Problem: A same-owner cosmetic combo may be mishandled if the shipment is described only as “cosmetic set” without proving the essential character, notification status of each item, labels and C/O consistency.

Agitate: For retail sets, the risk often lies in how individual items are bundled: main item, accessory item, sample, outer box, Vietnamese sub-label, notification number and invoice description may not match.

Solution: This article provides an E2E map for pre-ETA review: HS code, duties, C/O, cosmetic compliance, document set, customs clearance process and key risk controls.

Legal note

This guide applies to imported cosmetic combos intended for commercial circulation in Vietnam. HS, duties and specialized policy must be reviewed against actual catalogue, SKU, formula, label, C/O and import purpose.

QUICK FACT

Review area	Operational conclusion	What to verify before declaration
Product scope	Same-owner cosmetic combo sold as a set: multiple cosmetic products packed together for retail sale under the same brand owner/responsible person.	Do not apply to sets containing beauty supplements, electric beauty devices, non-cosmetic accessories or separate promotional items without further review.
Indicative HS	Common directions: 3304.99.90 for skincare sets; 3304.10.00, 3304.20.00, 3304.91.00 for makeup sets depending on the essential character; 3303.00.00 or 3307 for fragrance/toilet preparations.	Determine by set structure, essential character, product function, retail packing and actual documents.
Taxes	MFN may range around 18%–22%; ordinary duty around 27%–33%; VAT normally 10%, potentially 8% during the VAT-reduction period if eligible.	Verify the tariff schedule, HS at 8-digit level and C/O at declaration date.
Specialized policy	Imported cosmetics for circulation require cosmetic product notification and appropriate PIF control.	A multi-product combo is not automatically covered by one notification number.
Labeling	Original label, Vietnamese sub-label, owner information, ingredients, claims, lot number, expiry date and origin must be checked.	Mismatch between notification, invoice, packing list and labels may trigger explanation or post-clearance risks.

SCOPE OF APPLICATION

This article only covers same-owner cosmetic combos sold as retail sets, including skincare sets, makeup sets or multiple cosmetic products packed together as one commercial retail unit.

It does not automatically apply to combos containing supplements, electric/battery beauty devices, medical devices, disinfectants or treatment-claim products.
Samples, testers, gifts, exhibition goods, temporary imports or non-commercial goods may follow different procedures.
If the set contains perfume, body spray or alcohol-based products, Dangerous Goods transport requirements must be reviewed.
If accessories, batteries, adapters, wireless modules or software are included, each component must be reviewed separately.

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

CLASSIFICATION & PRODUCT IDENTIFICATION

Set structure

Verify whether the goods qualify as a retail set rather than separate items grouped on an invoice. Check packaging, common use, routine and the item giving the essential character.

Cosmetic compliance file

Each item should be checked against notification number, formula, PIF, CFS where required and authorization from the manufacturer/brand owner.

Label and commercial documents

Outer-box label, individual labels, leaflet and commercial descriptions must match invoice, packing list, catalogue, notification and C/O.

Identification warning

Generic descriptions such as “cosmetic set”, “beauty box” or “gift set” may lead to incorrect HS classification, specialized policy, labeling and C/O review.

TECHNICAL IDENTIFICATION CRITERIA

Criteria to check	Documents to compare	Risk if described incorrectly	Suggested goods description
Set/combo structure	Product photos, packing specification, catalogue, sales kit layout.	Customs may split items or challenge the set classification.	“Cosmetic skincare/makeup combo, including…, same owner, packed for retail sale as a set”.
Item giving essential character	Value breakdown, main function, marketing description, instruction leaflet.	Incorrect HS if based on an accessory/gift item instead of the main item.	State the main item and function: skincare, lip makeup, eye makeup, powder, perfume.
Legal status of each item	Notification numbers, formula, CFS/authorization, PIF.	One unnotified item may affect the whole commercial combo.	List each SKU/variant with corresponding notification number.
Labels and retail packaging	Artwork, original label, planned Vietnamese sub-label, outer box.	Incorrect claims or missing mandatory information.	Avoid treatment claims where the product is only cosmetic.
Accessories or non-cosmetic items	Accessory list, tools, bags/boxes, samples, devices if any.	May trigger separate policy such as electrical safety, battery or quality inspection.	Separate cosmetics from accessories or devices.

HS CODE – DUTIES – C/O

HS should not be determined mechanically by the phrase “combo”. First verify if the goods qualify as a retail set, then identify the item that gives the set its essential character. For high-value or ambiguous shipments, an advance ruling or a classification memo should be considered.

