Empty plastic packaging for cosmetic filling is often treated as a simple cargo item, but customs clearance may still be delayed if the HS Code, material, shape, capacity, cap/pump accessories, declared value or C/O is not locked before ETA. A broad description such as “plastic packaging” can lead to HS challenges, customs inspection, loss of FTA preference or unexpected storage cost. This guide provides an E2E (End-to-End) checklist covering HS classification, duty, C/O, customs dossier, specialized policy, clearance workflow and pre-ETA risk control.

QUICK FACTS

Content group	Operational conclusion	Items to lock before ETA	Risk if omitted
Product scope	Empty plastic packaging for cosmetics: bottles, flasks, jars, tubes and similar plastic packing bodies; simple caps may be included if imported as a set.	Material, shape, capacity, use, accessories and import condition.	Wrong HS between 3923.30.90, 3923.90.90, 3923.50.00 or another heading.
Reference HS	3923.30.90 for plastic bottles/flasks; 3923.90.90 for plastic jars/tubes/other packing articles; 3923.50.00 for caps/closures imported separately.	Catalogue, photos, drawings, material declaration and invoice lines.	Mixing different items in one declaration line may distort HS, duty and customs value.
Reference taxes	MFN: 15% for 3923.30.90/3923.90.90; 10% for 3923.10.90/3923.50.00/3923.90.10. Ordinary duty: 22.5% or 15%. Standard VAT: 10%; 8% only where the VAT reduction policy applies.	Verify tariff at declaration date.	Incorrect import cost estimate, duty reserve and cost accounting.
Specialized policy	Empty packaging without cosmetic content is not handled as finished cosmetics. Nevertheless, labeling, material, purpose, new/used status and accessories must still be checked.	Do not rely on a generic conclusion if products include cosmetic content, pump/sprayer mechanisms, samples or used goods.	Wrong policy conclusion or missing technical explanation.

Legal note: This guide applies only to empty plastic packaging. If the shipment contains filled cosmetics, retail kits, food-contact packaging, pump/sprayer parts imported separately, or used/refurbished goods, the compliance position must be reviewed against the actual catalogue, datasheet, model and import purpose.

Products covered by Import procedure for empty plastic packaging used for cosmetic filling at an import inspection area — Illustration of the product group and document review before customs clearance.

Reference translation: This English version follows the Vietnamese compliance logic and is not an official legal translation.

SCOPE OF APPLICATION

This article applies to empty plastic packaging imported for cosmetic manufacturing, filling, contract manufacturing, product development, storage, or factory use. Typical items include plastic bottles, flasks, jars, tubes, packing bodies and simple plastic closures imported with the packaging set.

It does not automatically apply to glass bottles, paper packaging, aluminium packaging, composite packaging, pumps/sprayers imported separately, packaging already filled with cosmetics, make-up tools, food-contact packaging or used packaging. The final position must be reviewed based on the actual documents.

CLASSIFICATION & PRODUCT IDENTIFICATION

Shape-based check Bottle or flask-shaped containers are usually reviewed under 3923.30.90. Jars, tubes and other packing bodies are normally reviewed under 3923.90.90.

Function-based check If the main function is packing, containing or protecting cosmetics, the item remains a packaging article. If it has an independent spraying or dosing mechanism, separate HS review is required.

Material-based check PET, PP, PE, HDPE, LDPE, ABS, SAN, PETG or other plastics should be supported by catalogue or material declaration.

TECHNICAL IDENTIFICATION CRITERIA

Criteria to check	Documents to cross-check	Risk if misdescribed	Suggested declaration wording
Packaging type	Catalogue, product photos, packing specification	Confusing bottles, jars, tubes and separate closures.	“Empty plastic cosmetic bottle, capacity…, material…, brand new”.
Plastic material	Material declaration, COA, MSDS if any	Insufficient basis for Chapter 39 classification.	State PET/PP/PE/HDPE/PETG/ABS where known.
Capacity/size	Drawing, specification, model list	Quantity, value and packing mismatch.	State ml/g capacity or dimension by item line.
Cap/pump/sprayer	Packing list, product photos, accessory structure	Accessories may require a separate HS line.	Separate declaration line if imported separately or mechanically functional.
Condition	Invoice, photos, supplier declaration	Used goods may trigger additional policy risks.	“Brand new, unused”.

HS CODE – DUTY – C/O

Classification principle: Empty plastic packaging for cosmetic filling does not have one universal HS code. The HS code must be locked based on the actual shape, plastic material, packing function, whether caps/pumps/sprayers/droppers are imported together, and the import condition. Where multiple packaging types are shipped together, documents should be split by product group to avoid HS, duty and C/O errors.

