Cosmetic breath spray may be delayed at customs if it is described only as “mouth spray” or “freshener spray”. The key risks are wrong HS classification, confusion with food or medicine, missing cosmetic product notification number, incorrect Vietnamese supplementary labeling, incomplete CFS/authorization documents, or failure to review alcohol content, fragrance ingredients and spray packaging before arrival. For the product covered in this article, the importer should confirm the model, intended use, construction or composition, new/used condition, and technical documents before concluding the HS code, tax treatment, or specialist policy. The following sections organize the main controls from document receipt, catalogue and label review through dossier preparation, declaration, and coordination at the port of entry.

If the Invoice, Packing List, label, product notification, C/O and technical documents are inconsistent, the shipment may be requested for additional documents, routed for inspection, denied preferential C/O treatment, or incur DEM/DET (container/storage charges under carrier/terminal rules). This article provides an E2E (End-to-End) operational map for review before ETA.

QUICK FACTS

Item	Operational review point	Notes
Product name	Cosmetic breath spray	Do not apply automatically to throat sprays, medicines, food supplements or medical disinfectants.
Reference HS	3306.90.00 – other preparations for oral or dental hygiene	Final classification must be checked against the formula, function, label, packaging and actual import documents.
Reference duties	Indicative MFN 20%; ordinary duty 30%; VAT 10% or 8% if eligible	Rates must be checked on the customs declaration date under the effective tariff and VAT policy.
Cosmetic policy	Cosmetic product notification number is required before market circulation	Commercial imports should prepare notification, label, CFS, authorization letter and PIF.
Specific transport risk	Alcohol content or aerosol packaging may create dangerous goods risk	Check SDS/MSDS, UN number, flash point and IATA/IMDG requirements.

Legal note: This article applies only to cosmetic breath spray/oral hygiene preparations. It should not be used as a final conclusion for medicinal throat sprays, therapeutic mouth products, food supplements or medical disinfectants.

Illustration for IMPORT PROCEDURES FOR COSMETIC BREATH SPRAY — Illustration of the product group and document review before customs clearance.

SCOPE OF APPLICATION

This article applies to cosmetic breath spray products used to freshen breath and support oral hygiene within the cosmetic/personal care scope. Typical forms include pump spray, mini spray bottle, alcohol or alcohol-free liquid spray, and products containing flavoring, sweeteners, preservatives and cooling agents.

Do not automatically apply this article to toothpaste, cosmetic mouthwash, medicinal throat spray, therapeutic mouthwash or food supplements.
Commercial goods, samples, testers, exhibition goods and EPE/FDI imports may require different customs and compliance treatment.
If the product contains ethanol, aerosol propellant, pressurized packaging, accessories or promotional devices, separate review is required.

Review must be based on catalogue, datasheet, formula, label, SDS/MSDS and actual import purpose.

PRODUCT CLASSIFICATION & IDENTIFICATION

Main function

Freshening breath and supporting oral hygiene within cosmetic claims, not treating a disease.

Product form

Liquid spray, pump spray or aerosol; capacity must match actual packaging.

Sensitive elements

Ethanol, menthol, flavorings, preservatives and claims that may cross the cosmetic boundary.

Criteria to check	Documents to compare	Risk if incorrectly described	Suggested goods description
Commercial name and function	Label, catalogue, artwork and marketing claims	May be treated as medicine, food or disinfectant	Cosmetic breath spray, oral hygiene preparation, brand, capacity
Packaging form	Product images, packing list and specification	Aerosol/DG risk may be missed	Pump spray/non-aerosol or aerosol where applicable
Alcohol/flavoring content	Formula, SDS/MSDS and COA if available	Wrong transport classification or booking refusal	Declare ethanol/non-ethanol where required
Label and claims	Artwork, original label and Vietnamese sub-label draft	Claims may exceed cosmetic scope	Describe as breath freshening/oral care cosmetic
Goods status	Invoice, packing list, PO and photos	Wrong customs regime for samples/commercial goods	New cosmetic product for import and distribution/sample as applicable

HS CODE – DUTY – C/O

For cosmetic breath spray, HS classification should not be based on the commercial word “spray” alone. The decisive factors are use inside the oral cavity, cosmetic/oral hygiene function, formula, claims, label wording and retail presentation. If the product claims to treat halitosis, treat oral diseases, provide therapeutic antibacterial effects or function as medicine, the dossier must be reviewed separately because it may fall outside ordinary cosmetics.

