Preservative used for cosmetic manufacturing is a high-risk raw material for customs classification because the same commercial name may refer to a single substance, a multi-component blend, a solvent-based solution, or a ready-made preservative system. If the invoice only states “preservative”, the shipment may face incorrect HS Code, missed chemical declaration, insufficient SDS/COA, unverified ASEAN cosmetic ingredient restrictions, or loss of C/O preferential duty. This article provides an E2E map for pre-ETA review: HS, duty, C/O, chemical compliance, dossier and customs decision points.

Quick facts

Item	What to review	Operational note
Product	Preservative used as cosmetic raw material; it may be a single substance, mixture, solution or commercial preservative blend.	Do not apply this article automatically to surfactants, emollients, extracts, fragrance oils, actives or colorants if the product nature is different.
Indicative HS	No single HS should be fixed. Common review directions include 2909.49.00, 2916.31.00, 2916.19.00, 2918.29.00, 2933.99.xx, 3824.99.xx or other codes depending on chemistry.	HS must be supported by CAS number, SDS, COA, TDS, composition percentage and actual import purpose.
Duty and VAT	Standard VAT is 10%. Duty is split by scenario: 2909.49.00: MFN 0%, 2916.31.00: MFN 5%, and 2916.19.00/2918.29.00/2933.21.00/3824.99.99 must be reviewed in the detailed matrix below; standard VAT is 10%.	Do not apply one duty rate to all preservatives.
Chemical policy	Chemical import declaration may apply if the CAS is listed in Appendix V of Decree 113/2017/ND-CP or the mixture meets the hazardous-chemical conditions amended by Decree 82/2022/ND-CP.	Review by CAS and hazard classification, not only by commercial name.
Cosmetics compliance	If imported as a raw material for manufacturing/R&D, it is normally not handled as a finished cosmetic product; however, the ingredient must be checked against cosmetic ingredient restrictions before formula use.	If imported as a finished cosmetic product for circulation, switch to cosmetic product notification procedure.

Legal note: Preservative is a functional name, not a customs classification basis. Companies should review the catalogue, TDS, SDS/MSDS, COA, CAS number, composition %, material code and actual import purpose. Do not state “no license/no chemical declaration required” before reviewing the chemical list and technical dossier.

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

Scope of application

Covered cases

Single-substance preservatives such as phenoxyethanol, sodium benzoate, potassium sorbate, parabens, benzyl alcohol, chlorphenesin, DMDM hydantoin or iodopropynyl butylcarbamate.
Commercial preservative blends containing active preservative substances, solvents, humectants or boosters.
Raw materials imported for cosmetic manufacturing, R&D, formula testing or plant use.

Not automatically covered

Disinfectants, biocides, antiseptics or products with non-cosmetic antimicrobial claims.
Food additives, pharmaceutical ingredients, pesticides or chemicals used for other industries.
Finished cosmetic products containing preservatives and packaged for direct retail circulation.

Classification and product identification

For preservative imports, the first step is to determine the chemical nature before considering the cosmetic use. A commercial name may represent pure phenoxyethanol, phenoxyethanol blended with ethylhexylglycerin, benzoate/sorbate salts, a paraben system, or a preservative preparation with solvent. CAS number, assay, purity, solvent, liquid/powder form, pH, flash point, UN number and GHS classification may affect HS, transport safety and chemical declaration.

Criterion	Document to check	Risk if misdescribed	Suggested goods description
Commercial name and INCI/chemical name	TDS, COA, SDS, specification	Generic “preservative” may be insufficient for customs classification.	“Cosmetic preservative – [chemical/INCI name], CAS…, raw material for cosmetic manufacturing”.
CAS number and composition %	SDS Section 3, COA, manufacturer data	Wrong CAS may lead to wrong HS, chemical declaration and C/O.	State the main CAS and active percentage where appropriate.
Single substance or mixture	SDS, formulation sheet, assay	Single substances in Chapter 29 differ from preparations under Chapter 38.	Indicate “single substance” or “preservative blend/preparation”.
DG / hazard status	SDS Sections 2, 9 and 14; UN/IMDG/IATA if any	Wrong transport booking, DG declaration or port/warehouse handling.	State DG/non-DG according to the latest SDS.
Import purpose	PO, contract, R&D/manufacturing records	Food/pharmaceutical/biocidal use may trigger a different policy regime.	“Raw material for cosmetic manufacturing/R&D, not for direct retail”.

