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IMPORT PROCEDURE GUIDE FOR MAKEUP BRUSHES
Makeup brushes are personal-care accessories used directly on the skin, but they should not automatically be treated as finished cosmetic preparations. Operational risk usually comes from vague product descriptions, incorrect classification under HS 9603.30.00, insufficient proof of bristle/handle material, or mixing brushes with sponges, cosmetic sets or electronic devices. This guide gives an E2E map for importers to review HS code, duty, C/O, labeling, documents, customs process and pre-ETA risk controls.
QUICK FACTS
| Item | What to review | Operational note |
|---|---|---|
| Product scope | Makeup brushes used for powder, foundation, blush, eye shadow, lip products, concealer or other cosmetic application. | This article only covers makeup brushes; it does not automatically cover facial devices, massage devices, LED masks, steamers or sponges. |
| Reference HS | 9603.30.00 – artists’ brushes, writing brushes and similar brushes for the application of cosmetics. | Check actual use, catalogue, bristle material, handle material and packing mode. |
| Base duty | MFN 25%; ordinary duty 37.5%; base VAT 10%. | VAT may be reviewed at 8% if eligible under the VAT reduction policy at the declaration date. |
| C/O | Several FTAs may reduce duty to 0%; AIFTA may require checking the reference rate of 5%. | Do not claim preferential duty when the C/O form, origin criterion, description, HS code or direct transport evidence is inconsistent. |
| Specialized policy | Not automatically a cosmetic declaration item; review if packed with cosmetics, made of animal hair/wood, or imported as a mixed set. | Do not conclude “no permit required” without reviewing the actual file. |
| Key documents | Invoice, Packing List, B/L/AWB, C/O if any, catalogue/datasheet, product photos, original label and material declaration if needed. | Product name, SKU/model, quantity, origin and material must be consistent. |
Legal note: Duty rates are for reference only based on the HS code and tariff sources available when this article is prepared. Importers should verify the current tariff, catalogue, material, origin, import purpose and actual documents before customs declaration.
SCOPE OF APPLICATION
This article applies to makeup brushes imported for trading, distribution, retail, promotional use or as part of a makeup tool kit. Typical products include powder brush, foundation brush, blush brush, eye brush, lip brush, concealer brush, contour brush, multi-piece brush set and replacement brush heads.
- It does not cover makeup sponges/puffs, which may need separate material-based classification.
- It does not cover electric brush cleaners, powered brushes or battery/USB devices.
- It does not cover sets packed with cosmetics such as powder, lipstick, cushion or foundation; each item must be reviewed separately.
- If the brush uses natural animal hair, wooden/bamboo handle, leather or special materials, additional material-origin checks may be required.
Review must be based on catalogue, datasheet, model and actual import purpose.
PRODUCT CLASSIFICATION & IDENTIFICATION
Main use
Used to pick up, apply, spread or blend cosmetic products on skin, eyes or lips. This use supports the review of HS 9603.30.00.
Construction
Usually includes synthetic or natural bristles, metal ferrule and plastic/wood/metal handle. Material photos and declaration should be available.
Packing mode
Single brush, multi-piece set, replacement head or brush packed with makeup products. Packing affects declaration and naming.
| Checkpoint | Supporting document | Risk if described incorrectly | Suggested goods description |
|---|---|---|---|
| Cosmetic application use | Catalogue, product page, usage photo | Wrong HS or wrong policy review | Makeup brush for applying cosmetics, material…, SKU… |
| Bristle material | Material declaration, catalogue, MSDS if available | Animal-origin materials may trigger additional questions | Makeup brush with synthetic fiber bristles/plastic handle |
| Multi-piece brush set | Packing List, SKU list, set photo | Wrong quantity or wrong unit | Set of makeup brushes, … pieces/set, not packed with cosmetics |
| Packed with cosmetics or not | Invoice, packing photo, label, cosmetic declaration if any | Cosmetic products in the set may require separate compliance | Makeup brush only, not packed with cosmetic products |
| Battery/USB/wireless function | Datasheet, manual, product photo | May become an electronic device or accessory | Non-electric makeup brush, no battery, no USB, no wireless function |
HS CODE – DUTY – C/O
For ordinary makeup brushes, the first HS code to consider is 9603.30.00. However, classification should not be locked only by the commercial name “makeup brush”; importers need proof of cosmetic application use, construction and packing. If the item is not used for cosmetic application or is a device accessory, other headings under 9603 should be reviewed.
