Importing cosmetic active ingredients is operationally sensitive because commercial names are often insufficient to determine HS code, import duty and specialized policy. If the goods are declared merely as “active ingredient”, “cosmetic active” or “skin whitening active”, Customs may request clarification on chemical identity, CAS number, COA/MSDS, intended use and may require HS adjustment after arrival. This article provides an E2E (End-to-End) map for reviewing HS code, duty, C/O, technical dossier and pre-ETA risks.

QUICK FACT

Item	Content
Product	Cosmetic active ingredients: niacinamide, panthenol, retinol derivatives, peptides, HA, AHA/BHA, brightening actives, etc.
HS nature	There is no single HS code for “active”; classification depends on chemical identity, CAS number, single substance/mixture status and intended use.
Common HS references	Examples: 2936.29.00 other vitamins/derivatives; 2918 carboxylic acids; 2922/2933/2934 organic compounds containing N/O; 3824.99.99 other chemical preparations N.E.S. if formulated mixtures.
Reference duties	Depending on HS: some headings may have MFN 0% such as 2936.29.00; other groups must be checked at declaration date; VAT commonly requires review and many chemical codes are at 10%.
Specialized policy	Review based on dossier: chemicals, precursors, restricted cosmetic substances, pharmaceutical-like use, DG cargo, SDS/COA requirements.
Key dossier	Invoice, Packing List, B/L/AWB, COA, MSDS/SDS, TDS, CAS number, INCI name, specification, C/O, original label, intended use.

Illustration for Import procedure for cosmetic active ingredients into Vietnam — Illustration of the product group and document review before customs clearance.

Legal note: This article applies only to active ingredients used as cosmetic raw materials. It does not apply to finished retail serum/cream, pharmaceuticals, health supplements or raw materials managed under other regulatory regimes.

SCOPE OF APPLICATION

This article applies to active ingredients used as cosmetic raw materials, imported as powder, granules, liquid, gel, premix or solvent-carried ingredients. Related groups include surfactants, emollients, extracts, fragrance oils, preservatives, actives and colorants; however, this article addresses only actives and must not be automatically applied to other groups. Review must be based on catalogue, datasheet, material code, CAS number, INCI name, COA, MSDS/SDS and the actual import purpose.

CLASSIFICATION & TECHNICAL IDENTIFICATION

Do not classify by trade name

“Active” is a functional term. Classification must start from CAS, INCI, assay, form and intended use.

Description risk

Generic “cosmetic raw material” may cause HS error, chemical-policy issue, C/O discrepancy or declaration amendment.

TECHNICAL IDENTIFICATION CRITERIA

Criteria	Documents to check	Risk if wrongly described	Suggested declaration description
CAS number	COA, SDS/MSDS, specification	Chemical identity cannot be confirmed; HS risk increases	Active ingredient for cosmetic manufacturing – CAS … – INCI …
INCI name	TDS, intended-use formula	Commercial name may differ from ingredient name	Cosmetic active raw material – INCI …
Physical form	Packing List, packaging photos, original label	Liquid/mixture form may change HS classification	Powder/liquid cosmetic active, packed in … kg/drum
Assay & solvent	COA, composition statement	Premix may no longer be treated as a single substance	Active premix in solvent, for cosmetic production
Intended use	PO, technical declaration	May be interpreted as pharmaceutical/food/other chemical	Raw material for cosmetic manufacturing, not for retail sale

HS CODE – DUTIES – C/O

Cosmetic active is not a single fixed HS code. Customs classification must not rely on the commercial wording “active”, “whitening active”, “anti-aging active” or “cosmetic active”. The classification basis must include the CAS number, INCI name, COA (Certificate of Analysis), SDS/MSDS (Safety Data Sheet), chemical structure, pure substance/mixture status, carrier solvent, active content and actual import purpose.

Legal note: The following matrix is an operational classification framework before ETA. The final 8-digit HS code should only be confirmed after reviewing CAS, COA, SDS/MSDS, quantitative composition and technical literature. If the chemical falls under chemical declaration, precursor or restricted-substance control, specialized policy must be checked before arrival.

