Product development samples in the cosmetics and personal-care sector are usually imported for formula review, sensory testing, stability testing, packaging matching, fragrance/color selection or laboratory evaluation. Even when not intended for sale, the shipment may still be questioned on import purpose, HS classification, customs value, ingredients, sample label, MSDS/SDS, product notification and non-commercial use.

This article provides an E2E (End-to-End) operational map for checking before ETA: sample classification, HS code, duty, C/O, technical documents, customs dossier and key risk points that may hold the shipment.

QUICK FACTS

Item	Key point	Operational note
Product	Product development samples – cosmetic/R&D samples imported for formula review, evaluation, compatibility testing or internal product development.	Not automatically applicable to commercial goods, tester/sample sale goods, gifts for market circulation or finished cosmetics sold to consumers.
HS principle	No separate HS code applies merely because the goods are “samples”. Classification follows the actual nature of the goods: skin-care, hair-care, oral-care, fragrance, surfactant washing preparation, raw material or active ingredient.	Review catalogue, ingredient list, MSDS/SDS, sample label, form, use purpose and customs value before ETA.
Regulatory principle	Internal R&D/testing samples may need a purpose explanation; samples placed on the market may trigger cosmetic notification and labeling requirements.	No blanket exemption should be assumed only because the goods are described as “sample”.
Tax principle	MFN, ordinary duty, VAT and special preferential duty must be checked by exact HS code, origin and declaration date.	C/O can affect duty materially but will be rejected if HS, description, origin criterion or transport condition is inconsistent.
Pre-ETA focus	Lock sample description, quantity, value, SDS, R&D purpose, C/O and label/photo set before the shipment arrives.	Late explanation often leads to yellow/red channel queries, additional documents or storage cost.

Legal note: “Product development sample” is a use-purpose description, not an independent HS code. The importer must prove R&D/testing purpose and non-commercial use; if the sample is sold, given away, promoted or distributed, it should be reviewed as a market cosmetic product.

SCOPE OF APPLICATION

Covered

Cosmetic formula samples, pilot-batch samples, bulk samples, pre-production samples and lab samples.
Samples for sensory review, stability testing, packaging compatibility, fragrance/color selection or R&D evaluation.
Small-quantity samples imported for internal laboratory or product-development work.

Not automatically covered

Commercial goods, testers/sample sales/gifts placed on the Vietnamese market.
Cosmetic raw materials, standalone chemicals, drugs, medical disinfectants or food supplements.
Dangerous goods without MSDS/SDS and transport classification.

PRODUCT IDENTIFICATION

Checkpoint	Documents to review	Risk if inaccurate	Suggested description
Sample nature	Photos, label, TDS, packing list.	Wrong HS or policy.	“Cosmetic product development sample – exact sample type – not for sale”.
Claims and use	Artwork, claim sheet, R&D email.	May be treated as drug/disinfectant/medical product.	Use neutral R&D/testing wording.
Ingredients and DG risk	Ingredient list, COA, MSDS/SDS.	Wrong HS/DG handling.	Declare alcohol/aerosol/solvent if applicable.
Quantity and value	Sample invoice, packing list.	Commercial suspicion or customs valuation query.	State customs value and non-sale purpose where true.

HS CODE – DUTY – C/O

HS classification for product development samples follows the actual nature of the goods, not the word “sample”. The following matrix is operational guidance only and must be checked against the actual dossier and tariff schedule at the declaration date.

Sample type	Reference HS	Application condition	MFN reference	Ordinary duty reference	VAT	Key risk	Documents to compare
Skin-care cream/lotion/serum/essence sample	3304.99.30 or 3304.99.90	Skin-care/cosmetic preparation.	18%	27%	10%	Wrong duty and origin treatment.	Ingredient list, label, claim, photos.
Hair-care/styling/hair tonic sample	3305.10, 3305.20.00, 3305.30.00, 3305.90.00	Hair preparation, depending on exact function.	15%–20%	22.5%–30%	10%	Mis-grouping all hair samples under “other”.	Function, form, SDS if aerosol/solvent.
Oral-care sample	3306.10, 3306.20.00, 3306.90.00	Toothpaste, dental floss or other oral-hygiene preparation.	6%–20%	9%–30%	10%	Therapeutic/antiseptic claims may change policy.	Claim, active ingredients, label.
Fragrance/body mist sample	3303.00.00 or relevant heading	Perfume/fragrance preparation; alcohol/DG must be checked.	Check at declaration date	Check at declaration date	10%	Undeclared DG/alcohol.	MSDS/SDS, flash point, UN number.
Wipes/pads impregnated with cosmetic	3307.90.30 or suitable code	Wipes/pads impregnated with cosmetic preparation.	20% reference	30% reference	10%	Confusion with paper/packaging or skin-care goods.	Structure, liquid, claim, photos.
Skin-washing surfactant sample	3401.30.00 or chapter 33/34 as applicable	Organic surface-active skin-washing preparation.	Check chapter 34 tariff	Check chapter 34 tariff	10%	Confusion between skin-care cosmetics and surface-active washing preparations.	Surfactant composition, label, use.
Raw material/active/fragrance compound	Classify by actual raw material	Not a finished cosmetic product.	Depends on code	Depends on code	Usually 10%, verify	Wrongly declaring as finished cosmetics.	COA, MSDS/SDS, CAS, use purpose.

