Tiếng Việt
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IMPORT PROCEDURE FOR PLASTIC CAPS, STOPPERS AND CLOSURES
Plastic caps, stoppers and closures may look simple, but customs classification can become problematic when documents only state “plastic parts”, “cap” or “accessories”. For closures used on cosmetic bottles, jars or tubes, the importer should confirm the closing/sealing function, plastic material, item size, intended use and whether the goods are empty packaging components before customs declaration. This article provides an E2E (End-to-End) review map covering HS code, duties, VAT, C/O, labeling, customs documents and key risks before ETA.
Classification riskConfusing packaging closures with general plastic parts, household articles or functional accessories.
Document riskInsufficient description of material, closure type, size or use may trigger additional explanation.
Pre-ETA checkpointFix HS code, duty, C/O, labeling, intended use and item list before pre-alert.
QUICK FACT TABLE
| Item | Review points |
|---|---|
| Product | Plastic caps, stoppers and closures used to close or seal bottles, jars, tubes or packaging. |
| Reference HS | 3923.50.00 – Stoppers, lids, caps and other closures of plastics. |
| MFN import duty | 10% according to Vietnam Trade Portal for HS 3923.50.00. |
| Ordinary duty reference | 15% if the 150% of MFN principle applies under Decision 15/2023/QD-TTg. |
| VAT | Base rate 10%; 8% only if eligible under the VAT reduction policy and not excluded. |
| Specialized policy | Not treated as finished cosmetics if imported as empty packaging; review separately if food-contact, medical-use or imported with filled products. |
| Core documents | Invoice, packing list, B/L or AWB, catalogue/photos, material and size specification, C/O if preferential duty is claimed. |
Legal note: HS code and duty rates are planning references. At declaration stage, the importer should verify current tariff schedules, technical documents, intended use and customs guidance.
SCOPE OF APPLICATION
Applicable goods
- Screw caps, flip-top caps, disc-top caps.
- Plastic stoppers, inner plugs and closures for sealing packaging.
- Empty closures for cosmetic or personal-care bottles, jars and tubes.
- New goods imported for production, packing or trading.
Not automatically covered
- Pumps, sprayers, trigger sprayers or atomizers.
- Droppers with rubber bulbs, glass/plastic pipettes or complex functional assemblies.
- Caps imported as part of household cup/container sets.
- Packaging already filled with cosmetic products.
Review must be made based on catalogue, datasheet, item code and actual import purpose.
PRODUCT IDENTIFICATION
The decisive point is whether the item is designed to cap, stop, seal or protect the mouth of packaging during storage, packing or transport of goods. Documents should clearly state plastic material such as PP, PE, PET, HDPE, LDPE or ABS; thread or snap type; neck size; liner; color; item code; and actual photos.
| Criteria | Documents to check | Risk if unclear | Suggested customs description |
|---|---|---|---|
| Main function | Catalogue, photos, drawings | HS 3923.50.00 may be questioned | Plastic closure/cap/stopper for sealing packaging, new 100% |
| Material | Specification/COA | Wrong classification as metal, rubber or composite | PP plastic cap / PE stopper, size… |
| Closure type | Catalogue, photos | Confusion with pump/sprayer/dropper | Flip-top plastic cap / screw plastic closure |
| Intended use | PO, contract, internal use explanation | Food/medical use may trigger other policies | For empty cosmetic packaging, not filled products |
| Condition | Invoice, packing declaration | Used/recycled goods may be inspected more deeply | New goods, unused |
HS CODE – DUTY – C/O
For plastic caps, stoppers and closures imported separately, the main classification direction is 3923.50.00 when the documents prove that the product is used to close, seal, plug, cap or protect the mouth of packaging. Classification should not rely only on the trade name “cap/closure”; the structure, material, photos, technical drawings and actual intended use must be reviewed.
HS decision point: If the item is only an empty plastic cap/stopper/closure for packaging and has no pump, spray, dropper or separate technical mechanism, 3923.50.00 is the primary review direction. If the shipment includes pumps, sprayers, triggers, droppers or pipettes, or caps sold with household/food/medical articles, each SKU should be separated and reviewed independently.