| Reference HS code | Applicable situation | MFN | Ordinary duty | VAT | Risk if wrong | Documents to review |
|---|---|---|---|---|---|---|
| 9603.30.00 | Artists’ brushes, writing brushes and similar brushes for the application of cosmetics; main code for ordinary makeup brushes. | 25% | 37.5% | 10%; review 8% if eligible | Wrong if the item is a sponge, cleaning brush, electric accessory or makeup set with cosmetics. | Catalogue, product photos, use description, material declaration, original label. |
| 9603.29.00 | Other toilet/personal brushes not clearly classified as cosmetic application brushes under 9603.30.00. | 25% | 37.5% | 10%; review 8% if eligible | May be confused with makeup brush if use is unclear. | Catalogue, function, use photo, trade name. |
| 9603.90.40 / 9603.90.90 | Other brushes not used for cosmetic application; only when actual function is not makeup application. | 25% | 37.5% | 10%; review 8% if eligible | Using an “other” code while the item is a cosmetic brush may be challenged. | Product photo, catalogue, function description, HS explanation. |
| 9603.50.00 | Brushes constituting parts of machines/appliances; only if the item is a replacement head/accessory for a device. | 25% | 37.5% | 10%; review 8% if eligible | Device accessories may require additional technical review. | Device manual, model list, assembly photo, accessory description. |
| Origin route | C/O form or origin document | Reference special preferential duty for 9603.30.00 | Condition | Documents to check | Risk |
|---|---|---|---|---|---|
| ASEAN | Form D / ATIGA document | 0% | ASEAN origin, origin criterion and direct transport must be valid. | Form D, Invoice, Packing List, B/L, origin country. | Incorrect form or unproven third-country transit may invalidate preference. |
| China | Form E / ACFTA | 0% reference | Meet ACFTA origin rules; description and HS must match the shipment. | Form E, third-party invoice if any, B/L, catalogue. | Generic “brush set” description may be queried. |
| RCEP | RCEP C/O or origin document | 0% reference | Apply according to RCEP member and tariff schedule. | C/O, origin criterion, transport route, description. | Wrong member/schedule may lead to wrong duty claim. |
| Korea | Form AK / VK | 0% reference | Korean origin under AKFTA or VKFTA. | Form AK/VK, Invoice, Packing List, B/L. | Do not claim preference if C/O description does not match SKU/model. |
| Japan | Form AJ / VJ or CPTPP where applicable | 0% reference | Choose the agreement matching documents and origin rules. | C/O, origin criterion, invoice, B/L. | Using the wrong scheme may cause duty rejection. |
| EU / UK | EUR.1 or origin statement under EVFTA/UKVFTA | 0% reference | Origin document must be valid under EVFTA/UKVFTA. | Origin document, invoice declaration where applicable, B/L. | Without valid origin proof, MFN 25% applies. |
| Australia / New Zealand | Form AANZ or CPTPP document | 0% reference | Depending on exporting country and applicable agreement. | C/O, transport document, invoice. | Direct transport evidence may be requested. |
| India | Form AI / AIFTA | 5% reference | Use only when lower than MFN and the file is eligible. | Form AI, product description, origin criterion. | If not eligible, MFN 25% applies. |
| United States / no applicable FTA | No special preferential C/O | MFN 25% | Non-preferential origin may prove origin but does not reduce duty without an FTA. | Non-preferential CO if needed, invoice, packing list. | Do not claim FTA preference without agreement/document. |
| Declaration scenario | Recommended handling | Pre-ETA lock point |
|---|---|---|
| Single synthetic makeup brush, no cosmetics packed | Review 9603.30.00; apply MFN 25% if no preferential C/O. | Catalogue, product photo, bristle material, label, C/O if any. |
| Multi-piece makeup brush set only | Still consider 9603.30.00 if all pieces are cosmetic application brushes; declare pieces/set clearly. | SKU list, pieces per set, packing, unit kg/unit. |
| Natural animal-hair brush | Review not only HS but also animal material origin and treatment evidence where required. | Material declaration, animal-hair statement, manufacturer documents. |
| Brush packed with cosmetics | Do not use one code for all items; separate brush and cosmetics, and review cosmetic declaration if required. | Detailed packing list, declaration documents, label, separated value if needed. |
| C/O available but description is generic | Claim preferential duty only when description, HS, quantity, weight, origin and direct transport are supported. | C/O form, origin criterion, third-party invoice, date of issue, stamp/signature. |
- Check C/O form, reference number, issue date, stamp/signature and origin country.
