COSMETICS – RAW MATERIALS
Extracts are often declared too generally as “plant extract” or “cosmetic raw material”, while the actual goods may be botanical extract, medicinal extract, essential oil, fragrance mixture, isolated active or chemical mixture. If HS classification, intended use, COA/SDS and specialized policy are not locked before ETA, the shipment may face document queries, C/O preference denial, wrong VAT treatment or specialized control. This article provides an E2E map to review HS, duties, C/O, technical documents, chemical/cosmetic policy and pre-ETA risks.
QUICK FACT
| Item |
Review point |
Operational note |
| Product |
Extract / cosmetic raw material extract in powder, liquid, concentrated extract or solvent-based form. |
Do not merge with actives, fragrance oils, essential oils, preservatives, colorants or finished cosmetics. |
| Main HS reference |
1302.19.90 – other vegetable saps and extracts. |
Suitable only when the product remains a botanical/plant extract and is not a medicinal extract, food ingredient, fragrance mixture or isolated chemical. |
| MFN import duty |
5% for 1302.19.90. |
Check Decree 26/2023/ND-CP and the tariff schedule at the declaration date. |
| Ordinary import duty |
7.5% for 1302.19.90. |
Used where MFN/preferential eligibility is not satisfied. |
| VAT |
Baseline often 10%; review 8% if VAT reduction is still applicable and the goods are not excluded. |
Do not automatically apply 8%. |
| Specialized policy |
Review actual use: cosmetic raw material, food ingredient, medicinal extract, chemical, plant/animal origin or restricted substance. |
Each use scenario may trigger a different policy. |
Legal note: This article covers extract as a cosmetic raw material. If used for food, medicine, essential oil/fragrance or sold directly as a finished consumer product, policy must be reviewed by the actual file.
SCOPE OF APPLICATION
Applicable to
- Extract/plant extract imported for cosmetic manufacturing.
- Powder, liquid, concentrated extract or solvent-based material.
- R&D sample, production material, B2B raw material distribution or formula evaluation sample.
Not automatically applicable to
- Finished topical products sold directly to consumers.
- Food extract, oral supplement, herbal medicine or medicinal extract.
- Essential oil, fragrance oil, isolated active, colorant or separate preservative.
- Restricted species/CITES/cannabis extract or therapeutic claims.
CLASSIFICATION & TECHNICAL IDENTIFICATION
Extract must be identified by biological source, extraction solvent, active ratio, physical form, quality standard, intended use and COA/SDS. A generic “extract” description is not enough to lock HS and policy.
| Criteria |
Documents |
Risk if wrong |
Suggested declaration description |
| Nguồn gốc/Source/来源 |
COA, specification, botanical/animal source statement |
Wrong quarantine/CITES/HS policy |
Extract from [botanical name], cosmetic raw material, grade … |
| Dung môi/Carrier/载体 |
MSDS/SDS, composition, solvent ratio |
May trigger chemical/DG review |
Water/glycerin/propylene glycol/oil soluble extract, non-retail raw material |
| Công dụng/Use/用途 |
Intended use statement, catalogue, label |
Confusion with food/drug/finished cosmetic |
Cosmetic ingredient for manufacturing, not for direct retail use if true |
| Thông số chất lượng/Quality/质量 |
Assay, microbiology, heavy metals, preservative/solvent content |
Insufficient QA/PIF support |
Batch/lot, net weight, shelf life, storage condition |
HS CODE – DUTY – C/O
This section does not fix one HS code for all extracts. Classification must follow product nature, source, composition and intended use.
