Products claiming antibacterial, disinfecting, antimicrobial, germ-killing or “kills 99.9% germs” should not be handled as ordinary cosmetics merely because they are sold as gels, sprays, wipes or hand-cleansing liquids.

The key risk lies in product claims, active ingredients, intended use and label wording. A single statement on the label or catalogue may move the shipment from cosmetics to household/medical disinfectant preparations, or even require review under pharmaceutical or medical device rules if the product is linked to wound antisepsis, pre-surgical use or treatment.

This article provides an E2E (End-to-End) operational map for pre-ETA review: HS code, duty, C/O, specialized policy, clearance documents, customs process and risk controls before arrival.

QUICK FACTS

Item to review	Operational reference conclusion	Application note
Product nature	Products with antibacterial/disinfecting/germ-killing claims should normally be reviewed as household/medical disinfectant preparations.	Do not automatically use cosmetic notification if the label shows disinfecting as the main function.
Main reference HS	3808.94.90 – other disinfectants; aerosol/spray cans may require review under 3808.94.20.	Final classification depends on active ingredients, packaging form, main function and technical documents.
Import duty reference	For 3808.94.90: reference MFN 0%; ordinary rate 5%; valid FTA C/O may often result in 0%.	Verify the tariff schedule at declaration time and actual origin.
VAT reference	For HS 3808.94.90, VAT must be reviewed as 5% or 10% depending on product nature, use, VAT code and tax policy at declaration time.	Do not automatically fix 5% if the goods are consumer chemicals, insecticidal products or items excluded from VAT reduction.
Specialized dossier	Circulation registration number or import license depending on case; CFS; active ingredient data; label; testing/efficacy documents where required.	For commercial import, review circulation status before shipment.
Authorities/portals	Ministry of Health / Department of Preventive Medicine or delegated authority; public service portal; customs office.	Responsible authority may change under decentralization rules.

Legal note: This guide applies only to antibacterial/disinfecting products. It is not a combined guide for acne-treatment claims, beauty supplements or beauty devices. Review catalogue, formula, SDS/MSDS, label artwork, marketing claims, import purpose and the actual dossier.

Illustration for Import procedure guide for antibacterial/disinfecting products — Illustration of the product group and document review before customs clearance.

SCOPE OF APPLICATION

This guide applies to liquids, gels, sprays, wipes, surface-cleaning solutions or skin/surface-contact products whose main claim states antibacterial, disinfecting, antimicrobial, sterilising or germ-killing functions.

Covered in this guide

Hand sanitizing gels/sprays with disinfecting claims.
Surface, tool or environmental disinfectants for household/medical use.
Antibacterial wipes or products impregnated with disinfecting active ingredients.
Commercial imports, samples, gifts or project supplies.

Not automatically covered

Products only claiming cleansing, refreshing, fragrance or moisturizing without germ-killing claims.
Wound antiseptics, pre-surgical antiseptics or products presented as treatment.
Beauty devices or physical equipment.
Oral beauty supplements or health foods.

Review according to the actual catalogue, datasheet, model/SKU and import purpose. If the product contains alcohols, chlorhexidine, quaternary ammonium compounds, iodine, peroxide, chlorine compounds or other biocidal actives, check the restricted/prohibited chemical lists.

CLASSIFICATION & PRODUCT IDENTIFICATION

The decisive factor is not only the dosage form, but the main function represented on labels, catalogues, websites, instructions and technical dossiers. The same base formulation may fall under different policies if claims differ.

Criteria	Documents to check	Risk if incorrectly described	Suggested goods description
Main function	Catalogue, label artwork, claim list, website listing	Declared as cosmetics while label shows disinfecting, causing requests for registration/license.	“Disinfectant preparation/solution for household/medical use, ingredients…, packing…, brand new”.
Active ingredient	Formula, COA, SDS/MSDS, technical specification	Wrong active ingredient may lead to wrong HS, policy and label.	State key active ingredient where supported by documents.
Intended use	IFU, label, safety instruction	Hand use differs from surface/tool/medical facility use.	Clearly separate skin use, surface use or medical-facility use.
Packaging form	Packing List, catalogue, product photos	Aerosol/spray cans may require another subheading.	State bottle/can/spray/wipe, volume and quantity.
Import status	Invoice, Packing List, contract	Samples/gifts/research goods may need separate permit basis.	State commercial, sample, gift, testing or internal-use purpose.
Label & safety warning	Original label, Vietnamese sub-label draft, SDS/MSDS	Missing warnings/instructions/registration number may delay clearance or market circulation.	Prepare Vietnamese label before ETA.