REFERENCE HS CLASSIFICATION TABLE

Reference HS code	Applicable product group	Conditions for use	Risk if misclassified	Documents to check
3923.30.90	Empty plastic bottles, flasks and similar containers for cosmetic filling.	The goods are empty plastic bottles/flasks/containers, not gas cylinders, not pre-filled cosmetics, and not independent spraying/pumping mechanisms.	Using this code for jars, tubes or separate caps may lead to wrong subheading; complex pumps or metal parts may require line separation or explanation.	Catalogue, photos, drawings, capacity, material declaration and packing list.
3923.90.90	Plastic jars, empty cosmetic tubes and other plastic packing articles not specifically covered elsewhere.	Use where the goods are plastic packing articles but not bottles/flasks under 3923.30, not caps/closures under 3923.50, and not toothpaste tubes.	Confusion with 3923.30.90 or 3923.50.00 may affect duty and C/O review.	Product photos, drawings, description such as “empty plastic cosmetic jar/tube/container”, packing specifications.
3923.50.00	Plastic stoppers, lids, caps and closures imported separately.	Apply to caps, lids, closures, flip-top caps and screw caps when imported as separate items.	Combining caps with bottles in one declaration line may distort customs value and inspection findings.	Separated invoice line, packing list, cap photos, thread/diameter/closure specifications.
3923.10.90	Plastic boxes, cases and similar packaging for cosmetics, other types.	Review when the packaging is an empty plastic box/case, not a bottle, jar, tube or paper box.	A generic “plastic packaging” description may incorrectly push the goods to 3923.90.90.	Photos, structure, dimensions, packing function and catalogue.
3923.90.10	Plastic toothpaste tubes.	Only review if the goods are actually tubes for toothpaste; do not apply by default to all cosmetic tubes.	Applying this to ordinary cosmetic tubes may cause HS rejection and duty reassessment.	Catalogue, buyer specification and label/design showing toothpaste use.
Other headings to review	Pumps, sprayers, spray heads, droppers, applicators or packaging with mechanical/metal parts.	If imported separately, or if the main character is not simple plastic packaging, classify by structure and actual function.	Declaring all items under Chapter 3923 may trigger technical explanation requests.	Datasheet, exploded drawing, material composition, photos of each component and model list.

REFERENCE IMPORT DUTY TABLE

HS code	Short description	MFN/WTO import duty	Ordinary import duty	VAT	Operational note
3923.30.90	Other plastic bottles/flasks/containers	15%	22.5%	10%; 8% only if the VAT reduction policy applies and the goods are not excluded.	Commonly relevant for empty plastic cosmetic bottles.
3923.90.90	Other plastic packing articles, jars/tubes/bodies	15%	22.5%	10%; 8% only if eligible.	Use for other plastic packaging not classified as bottles, caps or boxes.
3923.50.00	Plastic caps, stoppers and closures	10%	15%	10%; 8% only if eligible.	Separate the line if caps/closures are imported separately.
3923.10.90	Other plastic boxes/cases for packing	10%	15%	10%; 8% only if eligible.	Review when the goods are empty plastic boxes/cases.
3923.90.10	Toothpaste tubes	10%	15%	10%; 8% only if eligible.	Only for toothpaste tubes.

C/O / FTA SPECIAL PREFERENTIAL DUTY TABLE

Origin/route	C/O form or origin document	Preferential rate to verify	Conditions	Documents to check	Risk if incorrect
ASEAN	Form D / ATIGA	Many heading 3923 lines may reach 0% under ATIGA if origin criteria are met; verify the ATIGA schedule at declaration date.	Valid ASEAN origin, direct consignment, consistent description and HS code.	Form D, invoice, packing list, B/L, catalogue and specification sheet.	Wrong description or HS on C/O may lead to denial of preferential duty.
China	Form E / ACFTA or RCEP origin document	Preferential duty may be lower than MFN; compare ACFTA and RCEP for the exact HS code.	Origin criteria, direct consignment and third-party invoice requirements must be satisfied.	Form E/RCEP C/O, B/L, third-party invoice, packing list and catalogue.	Transshipment without origin proof or missing origin criteria may invalidate the preference.
Korea	Form AK / Form VK / RCEP	Compare AKFTA, VKFTA and RCEP to select the valid preferential basis.	Valid C/O, Korean origin and consistent goods description.	C/O, invoice, packing list, transport document and catalogue.	Wrong FTA selection or expired C/O may remove the preference.
Japan	Form AJ / Form VJ / CPTPP or RCEP	Verify AJCEP, VJEPA, CPTPP or RCEP schedules according to actual documents and origin.	Rules of origin and document requirements under the selected agreement must be met.	C/O or origin document, invoice, B/L, catalogue and HS description.	Insufficient direct consignment or origin criteria may trigger duty reassessment.
EU / UK	EVFTA: EUR.1 or origin statement; UKVFTA equivalent	Verify EVFTA/UKVFTA schedule by year and actual HS; not applicable without valid EU/UK origin.	Valid origin document, specific description and correct exporter evidence where self-certification is used.	EUR.1/origin statement, invoice, packing list, B/L and exporter details.	Generic “plastic goods” descriptions may trigger further customs queries.
Australia – New Zealand / CPTPP	AANZFTA, CPTPP or RCEP	Compare the special preferential schedule by origin and available document.	Origin, direct consignment and document content must be consistent.	C/O/origin document, invoice, B/L, packing list and catalogue.	Wrong form or origin criteria may remove duty preference even where HS is correct.