| Reference HS code |
When applicable |
Base duty reference |
Misclassification risk |
Documents to verify |
| 1302.19.90 |
Other plant extracts for cosmetic raw material use; not a medicinal extract, food supplement, essential oil or chemical active. |
MFN 5%; ordinary 7.5%; VAT baseline 10%, review 8% if eligible. |
Wrong HS affects duty and specialized control. |
COA, MSDS/SDS, INCI, botanical source, solvent, specification, label, intended use. |
| 1302.19.30 |
Medicinal extract scenario; not automatically applicable to cosmetic raw material extracts. |
MFN reference 5%; ordinary often 150% of MFN if no specific rate; VAT by actual product. |
Medicinal claims may shift policy to pharmaceutical/herbal management. |
COA, claims, label, supplier documents, intended use. |
| 3301.xx |
Essential oil, oleoresin or resinoid scenario. |
Duty/VAT depends on exact 3301 subheading. |
Confusion with extract may affect HS and DG transport. |
GC/MS if any, MSDS, trade name, flash point. |
| 3302.90.00 |
Mixture of odoriferous substances or compounded fragrance for cosmetics. |
Duty/VAT depends on heading 3302. |
Not used for a single botanical extract without fragrance compounding. |
Formula statement, IFRA if any, MSDS, specification. |
| 3824.99.xx / Chapter 29 |
Chemical mixture or isolated active ingredient. |
Duty/VAT depends on CAS/composition. |
May trigger chemical declaration or chemical restrictions. |
CAS No., purity, assay, SDS, composition. |
Preferential C/O/FTA review
| Origin route |
C/O / origin proof |
Reference duty |
Conditions |
Documents |
Risk |
| ASEAN – ATIGA |
Form D |
0% reference for 1302.19.90 |
ASEAN origin, direct transport and matching HS/description. |
Form D, Invoice, Packing List, B/L, origin criterion. |
Mismatch may lead to denial. |
| China – ACFTA |
Form E |
0% reference |
ACFTA origin and third-party invoice control if any. |
Form E, transport documents, COA/MSDS. |
Form E is often checked closely. |
| RCEP |
RCEP C/O or origin document |
May be 0% or by annual schedule; compare before filing. |
Compare with ACFTA/AKFTA/VJEPA/AANZFTA/CPTPP. |
RCEP origin document, origin criterion. |
RCEP is not always the lowest route. |
| Korea – AKFTA/VKFTA |
Form AK/VK |
Reference 0% if valid. |
Choose the better agreement. |
Form AK/VK, Invoice, B/L, COA. |
Product description must match. |
| Japan – AJCEP/VJEPA/CPTPP/RCEP |
Form AJ/VJ, CPTPP or RCEP |
Some routes 0%; check annual schedule. |
Use the agreement matching actual origin. |
C/O and production evidence. |
Do not claim preference with vague extract description. |
| EU/UK – EVFTA/UKVFTA |
EUR.1 or statement on origin |
EVFTA may still have a schedule; reference can be around 2.5% or by year. |
Apply the right proof of origin. |
EUR.1/statement, Invoice, B/L. |
Check self-certification threshold. |
| Australia/New Zealand – AANZFTA/CPTPP |
Form AANZ or CPTPP |
Reference 0% if valid. |
Origin and direct transport required. |
C/O, transport, COA. |
Transit documents may be required. |
| India – AIFTA |
Form AI |
May be around 0–1%; check current schedule. |
AIFTA origin required. |
Form AI, Invoice, Packing List, B/L. |
Avoid vague description. |
| United States/no FTA |
No common special preferential C/O |
Expected MFN 5% if eligible; ordinary 7.5% otherwise. |
COO only supports origin; it does not reduce duty as an FTA C/O. |
COO if any, origin label, contract. |
Do not confuse COO with preferential C/O. |
Note: No landed cost section is included. Rates are references for dossier review and do not replace official tariff lookup at declaration time.