HS Code – Duty – C/O

For preservatives, the decisive classification factors are the CAS number, chemical structure, active concentration, solvent base, and whether the goods are a single substance or a formulated blend. Therefore, duty must be reviewed by scenario, not under one generic “preservative” rate. The table below is a pre-ETA working matrix; the official declaration must still be checked against the tariff in force, the actual C/O and the customs declaration date.

Common preservative group	Indicative HS	Application condition	Indicative MFN	Indicative ordinary duty	VAT	C/O/FTA to review	Required documents	Risk if wrong
Phenoxyethanol / ether-alcohol preservative	2909.49.00	Single substance with clear CAS; e.g. phenoxyethanol CAS 122-99-6, not a ready-made blend with ethylhexylglycerin, solvent or multiple actives.	0%	0% if no separate ordinary rate applies on the declaration date; verify before filing.	10%	C/O may not create duty savings if MFN is already 0%, but may still be needed for origin evidence or contract requirements.	COA assay, SDS Sections 1–3, CAS, TDS, chemical name on invoice.	A blend with solvent/boosters may not fit a single-substance code.
Benzoic acid / sodium benzoate / potassium benzoate	2916.31.00	Benzoic acid, salts or esters used as cosmetic/industrial preservative raw material.	5%	7.5%	10%	Review ATIGA, ACFTA, RCEP, VKFTA/AKFTA, EVFTA/UKVFTA, CPTPP by origin; many routes may reduce to 0% if origin proof is valid.	CAS, COA, SDS, grade, concentration, cosmetic/non-food use.	“Food grade/food additive” documents may trigger food additive policy review.
Sorbic acid / potassium sorbate	2916.19.00	Unsaturated acyclic monocarboxylic acid or salts/derivatives fitting 2916.19; not a formulated preservative system.	0% working reference for 2916.19.00; verify the tariff in force.	0% if no separate ordinary rate applies; verify before filing.	10%	If MFN is 0%, C/O mainly supports origin evidence; if tariff changes, review FTA by exact 8-digit HS.	CAS, COA, SDS, specification, grade, import purpose.	May be misclassified if actually a food additive or ready-made blend.
Parabens – methylparaben, propylparaben, butylparaben	2918.29.00	Esters/derivatives of p-hydroxybenzoic acid where the chemical structure fits; single substance.	0% working reference for Chapter 29 chemical substances; verify exact 8-digit HS.	0% if no separate ordinary rate applies.	10%	C/O may not reduce duty further where MFN is 0%; still review origin evidence if required.	Chemical name, INCI, CAS, assay, COA, SDS, cosmetic use limit.	A mixture of several parabens in solvent may fall under a preparation code.
DMDM hydantoin or hydantoin derivatives	2933.21.00	Nitrogen heterocyclic compounds with hydantoin structure; apply only when chemical structure supports this line.	0% working reference; verify current tariff.	0% if no separate ordinary rate applies.	10%	C/O mainly completes origin records where MFN is already 0%.	CAS, chemical structure, SDS, COA, INCI, concentration limit.	Using only INCI without structure review may lead to Chapter 29/38 error.
Imidazolidinyl urea / Diazolidinyl urea / other heterocyclic preservatives	2933.99.xx	Nitrogen heterocyclic compounds not more specifically covered; exact 8-digit HS must be decided after structure review.	0% working reference for many heterocyclic lines; verify exact 8-digit HS.	0% if no separate ordinary rate applies.	10%	Review C/O when supplier issues origin proof; HS and description must match.	SDS, COA, CAS, structure, chemical name, INCI.	High risk if the importer relies only on trade name or manufacturer code.
Preservative blend / ready-made preservative system	3824.99.99 or suitable 3824.99.xx	Mixture of several preservative actives, solvent/stabilizer, and no longer classifiable as one defined substance under Chapter 29.	0% working reference for 3824.99.99; verify if the product falls under a different sub-line.	0% if no separate ordinary rate applies.	10%	C/O must match the finished blend/preparation; component-origin documents cannot replace the C/O of the imported goods.	SDS Section 3, formulation sheet, active %, solvent, TDS, blend COA.	Using Chapter 29 for a blend may trigger HS challenge and duty adjustment.
Biocide/disinfectant claim	3808.94.xx or another specialised group	Review only if the goods claim disinfectant, biocide, surface sanitizer or use outside cosmetic preservation.	Not applied by default in this cosmetic-preservative article.	Review under the separate policy for heading 3808 and relevant permits.	10% or actual VAT policy.	C/O does not solve licensing risk where the product is a disinfectant/biocide.	Label, claim, SDS, use purpose, specialised permit if any.	Wrong product nature may trigger chemical/biocide/pharmaceutical/food-additive controls.