PRE-ETA HS – DUTY – C/O LOCKING CHECKLIST

Lock the packaging shape: bottle, jar, tube, box, cap, closure or set with pump/sprayer.

Lock the material: PP, PE, PET, ABS, acrylic or mixed plastics; cross-check material declaration.

Split document lines: do not combine bottles, caps, pumps, jars and tubes under one generic description where HS/duty differs.

Check C/O: form, origin criterion, HS, description, quantity, weight, issuance date, signature and stamp.

Lock VAT: review 10% as standard; use 8% only when eligible and not excluded.

Keep explanation records: catalogue, photos, packing specification and HS mapping by line item.

SPECIALIZED POLICY MATRIX

Goods situation	Possible policy	Documents to check	Authority/portal	Recommended timing	Risk note
Brand-new empty plastic packaging	Normal customs clearance, labeling and HS classification under Chapter 39.	Invoice, packing list, catalogue, material declaration.	Customs office.	3–5 working days before ETA.	Do not conclude policy without actual documents.
Direct cosmetic-contact packaging	Not a finished cosmetic if empty; internal material control is still advisable.	Material COA, MSDS if any, specification.	Importer quality/compliance team; customs may query.	Before booking.	If filled with cosmetics, policy changes.
Separate caps/pumps/sprayers	Separate HS review may be required.	Drawing, structure, photos, material.	Customs; classification consultation if needed.	Before invoice issuance.	Grouping with bottles may be challenged.
Samples or FOC items	Customs value and import purpose still need declaration.	Invoice, PO, FOC confirmation.	Customs.	Before ETA.	“No commercial value” does not remove customs value obligation.
Used/refurbished packaging	Additional policy review may be triggered.	Photos, condition statement.	Customs/specialized authority if applicable.	Before purchase.	Do not apply new-goods assumptions.
Food-contact or multi-purpose packaging	Food-contact regulations may apply; outside this article.	Catalogue, intended use, contract.	Food safety authority if applicable.	Before HS locking.	Do not claim cosmetic use if actual use is food contact.

LEGAL DOCUMENTS TO REVIEW

Document group	Document	Issuing authority	Effective date/application timing	Role	Key point	Review note
Tariff	Decree 26/2023/ND-CP	Government	Effective from 15 July 2023	MFN import tariff basis.	Chapter 39, heading 3923.	Check amendments at declaration date.
Tariff reference	Vietnam Customs Tariff Schedule – Chapter 39	ITPC Ho Chi Minh City	2024 reference schedule	Quick reference for MFN, ordinary duty, VAT and FTA indications.	3923.30.90, 3923.50.00, 3923.90.90.	Not a replacement for official customs system.
Labeling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Decree 43 effective 01 June 2017; Decree 111 effective 15 February 2022	Labeling requirements.	Origin, responsible organization, goods name and mandatory information.	Important if packaging is circulated separately.
VAT	Decree 174/2025/ND-CP; Resolution 204/2025/QH15	Government/National Assembly	01 July 2025–31 December 2026	Review 10% to 8% VAT reduction eligibility.	Eligible and excluded goods/services.	Do not default to 8%.
Foreign trade management	Decree 69/2018/ND-CP	Government	Review effective status when applied.	Import restrictions/conditions where relevant.	Appendices on prohibited/conditional goods.	Relevant if goods are used or have special functions.

VIEW / DOWNLOAD ORIGINAL LEGAL TEXTS

Enterprises should cross-check legal documents on official legal portals or websites of issuing authorities before application.

Decree 26/2023/ND-CP Chapter 39 tariff Decree 43/2017/ND-CP Decree 174/2025/ND-CP Vietnam Trade Portal

CUSTOMS CLEARANCE DOSSIER

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
C/O if FTA preference is claimed.
Catalogue, photos, model/size list, specification.

Technical/supporting documents

Material declaration or plastic material COA.
MSDS if relevant.
Drawings, capacity, dimensions and accessory structure.
Label dossier if packaging is circulated separately.
Import purpose explanation for samples or FOC items.