1. HS classification matrix

Reference HS code	When to consider	Exclusion/risk points	Documents to verify before locking the code
3306.90.00	Main reference for cosmetic breath spray as an oral/dental hygiene preparation in spray/liquid form, retail-packed for breath freshening or oral hygiene within cosmetic scope.	If the invoice only states “mouth spray/freshener spray” without proving oral use and cosmetic function, Customs may request explanation or challenge classification.	Original label, formula/ingredient list, catalogue, instruction for use, SDS/MSDS, cosmetic notification, product and packaging photos.
3306.10.90	Only where the product is a dentifrice, such as toothpaste, dental gel or powder used for brushing teeth.	Not suitable for spray-form breath products without dentifrice characteristics.	Texture, product form, label claim and whether it is used with a toothbrush.
3306.20.00	Only for dental floss in individual retail packages.	Not applicable to liquid/spray breath products.	Product images, retail pack, catalogue.
3307.90.90 or other headings	Only where the product is not proven to be an oral hygiene preparation, or is a spray for fragrance/deodorising outside the oral cavity.	Wrong chapter may result in incorrect duty, notification and Vietnamese labeling.	Marketing claims, use area, formula, warnings, SDS/MSDS and import purpose.
Food/medicine-related headings if triggered	Separate review is required if the product is swallowed, fortified with nutrients, or makes therapeutic/medical oral-care claims.	Do not process as ordinary cosmetics if claims exceed cosmetic scope.	Label, product website, CFS, authorization letter, formula, efficacy documents and relevant specialized-management dossier.

2. Reference import taxes for HS 3306.90.00

Tax item	Reference rate	Application condition	Control points
MFN/WTO import duty	20%	Applicable where goods originate from a country/territory enjoying MFN treatment with Vietnam and no special preferential C/O is used.	Verify HS 3306.90.00, origin, invoice, packing list, declaration and the tariff schedule on the declaration date.
Ordinary import duty	30%	Applicable where goods are not eligible for MFN/FTA treatment or supporting origin documents are insufficient.	Do not apply MFN if origin or documentation does not qualify; check C/O, transport documents and export country.
Standard VAT	10%	Applicable where the product is not eligible for VAT reduction or falls under excluded groups at the time of import.	Check HS code, product nature, customs declaration date and current VAT guidance.
Reduced VAT	8% if eligible	Only where the VAT reduction policy remains effective and the goods are not excluded.	Do not assume 8%; verify exclusion appendices, product description and customs/tax guidance.
Special preferential duty under C/O	May be significantly reduced; many routes may reach 0% or a scheduled preferential rate.	Valid C/O or origin declaration, correct form, rule of origin and FTA route are required.	Check C/O form, WO/RVC/CTH/CTSH criterion, direct transport, third-party invoice, description, HS code and issue date.

3. C/O/FTA reference table for HS 3306.90.00

Route/origin	C/O form or origin document	Reference preferential treatment to verify	Application condition	Common risks
ASEAN	Form D / e-Form D	Often may reach 0% if ATIGA requirements are met.	Goods must satisfy ATIGA origin rules, direct transport and third-party invoice rules if any.	Mismatch in description, HS code, quantity or missing direct transport proof.
China	Form E or RCEP	Compare ACFTA and RCEP; many cases may be 0% if eligible.	Verify origin criterion, manufacturer, country of origin and oral hygiene/breath spray description.	Generic item name, wrong origin criterion, invalid retrospective C/O or no through transport evidence.
Korea	Form AK, VK or RCEP	Select the best eligible FTA rate on the declaration date.	Compare AKFTA/VKFTA/RCEP under HS 3306.90.00 and actual origin.	Wrong form used for a product that does not meet the corresponding rule.
Japan	Form AJ, VJ, CPTPP or RCEP	Review each tariff schedule; several routes may be well below MFN.	Check rule of origin under each FTA and self-certification where applicable.	HS code on C/O differs from the declaration or origin basis is insufficient.
EU	EUR.1 or origin statement under EVFTA	Review EVFTA schedule by year; do not assume without valid documents.	The exporter must satisfy EVFTA origin documentation requirements.	Incorrect origin statement or mismatch with invoice.
UK	EUR.1 or UKVFTA origin document	Review UKVFTA tariff schedule by year.	Check HS code, description and exporter information.	Confusing EVFTA and UKVFTA documents.
Australia – New Zealand / CPTPP	AANZ form or CPTPP origin certification	Special preferential duty may apply if origin and transport conditions are met.	Check AANZFTA/CPTPP by country of origin, not merely port of loading.	Failure to prove originating status in a member country.
India / Hong Kong / EAEU	Form AI / AHK / EAV where applicable	Review each agreement; not every route automatically reaches 0%.	Verify special preferential tariff, C/O form and direct transport.	Assuming “any C/O means 0%” may lead to incorrect duty treatment.

