IMPORT PROCEDURE FOR SKINCARE SETS
A skincare set may look simple because it is sold as a retail bundle, but customs and compliance risks usually arise from wrong HS classification, using one cosmetic notification for components that do not match, inconsistent outer/inner labels, or a vague C/O description. This guide gives an E2E map for reviewing HS codes, duties, C/O, cosmetic notification, labelling, documents and clearance decision points before ETA. 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.
QUICK FACTS
| Item | Operational review |
|---|---|
| Product | Skincare set – same-owner/same-brand cosmetics sold as a retail set or combo, possibly including serum, essence, cream, lotion, mask, toner or cleanser. |
| Primary HS codes to review | 3304.99.90 for other skincare preparations; 3304.99.30 where face/skin cream or lotion determines the essential character; 3401.30.00 where a cleanser/skin-washing preparation dominates or components are declared separately. |
| Reference MFN duty | 3304.99.90: 20%; 3304.99.30: 20%; 3401.30.00: 27%. |
| Reference ordinary duty | 3304.99.90: 30%; 3304.99.30: 30%; 3401.30.00: 40.5%. |
| VAT | Base VAT 10%; 8% only where the VAT reduction policy is still applicable and the goods are not excluded at the declaration date. |
| Specialized policy | Cosmetic product notification must be reviewed for each component or under the accepted packaging/dossier approach. One notification number should not be used to cover different formulas/functions without legal basis. |
| Main risks | Wrong HS for the whole set, missing notification for components, inconsistent names among invoice, packing list, label and notification, or C/O description not matching the set/components. |
SCOPE OF APPLICATION
This article covers same-owner or same-brand skincare sets sold as a retail kit/combo, such as serum + cream, toner + essence + lotion, mask + cream, or a set including cleanser.
- It does not automatically apply to makeup sets, fragrance sets, beauty devices or combos containing non-cosmetic goods.
- Samples, testers, promotional gifts and warranty shipments may require a separate review of purpose, label and dossier.
- If the set includes electronic devices, batteries, massage tools or LED mask devices, the device portion must be reviewed separately.
PRODUCT CLASSIFICATION AND IDENTIFICATION
Set structure
Check the number of components, each item’s volume/weight, function, form, individual label and SKU.
Function
Distinguish leave-on skincare products from rinse-off cleansers. Function drives HS, cosmetic notification and labelling requirements.
Notification dossier
Each component should be matched against its name, form, INCI formula, manufacturer and notification number.
Labelling
Outer set label and inner product labels must align with the notification dossier and Vietnamese labelling requirements.
| Check item | Documents to compare | Risk if wrongly described | Suggested declaration wording |
|---|---|---|---|
| Set and component names | Invoice, packing list, outer/inner labels | Vague goods description makes HS and notification review difficult | Skincare set including serum, cream, toner etc.; specify number of pieces per set |
| Leave-on/rinse-off function | Catalogue, directions for use, claim list | Wrong classification between 3304 and 3401 | State leave-on skincare preparations or skin-washing preparation where applicable |
| INCI formula | Notification dossier, PIF, label | Notification may not cover all components | Map each component before declaration |
| Retail packaging | Set photos, carton marks, packing list | Cannot prove retail set or may need line-by-line declaration | Specify set quantity and component quantity |
| Origin of components | C/O, label, manufacturer invoice | Preference may be rejected | Review component origin where preferential duty is claimed |
HS CODE – DUTY – C/O
For skincare sets, HS should not be determined solely by the commercial name “set”. Determine the essential character, retail packaging and whether components should be declared separately.
| HS code | When to consider | MFN | Ordinary duty | Base VAT | Risk | Documents to check |
|---|---|---|---|---|---|---|
| 3304.99.90 | The set is mainly other skincare preparations such as serum, essence, mask, gel/oil or mixed skincare items without a dominant cream/lotion. | 20% | 30% | 10% | If a cleanser dominates or components must be declared separately, using one 3304.99.90 line may trigger classification queries. | Catalogue, set configuration, INCI, notification numbers, images, inner/outer labels. |
| 3304.99.30 | The essential character is face/skin cream or lotion, or the set is mainly cream/lotion products. | 20% | 30% | 10% | May be inaccurate if the set includes serum, mask, cleanser or toner with different characters. | Product list, value/quantity ratio, label, use instructions. |
| 3401.30.00 | Retail skin-washing preparation in liquid/cream form; cleanser is dominant; or components are declared line by line. | 27% | 40.5% | 10% | Wrong if applied to the whole set where most items are leave-on skincare preparations. | Rinse-off/leave-on evidence, label, packing list and draft declaration. |
DETAILED HS AND DUTY CONTROL
Do not apply one HS code to the whole skincare set unless the essential character is evidenced. Prepare component-level HS mapping where the set contains different formulas/functions.