APPLICABLE SPECIALIZED POLICY
| Goods scenario |
Possible policy |
Documents |
Authority/portal |
Timing |
Risk note |
| Extract for cosmetic manufacturing |
Not treated as a finished cosmetic if imported only as production material; keep raw material file for PIF/manufacturing records. |
COA, SDS, specification, INCI, plant source, quality standard. |
Customs; internal QA/R&D; cosmetic authority when declaring finished products. |
Before PO and before ETA. |
Missing COA/SDS or unclear INCI may block HS and quality review. |
| Extract sold directly as a topical product |
May be treated as finished cosmetic: product notification, Vietnamese label, PIF. |
Label, claims, instructions, formula, notification if marketed. |
Cosmetic authority. |
Before placing on market. |
Do not call it raw material if sold to consumers. |
| Food/oral/health claims |
May shift to food/supplement policy; this article does not apply. |
Label, COA, claims, dosage, catalogue. |
Food safety/health authority. |
Before commercial import. |
Oral claims change policy. |
| Treatment/medicinal claims |
May be pharmaceutical/herbal medicine. |
CFS, GMP, herbal dossier, treatment claims. |
Drug/health authority. |
Before ordering. |
Do not import as cosmetic raw material if therapeutic. |
| Hazardous chemical/mixture |
Review Decree 26/2026/ND-CP and controlled chemical lists if CAS/solvent/hazard exists. |
SDS, CAS, composition, GHS. |
MOIT/chemical declaration portal if applicable. |
Before booking and ETA. |
Missing SDS/CAS affects chemical and DG review. |
| Special plant/animal origin |
Review quarantine, CITES and restricted species if relevant. |
Source, origin country, processing, CITES statement. |
Quarantine/CITES authority if triggered. |
Before supplier confirmation. |
Restricted species may require permit or be prohibited. |
LEGAL DOCUMENTS TO REVIEW
| Document group |
Document |
Issuer |
Effective date |
Role |
Key provisions/appendix |
Review note |
| Tariff |
Decree 26/2023/ND-CP |
Government |
Effective 15/07/2023 |
MFN tariff and taxable import list. |
Appendix II; HS 1302.19.90. |
Check tariff at declaration date. |
| Chemical |
Decree 26/2026/ND-CP |
Government |
Effective 17/01/2026 |
Management of chemical activities and hazardous chemicals in products/goods. |
Controlled chemical lists and declaration triggers. |
Apply only if the extract/mixture falls within scope. |
| Cosmetics |
Circular 06/2011/TT-BYT and Circular 34/2025/TT-BYT |
Ministry of Health |
Circular 34 effective 18/08/2025 |
Cosmetic notification/PIF/finished product control. |
Notification and product responsibility. |
Raw material differs from finished cosmetics. |
| Labeling |
Decree 43/2017/ND-CP and 111/2021/ND-CP |
Government |
Effective 01/06/2017 and 15/02/2022 |
Original/Vietnamese labels and origin. |
Mandatory label contents. |
Applies when circulated or sold domestically. |
| VAT |
Decree 174/2025/ND-CP |
Government |
From 01/07/2025 in applicable period. |
Review 8%/10% VAT. |
Exclusion appendices. |
Do not automatically apply 8%. |
| Customs |
Customs Law and implementing decrees/circulars |
National Assembly/Government/MOF |
Check consolidated/amended texts. |
Customs dossier, HS, valuation, C/O, post-clearance. |
Declaration and inspection rules. |
Review by actual shipment file. |
VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS
Enterprises should also verify documents on official legal portals or issuer websites before applying them.
CUSTOMS DOCUMENTATION SET
| Document group |
Required documents |
Used for |
Prepared by |
Common errors |
Pre-ETA check |
| Commercial documents |
Commercial Invoice, Packing List, B/L or AWB, contract/PO, C/O if claiming preference. |
Customs declaration, valuation, origin and quantity. |
Exporter, importer, forwarder. |
Generic “extract” description; wrong origin/weight. |
Lock bilingual description, specification, source and HS before ETA. |
| Technical file |
COA, MSDS/SDS, specification, INCI, CAS if any, solvent ratio, extraction method. |
HS classification, chemical/DG review, quality control. |
Manufacturer, QA/R&D, purchasing. |
Missing COA/SDS; INCI mismatch. |
Check each raw material code, batch, shelf life and quality standard. |
| Specialized dossier if triggered |
Chemical declaration, quarantine/CITES, cosmetic/food/drug file if applicable. |
Specialized control before clearance or circulation. |
Importer, regulatory, QA, service provider. |
Policy discovered only after ETA. |
Review intended use and claims before PO. |
| Label/storage file |
Original label, Vietnamese label if circulated, SDS, storage conditions, shelf life. |
Circulation, resale, storage and audit. |
Importer, warehouse, QA, marketing. |
Missing origin, quantity, warning or storage condition. |