HS CODE – DUTY – C/O

For antibacterial/disinfecting products, HS classification must be based on the principal function, active ingredients, packaging form, intended use and label claims. If the goods are household/medical-use disinfectant preparations, the review normally starts from heading 38.08, especially disinfectants under 3808.94.

Classification principle: HS 3808.94.90 is only a reference direction for other disinfectant preparations when the goods are not medicines, not ordinary cosmetics, not medical devices, and not specifically described as aerosol/spray or another special subcategory.

1. HS orientation by product nature

Reference HS	Product group	Application conditions	Risk if wrong	Documents to check
3808.94.90	Other disinfectants.	Main reference for disinfectant liquid, gel, wipes, surface disinfectant solution and other non-aerosol preparations.	May be challenged if the product is actually medicine, cosmetic, medical device or treatment-oriented antiseptic.	Catalogue, SDS/MSDS, COA, active formula, original/Vietnamese labels, IFU, images and packing specs.
3808.94.20	Other disinfectants, aerosol/spray form.	For aerosol/spray can with propellant or pressurized spraying mechanism.	Wrong distinction between aerosol and pump spray may cause HS error.	Packaging images, propellant/pressure information, SDS, packing list and catalogue.
3808.94.10	Disinfectants containing coal-tar acid mixtures and alkalis.	Only where the formula matches this specific chemical description.	Using this special code without formula support may lead to wrong policy.	COA, SDS/MSDS, composition sheet and technical documents.
3808.59.60 or other 38.08 codes	Disinfectant preparations separately described in the specialized list.	Review when active ingredient or MOH HS list does not point directly to 3808.94.	Relying only on “disinfectant” claims may lead to wrong specialized policy.	MOH HS list, SDS/MSDS, active ingredients, intended use, label and circulation dossier.
3004 or pharmaceutical headings	Medicinal antiseptic products.	For treatment, wound antisepsis, pre-surgical use or infection treatment.	Missing pharmaceutical registration/licensing.	Label, indications, IFU, foreign MA and pharmaceutical dossier.
3304/3401	Cosmetics/skin cleansing/soap.	Only if the product is ordinary cleansing/skin-care and does not use disinfecting action as the main claim.	Cosmetic/soap HS may be rejected for strong disinfecting claims.	Ingredient list, claim list, labels, cosmetic notification, catalogue and intended use.

2. Import duty and VAT table

HS	Description	MFN import duty	Ordinary import duty	VAT / VAT reduction	Operational note
3808.94.90	Other disinfectants.	0%.	5%.	Base VAT is generally reviewed at 10%; during 01 Jul 2025–31 Dec 2026, 8% may apply if eligible and not excluded. Verify the VAT code in the customs system on the declaration date.	Main reference code, not a substitute for technical classification.
3808.94.20	Other disinfectants, aerosol/spray.	0%.	5%.	Review by final HS/VAT code.	Evidence of aerosol/pressurized spray is required.
3808.94.10	Coal-tar acid/alkali mixture disinfectants.	0%.	5%.	Check by final VAT code.	Only if formula matches.
3808.59.60	Separately listed disinfectant preparations.	Check final code.	Check final code.	Check final code and policy.	Do not use without active-ingredient/list evidence.

C/O note when MFN is already 0%: for 3808.94.10/3808.94.20/3808.94.90, MFN import duty is currently 0%, so preferential C/O may not create additional duty savings. C/O remains useful for origin proof and compliance control.

3. Preferential C/O and FTA table

Origin route	C/O or origin document	Reference preferential duty	When to use	Key conditions	Risk if incorrect
ASEAN	Form D – ATIGA	Usually 0%.	ASEAN origin proof or internal compliance.	Origin criterion, direct consignment and matching description/HS/quantity.	Wrong RVC/CTH/CTSH or mismatched description may lead to rejection.
China	Form E – ACFTA or RCEP.	Usually 0%.	China/RCEP origin proof.	Third-party invoice, direct transport, description and HS consistency.	Incorrect Form E or HS mismatch may invalidate C/O.
Korea	Form AK/VK or RCEP.	Usually 0%.	Select the best matching agreement.	C/O, invoice, packing, B/L/AWB and origin criterion.	Wrong form or criterion may cause loss of preference.
Japan	Form VJ/AJ, CPTPP or RCEP.	May be 0%.	Japan-origin compliance.	Origin rules, transport documents and self-certification if used.	Wrong agreement or missing direct consignment evidence.
EU/UK	EUR.1 or origin statement under EVFTA/UKVFTA.	May be 0%.	EU/UK origin proof.	Correct origin certification, exporter info, description, HS and transport evidence.	Incorrect statement/EUR.1 or insufficient origin evidence.
Australia-New Zealand/India/Hong Kong/UAE	AANZFTA, AIFTA, AHKFTA or relevant CEPA.	Check effective tariff on declaration date.	Eligible origin routes.	Valid C/O, invoice, B/L, origin marking and matching HS.	Incomplete evidence may trigger duty reassessment.