| HS | Use case | MFN | Normal duty reference | Base VAT |
|---|---|---|---|---|
| 3304.99.90 | Other skincare/cosmetic preparations. | 20% | 30% | 10% |
| 3304.99.30 | Face/skin creams and lotions. | 20% | 30% | 10% |
| 3401.30.00 | Liquid/cream skin-washing preparations such as cleanser. | 27% | 40.5% | 10% |
REFERENCE DUTY TABLE
| HS | Reference description | MFN | Ordinary duty | Base VAT | Application note |
|---|---|---|---|---|---|
| 3304.99.90 | Other skincare/cosmetic preparations | 20% | 30% | 10% | Preferable where the set’s essential character is other skincare preparations. |
| 3304.99.30 | Face or skin creams and lotions | 20% | 30% | 10% | Use where cream/lotion determines the essential character or is declared separately. |
| 3401.30.00 | Retail skin-washing preparations in liquid/cream form | 27% | 40.5% | 10% | Use for cleanser/rinse-off components or where cleanser dominates. |
SPECIAL PREFERENTIAL C/O REVIEW
| Origin route | Origin document | Preferential rate review | Conditions | Risk |
|---|---|---|---|---|
| ASEAN | Form D | Check the current ATIGA tariff schedule by HS; many cosmetic lines may reach 0% where the schedule and C/O are valid. | Origin criteria, direct transport, matching description and HS. | Wrong form or mismatched set description may lead to rejection. |
| China | Form E | Check ACFTA schedule for 3304.99.90 / 3304.99.30 / 3401.30.00. | Exporter, goods description, quantity, weight and third-party invoice declaration if any. | Set packed in China with multi-origin components needs careful origin review. |
| Korea | Form AK / VK | Check AKFTA/VKFTA schedule by HS and declaration year. | Invoice, packing list, C/O and origin marking must align. | HS mismatch may trigger verification. |
| EU / UK | EUR.1 or origin statement | Check EVFTA/UKVFTA schedule. | Comply with origin rules and direct transport. | Invalid origin wording or vague description may deny preference. |
| CPTPP / RCEP / Japan / ANZ | Agreement-specific C/O or origin document | Check the relevant FTA schedule by HS and year. | Origin criteria, third-party invoice, route and HS must be consistent. | Multi-component set may require component-level origin review. |
PRE-ETA HS AND TAX CHECKLIST
- List every component with name, function, form and volume.
- Decide whether to declare one set line or separate component lines.
- Check MFN, ordinary duty, VAT and C/O preference by final HS.
- Review draft C/O: form, origin criterion, description, HS, quantity, weight, third-party invoice and direct transport.
SPECIALIZED POLICY MATRIX
| Goods situation | Possible policy | Documents | Authority/portal | Timing | Risk note |
|---|---|---|---|---|---|
| Commercial skincare set | Cosmetic notification, labelling and customs declaration | Notification, LOA, CFS if any, INCI, labels, invoice, packing list | Cosmetic authority and customs office | Before ETA and before circulation | Do not treat all components as one product without basis |
| Set with cleanser plus cream/serum/mask | HS may need component-level review | Component list, value ratio, labels | Customs | Before invoice finalization | Wrong set declaration may distort duty |
| Treatment/anti-acne/antibacterial claims | Review cosmetic vs drug/biocidal boundary | Claims, formula, label, catalogue | Relevant health authority where applicable | Before label and notification approval | Over-claiming may change regulatory treatment |
| Samples/testers/gifts | Review purpose, quantity, label and circulation plan | PO, invoice, sample label | Customs and cosmetic authority | Before ETA | Samples are not automatically exempt if circulated |
| EPE/FDI/factory shipment | Review customs regime and post-clearance obligations | Contract, use plan, transport docs | Customs office | Before declaration | Wrong regime may affect duty and audit |
LEGAL DOCUMENTS TO REVIEW
| Group | Document | Issuer | Effective date | Role | Key points | Review note |
|---|---|---|---|---|---|---|
| Circular | Circular 06/2011/TT-BYT | Ministry of Health | Review consolidated/amended text | Cosmetic notification, labels and PIF | Notification and labelling rules | Apply by component where formulas/functions differ |
| Amending Circular | Circular 34/2025/TT-BYT | Ministry of Health | 18 Aug 2025 | Amends Circular 06/2011/TT-BYT | Updated filing/form requirements | Review when filing after effective date |
| Decree | Decree 43/2017/ND-CP and amendments | Government | Check current validity | Goods labelling | Mandatory label information | Cosmetics also follow sector rules |
| Tariff | MFN and FTA tariff schedules | Government/MOF | By declaration year | Duty and C/O preference | HS 3304.99.90, 3304.99.30, 3401.30.00 | Do not finalize duty without current tariff check |
| VAT Decree | Decree 174/2025/ND-CP | Government | 1 Jul 2025 | VAT reduction review | Exclusion annexes and applicable period | 8% is not automatic |
VIEW / DOWNLOAD OFFICIAL DOCUMENTS
Companies should verify the official text on the Government legal database or the issuing authority’s website before applying.