Indicative HS table

Indicative HS	Application condition	Risk if misapplied	Documents to verify
3304.99.90	Skincare-oriented set where the essential character is other skin-care preparation.	Wrong if the essential character is lip/eye makeup, powder or perfume.	Catalogue, use, ingredients, label, set structure, value breakdown.
3304.99.30	Set mainly consisting of face/skin creams or lotions.	Too broad if the main item is not cream/lotion.	Dosage form, instruction, product name, label.
3304.10.00	Makeup set whose essential character is lip makeup.	Wrong for skincare, eye makeup or powder set.	SKU list, value ratio, product photos.
3304.20.00	Makeup set whose essential character is eye makeup.	May cause duty and classification discrepancy.	Catalogue, eye-use claim, warnings.
3304.91.00	Set whose essential character is powder, pressed or not.	Not for cushion/cream/lotion if not powder.	Physical form, composition, product description.
3303.00.00	Set whose essential character is perfume/toilet water.	May be wrong for body mist/deodorant/cosmetic spray.	Concentration, use, label, SDS if alcohol-based.
3307.90.40 / 3307.90.90	Only where the essential character falls under other perfumery/cosmetic/toilet preparations.	Incorrect policy and duty if used broadly.	Function, ingredients, form, label.

Indicative duty table

Indicative HS	Description	MFN/preferential	Indicative ordinary duty	VAT	Application note
3304.99.90	Other cosmetics/skin-care preparations	18%	27%	10% or 8% if eligible for VAT reduction	Common direction for other skincare sets; finalize by essential character.
3304.99.30	Face or skin creams/lotions	18%	27%	10% or 8% if eligible	Use only where the file clearly shows cream/lotion nature.
3304.10.00	Lip makeup preparations	20%	30%	10% or 8% if eligible	For lip-makeup sets where the lip product gives essential character.
3304.20.00	Eye makeup preparations	22%	33%	10% or 8% if eligible	For eye-makeup sets where the eye product gives essential character.
3304.91.00	Powder, pressed or not	22%	33%	10% or 8% if eligible	Only where the set’s essential character is powder.
3303.00.00	Perfumes and toilet waters	18%	27%	10% or 8% if eligible	Review DG requirements if alcohol/flammable solvent is present.
3307.90.40 / 3307.90.90	Other perfumery/cosmetic/toilet preparations	18%–20%	27%–30%	10% or 8% if eligible	Use only if goods description and nature match.

Duty control principle

The duty rates are indicative for common Chapter 33 lines. The importer must verify MFN duty, special preferential tariff and VAT policy at the declaration date.

C/O and FTA review

Route/origin	C/O or origin document	Indicative special preferential duty	Conditions	Documents to compare	Risk
ASEAN	Form D / ATIGA origin document	Often 0% for many Chapter 33 lines where available.	Origin rule, direct transport, matching description and HS.	C/O, invoice, packing list, B/L, WO/RVC/CTH/CTSH criteria.	Wrong form or set description may lead to rejection.
China	Form E / ACFTA or RCEP document	Indicatively 0% if the HS line is committed and C/O is valid.	Compare ACFTA/RCEP tariff by 8-digit HS at declaration year.	Form E, third-party invoice if any, through B/L.	Incorrect third-party invoice declaration is a common risk.
Korea	Form AK / VK / RCEP	Indicatively 0% where AKFTA/VKFTA/RCEP applies.	Select the most beneficial agreement that matches origin rules.	C/O, origin criteria, transport documents.	Wrong agreement or origin criteria may void preference.
Japan	Form VJ / AJ / CPTPP / RCEP	Indicatively 0% where the line has reached zero.	Check exporting country, agreement and product-specific rules.	C/O or permitted self-certification, invoice, B/L.	No direct-transport proof may trigger rejection.
EU	EUR.1 or EVFTA statement on origin	Indicatively 0% where tariff elimination applies.	Satisfy EVFTA origin rules and document requirements.	Statement/EUR.1, REX if relevant, invoice.	“Made in EU” alone is not a valid origin proof.
UK	EUR.1 or UKVFTA origin document	Indicatively 0% where applicable.	Compare UKVFTA schedule by HS.	C/O/statement, invoice, B/L.	Wrong form or vague goods description.
Australia/New Zealand	AANZ Form or CPTPP/RCEP document	Indicatively 0% if eligible.	Compare AANZFTA, CPTPP and RCEP.	C/O, self-certification if allowed, transport document.	Inconsistent origin on label, C/O and invoice.
India	Form AI / AIFTA	Must be checked; not all lines are automatically 0%.	Apply only where the HS line and origin criteria are met.	Form AI, origin criteria, invoice, B/L.	Assuming 0% without tariff-line support.
Hong Kong (China)	Form AHK / AHKFTA	Check AHKFTA schedule by HS and declaration year.	Valid origin document and direct transport.	C/O, invoice, packing list, transport documents.	Confusion between origin country and export country.