- Check origin criteria such as WO/RVC/CTH/CTSH depending on the agreement.
- Match “makeup brush / cosmetic brush” with Invoice, Packing List and catalogue.
- Compare HS on C/O with declared HS; prepare explanation if the 8-digit code differs.
- Check direct transport, third-party invoicing, quantity, weight and package marks.
APPLICABLE SPECIALIZED POLICY
| Goods situation | Possible policy | Documents to check | Authority/platform | Recommended timing | Risk note |
|---|---|---|---|---|---|
| Ordinary makeup brush, not packed with cosmetics | Normal customs procedure; review HS and labeling. | Invoice, Packing List, B/L/AWB, catalogue, original label. | Customs / VNACCS-VCIS. | Before ETA. | Not automatically subject to cosmetic product declaration, but review if packed with cosmetics. |
| Brush set packed with cosmetics | Cosmetic products may require cosmetic declaration; brush remains a tool/accessory. | Cosmetic declaration, formula/label, detailed packing list. | Public service portal/NSW where applicable. | Before arrival. | Do not declare the whole set generically as “makeup set”. |
| Natural animal hair bristles | May require review of animal material origin, CITES or treatment evidence depending on species/material. | Material declaration, origin certificate, treatment evidence if any. | Relevant specialized authority depending on actual material. | Before purchase/shipment. | Do not conclude no permit without species/material review. |
| Wood/bamboo handle or wood packaging | Review wood packaging treatment/ISPM 15 if wood packaging is used. | Packing photos, fumigation/treatment certificate if any. | Plant quarantine authority if triggered. | Before shipment. | Risk often comes from pallet/wood packaging rather than processed handle. |
| Branded goods | Review IP rights, anti-counterfeit risk and distribution authorization if necessary. | Contract, authorization letter, catalogue, label. | Customs/right holder if inspected. | Before declaration. | Goods may be held if suspected counterfeit. |
| Samples, gifts or promotional goods | Import purpose, value and labeling still need to be reviewed. | Commercial/non-commercial invoice, packing list, import purpose. | Customs. | Before ETA. | Sample status does not remove HS, value, label and C/O obligations. |
LEGAL DOCUMENTS TO REVIEW
| Document group | Document name/number | Issuing authority | Effective timing | Role | Key points | Review note |
|---|---|---|---|---|---|---|
| Law | Customs Law 54/2014/QH13 | National Assembly | Currently applicable; check amendments | Base for customs declaration and inspection. | Customs dossier, declaration, inspection and supervision. | Applies to all import shipments. |
| Law | Law on Foreign Trade Management 05/2017/QH14 | National Assembly | Currently applicable | Principles for managing import/export goods. | Licensing/conditional management where applicable. | Makeup brush is not automatically licensed, but material-specific checks may apply. |
| Decree | Decree 08/2015/ND-CP and amendments such as 59/2018/ND-CP | Government | Check current validity | Detailed customs procedure rules. | Customs dossier, physical inspection, value, HS. | Base for declaration process. |
| Decree | Decree 69/2018/ND-CP | Government | Currently applicable | Foreign trade management guidance. | Prohibited/restricted/licensed goods if any. | Review for samples, gifts or temporary import. |
| Decree | Decree 26/2023/ND-CP | Government | Effective from 15 July 2023 | MFN import tariff schedule. | Chapter 96, heading 9603. | Update if amended/replaced. |
| Decree | Decree 174/2025/ND-CP | Government | Effective from 01 July 2025 | VAT reduction policy. | Exclusion appendices and conditions for 8% VAT. | Do not apply 8% VAT without checking conditions. |
| Decree | Decree 43/2017/ND-CP and 111/2021/ND-CP | Government | 43 partly expired; 111 currently effective | Goods labeling rules. | Original label, Vietnamese sub-label, origin, responsible party. | Important for retail goods. |