HS CLASSIFICATION BASIS FOR COSMETIC ACTIVE INGREDIENTS

Review layer	What to determine	HS impact	Evidence documents
1. Chemical nature	Vitamin derivative, organic acid, peptide, amino derivative, heterocyclic compound, botanical extract or formulated blend.	Determines whether Chapter 29, 32, 33 or 38 may apply.	CAS, INCI, COA, SDS/MSDS, structure if available.
2. Pure substance or mixture	Pure active or premix containing solvent, carrier, preservative or stabilizer.	Pure substances are usually classified by chemical structure; premixes may shift to preparation headings.	Composition statement, percentage, solvent carrier, specification.
3. Declared use	Raw material for cosmetic manufacturing, not medicine or food supplement.	Prevents misclassification into pharmaceutical/food categories due to therapeutic or oral-use claims.	PO, contract, TDS, application note, outer label.
4. Commercial condition	Raw material, R&D sample, testing sample, semi-finished or finished cosmetic.	Finished/semi-finished goods for direct skin/hair use may fall under Chapter 33.	Catalogue, packing, label, intended-use declaration.

DETAILED HS – DUTY MATRIX BY ACTIVE GROUP

Common active group	Reference/proposed HS code	Identification basis	Normal duty	MFN	VAT	Risk if misclassified	Documents to check
Vitamin/derivative active Niacinamide, Panthenol, Retinyl Palmitate, Ascorbyl Glucoside, Tocopheryl Acetate.	2936.29.00 if classified as other vitamins and derivatives, unmixed; specific vitamins may fall under 2936.21–2936.28.	CAS and structure show vitamin/vitamin derivative mainly used as vitamin.	0% reference if MFN is 0%; verify at declaration date.	0% for 2936.29.00 per VTIP.	10%	Premixed vitamin in solvent may no longer remain under 2936.	CAS, INCI, COA, SDS/MSDS, assay %, solvent, C/O.
AHA/BHA/organic acids Glycolic Acid, Lactic Acid, Salicylic Acid, Mandelic Acid.	2918.xx.xx; final 8-digit code depends on each CAS.	Carboxylic/hydroxy acid structure; salt/ester forms may change HS.	0–15% depending on 8-digit code.	0–10% depending on code.	10%	Different acids have different codes; wrong CAS may lead to wrong duty and chemical policy.	CAS, purity %, acid/salt/ester form, SDS, COA.
Amino acid / peptide / amino derivatives	2922.xx.xx, 2933.xx.xx or 2934.xx.xx; mixtures may shift to Chapter 38.	Amino group, nitrogen heterocycle or peptide structure.	0–10% depending on 8-digit code.	0–5% or other rate by code.	10%	Trade names of peptides are insufficient for classification.	CAS, sequence/structure, assay, molecular weight, COA, SDS.
Standardized botanical extract	1302.xx.xx for plant extracts; formulated blends may fall under 3824.99.xx.	Botanical source, extraction method, solvent, marker content, powder/liquid form.	5–20% depending on code and processing level.	0–15% depending on 8-digit code.	5% or 10% depending on classification and VAT policy.	May be confused with raw extract, flavour, food additive or cosmetic raw material.	Botanical source, extraction solvent, marker %, COA, SDS, TDS.
Formulated active complex/premix	3824.99.xx is a key review direction if it is a chemical preparation not elsewhere specified.	Multiple components, carrier solvent, no single component gives the essential classification.	0–15% depending on 8-digit code.	0–5% or rate by code.	10%	High risk if supplier refuses full composition disclosure.	Full composition, percentages, SDS, TDS, function of each component, COA.
Finished/semi-finished cosmetic preparation	May shift to 3304 or 3305 if directly used on skin/hair or retail-packed.	Claims, label, direct use, packaging and product presentation.	Generally higher; depending on cosmetic HS code.	Often around 18–27% for many cosmetic headings; verify code-specific rate.	10%	Wrong HS plus missing cosmetic notification number if placed on market.	Original label, claim, packaging, cosmetic notification, catalogue.

C/O AND FTA PREFERENTIAL DUTY REVIEW

Route/origin	C/O form or origin proof	Preferential rate to verify	Conditions	Documents to check	Risk
ASEAN / ATIGA	Form D or accepted origin proof.	Many chemical codes may be 0% if PSR is met; verify final HS.	Correct PSR and direct transport.	Form D, Invoice, Packing List, B/L, HS 6-digit, description, CTH/RVC.	Wrong HS or vague description may lead to rejection.
China / ACFTA	Form E.	Verify by final HS; do not assume 0%.	ACFTA origin criteria, proper third-party invoicing if any.	Form E, third-party invoice, B/L, COA/SDS.	Form E is often checked for description, HS and origin criterion.
RCEP	RCEP C/O or origin proof.	Check the RCEP schedule by exporting country.	Correct origin, PSR and transport condition.	RCEP C/O, transport docs, origin explanation if needed.	RCEP may not be better than another FTA.
Korea / AKFTA, VKFTA	Form AK or VK.	Compare AKFTA/VKFTA/RCEP and choose the lowest valid rate.	PSR met; exporter, criterion and goods description match.	C/O, invoice, packing, B/L, COA, SDS.	Mismatch of CAS/goods name may require explanation.
Japan / VJEPA, AJCEP, CPTPP, RCEP	Form VJ/AJ, CPTPP origin document or RCEP.	Compare each schedule by final HS.	CTC or RVC under PSR.	C/O/origin statement, production statement if needed, B/L.	Synthetic actives may require proof of substantial transformation.
EU / EVFTA; UK / UKVFTA	EUR.1/origin statement or UKVFTA origin proof.	Check the relevant tariff reduction schedule by HS.	Valid origin proof and transport condition.	Origin proof, invoice, B/L/AWB, COA/SDS.	Trader invoice and third-country routing must be controlled.