Duty note: The rates above are a working reference for pre-ETA costing. Before filing, the dossier must be checked against Decree 26/2023/ND-CP, amending Decree 108/2025/ND-CP, special preferential tariff schedules and the actual declaration system. Do not apply one duty rate to all preservatives.

C/O and FTA review matrix for preservatives

Origin route	Origin document	Preferential duty to review	Application conditions	Documents to cross-check	Common risk
ASEAN	Form D – ATIGA	Many chemical HS lines may be 0% if PSR is met.	WO/RVC/CTH/CTSH, direct transport, HS and description consistency.	C/O, invoice, packing list, B/L, SDS, COA, CAS, HS on C/O.	C/O describes generic “preservative” while SDS shows a multi-component blend.
China	Form E – ACFTA or RCEP origin document	Compare ACFTA and RCEP by exact HS; many lines may reduce to 0%.	Qualified exporter/manufacturer, correct origin criterion, direct transport or transit proof.	Form E/RCEP, third-party invoice if any, B/L, COA, SDS.	Shipment from China does not automatically mean Chinese origin.
Korea	Form AK/VK or RCEP	Review AKFTA/VKFTA/RCEP to select the appropriate tariff.	PSR met; description and HS on C/O match the declaration.	C/O, invoice, packing list, B/L, COA, SDS.	Wrong AK/VK form or HS mismatch may remove preferential duty.
Japan	VJEPA/AJCEP/CPTPP/RCEP	Do not assume 0%; check each agreement by 8-digit HS.	Valid C/O or origin statement; correct CTH/RVC criterion.	C/O, contract, invoice, transport documents, COA, SDS.	Blend products using multi-country materials may fail origin criteria.
EU/UK	EVFTA/UKVFTA	Preferential rate depends on HS, phase-out schedule and valid proof of origin.	Valid statement on origin/C/O, correct exporter and goods description.	Origin statement, invoice, packing list, COA, SDS.	Missing REX/statement or inconsistent description with SDS/invoice.
Australia–New Zealand / India / Hong Kong	AANZFTA, CPTPP, AIFTA, AHKFTA where applicable	Check special preferential schedules by exact 8-digit HS.	Correct form, origin criterion, direct transport and eligible country.	C/O, B/L, invoice, packing list, COA, SDS.	Using FTA without checking route or excluded country may cause duty reassessment.

Pre-ETA C/O checklist

Compare HS on C/O with intended declaration HS and invoice description.
Review origin criterion: WO, RVC, CTH, CTSH or agreement-specific PSR.
Check third-party invoice, direct transport, exporting country, origin country and transit evidence.
Match description against CAS, COA, SDS and TDS; avoid overly generic descriptions.
Check C/O issue date, signature/seal, quantity, weight, Incoterms, invoice number and B/L number.

Applicable specialised policy

Goods scenario	Possible policy	Documents to check	Authority / portal	When to do	Risk note
Chemical listed in Appendix V or hazardous mixture containing Appendix V substances	Chemical import declaration under Decree 113/2017/ND-CP as amended by Decree 82/2022/ND-CP.	SDS, CAS, composition %, GHS classification, invoice, packing list, B/L/AWB.	National Single Window / chemical declaration portal where applicable.	Before customs clearance.	Missing declaration may delay clearance.
Preservative not subject to chemical declaration	SDS/COA should still be retained to prove product nature if queried.	SDS, COA, TDS and internal Appendix V review.	Customs branch.	Before ETA.	Do not state no declaration until CAS is checked.
DG / UN classified goods	Dangerous goods transport requirements under IMDG/IATA where applicable.	SDS Section 14, DG declaration, packing instruction.	Carrier, airline, port/warehouse, forwarder.	Before booking.	Wrong DG status may lead to rejection or storage charges.
Cosmetic R&D/manufacturing raw material	Review ASEAN cosmetic restrictions and Circular 06/2011 with Circular 34/2025 before formula use.	INCI, CAS, use limit, COA, PIF data if relevant.	Company compliance/QA; health authority at finished product notification stage.	Before import and before production.	Imported raw material does not mean unrestricted cosmetic use.
EPE/FDI/factory import	Warehouse, usage purpose, material code and reporting control may apply.	PO, contract, production plan, SDS, internal material code.	Customs and relevant local authorities.	Before declaration.	Wrong import purpose may affect later audit/settlement.