CUSTOMS DOCUMENT CHECKLIST
| Document group | Required documents | Used for | Prepared by | Common errors | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial documents | Commercial Invoice, Packing List, Sales Contract/PO, B/L/AWB, arrival notice. | Customs declaration, tax calculation and cargo release. | Importer, seller, forwarder. | Invoice only says “skincare set” without component breakdown. | Request annex showing set SKU, pieces per set, volume and net/gross weight. |
| Cosmetic dossier | Cosmetic product notification, LOA/authorization, CFS if required, INCI formula, original/Vietnamese label, PIF for internal file. | Notification, circulation and sector explanation. | Importer/Responsible person, brand owner, manufacturer. | One notification number does not match all components in the set. | Match name, product form, function, formula, manufacturer and owner by component. |
| HS and tax dossier | Catalogue, set images, product list, value allocation, C/O and origin criteria sheet. | HS classification and preferential duty claim. | Importer, customs broker, seller. | One HS is applied to all components without proof of essential character. | Prepare component-level HS mapping before deciding the declaration structure. |
| Label dossier | Outer box artwork, inner product labels, Vietnamese supplementary label, lot number and shelf life. | Clearance/circulation/post-clearance review. | Importer, brand, QA/regulatory team. | Outer label and inner product labels differ in name, function or volume. | Compare every label line with notification dossier and invoice before ETA. |
| Logistics dossier | Pre-alert, booking, bill, ETA, arrival notice and freight-related documents. | Shipment tracking, D/O and delivery. | Forwarder/agent/importer. | Pre-alert is received too late for HS/C/O/notification review. | Request pre-alert and draft documents several working days before ETA. |
CLEARANCE DECISION POINTS
| Decision point | Question | Evidence | Consequence if unclear | Recommended action |
|---|---|---|---|---|
| Declaration structure | Declare one set line or separate component lines? | Invoice, packing list, catalogue, component list. | Possible amendment request or HS explanation. | Agree the approach with customs broker before final invoice. |
| HS determination | Does the essential character fall under 3304.99.90, 3304.99.30 or 3401.30.00? | Function, product form, value/quantity ratio. | Wrong duty, wrong C/O and sector mismatch. | Prepare a component-level HS mapping table. |
| Cosmetic notification | Does each component have a suitable notification number? | Notification, LOA, INCI formula. | Insufficient circulation dossier and possible document request. | Do not wait until arrival to review notification status. |
| Labelling | Do outer and inner labels match the dossier? | Artwork, label images, Vietnamese supplementary label. | Post-clearance/circulation risk. | Standardize labels before shipment. |
| C/O | Does C/O describe the set/components and match HS on declaration? | Draft C/O, invoice, packing list, transport document. | Preference may be rejected or verification may be prolonged. | Review draft C/O before original issuance. |
E2E PRACTICAL PROCESS
Step 1: Pre-ETA review
Finalize component list, HS, duty, C/O, notification, label and declaration approach.
Step 2: Lock documents
Lock invoice, packing list, bill, catalogue, labels, notification and component mapping.
Step 3: Complete sector dossiers
Check notification numbers, LOA/CFS if any, Vietnamese labels and cosmetic claims.
Step 4: Customs declaration
Prepare HS, value, C/O, goods name, set quantity and component explanations.
Step 5: Clearance and post-clearance filing
Deliver goods, verify labels and archive the shipment dossier.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA prevention | Documents to check |
|---|---|---|---|
| Multiple components but notification dossier is incomplete | Document amendment and circulation delay. | Map every component against its notification number. | Notification dossier, labels, INCI, product list. |
| Wrong HS because the set is treated as one code without basis | Wrong duty and possible customs query. | Prepare component-level HS and decide declaration approach. | Catalogue, invoice, packing list. |
| C/O has vague description or wrong HS | Preferential duty may be rejected. | Review draft C/O before issuance. | C/O, invoice, B/L, origin form. |
| Claims exceed cosmetic scope | Label/notification may need revision or product may fall into another regime. | Review label, website and catalogue claims before filing. | Artwork, dossier, claim list. |
| Product names differ across label, invoice and notification | Customs query, delay and storage cost risk. | Standardize naming from PO to label. | Invoice, packing list, notification and label. |
FAQ
| Question | Answer |
|---|---|
| Does a skincare set need cosmetic notification? | Very likely yes before circulation. Review each component rather than assuming one notification covers all. |
| Can the whole set use one HS code? | Only where the set approach is defensible and essential character can be determined. Otherwise, review component-level declaration. |
| What HS codes are usually reviewed? | 3304.99.90, 3304.99.30 and 3401.30.00 where cleanser is included. |
| Can C/O reduce duty? | Yes if the C/O form, origin criterion, HS and description are valid. |
| Is the outer label enough? | No. Review both outer set label and inner product labels. |
| Is a vague invoice risky? | Yes. Ask the seller to specify components, volume, SKU and origin. |
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