C/O CHECKLIST FOR COSMETIC ACTIVE

Match HS 6-digit on C/O with the intended declaration HS.
Match chemical name / INCI / CAS across C/O, Invoice, Packing List, COA and SDS/MSDS.
Check origin criterion: WO, CTH, CTSH, RVC or code-specific PSR.
Verify third-party invoice, C/O issuing date, stamp/signature, quantity, weight, country of origin and direct transport.
Do not claim FTA preference when the supplier only proves country of export, not country of origin.

APPLICABLE SPECIALIZED POLICY

SPECIALIZED POLICY MATRIX

Goods situation	Possible policy	Dossier to check	Authority/portal	Recommended timing	Risk note
Single-substance active	Managed by chemical HS; chemical declaration may apply if listed	CAS, SDS, COA, composition, quantity	Customs / relevant specialized authority	Before ETA	Do not conclude no permit without chemical-list review.
Mixture/premix active	May fall under 3824 or other preparations	Composition, TDS, SDS, solvent ratio	Customs	Before HS finalization	Mixtures often trigger composition explanation.
Pharmaceutical-like/strong antimicrobial active	May be reviewed under pharmaceutical/restricted substance policy	Use documents, claims, label, SDS	MOH/relevant authority if triggered	Before purchase order	Avoid pharmaceutical claims where the goods are cosmetic raw materials.
Restricted cosmetic substance	Must be checked against ASEAN cosmetic restrictions/prohibited lists	INCI, CAS, expected concentration in finished product	MOH / provincial health authority	Before import and production	Importability does not mean finished product can exceed allowed limits.
DG cargo	Transport must comply with IMO/IATA if SDS indicates DG	SDS section 14, UN number, packing group	Carrier/airline/forwarder	Before booking	Wrong DG declaration creates transport and cost risks.

LEGAL DOCUMENTS TO REVIEW

Document group	Name / number	Issuing authority	Effectiveness / timing	Role in procedure	Articles/annexes to note	Review note
Circular	Circular 06/2011/TT-BYT	Ministry of Health	Effective from 01/04/2011	Cosmetics management, notification, PIF, safety and labeling	Articles 3, 10, 11, 13 should be reviewed where finished cosmetics are concerned	Applies when active ingredients are used for marketed cosmetic products.
Amending Circular	Circular 34/2025/TT-BYT	Ministry of Health	Effective 18/08/2025	Amends Circular 06/2011/TT-BYT	Notification dossier must be checked under the amended version	Apply by filing/notification timing.
Decree	Decree 43/2017/ND-CP and 111/2021/ND-CP	Government	43: 01/06/2017; 111: 15/02/2022	Goods labeling and Vietnamese supplementary label	Article 10 and mandatory label contents	Applies to imported raw-material packaging/storage/circulation.
Tariff	Decree 26/2023/ND-CP and current tariff	Government	Check at declaration date	MFN duty, ordinary duty, VAT	Chapters 29, 33, 38 depending on goods nature	No universal HS code for all actives.
Origin rules	Circulars implementing ATIGA, ACFTA, RCEP, VKFTA, EVFTA, CPTPP, etc.	Ministry of Industry and Trade	By each agreement	Preferential origin and C/O	PSR, CTH, RVC, WO, direct transport	Review based on final HS.

VIEW / DOWNLOAD SOURCE DOCUMENTS

Companies may search documents by number on official legal document portals, the Government Portal or the issuing authority’s website. Companies should additionally verify the documents on official portals before application.