Legal documents to review

Document group	Legal document	Issuing authority	Effective time	Role	Key review point	Review note
Law	Law on Chemicals 2007	National Assembly	Check validity at import time.	Legal basis for chemical activities and safety.	Chemical activities, chemical safety sheets.	Applies where the goods are chemicals.
Decree	Decree 113/2017/ND-CP	Government	Issued on 09/10/2017, effective from 25/11/2017; partially amended.	Details implementation of the Law on Chemicals.	Appendix V and chemical import declaration rules.	Review by CAS and hazardous mixture status.
Decree	Decree 82/2022/ND-CP	Government	Effective from 22/12/2022.	Amends Decree 113/2017/ND-CP.	Chemical declaration and exemptions.	Use together with Decree 113.
Circular	Circular 06/2011/TT-BYT and 34/2025/TT-BYT	Ministry of Health	Circular 06 effective 01/04/2011; Circular 34 effective 18/08/2025.	Cosmetics management framework.	Notification, PIF, ingredient/label responsibility.	Relevant when the raw material is used in cosmetic formulas.
Circular	Circular 31/2022/TT-BTC	Ministry of Finance	Effective from 01/12/2022.	Vietnam export-import nomenclature.	HS structure and legal notes.	Initial classification basis.
Tariff	Decree 26/2023/ND-CP and 108/2025/ND-CP	Government	Decree 26 effective 15/07/2023; Decree 108 effective 19/05/2025.	MFN import tariff and amendments.	Check exact 8-digit HS and duty on declaration date.	Do not use outdated duty rates.
VAT	Decree 174/2025/ND-CP	Government	Effective from 01/07/2025.	VAT reduction review if eligible.	Exclusion annex and valid period.	Do not default to 8%.

View / download original legal sources

Companies should cross-check official legal databases or issuing authority websites before applying the guidance.

View source: Decree 113/2017/ND-CP View source: Decree 82/2022/ND-CP View source: Chemical import declaration View source: Circular 31/2022/TT-BTC View source: Decree 26/2023/ND-CP View source: Circular 06/2011/TT-BYT

Customs clearance dossier

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if available.
C/O if claiming preferential duty.
Catalogue/TDS, SDS/MSDS, COA, specification and original label photos.

Specialised documents if applicable

Chemical import declaration.
Latest SDS.
DG declaration if dangerous goods.
Proof of cosmetic raw material/R&D/manufacturing use.
Ingredient restriction review for cosmetic formulation.

Dossier group	Required document	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, contract/PO	Declaration, valuation, quantity control	Purchasing/Docs	Generic name, missing CAS or grade.	Request shipper to revise description before final documents.
Technical	SDS, COA, TDS, specification	HS, DG and chemical declaration	QA/R&D/Supplier	Outdated SDS or unclear Section 3/14.	Use the latest SDS with CAS and transport classification.
Chemical	Chemical declaration data, CAS, composition %, hazard class	Chemical declaration if applicable	Compliance/Docs	Appendix V not reviewed.	Prepare CAS comparison before ETA.
Origin	C/O, direct transport proof, third-party invoice if any	Preferential duty	Supplier/Forwarder/Docs	C/O description/HS differs from declaration.	Check C/O against invoice, packing list, B/L and COA.
Label & warehouse	Original label, lot/batch, shelf life, storage condition	Physical inspection and warehouse receipt	Warehouse/QA	COA lot does not match package label.	Request label photo, batch and shelf life before shipment.

Decision points that may hold the shipment

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended handling
HS support	Single substance or mixture? What is the main CAS?	SDS, COA, TDS, chemical structure	HS rejection, duty adjustment or analysis request.	Finalize HS pre-ETA with full technical dossier.
Chemical declaration	Is the CAS in Appendix V? Is the mixture hazardous?	SDS Sections 2–3, Appendix V review	Additional filing before clearance.	Review chemical policy before booking/ETA.
C/O eligibility	Correct form, HS, description and origin criterion?	C/O, invoice, B/L, COA	Loss of preferential duty.	Check draft C/O before issuance.
DG status	Does Section 14 show UN/class/packing group?	SDS, DG declaration	Carrier refusal or storage cost.	Send SDS to forwarder before booking.
Import purpose	Cosmetic raw material, R&D, food, pharma or biocide?	PO, contract, internal records	Different specialised policy.	State actual use consistently in internal dossier and supporting documents.