4. Pre-ETA C/O checklist

Formality

Correct form or self-certification mechanism.
Valid issue date, reference number, stamp/signature or verification code.
No expiry, erasure or formal defect.

Goods information

Description matches Invoice, Packing List, B/L/AWB and label.
HS on C/O does not conflict with customs declaration.
Quantity, weight, packing and origin country are consistent.

Origin criterion

Check WO/RVC/CTH/CTSH or agreement-specific criterion.
Check third-party invoicing if any.
Check direct consignment and transit evidence.

APPLICABLE SPECIALIZED POLICY

Scenario	Possible policy	Dossier to check	Authority/portal	When to act	Risk note
Commercial disinfectant import	Circulation registration for household/medical disinfectant preparations under Decree 91/2016 and amendments.	Registration number, CFS, label, active ingredients, testing data where required.	MOH / Department of Preventive Medicine or delegated authority; public service portal.	Before order or before ETA; preferably before shipment.	Cosmetic notification cannot replace disinfectant registration.
Unregistered or special-need import	May require a specific import license.	Import request, technical documents, reason, CFS/COA/SDS.	Public service portal/MOH.	Before ETA.	Late license application may cause storage/demurrage.
Samples/testing goods	May require permit or explanation of sample purpose.	Sample invoice, technical documents, purpose, quantity.	MOH/customs depending on case.	Before shipping.	Wrong purpose/quantity may require correction.
Therapeutic/wound/pre-surgical claims	May move to pharmaceutical or medical device policy.	IFU, label, indication, authorization, active ingredient.	Drug Administration or medical device authority where applicable.	At catalogue review stage.	Do not classify as disinfectant preparation if therapeutic indication dominates.
Cleansing/cosmetic only, no disinfecting claim	May follow cosmetic notification if cosmetic definition is met.	Ingredient list, label, cosmetic notification/PIF.	Drug Administration/provincial health authority where delegated.	Before commercial import.	This guide does not apply to ordinary cosmetics.
Restricted/dangerous chemicals	Review prohibited chemicals and dangerous chemicals requiring information disclosure under Circular 05/2026/TT-BYT.	SDS/MSDS, COA, formula, active concentration.	MOH/specialized authority.	Before purchase order.	Missing SDS/concentration data may cause rejection.

LEGAL DOCUMENTS TO REVIEW

Document group	Document	Authority	Effective timing	Role	Key point	Review note
Decree	Decree 91/2016/ND-CP on household/medical insecticidal and disinfectant preparations.	Government	Effective 01/07/2016.	Base regulation for registration/import/management.	Registration, import, labeling and dossier requirements.	Check consolidated/amending documents.
Amending decrees	Decree 155/2018/ND-CP and Decree 129/2024/ND-CP.	Government	Decree 129/2024 effective 30/11/2024.	Amends conditions and administrative procedures.	Forms, import license and amended conditions.	Use current consolidated basis.
Healthcare decentralization	Decree 148/2025/ND-CP.	Government	Effective 01/07/2025.	Determines delegated authority for healthcare procedures.	Relevant procedural annexes.	Check receiving authority at filing time.
Specialized circular	Circular 16/2024/TT-BYT on HS codes for certain disinfectant preparations.	MOH	Effective 15/11/2024.	Supports HS/policy review.	HS list and description.	Match actual goods, not only trade name.
Medical device circular	Circular 19/2024/TT-BYT on HS codes for exported and imported medical devices.	MOH	Effective 16/11/2024.	Reviews cases where disinfecting/sterilizing products are used for medical devices or presented as medical device-related goods.	HS-coded medical device list.	Apply only if the actual use/function falls within medical device scope; review the actual dossier.
Specialized circular	Circular 05/2026/TT-BYT on prohibited/dangerous chemicals in disinfectant preparations.	MOH	Effective 15/05/2026.	Checks active ingredients and restrictions.	Prohibited and disclosure-required chemicals.	Compare SDS/MSDS and formula.
Cosmetics	Circular 06/2011/TT-BYT and Circular 34/2025/TT-BYT.	MOH	Circular 34/2025 effective 18/08/2025.	Boundary check for products called cosmetics.	Cosmetic definition, notification and PIF.	Do not apply to disinfecting main function.
Tariff	Decree 26/2023/ND-CP.	Government	Effective 15/07/2023.	MFN tariff basis.	Chapter 38 / heading 38.08.	Check new tariff amendments at declaration time.
Labeling	Decree 43/2017/ND-CP and 111/2021/ND-CP.	Government	2017 and 2022 effective dates.	Goods labeling and Vietnamese sub-label.	Name, origin, responsible party, quantity, ingredients, warnings.	Labels must match specialized dossier and customs declaration.