HS and duty table by scenario
| Reference HS code | Application condition | MFN import duty | Ordinary duty reference | VAT | Risk if misapplied | Documents to review |
|---|---|---|---|---|---|---|
| 3923.50.00 | Stoppers, lids, caps and other closures of plastics used for packaging goods. | 10% | 15% if the 150% of MFN principle applies and no separate ordinary rate is applicable. | Base rate 10%; 8% only if eligible for VAT reduction at declaration time. | Generic descriptions such as “plastic accessories” or “cosmetic packaging parts” may fail to prove the closure function. | Catalogue, product photos, material specification, neck size, drawings, PO, invoice and packing list. |
| 3926.90.99 | Only considered when the product is another article of plastics and cannot be proven to be a packaging closure. | Not a default duty option for plastic caps. Review the tariff only when technical documents prove that 3923.50.00 is not applicable. | The item may be reclassified if its actual nature remains a packaging closure. | Function explanation, installed-use photos, catalogue and technical drawings. | ||
| 3924.xx | Only considered for household/kitchen articles or caps sold as part of cups, boxes, bottles or household containers. | Not applied to separate closures for cosmetic packaging if documents clearly prove the packaging-closure function. | Wrong policy or duty exposure if the cap is separated from a set or declared under a lower-duty heading. | Product-set catalogue, intended use, sale/packing method and contract/PO. | ||
C/O and FTA preferential duty table to review
| Origin route | C/O form or origin document | Preferential rate to confirm | Conditions | Documents to check | Risk if incorrect |
|---|---|---|---|---|---|
| ASEAN | Form D / ATIGA origin document | The ATIGA 2022–2027 schedule usually shows 3923.50.00 at 0%; the official schedule for the declaration year must still be checked. | Origin criteria, direct transport, description and HS must match. | Draft C/O, invoice, packing list, B/L, origin country and WO/RVC/CTH/CTSH criteria. | Wrong form, wrong HS or lack of direct transport evidence may lead to rejection. |
| China | Form E under ACFTA or RCEP origin document if eligible | Check ACFTA/RCEP schedules for the declaration year; do not assume 0% before reviewing HS, origin and agreement conditions. | The goods must qualify under the relevant agreement; third-party invoicing must be properly declared. | Form E/RCEP document, third-party invoice if any, B/L, origin criteria and “plastic closures” description. | Generic descriptions or HS mismatch between C/O and declaration may trigger verification. |
| Korea | Form AK / VK or RCEP | Check AKFTA/VKFTA/RCEP schedules for 3923.50.00 and declaration year. | PSR, issue date, seal/signature, origin criterion and transport route must be valid. | C/O, invoice, packing list, B/L and manufacturer information. | Using the wrong FTA or origin criterion can remove the preferential benefit. |
| Japan | VJEPA / AJCEP / CPTPP / RCEP | Check the relevant schedule for Japanese origin and 8-digit HS code. | Origin rules, direct transport and valid origin document are required. | Origin document, HS on C/O, description, invoice and transport document. | Wrong FTA route or unmet CTH/CTSH/RVC requirement may result in rejection. |
| EU/UK | EUR.1 or EVFTA/UKVFTA origin statement | Check EVFTA/UKVFTA schedules for 3923.50.00. | The origin document must be valid; self-certification must meet exporter requirements. | Statement on origin/EUR.1, invoice, B/L, description and HS code. | Incorrect exporter information, description or HS code increases verification risk. |
| Australia–New Zealand / India / Hong Kong | AANZFTA, CPTPP, RCEP, AI or AHKFTA if applicable | Check the schedule by agreement and actual country of origin. | Do not rely only on shipping country; origin country and origin rule must be verified. | C/O, transport documents, invoice, product description and origin criterion. | Mismatch between C/O, actual origin or transport route may prevent preferential treatment. |
C/O checklist: check form, origin criteria WO/RVC/CTH/CTSH, goods description, HS code, quantity, weight, country of origin, third-party invoice, direct transport, issue date, seal/signature and submission deadline. For plastic caps/stoppers/closures, the C/O description should be specific enough to link with the invoice, packing list and catalogue, not merely “plastic goods”.