4. Practical duty scenarios

Scenario	Duty/VAT treatment	Documents to check	Recommended action
No special preferential C/O	Expected MFN 20% and VAT 10%, or 8% if eligible.	Invoice, Packing List, B/L/AWB, origin, cosmetic notification and label.	Lock HS and taxes before ETA to avoid wrong landed-cost planning.
C/O description does not match	Preferential duty may be rejected and MFN 20% applied.	C/O, invoice, packing list, catalogue, label and declaration data.	Ask exporter to correct/recheck C/O before cargo arrival.
Wrong C/O form or wrong FTA route	Special preference may be denied; MFN or ordinary duty may apply depending on facts.	C/O form, origin country, export country, B/L and third-party invoice.	Compare FTA options before selecting the form.
Product may be medicine/food	Do not rely only on HS 3306.90.00; other specialized policy may arise.	Claims, formula, instructions, CFS, SDS/MSDS and efficacy documents.	Re-assess product nature before notification and customs declaration.
Aerosol or flammable solvent formula	Duty is not the only issue; DG transport acceptance may arise.	SDS/MSDS, UN number if any, packing instruction and carrier acceptance.	Check DG status before booking to avoid carrier refusal.

5. Pre-ETA HS – duty – C/O lock checklist

Lock the product description as cosmetic breath spray/oral hygiene preparation; avoid generic “spray”, “freshener” or “cosmetics”.
Verify HS 3306.90.00 against formula, label, claim, SDS/MSDS and cosmetic notification.
Check MFN 20%, ordinary duty 30%, VAT 10%/8% according to declaration date.
Compare C/O routes: ATIGA, ACFTA/RCEP, AKFTA/VKFTA, AJCEP/VJEPA/CPTPP/RCEP, EVFTA/UKVFTA, AANZFTA, AIFTA, AHKFTA, VN–EAEU.
Check C/O form, reference number, origin criterion, description, HS, quantity, weight, invoice, third-party invoice, direct transport, issue date and electronic/manual authentication.

SPECIALIZED POLICY MATRIX

Goods situation	Possible policy	Documents to check	Authority/portal	Recommended timing	Risk note
Standard cosmetic breath spray	Cosmetic product notification, labeling and PIF obligations	Notification, CFS, authorization letter, label, ingredients and formula	Drug Administration of Vietnam / Ministry of Health; National Single Window where applicable	Before commercial import	Do not place goods on the market without a valid notification number.
Claims such as antiseptic, therapeutic bad breath treatment or throat treatment	May exceed cosmetic scope and trigger other regimes	Label, marketing claims, formula, scientific support, instructions	Relevant specialized authority if triggered	Before PO/PI confirmation	Avoid therapeutic words if not legally supported.
High alcohol content or aerosol packaging	Dangerous goods risk during international transport	SDS/MSDS, UN number, flash point, packaging pressure and volume	Carrier/airline/shipping line; IATA/IMDG rules	Before booking	May cause route limitations, DG surcharge and packaging/marking requirements.
Samples, testers or exhibition goods	Purpose of import, label and product dossier still need review	Invoice, packing list, purpose explanation and sample labels	Customs and relevant authority when requested	Before ETA	Do not assume samples are exempt from all requirements.
EPE/FDI/factory imports	Customs regime and internal use purpose review	Contract, PO, use purpose and internal records	Customs office	Before declaration	Wrong regime may affect tax and settlement obligations.