VIEW / DOWNLOAD ORIGINAL LEGAL DOCUMENTS

Enterprises should additionally cross-check the legal database or the issuing authority’s website before application.

Decree 91/2016/ND-CP Decree 129/2024/ND-CP Circular 05/2026/TT-BYT Circular 16/2024/TT-BYT Circular 19/2024/TT-BYT Registration public service Decree 26/2023/ND-CP

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order where available.
C/O if preferential duty is claimed.
Catalogue, SDS/MSDS, COA, label images and packing details.

Specialized documents

Circulation registration number or import license by case.
CFS where required.
Testing/efficacy data, active ingredient formula, safety documents.
Original label and Vietnamese sub-label draft.
Purpose evidence for samples, gifts or testing goods.

Dossier group	Required documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO, B/L/AWB.	Declaration, value, quantity and Incoterms.	Importer, exporter, forwarder.	Goods named “cosmetic” while label says disinfectant.	Check name–active–claim–HS before manifest/pre-alert.
Technical	Catalogue, SDS/MSDS, COA, formula summary, label artwork.	HS, specialized policy and label.	Manufacturer/exporter/regulatory team.	SDS lacks CAS/concentration or catalogue lacks function.	Request clear English/bilingual technical documents.
Specialized	Registration/license/CFS/testing where applicable.	Clearance and circulation.	Importer/registration holder.	Registration number not matching trade name/SKU/manufacturer.	Check each SKU and packing size.
Origin	C/O, direct transport proof, third-party invoice where applicable.	Preferential duty.	Exporter/documentation team.	Wrong HS/description on C/O.	Compare C/O with Invoice, Packing, B/L before shipment.
Labeling	Original label, Vietnamese sub-label, instructions, safety warning.	Market circulation/post-clearance audit.	Importer, regulatory, marketing.	Claims exceed registered dossier; missing flammability warning.	Lock label before ETA.

100% consistency rule: goods name, quantity, packing, active ingredient, origin, manufacturer, registration number, claims and labels must match across commercial documents, catalogue, SDS/MSDS, specialized dossier and customs declaration.

CLEARANCE DECISION POINTS

Decision point	Question	Evidence	Consequence if unclear	Recommended action
Product nature	Is it cosmetic cleansing or disinfectant preparation?	Label, claims, catalogue, SDS/MSDS.	Request for registration/license or amended declaration.	Prepare classification memo before purchase.
Registration/license	Is a valid registration/license available for this SKU?	Registration number, license, dossier.	Delay or inability to circulate.	Check per SKU/packing before ETA.
HS and duty	Is HS 3808.94.90 supported?	Composition, function, packing, classification notice if any.	Tax assessment, C/O rejection, explanation request.	Prepare HS analysis pack.
Label claims	Do label claims exceed the dossier?	Label artwork and claim list.	Relabeling or policy mismatch.	Legal review before printing/shipping.
C/O	Is C/O form, HS, description and direct transport correct?	C/O, B/L/AWB, invoice, packing.	No preference or tax reassessment.	Pre-check draft C/O.
Hazardous chemical	Is the active ingredient prohibited or disclosure-required?	SDS/MSDS, COA, formula, Circular 05/2026.	Specialized rejection/safety explanation.	Check CAS and concentration before PO.

PRACTICAL E2E PROCESS

Step 1: Pre-ETA review

Confirm nature: cosmetic, disinfectant, medicine or medical device.
Confirm HS, duty, VAT and C/O.
Check registration/license.
Review label, claims, active ingredients and SDS/MSDS.