SPECIALIZED POLICY MATRIX
| Scenario | Possible policy | Documents | Authority / portal | Timing | Risk note |
|---|---|---|---|---|---|
| Empty plastic closures for cosmetic packaging | Ordinary customs procedure and import labeling review. | Invoice, packing list, B/L/AWB, catalogue, photos, material description. | Customs / VNACCS-VCIS. | Before ETA. | Not automatically treated as cosmetic product notification. |
| Closures imported with bottles/jars/tubes as a set | Review classification as a packaging set; do not split or merge HS arbitrarily. | Item list, value ratio, photos. | Customs office. | Before invoice finalization. | Classification may differ if sold as a complete set. |
| Food-contact closures | Food safety inspection may apply depending on actual use. | Food-contact material information, test report if any. | National Single Window / competent authority. | Before ETA. | Vietnam Trade Portal displays food safety measures for food-contact packaging. |
| Medical/pharmaceutical use | Review under the corresponding product/use regime. | Catalogue, use description and sector documents if applicable. | Relevant ministry/authority. | Before contract signing. | Do not apply cosmetic packaging logic to medical/pharma use. |
| Used/recycled/refurbished goods | Review import eligibility and environmental issues if any. | Condition declaration and origin documents. | Customs/specialized agency if any. | Before booking. | May trigger deeper inspection. |
| EPE/FDI/factory import | Review import type, consumption norms and internal use. | PO, contract, BOM/norms, item list. | Managing Customs office. | Before declaration. | Incorrect import type may affect post-clearance settlement. |
LEGAL DOCUMENTS TO REVIEW
| Group | Document | Issuer | Effective timing | Role | Key point | Review note |
|---|---|---|---|---|---|---|
| HS / tariff | Vietnam Trade Portal – HS 3923.50.00 | Vietnam Customs / Trade Portal | Current lookup data | Reference for description, MFN, VAT and measures. | Chapter 39, heading 3923, subheading 392350. | Verify tariff at declaration time. |
| Ordinary duty | Decision 15/2023/QD-TTg | Prime Minister | Effective from 15 July 2023 | Ordinary import duty application. | 150% of MFN principle where applicable. | Check if a specific ordinary rate exists. |
| VAT | Decree 174/2025/ND-CP | Government | 1 July 2025 to 31 December 2026 | VAT reduction review. | Excluded goods/services appendices. | Do not automatically apply 8%. |
| Labeling | Decree 43/2017/ND-CP and 111/2021/ND-CP | Government | 111/2021 effective 15 February 2022 | Goods labeling requirements. | Goods name, origin and responsible entity. | Commercial circulation should be reviewed. |
| Classification risk | Decision 2079/QD-TCHQ | General Department of Customs | Issued 19 July 2021 | Classification risk list. | Plastic caps and plastic articles may be risk items. | Use as a risk checklist, not a final ruling. |
| Food-contact use | Decree 15/2018/ND-CP, Circular 52/2015/TT-BYT if applicable | Government / MOH | Verify current validity | Only for food-contact closures. | Food safety inspection scope. | Not automatically for cosmetic packaging. |
VIEW / DOWNLOAD ORIGINAL REFERENCES
Businesses should also verify documents on official legal databases or the issuing authority’s website before applying them.
CUSTOMS DOSSIER
Commercial documents
- Commercial Invoice.
- Packing List.
- Bill of Lading / Air Waybill.
- Sales Contract / Purchase Order if any.
- C/O if preferential duty is claimed.
- Catalogue, photos and specification sheet.
Technical / specialized files if any
- Plastic material, size and closure type.
- Material COA or test report if required.
- Labeling file.
- Use explanation: cosmetic, food, medical or factory use.
