Tiếng Việt
中文 (中国)
IMPORT PROCEDURE FOR ORAL BEAUTY PRODUCTS
This article applies to oral beauty products such as collagen drinks, beauty drinks, skin-support capsules, sachets, gummies or supplements claiming beauty-from-within benefits. Before ETA, importers should lock product classification, HS code, duties, C/O, product declaration, imported food safety inspection, Vietnamese supplementary labeling and claims to avoid dossier supplementation, loss of C/O preference or storage costs.
QUICK FACT TABLE
| ITEM | REVIEW POINTS |
|---|---|
| Product | Oral beauty product – beauty drink, collagen drink, oral skin-support supplement, collagen/vitamin/mineral/probiotic product or bioactive supplement for oral use. |
| Key legal classification | Usually reviewed as health supplement / functional food / supplemented food. If circulated as a common beverage, a different procedure may apply; therapeutic claims may require reclassification. |
| Reference HS codes | 2106.90.70 – food supplements; 2202.90.50 – other non-aerated beverages ready for immediate consumption without dilution; 2202.90.90 – other non-alcoholic beverages. |
| Reference taxes | 2106.90.70: MFN 15%, VAT 10%; 2202.90.50: MFN 30%, ordinary duty 45%, VAT 10%; 2202.90.90: MFN 20%, ordinary duty 30%, VAT 10%. Verify at declaration date. |
| Specialized dossier | Product declaration registration or self-declaration depending on classification; imported food safety inspection; CFS/Health Certificate/GMP if health supplement; COA/testing result; Vietnamese supplementary label. |
| Typical hold points | Therapeutic claims, missing product declaration receipt, missing CFS/GMP, labels without the “not a medicine” disclaimer, and C/O with wrong HS or description. |
SCOPE OF APPLICATION
This article applies only to oral beauty products within a sensitive regulatory boundary between cosmetics, health supplements and products with therapeutic claims. It does not apply automatically to acne drugs, disinfectants, beauty devices or external-use cosmetics.
- Applies to bottled collagen drinks, cans, stick packs, sachets, oral ampoules, capsules, tablets or gummies.
- Applies to commercial imports, testing samples, R&D samples, imports for EPE/FDI/factories, and promotional products placed on the market.
- Does not automatically apply to alcoholic beverages, drugs, external-use cosmetics, medical foods, infant products or products with specially controlled substances.
- If claims include “treat acne”, “cure melasma”, “anti-inflammatory” or “antibacterial from within”, classification must be reviewed before import.
Review is required based on catalogue, formula, nutrition facts, label, COA, CFS/GMP, packaging form and actual import purpose.
CLASSIFICATION & TECHNICAL IDENTIFICATION
Technical identification
- Product form: collagen drink, powder for drink, capsule, tablet, gummy, oral ampoule.
- Main ingredients: collagen peptide, vitamin C, biotin, zinc, hyaluronic acid, probiotics, botanical extracts, sweeteners, flavours.
- Claims: supports skin beauty, antioxidant support, collagen supplementation, skin health support; therapeutic claims must be removed or reclassified.
- Usage: oral use, dosage, target users, warnings and contraindications if any.
- Market form: bulk, retail, sample, combo, promotion or testing product.
Do not describe it as cosmetics
Oral-use products should not be declared under Chapter 33 merely because they relate to beauty. A vague description such as “cosmetic drink” may cause wrong HS classification, wrong declaration route and food safety inspection issues.
| Criterion | Documents to verify | Risk if misdescribed | Suggested customs/commercial description |
|---|---|---|---|
| Product form | Catalogue, label, packing photo | Confusion between common beverage and health supplement | Beauty supplement drink / collagen drink, ready-to-drink, bottle … ml |
| Active ingredients | Formula, COA, nutrition facts | Wrong HS or missing food safety dossier | Food supplement containing collagen peptide, vitamin C … |
| Claims | Label, leaflet, web claims | Drug-boundary review | Use support claims only; avoid treatment wording |
| Declaration classification | Product declaration, CFS, GMP, test report | Wrong authority or incomplete dossier | Imported health supplement under registered declaration |
HS CODE – DUTIES – C/O
HS classification depends on product form, ingredients, use and claims. Do not lock an HS code solely from the trade name “beauty drink”.