| Circular | Circular 09/2024/TT-BYT | Ministry of Health | Effective from 26 July 2024 | HS list for medicines, ingredients and cosmetics. | Cosmetics under Chapter 33; useful when a brush is packed with cosmetics. | Review only when cosmetics are included. |
| Circular | Circular 06/2011/TT-BYT and 34/2025/TT-BYT | Ministry of Health | TT34 effective from 18 Aug 2025 | Cosmetic management. | Cosmetic declaration for cosmetic products in a set. | Not automatically applicable to standalone brushes. |
| FTA | Current special preferential import tariff decrees | Government / Ministry of Finance | By agreement and period | Legal basis for FTA preferential duty. | ATIGA, ACFTA, RCEP, AKFTA, VKFTA, AJCEP, VJEPA, EVFTA, UKVFTA, AANZFTA, CPTPP, AIFTA. | Search by exact HS, year and origin country. |
VIEW / DOWNLOAD ORIGINAL LEGAL SOURCES
Enterprises may search legal documents by number on official legal databases, the Government portal or the issuing authority’s website.
Enterprises should cross-check official legal databases or issuing authority websites before application.
CUSTOMS CLEARANCE DOCUMENTS
Commercial documents
- Commercial Invoice.
- Packing List.
- Bill of Lading/Air Waybill.
- Sales Contract/Purchase Order where available.
- C/O if claiming preferential duty.
Technical file
- Catalogue/datasheet.
- Product photos and original label.
- Material declaration.
- SKU/model list.
- Number of pieces per set.
Specialized file if triggered
- Animal hair origin document if applicable.
- Wood/wood packaging treatment document if applicable.
- Trademark authorization if needed.
- Cosmetic documents if packed with cosmetics.
| Document group | Required document | Used for | Prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, Packing List, Contract/PO | Declaration, value, quantity | Importer, supplier, procurement | Product name only says “brush” | Request makeup/cosmetic brush, material, pieces/set. |
| Transport | B/L or AWB, arrival notice | Cargo release, declaration and ETA tracking | Forwarder, carrier, logistics | Wrong consignee/packages, missing pre-alert | Match transport docs with invoice/packing before ETA. |
| Technical | Catalogue, photos, material declaration | HS and policy review | Supplier, importer, compliance | Cannot prove cosmetic application use | Prepare use photo, construction, material and product link. |
| Origin | Preferential C/O or origin proof | FTA preferential duty | Supplier, exporter | Wrong C/O form/description/date | Check form, criterion, HS, description and direct transport. |
| Labeling | Original label and Vietnamese sub-label draft | Domestic circulation | Importer, brand owner | Missing origin/responsible importer/material information | Review under Decrees 43/2017 and 111/2021. |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question to answer | Evidence | Consequence if unclear | Recommended handling |
|---|---|---|---|---|
| HS code | Is the item a brush for cosmetic application? | Catalogue, use photo, description | HS explanation or document inspection | Prepare classification rationale by use and construction. |
| Material | Are the bristles synthetic or natural animal hair? | Material declaration, COA if any | Additional material-origin questions | Get manufacturer confirmation before shipment. |
| Set packing | Does the set include cosmetics or sponges? | Packing list, packing photos, SKU list | Wrong HS or missing cosmetic compliance | Separate each item and value where needed. |
| C/O | Is the C/O form, description, HS, origin and transport valid? | C/O, B/L, invoice, packing list | Loss of preferential duty | Review C/O before declaration transmission. |
| Label | Do original and Vietnamese labels have required information? | Label photo, artwork, draft sub-label | Retail/post-clearance risk | Prepare Vietnamese label before warehouse delivery. |
| Trademark/IP | Is there any protected brand/counterfeit risk? | Contract, authorization letter | Goods may be held for IP verification | Ensure sourcing and authorization are clear. |
PRACTICAL E2E PROCESS
Step 1: Pre-ETA review
Lock HS, duty, C/O, label, bristle/handle material, packing status and material-related risk.