LEGAL DOCUMENTS TO REVIEW

Document group	Document number/name	Issuing authority	Effective timing	Role in procedure	Key points to review	Review note
Cosmetics regulation	Circular 06/2011/TT-BYT and consolidated/amending documents	Ministry of Health	Currently applied as amended/consolidated	Cosmetic notification, PIF, labeling and responsibilities	Notification dossier, PIF and cosmetic label requirements	Review against actual formula and claims.
Amending circular	Circular 34/2025/TT-BYT	Ministry of Health	Effective from 18/08/2025	Amends cosmetic management requirements	Forms, dossier submission and updated requirements if applicable	Use the latest consolidated version.
Goods labeling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Currently effective	Original label and Vietnamese supplementary label	Product name, origin, responsible party, quantity and warnings	Labels must match notification and formula.
Tariff schedule	Decree 26/2023/ND-CP	Government	Effective from 15/07/2023	MFN tariff schedule	Chapter 33, heading 3306	Check on customs declaration date.
VAT reduction	Decree 174/2025/ND-CP	Government	From 01/07/2025 to 31/12/2026	VAT reduction policy where eligible	Excluded annexes and eligible goods/services	Do not automatically apply 8%.
FTA/C/O	Special preferential tariff decrees by agreement	Government / relevant ministries	By each effective period	Special preferential duty with valid origin proof	Origin criteria, direct transport and third-party invoicing	Review by actual origin and C/O form.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises should additionally verify the legal documents on official legal databases or websites of the issuing authorities before application.

Cosmetics regulations Decree 26/2023/ND-CP VAT policy

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/PO if any.
C/O if preferential duty is requested.
Catalogue, product photos and original label.

Specialized documents

Cosmetic product notification.
CFS and authorization letter.
PIF.
Vietnamese supplementary label.
SDS/MSDS if alcohol/aerosol is involved.
Claim support documents if needed.

Dossier group	Required documents	Used for	Usually prepared by	Common error	Pre-ETA check
Commercial documents	Commercial Invoice, Packing List, B/L/AWB, Sales Contract/PO	Customs declaration, value, quantity and origin check	Exporter, importer, logistics provider	Vague product name or mismatched quantity/ml/pcs	Lock description: “Cosmetic breath spray, oral hygiene preparation, brand/model, capacity”.
Cosmetic dossier	Notification number, CFS, authorization letter, formula/ingredients, PIF	Market circulation and specialized compliance	Importer/RA/Legal/QA	Expired CFS, wrong authorization, formula inconsistent with label	Match product name, form, manufacturer and country of manufacture.
Transport technical dossier	SDS/MSDS, alcohol content, flash point, aerosol/non-aerosol status	Booking and DG handling if any	Manufacturer, forwarder, carrier	DG not declared for ethanol/aerosol product	Request SDS before booking.
C/O documents	Form D/E/AK/VK/AJ/VJ/EUR.1 or appropriate origin document	Special preferential duty	Shipper/exporter/importer	Wrong HS, wrong description, missing stamp/signature	Check form, criterion, date, direct transport and third-party invoice.
Labeling	Original label, Vietnamese sub-label, label photos and warnings	Clearance and market circulation	Importer/brand owner	Sub-label does not match notification or lacks mandatory information	Compare 100% against notification and documents.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Proof documents	Consequence if unclear	Recommended handling
HS code	Is the product truly an other oral hygiene preparation?	Label, formula, catalogue, instructions	HS explanation, wrong duty or wrong policy	Confirm HS by function and product form before ETA.
Cosmetic scope	Do claims cross into medicine/food/therapeutic treatment?	Label, artwork, website claims, formula	May not be treated as ordinary cosmetics	Review claims before label printing and notification.
Cosmetic notification	Is the notification number valid?	Notification, authorization letter, CFS	Insufficient market circulation conditions	Complete notification before commercial shipment.
Label	Do original and supplementary labels match notification and documents?	Label, artwork, invoice and packing list	Label correction or explanation request	Approve artwork and sub-label before departure.
C/O	Is the C/O correct in form, criterion, date, description and HS?	C/O, invoice, B/L, packing list	Preferential duty may be rejected	Review draft C/O before issuance.
DG transport	Does ethanol/aerosol trigger dangerous goods review?	SDS/MSDS, flash point, UN number	Booking refusal or extra costs	Review SDS before air/sea booking.