Practical E2E workflow

Step 1: Pre-ETA review

Confirm CAS, composition %, physical state, indicative HS, duty, C/O, DG status and chemical declaration risk.

Step 2: Lock technical documents

Collect SDS, COA, TDS, specification, label photos, lot/batch and manufacturer data before shipment.

Step 3: Chemical declaration if required

Prepare declaration data through the applicable portal after reviewing Appendix V and hazard classification.

Step 4: Customs declaration

Handle green/yellow/red channels and explain HS, value, goods description, C/O, SDS and chemical policy.

Step 5: Clearance and post-clearance records

Store shipment records, labels, batch, shelf life, SDS and COA for traceability and post-clearance audit.

Step 6: Raw material warehouse receipt

QA/R&D verifies lot number, COA, storage condition and packaging status before internal release.

Pre-ETA risk checklist

Risk	Consequence	Pre-ETA control	Document to check
Generic “preservative” description	Insufficient basis for HS/policy.	Request INCI/chemical name/CAS/composition.	SDS, COA, TDS.
Chemical declaration not reviewed	Additional filing before clearance.	Compare CAS with Appendix V.	SDS Sections 2–3, Decree 113/82.
Wrong DG/non-DG status	Carrier rejection or storage cost.	Send SDS to forwarder before booking.	SDS Sections 9 and 14.
Wrong C/O form/HS/description	Loss of preferential duty.	Check draft C/O.	C/O, Invoice, B/L, COA.
Lot/COA mismatch	Warehouse QA and customs explanation difficulty.	Request label/batch/shelf life photos.	Original label, COA, Packing List.
Biocidal/disinfectant claim	Different specialised policy.	Review label/claim/catalogue before purchase.	Catalogue, label, SDS, contract.

FAQ

Question	Answer
Does preservative require cosmetic notification?	If imported as a raw material for manufacturing/R&D, it is usually not handled as a finished cosmetic product. If imported as a finished cosmetic for circulation, product notification must be reviewed.
Is chemical import declaration required?	It may be required if the CAS is listed in Appendix V of Decree 113/2017/ND-CP or the hazardous mixture meets declaration conditions; review SDS and composition.
Which HS applies to phenoxyethanol?	2909.49.00 is commonly reviewed for pure phenoxyethanol; blends may require preparation/mixture classification.
Can C/O reduce duty?	Yes, only where the C/O is valid, matches HS/description and satisfies origin and direct transport rules.
Can a blend use the HS of the main active?	Not automatically. The composition, principal function and classification rules must be reviewed.
Is English SDS sufficient?	It is commonly used for technical review; however, a translation or key data summary should be prepared if requested.

Application note: This content is for operational reference. Companies must verify valid legal documents, tariff schedules and actual product dossiers before declaration.

Execution support from TGIMEX

For preservatives, the key risk is not only the commercial documents but the ability to prove the chemical nature: clear CAS, SDS composition, COA assay, accurate invoice description and C/O matching the HS. If these elements are weak, customs may question HS classification, customs value, chemical declaration, DG status or preferential duty eligibility.

TGIMEX can support an E2E import execution model from pre-ETA review to clearance and post-clearance file retention, especially for cosmetic raw materials containing multiple actives, multiple CAS numbers or commercial blends.

1. HS and tax before ETA

Prepare a CAS – chemical name – INCI – HS – MFN – ordinary duty – VAT – C/O/FTA matrix; distinguish Chapter 29 single substances, Chapter 38 blends and biocide/disinfectant-claim scenarios.

2. Chemical dossier control

Review SDS Sections 1–3, COA, TDS, composition %, hazard classification, DG/MSDS, chemical declaration conditions and product description on invoice/packing list/declaration.

3. C/O and preferential duty

Cross-check C/O form, origin criterion, HS, goods description, third-party invoice, direct transport and consistency among C/O – Invoice – Packing List – B/L – COA – SDS.

4. Clearance and post-audit file

Prepare HS/policy explanation files, support Yellow/Red channel handling, retain shipment files and build evidence for post-clearance audit or raw material traceability.

For preservative shipments with sensitive CAS, multi-active blends, liquid solvents, flammable components or preferential C/O, companies should review the dossier before loading. A small mismatch among SDS, COA, invoice or C/O may change HS, duty, chemical policy and clearance timeline.

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