- Item list for multiple SKUs.
| File group | Documents | Used for | Prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO | Declaration and valuation | Purchasing/Docs | Generic product name | State plastic closure/cap/stopper clearly. |
| Transport | B/L or AWB, arrival notice, pre-alert | Delivery order and ETA tracking | Forwarder/Docs | Mismatch packages/weight | Compare with packing list. |
| Technical | Catalogue, photos, specification | HS review | Supplier/Compliance | Function not proven | Prepare photos fitted to packaging. |
| Origin | C/O, transport evidence | Preferential duty | Supplier/Export team | Wrong HS or description | Check draft C/O. |
| Labeling | Original label, Vietnamese label if required | Market circulation | Importer/QA | Missing origin/responsible party | Review before sale or distribution. |
CLEARANCE DECISION POINTS
| Decision point | Question | Proof | Impact if unclear | Recommended action |
|---|---|---|---|---|
| HS code | Is the item truly a packaging closure? | Catalogue, photos, drawings | Yellow/red lane or explanation request | Finalize technical description before invoice. |
| Intended use | Cosmetic, food, medical or household use? | PO, contract, use explanation | Different specialized policies | Separate purpose by item. |
| C/O | Does C/O match HS, description and route? | Draft C/O, B/L, invoice | Preference denied | Review draft before ETA. |
| Labeling | Are imported goods labeled sufficiently? | Original label/photos | Supplement request or circulation risk | Prepare label review. |
| Closure type | Mixed with pump/sprayer/dropper? | Detailed packing list | Incorrect HS | Split invoice lines by function. |
| Value | Is declared value supported? | Contract, invoice, payment proof | Valuation query | Prepare price basis and Incoterms. |
PRACTICAL E2E PROCESS
Step 1 – Pre-ETA review
Confirm HS 3923.50.00 or alternative direction; check duty, VAT, C/O, labeling and use.
Step 2 – Lock documents
Match product name, material, quantity, weight, origin and item codes across all documents.
Step 3 – Specialized review
For food/medical use or filled products, review specialized dossier before arrival.
Step 4 – Customs declaration
Prepare explanation for HS, value, C/O, product description and use.
Step 5 – Clearance and delivery
Release goods, count SKUs and prepare labels if goods circulate commercially.
Step 6 – Post-clearance archive
Keep declaration, C/O, invoice, packing list, B/L, catalogue and photos.
PRE-ETA RISK CHECKLIST
| Risk | Impact | Pre-ETA control | Documents |
|---|---|---|---|
| Generic “plastic accessories” description | Cannot prove closure function | Ask supplier to state plastic cap/closure/stopper | Invoice, packing list, catalogue |
| Pump/sprayer/dropper mixed in one line | Wrong HS for different functions | Separate SKUs by function | Item list/photos |
| C/O description or HS mismatch | Preference denied | Review draft C/O | C/O, invoice, B/L |
| Food-contact use not reviewed | Possible specialized hold | Confirm use in PO | PO, specification, test report |
| Used/recycled goods declared as new | Inspection risk | Request new-goods declaration | Invoice/photos |
| Label/origin mismatch | Document and circulation risk | Check original labels | Label photos |
FAQ
1. Is an import permit required?
Do not conclude absolutely. Empty plastic closures usually focus on customs, HS, duty and labeling; food/medical/filled-product cases require separate review.
2. Is HS 3923.50.00 the main code?
It is the primary reference when the item is a plastic stopper, lid, cap or closure for packing goods, but documents must prove the function.
3. Is cosmetic product notification required?
Not for empty packaging only. If imported with filled cosmetics, review the finished product regime.
4. Can C/O reduce duty?
Yes, if the C/O is valid and the FTA schedule grants preference for the relevant HS code.
5. Is Vietnamese labeling required?
For commercial circulation, labeling should be reviewed under Decrees 43/2017 and 111/2021.
6. What if caps, pumps and droppers are in one shipment?
Do not merge them. Separate invoice lines and review HS by function.
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EXECUTION SUPPORT FROM TGIMEX
This article provides a review map for plastic caps, stoppers and closures. In practice, each shipment still needs item-level review based on catalogue, specification, documents, origin, intended use and packing method.
Pre-ETA review
- Fix HS, MFN, VAT, C/O and description.
- Check item list, material, size and use.
- Prevent confusion with pumps, sprayers and droppers.
E2E document control
- Cross-check invoice, packing list, B/L/AWB, C/O and catalogue.
- Coordinate agents, carriers, ETA and pre-alert.
- Support customs declaration and post-clearance archive.
For packaging component shipments involving C/O, labeling or possible specialized policies, businesses should start document review before the cargo arrives, not after.
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