SPECIALIZED MANAGEMENT POLICY

Goods scenario	Potential policy	Documents to check	Authority/portal if identifiable	Recommended timing	Risk note
Standard cosmetic combo for market circulation	Cosmetic product notification, PIF control and imported-goods labeling.	Notification for each product/variant, CFS or authorization where applicable, formula, PIF and labels.	Drug Administration of Vietnam – Ministry of Health / National Public Service Portal; Customs authority.	Before declaration and before ETA.	Do not assume one combo equals one notification file where the items have different formulas or functions.
Combo containing acne-treatment, antibacterial, therapeutic or disease-related claims	May fall outside normal cosmetic scope; medicine, medical device, chemical or disinfectant policy may need review.	Label, marketing claims, scientific substantiation, PIF and formula.	Ministry of Health or relevant specialized authority depending on classification.	Before PO/order confirmation.	Incorrect claims may make the product ineligible for normal cosmetic handling.
Combo containing perfume, body spray or alcohol-based flammable items	Besides cosmetic rules, Dangerous Goods transport requirements may apply by air/sea.	SDS/MSDS, alcohol content, flash point and packing instruction.	Carrier/airline, IATA/IMDG review via forwarder.	Before booking.	Missing DG documentation may cause carrier rejection.
Combo containing beauty device, massage device, LED mask, battery or charger	Quality inspection, conformity, battery, electrical safety or telecom policy may arise if connectivity exists.	Device catalogue, battery, adapter, wireless module and test report.	Relevant specialized ministry/NSW where applicable.	Before locking import configuration.	Do not merge devices into “cosmetics” to avoid policy error.
Samples, testers or gifts that are still released to market	Cosmetic management, labeling and circulation documents may still apply.	Import purpose, distribution plan, label and notification number.	Customs authority / DAV if the goods are placed on the market.	Before ETA.	The word “sample” does not automatically remove obligations if sold or commercially distributed.
Import for EPE/FDI/factory use	Customs regime applies by import purpose; policy still needs review if later released into the domestic market.	Contract, use purpose, distribution plan and notification file.	Customs authority; specialized authority if applicable.	Before deciding declaration regime.	Wrong import purpose may create post-clearance risks.
Used/refurbished goods or altered retail packaging	Import eligibility, quality, label, expiry date and product safety must be reviewed.	Actual photos, expiry date, COA if any and packaging condition.	Customs, market surveillance or post-market authority.	Before purchase.	Used cosmetics or non-intact packaging may be unsuitable for market circulation.

LEGAL DOCUMENTS TO REVIEW

Document group	Document name/number	Issuing authority	Effective date/application time	Role in procedure	Key provisions/appendices	Review note
Law	Customs Law No. 54/2014/QH13	National Assembly	Effective from 01/01/2015	Basis for customs declaration, documentary check and physical inspection.	Rules on customs dossiers, declaration, inspection and supervision.	Check amendments/supplements applicable at declaration time.
Law	Law on Export and Import Duties No. 107/2016/QH13	National Assembly	Effective from 01/09/2016	Basis for duty liability, preferential duty and exemptions where applicable.	Principles for applying duty rates and origin-based preferences.	Does not replace the tariff schedule by HS code.
Circular	Circular 06/2011/TT-BYT on cosmetic management, amended by 29/2020/TT-BYT, 34/2025/TT-BYT and relevant documents	Ministry of Health	Circular 34/2025/TT-BYT effective from 18/08/2025	Main basis for cosmetic notification, PIF, CFS, authorization and responsible person obligations.	Articles 4, 5, 7, 10, 12, 46 and notification appendices.	Verify the latest consolidated/effective text before filing.
Decree	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP on goods labeling	Government	Decree 111/2021/ND-CP effective from 15/02/2022	Basis for original label, Vietnamese sub-label and mandatory information for circulation.	Rules on mandatory contents and labeling responsibility for imported goods.	Also review cosmetic-specific labeling rules.
Decree	Decree 26/2023/ND-CP on export tariff and preferential import tariff	Government	Effective from 15/07/2023	Basis for MFN duty lookup for Chapter 33 HS lines.	Preferential import tariff by 8-digit HS code.	Check subsequent tariff amendments at declaration date.
Resolution	Resolution 204/2025/QH15 on VAT reduction	National Assembly	From 01/07/2025 through 31/12/2026	Basis for considering 8% VAT instead of 10% where eligible.	Article 1 and Article 2 on scope and validity.	Do not apply if goods fall under excluded groups; verify actual declaration.
Customs circular	Circular 38/2015/TT-BTC, amended by 39/2018/TT-BTC	Ministry of Finance	Verify validity at declaration time	Rules on customs dossier, declaration, customs value, C/O review and channel handling.	Dossier, supplementary declaration and documents to submit/present.	Does not replace cosmetic specialized regulations.
FTA tariff schedules	Special preferential tariff decrees for ATIGA, ACFTA, AKFTA, VKFTA, VJEPA, AJCEP, CPTPP, EVFTA, UKVFTA, AANZFTA, AIFTA, AHKFTA and RCEP where relevant	Government / competent authorities	By each tariff schedule period	Determines special preferential duty where valid C/O/origin proof is available.	Tariff line by 8-digit HS and origin rules by agreement.	Match agreement, origin, HS and declaration year.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises should search documents by number on official legal databases, the Government Portal or the website of the issuing authority.