Step 2: Lock documents

Finalize Invoice, Packing List and B/L/AWB.
Finalize catalogue, SDS/MSDS, COA and label artwork.
Match goods name, packing, SKU, origin and active ingredient.
Request draft C/O where applicable.

Step 3: Complete specialized dossier

Check circulation registration or import license.
Submit/complete missing dossier before arrival.
Review CFS/testing data where required.
Avoid post-ETA specialized filings.

Step 4: Customs declaration

Green lane: system-based clearance under conditions.
Yellow lane: document check.
Red lane: document and physical inspection.
Prepare HS, valuation, C/O, policy and label explanations.

Step 5: Clearance and delivery

Fulfil tax obligations.
Pick up/deliver goods.
Check Vietnamese labels and registration before distribution.
Archive shipment and specialized documents.

Step 6: Post-clearance control

Archive C/O, SDS/MSDS, COA, registration and label files.
Prepare audit explanation set.
Do not change marketing claims beyond the dossier.
Re-review policy upon formula/packing/manufacturer changes.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents
Calling the product cosmetic while label says disinfectant	Policy switch and registration/license request.	Review all claims across labels, catalogues and invoice.	Label, catalogue, claim list, SDS/MSDS.
Missing registration/license	Delayed clearance or no circulation basis.	Check circulation status before shipment.	Registration, license, CFS, dossier.
Wrong HS/no HS analysis	Tax assessment, C/O rejection or inspection.	Prepare HS memo.	Catalogue, SDS/MSDS, COA, packing.
Incorrect C/O	Loss of preference and additional duty.	Review draft C/O.	C/O, Invoice, Packing, B/L/AWB.
Vietnamese label missing warning or wrong claim	Relabeling and market restriction.	Approve sub-label before ETA.	Original label, sub-label, SDS, dossier.
Restricted active not checked	Specialized rejection or safety explanation.	Check CAS and concentration under Circular 05/2026.	Formula, COA, SDS/MSDS.

FAQ

Question	Short answer
Can antibacterial/disinfecting products be notified as cosmetics?	Not automatically. If the main function is disinfecting, review as disinfectant preparation; cosmetic notification does not replace registration.
What is the common HS?	Often 3808.94.90 for other disinfectants; aerosol form may require 3808.94.20.
Is an import license required?	Commercial goods usually require review of circulation registration. Some unregistered, sample, gift or special-need imports may require a separate import license.
Is VAT 5% or 10%?	For HS 3808.94.90, VAT must be reviewed as 5% or 10%. Do not decide mechanically by HS only; verify the VAT code, product nature, use and tax policy at declaration time.
Can C/O reduce duty?	Possibly. Even where MFN is 0%, C/O remains useful for origin control and compliance.
What if the label only says “antibacterial”?	Review is still required. Antibacterial/disinfecting claims may change the specialized policy.
Are samples handled like commercial goods?	No. Samples need purpose and quantity evidence and may need separate permission.
Is Vietnamese sub-label required?	Yes. It must match the original label and the specialized dossier.

IMPLEMENTATION SOLUTIONS FROM TGIMEX

This article provides a map of HS code, duty, documents and specialized policy. For actual shipments, enterprises must still review catalogue, SDS/MSDS, active ingredient formula, documents, origin, label and import purpose.

TGIMEX has an agency network across more than 60 countries and memberships in WCA, WCA China Global, VLA and HNLA, with capabilities in sea, air, road/rail freight, customs clearance, C/O, import permits, warehousing and domestic delivery.

Pre-ETA review

HS, specialized policy, C/O, duty, label, catalogue and SDS/MSDS.
Assessment of cosmetics vs disinfectants vs medicine/medical device.

Compliance dossier control

Cross-check Invoice, Packing List, B/L/AWB, C/O, catalogue, test report, label and technical files.
Build SKU-level consistency checklist.

Logistics & customs

Coordinate agents/carriers, ETA, pre-alert and transport documents.
Prepare declaration dossier and handle Green/Yellow/Red lanes.

Post-clearance

Archive shipment dossier, sub-label and circulation files.
Prepare post-clearance explanation set.

For shipments involving specialized inspection, import licenses, C/O or labeling requirements, enterprises should not wait until arrival to review documents. Even minor mismatches between Invoice, Packing List, catalogue, SDS/MSDS, C/O or labels may trigger document requests, delayed clearance or unplanned storage costs.

TGIMEX supports enterprises in building an E2E import plan: pre-ETA policy review, document checking, international transport coordination, customs declaration, clearance handling, domestic delivery and post-clearance archiving.

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