C/O AND FTA REVIEW

Origin route	C/O or origin document	Preferential duty note	Application conditions	Documents to compare	Risk if incorrect
ASEAN / ATIGA	Form D or accepted electronic origin document.	Many cosmetic HS codes may enjoy 0% if the FTA rule is met.	Correct HS, origin criterion such as WO/RVC/CTH/CTSH, direct consignment and valid issuance.	C/O, invoice, packing list, B/L/AWB, sample description, ingredient evidence if needed.	The word “sample” differs from the goods description and customs rejects the preferential claim.
China / ACFTA or RCEP	Form E or RCEP proof of origin.	Preferential rate must be checked by the exact HS code and import year.	Correct form, origin country, HS, item description, third-party invoice declaration if applicable and direct transport rule.	C/O, invoice, third-party invoice, transport document, packing list.	HS mismatch or missing third-party invoice details may cause denial of preference.
Korea / AKFTA, VKFTA or RCEP	Form AK, Form VK or RCEP proof of origin.	Often preferential compared with MFN; exact rate depends on HS and tariff schedule.	PSR compliance, valid issuer, direct transport and matching product description.	C/O, invoice, packing list, B/L/AWB, manufacturer/exporter information.	Origin criterion not meeting PSR or sample description too generic.
Japan / AJCEP, VJEPA, CPTPP or RCEP	Form AJ/VJ, CPTPP origin certification or RCEP proof of origin.	Check by HS and agreement selected.	Do not mix forms/agreements; verify origin criterion and document format.	Origin proof, invoice, packing list, transport route.	Using the wrong agreement may lead to tax adjustment after clearance.
EU / EVFTA and UK / UKVFTA	EUR.1 or origin statement as applicable.	Preferential treatment depends on the HS code and proof of origin threshold/rule.	Correct exporter declaration/issuer, direct consignment/non-alteration and HS consistency.	Origin statement/EUR.1, invoice, packing list, transport documents.	Insufficient origin declaration wording or inconsistent description.
Australia – New Zealand / AANZFTA or CPTPP	Form AANZ or CPTPP origin certification.	Check exact HS and tariff schedule.	PSR, direct consignment and origin proof format must be valid.	C/O or origin certification, invoice, B/L/AWB.	Preference rejected due to invalid format or transport evidence.
India / AIFTA and Hong Kong / AHKFTA	Form AI or Form AHK if applicable.	Preferential rate must be verified by HS and schedule.	Correct origin criterion, form, stamp/signature or electronic validation where accepted.	C/O, invoice, packing list, B/L/AWB.	Using preference without checking the applicable schedule for the sample HS.