Step 2: Freeze documents
Match Invoice, Packing List, B/L/AWB, catalogue, label and SKU/model list; avoid generic “brush”.
Step 3: Check C/O
Review form, origin criterion, description, HS, quantity, issue date, direct transport and third-party invoice if any.
Step 4: Customs declaration
Declare Vietnamese goods name, use, material and origin clearly; prepare HS explanation for yellow/red channel.
Step 5: Clearance and delivery
Pay duties, release cargo, check Vietnamese label if circulated domestically and store shipment records.
Step 6: Post-clearance readiness
Archive invoice, packing list, C/O, declaration, label photos, catalogue and material documents.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA control | Document to check |
|---|---|---|---|
| Product name too generic | HS/policy/C/O queries | State makeup/cosmetic brush, use and material | Invoice, Packing List, catalogue |
| Sponges or cosmetics mixed in the set | Wrong HS or missing cosmetic compliance | Separate items, quantity, value and policy | SKU list, packing photos |
| C/O description or HS mismatch | No preferential duty | Review C/O before declaration | C/O, invoice, B/L |
| Bristle material not proven | Additional document request, especially natural hair | Obtain material declaration | Material declaration, catalogue |
| Vietnamese label not prepared | Circulation/post-clearance risk | Prepare sub-label under Decrees 43 and 111 | Artwork, original label, importer info |
| Trademark risk not checked | Possible hold for counterfeit suspicion | Prepare contract/authorization if branded | Contract, authorization letter |
FAQ
| Question | Short answer |
|---|---|
| Does a standalone makeup brush require cosmetic declaration? | A standalone brush is a tool/accessory, not a cosmetic preparation. If packed with cosmetics, the cosmetic items must be reviewed separately. |
| What is the main HS code? | Usually 9603.30.00 if it is a brush for the application of cosmetics. Catalogue and actual use still matter. |
| What are the import taxes? | Reference MFN 25%, ordinary duty 37.5%, base VAT 10%; valid C/O may reduce duty under FTA. |
| Can C/O reduce duty? | Yes. Several FTAs may provide 0% duty, subject to correct form, origin criterion, direct transport and matching description. |
| What is the risk with goat/sable/pony hair? | Natural animal hair may require additional origin/material checks, treatment evidence or CITES review depending on species. |
| Can a multi-piece brush set use one HS? | Possibly, if every piece is a makeup brush of the same nature. If sponges, cosmetics, mirrors, bags or electrical devices are included, review separately. |
| Is Vietnamese labeling required? | For domestic circulation, review original label and Vietnamese sub-label under Decrees 43/2017 and 111/2021. |
| What if the invoice model differs from the catalogue? | Ask the supplier to correct documents or provide SKU/model mapping before customs declaration. |
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IMPLEMENTATION SUPPORT FROM TGIMEX
This guide outlines the HS code, duty, C/O, dossier and compliance map for makeup brushes. In practice, importers still need to review catalogue, material declaration, original label, origin document, packing set and import purpose.
Pre-ETA review
Review HS, C/O, duty, label, bristle material, set packing and material-related risks.
Compliance file control
Match Invoice, Packing List, B/L/AWB, C/O, catalogue, label photos and SKU/model information.
E2E customs operation
Coordinate international transport, pre-alert, declaration, green/yellow/red channel handling, domestic delivery and post-clearance recordkeeping.
For shipments involving C/O, labeling, HS explanation or specialized material questions, importers should not wait until arrival to start file review. Minor inconsistencies across Invoice, Packing List, catalogue, C/O or label can trigger document supplementation, clearance delay or unplanned costs.
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.
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