WO/RVC/CTH/CTSH or PSR under the relevant agreement Preference claimed while origin criterion is not met.
Description and HS Goods name, HS, quantity, weight and origin must match declaration and commercial documents C/O says “hair cream” while declaration uses 3305.20.00.
Third-party invoice If used, it must be declared according to the agreement Missing issuing country or third-party invoice note.
Issuance date and validity Check issue date, retroactive issue, replacement C/O and submission deadline Late submission or incorrect retroactive marking.

APPLICABLE SPECIALIZED POLICY

Goods scenario Possible policy Documents to check Authority/portal if identifiable Recommended timing Risk note
Standard cosmetic goods Cosmetic management and product proclamation before circulation Proclamation, CFS, LOA, formula, label, PIF when needed Cosmetic authority under Ministry/Department of Health and relevant public service portals Before commercial import or market circulation Do not wait until cargo arrival to handle proclamation.
Professional salon products Still cosmetic if used externally for beauty purpose; review use instructions and warnings Original label, instructions, SDS/MSDS, formula Cosmetic authority; Customs during clearance Before ETA “Treatment/therapy” claims may need scope explanation.
Samples for proclamation/testing May have a sample purpose and should not be assumed identical to commercial import PO, sample invoice, quantity, import purpose, product dossier Customs and specialized authority if applicable Before booking/ETA Wrong purpose may trigger circulation/commercial-use questions.
Used/refurbished goods Used cosmetics are generally not suitable for market circulation; review carefully Goods condition, expiry, packaging, transaction documents Customs and market surveillance if circulated Before contract signing Quality, safety, expiry and label risks.
EPE/FDI/factory import Customs regime and internal use purpose may differ from domestic trading Contract, invoice, intended use, internal records Managing customs branch Before declaration Mismatch between declared purpose and actual use may trigger post-clearance risk.
Products with special ingredients/warnings Review ASEAN/Vietnam cosmetic ingredient and labelling requirements Ingredient list, PIF, SDS/MSDS, original label Cosmetic authority Before purchase order confirmation Restricted ingredients or excessive claims may affect proclamation and circulation.

LEGAL DOCUMENTS TO REVIEW

Document group Document name/number Issuing authority Effective date/application Role in procedure Key points to note Review note
Law Law on Customs 2014 National Assembly Currently applied, check amendments Customs declaration, dossier inspection and physical inspection framework Customs dossier, inspection and clearance provisions Review by import regime.
Law Law on Foreign Trade Management 2017 National Assembly Currently applied Foreign trade and specialized management framework Import/export management and conditional goods Does not replace cosmetic regulations.
Decree Decree 69/2018/NĐ-CP Government Currently applied, check amendments Guidance on foreign trade management Import management mechanisms Check for special conditions if applicable.
Circular Circular 06/2011/TT-BYT on cosmetic management and amendments Ministry of Health Amended by multiple documents Main basis for cosmetic proclamation and market responsibilities Proclamation, PIF, cosmetic management Use the latest consolidated/current version.
Circular Circular 34/2025/TT-BYT Ministry of Health Effective 18 Aug 2025 Amends Circular 06/2011/TT-BYT Updated cosmetic management provisions Do not infer without reading the official document.
Decree Decree 43/2017/NĐ-CP and Decree 111/2021/NĐ-CP Government Currently applied, check amendments Goods labelling in Vietnam Mandatory label/Vietnamese sub-label information Name, ingredients, quantity, origin and responsible party must match dossier.
Tariff Decree 26/2023/NĐ-CP, Decree 108/2025/NĐ-CP and relevant special preferential tariff schedules Government Decree 108/2025/NĐ-CP effective 19 May 2025 MFN and import tariff review Chapter 33, heading 3305, code 3305.20.00 Verify on system at declaration date.
VAT Decree 174/2025/NĐ-CP Government Effective 1 Jul 2025 VAT reduction policy by period Exclusions and applicable conditions Determine 8% or 10% at declaration time.

VIEW / DOWNLOAD OFFICIAL DOCUMENTS

Enterprises can search legal instruments by document number on the official legal document portal, the Government portal or the website of the issuing authority.

NoteEnterprises should further verify documents on the official legal document portal or the issuing authority’s website before applying them.

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice, Packing List, Bill of Lading/Air Waybill, Sales Contract/Purchase Order if any, C/O for tariff preference, catalogue/datasheet, product photos, original label, model/SKU list.

Cosmetic dossier

Cosmetic product proclamation, CFS (Certificate of Free Sale), LOA/authorization, formula/ingredient list, original/Vietnamese labels and PIF where required.

Supporting technical documents

SDS/MSDS where transport safety matters, product specification, user instructions, packaging photos, batch/expiry data and claim explanation documents if needed.

Dossier group Required document Used for Usually prepared by Common error Pre-ETA check
Commercial Invoice, Packing List, Contract/PO Customs declaration, value and quantity basis Importer, seller, forwarder/docs Generic “hair cream” description not showing waving/straightening function Compare name with label, catalogue and HS 3305.20.00.
Transport B/L or AWB, Arrival Notice, Pre-alert D/O, manifest and declaration Forwarder, carrier, overseas agent Wrong consignee, weight, packages or port Compare with Invoice/Packing List before ETA.
Origin C/O or proof of origin Special preferential duty claim Shipper, manufacturer, documentation team Wrong form, origin criterion, HS or no direct transport evidence Check form, HS, description, quantity, stamp/signature.
Cosmetics Proclamation, CFS, LOA, ingredient list, label Market circulation and customs explanation Importer/brand owner, regulatory team Proclamation inconsistent with product name, label or formula Match product name, use and responsible party.
Labelling Original label, Vietnamese sub-label, packaging photos Post-clearance circulation and audit Importer, compliance, warehouse Missing ingredients, origin, quantity, warning, responsible party Prepare Vietnamese sub-label consistent with proclamation and original label.
Dossier matching ruleProduct name, quantity, model/SKU, batch, expiry, origin, formula, use and labels should match across commercial documents, catalogue, labels, cosmetic dossier and customs declaration.

CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point Question to answer Supporting document Consequence if unclear Recommended action
HS code Is the product truly a hair waving/straightening preparation? Catalogue, label, instructions, proclamation HS explanation request or inspection Prepare HS reasoning and functional evidence before ETA.
Cosmetic proclamation Is there a suitable proclamation receipt number? Proclamation, CFS, LOA, label Insufficient market circulation condition or additional request Check number, name and responsible entity.
Product claims Any disease-treatment, hair-growth or scalp therapy claims? Label, brochure, website, catalogue May be considered outside ordinary cosmetic scope Standardize claims within cosmetic scope.
C/O Is C/O form, origin criterion and description correct? C/O, Invoice, B/L, Packing List Preference denied Check C/O before arrival.
Vietnamese label Does the label contain required information for circulation? Original label, Vietnamese sub-label, packaging photos Market surveillance/post-clearance risk Prepare sub-label consistent with proclamation.
Sample vs commercial goods Is import purpose consistent with documents? PO, Invoice, quantity, import purpose Questions on circulation and quantity Use suitable declaration regime and explanation.

PRACTICAL E2E WORKFLOW

Step 1 – Pre-ETA review

Confirm HS 3305.20.00, cosmetic policy, duty, C/O, labelling, proclamation and transport safety requirements.

Step 2 – Lock documents

Finalize Invoice, Packing List, B/L/AWB, catalogue, labels and SKU list; verify product name, quantity, origin, value, use and packing.

Step 3 – Review cosmetic dossier

Compare proclamation, CFS, LOA, formula, original label and claims; handle specialized dossier before arrival if not complete.

Step 4 – Customs declaration

Declare value, HS, goods name, C/O and policy. Green channel: conditional clearance; Yellow: document check; Red: document and physical inspection.

Step 5 – Clearance and delivery

Release cargo, check packaging, batch and expiry, then apply Vietnamese sub-label if required before circulation.

Step 6 – Post-clearance archive

Keep declaration, commercial documents, C/O, proclamation, labels, catalogue, product photos and transport records for audit and traceability.

PRE-ETA RISK CHECKLIST

Risk Consequence Pre-ETA control Documents to check
Wrong HS between 3305.20.00 and 3305.90.00 Wrong duty and HS explanation request Use waving/straightening function as the core criterion Catalogue, label, proclamation, ingredient list
Incorrect C/O form or origin criterion Loss of preferential duty Check form, criterion, direct transport and third-party invoice before ETA C/O, Invoice, B/L, Packing List
Product name mismatch between documents and proclamation Document correction or additional explanation Lock a consistent product name across documents Invoice, PL, proclamation, label
Treatment/therapy claims beyond cosmetic scope Risk of being outside ordinary cosmetic management Review label, brochure, website and catalogue Label, catalogue, marketing claims
Missing or inconsistent Vietnamese sub-label Post-clearance circulation risk Prepare sub-label matching proclamation and original label Original label, sub-label, proclamation
Batch/expiry not checked Circulation and internal quality risk Request clear batch/expiry data from supplier Packing List, label photo, COA if any

FAQ – FREQUENTLY ASKED QUESTIONS

Question Brief answer
Does perm/straightening cream require cosmetic proclamation? Yes, if it is a cosmetic product placed on the Vietnamese market, a suitable cosmetic product proclamation is required.
What is the reference HS code? The common reference code is 3305.20.00 for preparations for permanent waving or straightening. Actual classification must follow the dossier.
Is quality inspection or conformity certification required? The core requirement is cosmetic management/proclamation/labelling; do not conclude absolutely without reviewing formula, claims and actual documents.
Can C/O reduce import duty? Yes, if the C/O/proof of origin is valid and origin rules under the relevant FTA are met.
Is salon pack different from retail pack? It may differ in label, instructions, warnings and proclamation dossier. Review by packing and import purpose.
What if Invoice says hair cream but catalogue says straightening cream? Correct documents before declaration. Mismatched product names may trigger HS, proclamation and labelling questions.
Are samples handled like commercial goods? Not automatically. Import regime, quantity, purpose and explanatory dossier should be reviewed.
Is SDS/MSDS required? Not always for cosmetic clearance, but it is advisable where transport safety or carrier acceptance is relevant.

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Pre-ETA review

HS code, specialized policy, C/O, duty, labelling, catalogue/datasheet/model and cosmetic proclamation readiness.

Compliance dossier control

Cross-check Invoice, Packing List, B/L/AWB, C/O, catalogue, labels, formula, proclamation and technical documents.

Customs declaration

Prepare declaration dossier, handle Green/Yellow/Red channels and support explanations on HS, value, origin and policy.

International logistics

Coordinate agents, carriers/airlines, ETA tracking, pre-alerts, transport documents and domestic delivery plan.

Post-clearance

Archive shipment dossier, Vietnamese labels, proclamation documents, C/O and post-clearance explanation set if required.

For shipments involving specialized management, permits, C/O or labelling requirements, enterprises should not wait until cargo arrival to begin dossier review. A small mismatch among Invoice, Packing List, catalogue, datasheet, C/O or label may result in additional document requests, delayed clearance or unplanned storage charges.

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