SPECIALIZED POLICY MATRIX

Scenario	Possible policy	Documents to review	Authority/channel	Recommended timing	Risk note
Internal R&D sample, not for sale and not circulated	Customs clearance with purpose explanation and technical dossier; specialized review may still depend on the goods nature.	Purpose letter, non-sale undertaking, sample invoice, packing list, SDS/MSDS, R&D request.	Customs branch where the declaration is lodged.	Before ETA.	No blanket exemption; customs may still query HS, value, ingredients and purpose.
Finished cosmetic sample intended for market circulation, tester, sample sale or gift	Cosmetic product notification, labeling and PIF review may apply before circulation/import depending on actual dossier.	Notification receipt, LOA, CFS if required, PIF, label, ingredient list.	Drug Administration of Vietnam / Ministry of Health and relevant online channels where applicable.	Before import or before market circulation.	Do not use “sample” wording to bypass cosmetic market rules.
Raw material, active ingredient, fragrance compound or bulk development sample	HS/policy follows the actual chemical or preparation; may not be treated as finished cosmetics.	COA, SDS/MSDS, CAS, ingredient declaration, intended use letter.	Customs; specialized authority if the composition triggers another policy.	Before booking and before declaration.	Declaring raw material as finished cosmetics can lead to wrong HS and duty.
Alcohol, solvent, aerosol, flammable fragrance or pressurized sample	Dangerous goods (DG) transport screening under airline/shipping line rules and IATA/IMDG practice.	SDS/MSDS, flash point, UN number, packing instruction, DG declaration if required.	Carrier, forwarder, airline/shipping line; customs if inspected.	Before booking.	Undeclared DG may stop shipment, create rebooking cost or trigger storage issues.
Sample imported for EPE/FDI factory/R&D center	Customs regime, accounting/use control and internal handover evidence should match the import purpose.	Sample request, internal R&D plan, handover record, warehouse/lab record.	Customs branch and enterprise internal compliance team.	Before ETA and during post-clearance file retention.	Weak traceability may create post-clearance questions.
Sample returned, replaced, warranty or re-imported for evaluation	May require separate customs explanation and supporting documents for return/replacement/re-import scenario.	Previous export/import documents, return reason, correspondence, photos, serial/batch if any.	Customs branch.	Before shipment moves.	Purpose mismatch may cause valuation, tax or regime questions.

LEGAL DOCUMENTS TO REVIEW

Document group	Name / number	Issuer	Effective date / application timing	Role in the procedure	Key clauses / appendices to note	Review note
Law	Law on Customs 2014	National Assembly	In force; verify current consolidated status.	Core legal basis for customs declaration, inspection and supervision.	Rules on customs dossiers, inspection and clearance.	Applies to all import shipments.
Decree	Decree 08/2015/ND-CP as amended by Decree 59/2018/ND-CP	Government	Verify consolidated/current version.	Detailed customs procedures and customs control.	Customs dossier, inspection and practical clearance procedures.	Important when explaining sample purpose and dossier basis.
Circular	Circular 38/2015/TT-BTC as amended by Circular 39/2018/TT-BTC	Ministry of Finance	Verify current validity before application.	Customs declaration, customs valuation and dossier handling.	Declaration data, document submission and customs valuation logic.	Relevant for sample value and non-commercial shipments.
Cosmetics	Circular 06/2011/TT-BYT	Ministry of Health	01/04/2011	Cosmetics management, product notification, labeling and PIF framework.	Definition of cosmetics, notification and PIF requirements.	Review if the sample is a finished cosmetic or will be placed on the market.
Cosmetics amendment	Circular 34/2025/TT-BYT	Ministry of Health	18/08/2025	Amends and supplements Circular 06/2011/TT-BYT.	Updated notification/dossier requirements where applicable.	Apply for dossiers after the effective date.
Tariff	Decree 26/2023/ND-CP	Government	15/07/2023	MFN tariff basis and tariff schedule.	Tariff headings in chapters 33, 34 and other relevant chapters.	Exact HS and rate must be rechecked at declaration date.
Tariff amendment	Decree 108/2025/ND-CP	Government	19/05/2025	Amends Decree 26/2023/ND-CP.	Updated tariff content where amended.	Use together with the current tariff schedule.
Labeling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Verify current validity before use.	Goods labeling and supplementary Vietnamese labeling.	Label content, origin, responsible organization and supplementary label rules.	Especially important if samples are circulated or displayed to users.

VIEW / DOWNLOAD ORIGINAL DOCUMENTS

Enterprises should cross-check the documents on official legal portals or competent authority websites before applying.

Circular 06/2011/TT-BYT Circular 34/2025/TT-BYT Decree 26/2023/ND-CP Decree 108/2025/ND-CP

CUSTOMS DOSSIER

Commercial documents

Sample Invoice with customs value.
Packing List with sample quantity and volume/weight.
B/L or Air Waybill.
Sample request/R&D request.
Non-sale/non-payment letter if factually correct.
C/O if claiming preferential duty.

Technical documents

Ingredient list, COA if any, MSDS/SDS.
TDS/catalogue/photos/sample label.
Purpose explanation letter and non-commercial undertaking.
Notification/PIF/LOA/CFS if the sample is to be circulated or if required by dossier review.