Circular 34/2025/TT-BYT Consolidated cosmetics regulation Decree 26/2023/ND-CP Decree 111/2021/ND-CP

Enterprises should further verify on the official legal document portal or the issuing authority’s website before application.

CUSTOMS CLEARANCE DOCUMENT SET

Commercial documents

Commercial Invoice.
Packing List showing number of sets and items per set.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
C/O if preferential duty is claimed.
Catalogue, goods photos, original labels, SKU/model list.

Cosmetic compliance documents

Cosmetic notification number for each relevant product/variant.
Authorization letter if required.
CFS where required; exemption to be reviewed if claimed.
PIF, formula, quality standard and claim substantiation.
Labeling file and Vietnamese sub-label.
SDS/MSDS if alcohol/flammable solvent is present.

OPERATIONAL DOCUMENT CHECKLIST

Document group	Required documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial documents	Commercial Invoice, Packing List, Sales Contract/PO, B/L or AWB.	Declaration, customs value, quantity, origin and Incoterms review.	Exporter, importer and forwarder/docs team.	Goods name only states “cosmetic set”; set composition or set/pcs quantity is unclear.	Cross-check invoice, packing list, catalogue and labels by SKU and by set.
HS classification file	Catalogue, product photos, function description, item-value breakdown and ingredients.	HS finalization and explanation under Yellow/Red channel.	Importer, compliance team and customs broker.	HS selected by trade name only without identifying the set’s essential character.	Prepare a set-composition matrix: main item, accessory item, value, function and indicative HS.
Cosmetic notification file	Notification numbers for each product/variant, CFS where applicable, authorization and PIF.	Specialized policy control before circulation and support for customs explanation.	Importer/responsible person, brand owner and manufacturer.	One item in the combo has no notification or the notified name differs from the label.	Check notification number, product name, form, formula and brand owner.
Labeling file	Original label, Vietnamese sub-label, outer box, leaflet and warnings.	Market circulation control and explanation during inspection.	Brand owner, importer, marketing/legal team.	Missing ingredients, function, expiry date, lot number, origin or treatment claims.	Approve label draft before shipment and lock artwork with supplier.
C/O file	Appropriate C/O or origin document, invoice, packing list, B/L and direct-transport evidence.	Special preferential import duty claim.	Exporter, importer, forwarder and docs team.	Wrong form, wrong goods description, wrong HS or missing third-party invoice declaration.	Review form, origin criteria, description, HS, quantity, origin country, stamp/signature and issue date.
Special transport file if any	MSDS/SDS, DG declaration and packing instruction for perfume/alcohol/flammable items.	Booking, international transport and DG declaration if applicable.	Shipper, forwarder and carrier.	DG not declared or SDS missing, causing carrier rejection.	Check flash point, alcohol content and UN/class if any before booking.

CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended handling
Does it qualify as a retail set?	Are the items packed together for retail sale and intended for a common need?	Photos, packing specification, catalogue and sales kit.	Customs may split the items or request explanation.	Prepare a set-structure matrix before finalizing HS.
Which item gives the essential character?	Is the main character skincare, lip makeup, eye makeup, powder, perfume or another product?	Value ratio, function, marketing description.	Wrong HS and duty.	Document the classification logic with evidence.
Does each item have notification?	Does every product/variant in the combo have an appropriate notification?	Notification, PIF, CFS/authorization.	Market-circulation risk and possible supplementary request.	Do not commercially import until the file matches.
Is the C/O eligible?	Does the C/O/origin proof use the right form, HS and set description?	C/O, invoice, packing list, B/L.	Preference may be denied or duty may be reassessed.	Review C/O draft before original issuance.
Do labels match the compliance file?	Do name, function, ingredients, owner, expiry and lot match the documents?	Original label, sub-label, notification and artwork.	Explanations, relabeling or market delay.	Approve Vietnamese sub-label and artwork before import.
Are there non-cosmetic items in the set?	Are tools, devices, batteries, adapters or supplements included?	Packing list, catalogue and bill of materials.	Wrong specialized policy if everything is grouped as cosmetics.	Separate commodity groups and review each policy.

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Confirm indicative HS, cosmetic policy, C/O, VAT, label and DG status if relevant.

Step 2: Lock documents and technical files

Lock invoice, packing list, transport document, catalogue, label photos, SKU list, notification numbers, CFS/authorization and PIF.

Step 3: Handle specialized documents if any

Review notification, CFS, authorization, sub-label and claims; separate devices/accessories/non-cosmetics if present.

Step 4: Lodge customs declaration

Green channel allows clearance under system conditions; Yellow means documentary check; Red means documentary and physical inspection.

Step 5: Clearance, delivery and post-clearance file

Deliver goods, complete labeling plan, retain shipment file and prepare explanation set for post-clearance or cosmetic surveillance.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents to check
Applying one HS to all combos	Wrong duty, wrong policy and customs questions under Yellow/Red channel.	Identify retail-set status and essential character; prepare a classification memo.	Catalogue, set photo, value breakdown and invoice.
One item has no notification or mismatched notification	Insufficient market-circulation basis and post-market risk.	Match each SKU/variant with notification number before purchase.	Notification, PIF, CFS, authorization and label.
C/O uses wrong form or vague “set/combo” description	Preferential duty may be denied and origin verification may occur.	Review C/O draft before original issuance.	C/O form, origin criteria, invoice and B/L.
Vietnamese sub-label lacks information for each item	Delayed market release and market-inspection risk.	Design sub-label or accompanying leaflet suitable for multi-item sets.	Artwork, outer box, sub-label and leaflet.
Treatment or borderline claims in a cosmetic combo	May fall outside normal cosmetic procedure.	Review marketing claims before PO signing.	Label, website, catalogue and advertising materials.
Perfume/alcohol item not declared as DG where required	Carrier refusal, additional cost or schedule delay.	Review SDS/MSDS and request proper DG declaration if applicable.	SDS/MSDS, packing instruction and booking.

FAQ

Question	Answer
Does a same-owner cosmetic combo require cosmetic notification?	If imported for circulation in Vietnam, notification obligations must be reviewed. One combo is not automatically one notification number.
Can one HS code be declared for the whole combo?	Only if the goods qualify as a retail set and the essential character can be determined. Otherwise, split classification or further explanation may be required.
Do skincare sets and makeup sets use the same HS?	Not by default. Skincare often points to 3304.99; makeup may fall under 3304.10, 3304.20 or 3304.91 depending on the main item.
Can C/O reduce import duty?	Yes, if the origin document is valid, matches the agreement, HS and goods description, and satisfies origin rules.
Is Vietnamese sub-labeling required?	Imported goods for circulation in Vietnam must be reviewed for Vietnamese sub-label requirements.
Should labels and notification be reviewed only after arrival?	No. For multi-SKU combos, labels, notification numbers and C/O should be locked before ETA.

IMPLEMENTATION SOLUTION FROM TGIMEX

This article provides a map of HS, duties, documents and specialized policy. Actual shipments still require review against catalogue, SKU/model, documents, origin and import purpose.

TGIMEX has an agent network in more than 60 countries and is a member of WCA, WCA China Global, VLA and HNLA, with capability in international freight, customs clearance, C/O, import permits, warehousing and domestic delivery.

Pre-ETA review

HS, cosmetic policy, C/O, duty, labeling and retail-set classification.

Compliance document control

Cross-check invoice, packing list, B/L/AWB, C/O, catalogue, PIF, notification and labels.

International logistics

Coordinate agents, carriers, ETA tracking, pre-alert and DG requirements if any.

Declaration and post-clearance

Prepare declaration file, handle Green/Yellow/Red channels and keep the post-clearance file.

For shipments with potential specialized management, C/O or labeling requirements, enterprises should not wait until cargo arrival to start document review.

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