END-TO-END OPERATIONAL PROCESS

Step 1: Pre-ETA review

Confirm HS, policy, duty, C/O, label, cosmetic notification, SDS/MSDS and DG risk.

Step 2: Lock documents

Lock Invoice, Packing List, B/L/AWB, catalogue, label, composition, capacity, origin and goods description.

Step 3: Notification/documents

Prepare cosmetic notification, CFS, authorization and PIF; review sensitive claims.

Step 4: Customs declaration

Green lane: system clearance; Yellow lane: document check; Red lane: document and physical inspection.

Step 5: Clearance and post-clearance

Deliver goods, apply supplementary label if needed, archive shipment documents and PIF.

Step 6: Market control

Ensure product is sold according to notification, label, claims and responsible entity.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents to check
Confusion with throat spray, medicine or food supplement	Wrong regulatory regime and document request	Review claims, formula and use area before notification	Label, formula, catalogue and marketing claims
Wrong HS between 3306.90.00 and other headings	Wrong duty, C/O and HS consultation	Describe goods by oral hygiene function and cosmetic spray form	Invoice, packing list, label and product document
Missing cosmetic notification number	Market circulation risk and possible sanctions	Complete notification before commercial shipment	Notification, CFS, authorization and PIF
Wrong C/O form or origin criterion	Preferential duty rejected	Check draft C/O before ETA	C/O, invoice, B/L and origin criterion
DG risk not declared for alcohol/aerosol	Booking refusal, storage fees and delay	Request SDS/MSDS and transport classification	SDS/MSDS, UN number, flash point and packing instruction

FAQ

Question	Short answer
Does cosmetic breath spray require cosmetic notification?	Yes, if it is a cosmetic product imported for commercial circulation, a cosmetic product notification number is required before placing it on the market.
What is the HS code for cosmetic breath spray?	The usual reference HS is 3306.90.00, but final classification must be checked by function, composition, label and actual documents.
Can alcohol-containing breath spray be dangerous goods?	Possibly, especially if ethanol is high or packaging is aerosol. SDS/MSDS, flash point and packaging details must be reviewed.
Can C/O reduce import duty?	Yes, if the origin proof is valid, the form and origin criterion are correct, and all direct transport/third-party invoice requirements are met.
What should the Vietnamese sub-label include?	Product name, function, ingredients, quantity, lot number, manufacturing/expiry date, origin, responsible entity and warnings/instructions where applicable.
Are samples treated the same as commercial goods?	Do not assume exemption. Purpose, quantity, label, notification dossier and customs requirements should be reviewed for each shipment.
What if the product claims “antibacterial” or “treats bad breath”?	These claims are sensitive and may exceed cosmetic scope. Review before notification and import.

IMPLEMENTATION SUPPORT FROM TGIMEX

This article provides a framework for HS, duty, dossier and specialized policy. In practice, each shipment must be reviewed against formula, label, CFS, authorization letter, C/O, SDS/MSDS, origin and import purpose.

Coordination capacity

Agent network in over 60 countries.
Member of WCA, WCA China Global, VLA and HNLA.
Ocean, air, road and rail freight capabilities.
Customs clearance, C/O, permits, warehousing and domestic delivery.

Support scope

Pre-ETA review of HS, policy, duty, C/O, label and notification.
Cross-check Invoice, Packing List, B/L/AWB, C/O, SDS/MSDS and technical documents.
Coordinate agents, carriers, pre-alert and transport documents.
Support customs declaration, lane handling and post-clearance archiving.

ELECTRICAL – ELECTRONICS – IT EQUIPMENT

F&B

MACHINERY

HOUSEHOLD GOODS

COSMETICS – PERSONAL CARE