Operational dossier checklist

Dossier group	Required document	Used for which step	Usually prepared by	Common mistake	Pre-ETA check
Sample purpose	Purpose letter, sample request, R&D plan, non-sale/non-circulation undertaking if true.	Customs explanation when the purpose of import is questioned.	Importer, R&D, Regulatory/Compliance.	No evidence that the sample is not for sale.	Prepare before departure and keep signed/stamped version if available.
Invoice / packing	Sample Invoice, Packing List, customs value, quantity, volume, net/gross weight.	Customs declaration, customs value, duty and VAT review.	Supplier, Docs team, importer.	Zero value without customs value, vague item name, missing volume or unit.	State “value for customs purpose”, quantity and unit consistently.
Transport documents	Air Waybill/Bill of Lading, pre-alert, booking details.	Arrival control, manifest and clearance planning.	Forwarder, carrier, overseas agent.	Description on AWB/B/L does not match invoice or sample nature.	Cross-check shipper/consignee, description, number of packages and ETA.
Technical dossier	Ingredient list, COA if any, SDS/MSDS, TDS/catalogue/photos/sample label.	HS classification, DG screening, cosmetic/policy review.	Supplier, R&D, QA/Regulatory.	Only marketing name is available; no ingredient/SDS support.	Collect documents before booking; flag alcohol/aerosol/solvent early.
Origin/C/O	C/O or origin statement if preferential duty is claimed.	Special preferential duty review.	Exporter, supplier, importer.	Wrong form, wrong HS, wrong description or missing direct transport proof.	Check form, HS, description, origin criterion, invoice and transport route.

CLEARANCE DECISION POINTS

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended action
Actual nature of sample	Is it a finished cosmetic, semi-finished bulk, raw material, active ingredient or chemical preparation?	Ingredient list, SDS/MSDS, photos, TDS.	Wrong HS, wrong duty and wrong policy route.	Classify sample groups before shipment.
Import purpose	Is the sample for internal R&D/testing only or for market circulation/testing by consumers?	Purpose letter, R&D plan, supplier email, non-sale undertaking.	Customs may request product notification or further explanation.	Prepare a clear purpose letter before ETA.
Customs value	Is the value declared for customs purposes reasonable even if goods are free of charge?	Sample invoice, price reference, correspondence.	Valuation query and delayed clearance.	State value for customs purpose and Incoterms clearly.
DG / transport risk	Does the sample contain alcohol, aerosol, flammable solvent or pressurized packaging?	SDS/MSDS, flash point, UN number.	Carrier rejection, rebooking or storage issue.	Screen DG before booking and declaration.
C/O preference	Will preferential duty be claimed, and does the C/O match the exact HS and description?	C/O, invoice, packing list, B/L/AWB.	Loss of preferential duty or post-clearance tax adjustment.	Check form, origin criterion, HS, description and direct transport rule.

E2E OPERATIONAL FLOW

Step 1 · Pre-ETA review

Confirm sample nature, HS, duty, origin, DG and specialized policy.

Step 2 · Lock documents

Match sample invoice, packing list, AWB/B/L, ingredient list, MSDS/SDS and labels.

Step 3 · Prepare explanation dossier

Prepare R&D purpose letter, non-sale undertaking and technical evidence.

Step 4 · Customs declaration

Green, Yellow and Red channels must be handled according to customs inspection requirements.

Step 5 · Clearance and records

Receive samples, hand over to R&D/lab and archive documents for post-clearance review.

PRE-ETA RISK CHECKLIST

Generic description: avoid “cosmetic sample” only.

Weak HS basis: prepare ingredient list, function and label.

Missing MSDS/SDS: critical for alcohol, aerosol or solvent samples.

Zero value: no-charge samples still require customs value.

Commercial suspicion: control quantity and non-sale evidence.

C/O mismatch: HS, description and transport route must align.

FAQ

Question	Answer
Is there a separate HS code for product development samples?	No. HS follows the actual nature of the goods.
Are duties payable for no-charge samples?	They may still require customs value declaration and duty payment unless a valid legal basis applies.
Is cosmetic notification required?	If the sample is placed on the market, notification should be reviewed. Internal R&D samples require case-by-case dossier review.
Can alcohol-based samples be shipped by air?	Only after checking MSDS/SDS, flash point, UN number and IATA DGR requirements.
Can C/O be used for samples?	Yes, if the origin document is valid and matches HS, description, quantity and transport conditions.
Can multiple samples be imported in one shipment?	Yes, but each SKU/sample should be described clearly with quantity, volume, function and HS basis.

IMPLEMENTATION SOLUTION FROM TGIMEX

This article provides an operational map for HS, duty, C/O, dossier and specialized policy review for product development samples. Actual shipments must still be reviewed against catalogue, ingredient list, MSDS/SDS, documents, origin and import purpose.

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