Check label before applying/placing on market. |
CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point |
Question |
Evidence |
Consequence |
Recommended handling |
| Is HS supported? |
Is it plant extract, medicinal extract, essential oil, fragrance, active or chemical mixture? |
COA, MSDS, INCI, plant source, extraction method. |
Wrong HS/duty and possible classification analysis. |
Lock HS before ETA. |
| What is the import purpose? |
Cosmetic manufacturing, raw material resale, consumer sale, food or medicine? |
Contract, catalogue, label, marketing claims. |
Wrong specialized policy. |
State purpose clearly in internal dossier. |
| Chemical/DG elements? |
Flammable solvent, controlled CAS, GHS hazards? |
SDS, flash point, UN number. |
Transport refusal or chemical declaration. |
Review SDS before booking. |
| Is C/O valid? |
Form, origin criterion, HS, description and direct transport? |
C/O, B/L, Invoice, Packing List. |
Loss of FTA preference. |
Review draft C/O before issuance. |
| Do labels and documents match? |
Name, source, raw material code, batch, expiry and origin? |
Label, COA, invoice, packing list. |
Document queries/post-clearance risk. |
Use one master description. |
PRACTICAL E2E PROCESS
| Step |
Action |
| 1. Pre-ETA review |
Lock HS, intended use, COA/SDS, VAT, C/O, chemical/DG risk and species origin. |
| 2. Freeze documents and technical file |
Align Invoice, Packing List, B/L/AWB, COA, SDS, INCI, botanical source, lot/batch and label. |
| 3. Specialized handling if triggered |
Chemical declaration, quarantine/CITES, finished cosmetic file, food/drug policy if applicable. |
| 4. Customs declaration |
Explain HS, customs value, origin, C/O, import purpose and technical documents under Yellow/Red channel. |
| 5. Clearance and post-clearance |
Archive shipment file, COA/SDS, storage condition, Vietnamese label if resold and post-clearance explanation file. |
PRE-ETA RISK CHECKLIST
| Risk |
Consequence |
Pre-ETA prevention |
Documents |
| Generic product name “extract” |
Insufficient HS/policy basis. |
State botanical source, form, solvent base and cosmetic raw material use. |
Invoice, Packing List, COA, SDS, label. |
| Raw material vs finished cosmetic confusion |
Wrong notification/circulation treatment. |
Define whether used for manufacturing or sold to consumers. |
Contract, label, usage instruction. |
| No chemical/DG review |
Carrier rejection or extra declaration. |
Check SDS, flash point, CAS and GHS before booking. |
SDS/MSDS, COA. |
| C/O description/HS mismatch |
FTA preference denied. |
Review form, criterion, description, HS, date, direct transport. |
C/O, Invoice, B/L. |
| Restricted source/claim |
CITES, drug, food or restricted policy may arise. |
Check source, claims and restricted lists before purchase. |
Catalogue, source statement, CITES statement. |
FAQ
| Question |
Answer |
| Does cosmetic raw material extract require cosmetic notification? |
Not usually if imported only as manufacturing raw material. If sold directly as a topical cosmetic product, finished cosmetic notification may be required. |
| Is HS always 1302.19.90? |
No. It depends on composition, source and use; essential oils, fragrances, medicinal extracts or isolated actives may use different HS codes. |
| Is VAT 8% or 10%? |
Baseline must be checked at declaration time. 8% may apply only if the current VAT reduction policy covers the goods and no exclusion applies. |
| Can C/O reduce duty? |
Yes, if a valid preferential C/O/origin document matches the shipment and the FTA schedule provides a lower rate. |
| Is chemical declaration required? |
Not by default. Review only if the extract/mixture contains controlled or hazardous chemical components. |
| Are R&D samples easier? |
Purpose and quantity may differ, but Invoice, Packing List, transport document, COA/SDS and purpose explanation should still be ready. |
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EXECUTION SUPPORT FROM TGIMEX
This article provides an HS, duty, documentation and policy map for cosmetic raw material extract. In actual shipments, the enterprise must still review COA, SDS, INCI, catalogue, label, origin, C/O and intended use. For shipments that may involve chemicals, CITES, quarantine, C/O or labeling control, dossier review should start before ETA. TGIMEX supports an E2E import approach: pre-ETA policy review, document control, international logistics coordination, customs declaration, clearance handling, inland delivery and post-clearance file retention.
Pre-ETA review
- HS/C/O/VAT/policy
- COA/MSDS/INCI
- label/origin/claim
Operational control
- international freight coordination
- customs declaration
- inland delivery and file retention
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