OPERATIONAL DOSSIER CHECKLIST

Dossier group	Required documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO	Declaration, value, quantity	Importer/supplier/docs	Generic goods name, missing material/capacity.	Match every line with photos/catalogue.
Transport	B/L or AWB, Arrival Notice, Pre-alert	Delivery order and transport data	Forwarder/carrier	Package or weight mismatch.	Match with packing list and booking.
Technical	Catalogue, datasheet, drawing, material declaration	HS review and customs explanation	Supplier/QA/Purchasing	Catalogue covers multiple types but invoice does not split lines.	Link each item code to an invoice line.
C/O	C/O form or origin proof	FTA duty preference	Supplier/exporter/import docs	Wrong description, HS or quantity.	Check form, origin criterion and direct transport.
Labeling	Original label and Vietnamese label if needed	Domestic circulation/post-clearance	Importer/Compliance	Missing origin or responsible party.	Review Decree 43 and 111.

CLEARANCE DECISION POINTS THAT MAY HOLD THE SHIPMENT

Decision point	Question to answer	Supporting documents	Consequence if unclear	Recommended action
HS code	Is the item a bottle, jar, tube, cap or pump?	Catalogue, photos, drawings	HS query, channel change, delay.	Split lines by item nature.
Material	Is it plastic or composite/mixed material?	Material declaration, COA	Insufficient Chapter 39 basis.	Obtain supplier confirmation before shipment.
Accessories	Are caps/pumps imported with or separately from bottles?	Packing list, product photos	Wrong HS or value allocation.	Separate invoice lines where necessary.
C/O	Does C/O match HS, description, quantity and transport route?	C/O, B/L, invoice	Loss of preference, duty reassessment.	Pre-check C/O before ETA.
Condition	Are the goods brand new or used?	Invoice, photos, supplier declaration	Additional policy risk.	State condition clearly.

PRACTICAL E2E CLEARANCE PROCESS

Step 1 – Pre-ETA review Lock HS, duty, C/O, condition, import purpose and labeling policy.

Step 2 – Document lock Match invoice, packing list, B/L/AWB, catalogue, photos, capacity and material.

Step 3 – Line separation Separate bottles, jars, caps and pumps where the nature or HS differs.

Step 4 – C/O review Check form, origin criterion, direct transport, third-party invoice and issue date.

Step 5 – Declaration Green channel: conditional clearance; Yellow: documentary check; Red: documentary and physical inspection.

Step 6 – Post-clearance Archive shipment dossier, complete labeling if needed and prepare for post-clearance audit.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA prevention	Documents to check
Combining different packaging types in one HS	Wrong HS and duty; inspection difficulty.	Split by bottles, jars, tubes, caps and pumps.	Invoice, packing list, photos.
No catalogue/drawing	Weak basis for HS explanation.	Request photos, spec and material declaration.	Catalogue, drawing, specification.
C/O description or HS mismatch	FTA preference rejection.	Pre-check C/O before cargo arrival.	C/O, invoice, B/L.
FOC/sample value not supported	Customs valuation query.	Prepare value basis and supplier confirmation.	Invoice, PO, price list.
Unclear cosmetic use	Question whether goods are finished cosmetics.	State “empty plastic packaging, without cosmetic content”.	Invoice, photos, catalogue.

FAQ – COMMON QUESTIONS

1. Does empty plastic cosmetic packaging require cosmetic notification?

If it is truly empty packaging without cosmetic content, it is generally not handled as finished cosmetics. Filled samples or retail kits must be reviewed separately.

2. Is 3923.30.90 always the correct HS?

No. It is mainly for plastic bottles/flasks. Jars and tubes may require 3923.90.90; separate caps may be 3923.50.00.

3. Should caps and bottles be split?

If simple caps come as one set with bottles, they may be reviewed together. Separate caps/pumps should normally be reviewed as separate lines.

4. Can C/O reduce duty?

Yes, if the C/O is valid and the applicable FTA tariff schedule grants preference for the actual HS code.

5. Is VAT always 8%?

No. Standard VAT is 10%; 8% applies only where the active VAT reduction policy covers the goods.

6. Is “plastic packaging” enough on the invoice?

It is not recommended. State item type, material, capacity/size, cosmetic packaging purpose and brand-new condition.

IMPLEMENTATION SUPPORT FROM TGIMEX

This guide provides the HS, duty, C/O and dossier map for empty plastic cosmetic packaging. For actual shipments, documents still need to be reviewed against catalogue, model, material, accessories, origin and import purpose.

Pre-ETA review: HS, duty, C/O, labeling, catalogue/datasheet/model.
Compliance dossier control: Invoice, Packing List, B/L/AWB, C/O, catalogue, material data and product photos.
International logistics: coordination with agents, carriers, airlines, ETA and pre-alert.
Customs declaration: Green/Yellow/Red channel handling and HS/value/origin explanation.
Post-clearance: shipment dossier archive and labeling/post-audit preparation.

For shipments with many sizes, caps, pumps, FOC items or FTA claims, document review should start before ETA to reduce clearance delay and unplanned storage cost.

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