Government legal documents Vietnam Trade Portal

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice
Packing List
Bill of Lading / Air Waybill
Sales Contract / Purchase Order
C/O if preferential duty is claimed

Technical / specialized dossier

COA, SDS/MSDS, TDS
CAS number, INCI name
Specification, composition statement
Original label, packaging photos
DG declaration if required by SDS

OPERATIONAL DOSSIER CHECKLIST

Dossier group	Required document	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB, Contract/PO	Declaration, value and quantity review	Importer/Supplier/Forwarder	Generic goods description	Check description, quantity, Incoterms and origin before ETA.
Technical	COA, MSDS/SDS, TDS, specification, CAS, INCI	HS, policy, DG and restriction review	Supplier/QA/R&D	Missing CAS or solvent ratio	Request signed/stamped or manufacturer-confirmed documents.
Origin	C/O or origin proof	Claim preferential duty	Supplier/Exporter	Wrong form, HS or description	Check origin criteria and direct transport.
Label	Original label, draft Vietnamese sub-label, packaging photos	Storage, circulation, document inspection	Importer/Compliance	Missing chemical/CAS/warning information	Review under Decree 43/2017 and 111/2021.
Transport	SDS section 14, booking, DG declaration if any	Booking and delivery	Forwarder/Supplier	DG not declared despite UN number	Review SDS before booking.

DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Evidence	Consequence if unclear	Recommended handling
Is HS sufficiently supported?	Are CAS/INCI/COA/SDS available?	COA, SDS, TDS	Analysis request or declaration amendment	Finalize HS before booking or ETA.
Is it DG cargo?	Does SDS section 14 show UN number?	MSDS/SDS	Shipment rejection or additional fees	Check DG with forwarder.
Is C/O usable?	Are form, origin criteria and 6-digit HS aligned?	C/O, invoice, B/L	Preference may be rejected	Check before customs declaration.
Could it be treated as finished cosmetic?	Does label/packaging show direct-use instruction?	Label, catalogue	Cosmetic notification may be triggered	State raw material for production, not retail.
Is it restricted/prohibited?	Is INCI/CAS listed in restriction annexes?	ASEAN cosmetic annex, MSDS	Cannot be used in finished goods	Review with QA/R&D.

PRACTICAL E2E PROCESS

Step 1

Pre-ETA review: finalize HS by CAS/INCI; check duty, C/O, SDS, DG, label and import purpose.

Step 2

Lock documents: Invoice, Packing List, B/L/AWB, COA, SDS, TDS, C/O and manufacturer data must be consistent.

Step 3

Prepare specialized dossier if the active is listed chemical, DG, precursor or restricted substance.

Step 4

Customs declaration: prepare HS, valuation, use and origin explanations; note Green/Yellow/Red channels.

Step 5

Clearance and delivery: apply sub-label if required, archive COA/SDS/C/O by lot and prepare for post-clearance audit.

Step 6

Post-clearance: review active use in finished cosmetic, concentration, PIF and product notification dossier.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA prevention	Documents to check
Wrong C/O form or origin criteria	Loss of preference and higher landed cost	Check form, PSR, 6-digit HS and direct transport	C/O, invoice, B/L
CAS/INCI discrepancy between COA and SDS	Explanation or analysis may be required	Request supplier to confirm one consistent dataset	COA, SDS, TDS
Generic goods description	Wrong HS or reclassification	State chemical name, CAS, INCI and intended use	Invoice, Packing List
DG not checked	Shipment rejection or extra charges	Review SDS section 14 before booking	SDS/MSDS
Pharmaceutical-like claims	Policy may shift to another regime	Control wording in documents and catalogue	TDS, label, catalogue

FAQ – COMMON BUSINESS QUESTIONS

Does importing cosmetic active require a permit?

No general conclusion should be made. Review CAS, INCI, SDS, intended use and specialized-control lists.

Does active require cosmetic product notification?

Raw active ingredients are generally not notified like finished cosmetics. However, finished products using the active must satisfy cosmetic notification/PIF requirements.

Is Vietnamese sub-label required?

If imported goods are stored/circulated under labeling rules, original label and Vietnamese sub-label should be reviewed under Decree 43/2017 and 111/2021.

Can C/O reduce duty?

Possibly, only when the final HS is covered by a preferential schedule and the C/O meets origin rules.

Can declaration be made with trade name only?

Not recommended. CAS, INCI, COA and SDS are needed to reduce classification risk.

Is premix different from single substance?

Yes. Premix/mixture may be classified as another preparation and requires composition statement and ratios.

EXECUTION SOLUTION FROM TGIMEX

This article provides a review framework for cosmetic actives, but actual shipments must still be checked against catalogue, datasheet, CAS, INCI, COA, SDS, C/O and import purpose. TGIMEX supports an E2E import execution model: pre-ETA policy review, document control, international freight coordination, customs declaration, clearance handling, domestic delivery and post-clearance dossier archiving.

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