| Reference HS | Applicable case | Risk if wrong | Documents to verify |
|---|---|---|---|
| 2106.90.70 | Food supplements: capsules, sachets, collagen supplements, bioactive oral beauty supplements. | Wrong if circulated primarily as a beverage or as a drug. | Formula, COA, label, product declaration, CFS/GMP. |
| 2202.90.50 | Non-aerated ready-to-drink beverage for immediate consumption without dilution. | Higher MFN duty and possible mismatch with supplement declaration. | Label, usage, nutrition facts, declaration dossier. |
| 2202.90.90 | Other non-alcoholic beverages not fitting a more specific subheading. | Insufficient basis if the product is clearly a food supplement. | Catalogue, label, ingredients, declaration dossier. |
| 3004 / pharmaceutical headings | Only if active ingredients and therapeutic presentation indicate drug treatment. | Food procedure may be invalid. | Claims, actives, clinical documents, label and drug permit if applicable. |
| HS scenario | Reference MFN | Reference ordinary duty | VAT | Conditions |
|---|---|---|---|---|
| 2106.90.70 – Food supplements | 15% | 22.5% if no separate ordinary rate is available | 10% | For oral supplements/health supplements after checking formula and declaration dossier. |
| 2202.90.50 – Non-aerated ready-to-drink beverage | 30% | 45% | 10% | For ready-to-drink non-alcoholic beverages not falling under fruit juice heading 20.09. |
| 2202.90.90 – Other non-alcoholic beverage | 20% | 30% | 10% | For other non-alcoholic beverages depending on formula and description. |
| Valid C/O | Special preferential duty may apply if the C/O/origin document, HS code, description, origin criterion and direct transport conditions are valid. | |||
C/O / FTA preferential duty review
| Origin route | Form / origin document | Preferential duty to verify | Conditions | Risk |
|---|---|---|---|---|
| ASEAN | Form D or ATIGA origin document | 2106.90.70 often has an ATIGA 0% line if origin rules are met; 2202.90.xx must be checked by exact 8-digit HS. | Correct form, HS, goods description, origin criterion and direct transport. | Preference may be rejected if the C/O describes the goods too generally or shows mismatched HS/quantity. |
| China | Form E under ACFTA or RCEP origin document | Compare ACFTA and RCEP by exact HS; do not apply one rate to all 2106 and 2202 products. | Review CTH/RVC, third-party invoice, transit and ingredient description. | Wrong form or origin criterion may result in MFN/ordinary duty and tax adjustment. |
| Korea | Form AK, Form VK or RCEP | Deep preference may apply; select the lowest valid agreement at declaration date. | Check producer, origin criterion, third-party invoice and C/O issuance date. | Wrong form or expired C/O may shift the shipment back to MFN. |
| Japan | Form AJ, Form VJ, CPTPP or RCEP | Under CPTPP, Viet Nam’s schedule shows 2106.90.70 under B5 staging and reaching 0% after staging; verify the currently effective schedule. | Review self-certification, origin criterion and direct transport. | Preference is not available if the goods do not meet the origin rule. |
| EU | EUR.1 or EVFTA origin statement | Check EVFTA rate by exact 8-digit HS; do not generalize across all beauty drinks or supplements. | Check exporter statement, REX where applicable, goods description and origin country. | Wrong origin wording, HS or transport evidence may reject preference. |
| UK | UKVFTA origin declaration | Check by 8-digit HS at declaration date; preference depends on valid origin declaration. | Review invoice origin statement, description, origin criterion and transport route. | A commercial invoice without valid origin wording is insufficient. |
| Australia/New Zealand | AANZFTA, CPTPP or RCEP | AANZFTA provides deep preference for 2106.90.70; compare against CPTPP/RCEP for the actual shipment. | Select the best agreement only if the respective origin rule is met. | Wrong agreement selection or missing direct-transport proof may reject preference. |
| India | Form AI | Check by exact HS; do not assume 0% for all food supplements. | Review RVC/CTH, ingredients and production process. | Wrong origin criterion may invalidate AIFTA preference. |
| No C/O | Not applicable | MFN may apply if conditions are met; otherwise ordinary duty may apply, e.g. 22.5% for MFN 15%, 45% for MFN 30%. | Review origin, purchase terms and landed cost before ordering. | Higher landed cost, especially under 2202.90.50. |
Pre-ETA C/O checklist
| Checkpoint | What to verify | Risk if missed |
|---|---|---|
| Form / origin document | Correct agreement: Form D, E, AK, VK, AJ, VJ, AI, EUR.1, CPTPP/RCEP/UKVFTA declaration… | Wrong form may lose preferential duty. |
| Origin criterion | WO, RVC, CTH/CTSH under the relevant agreement. | A correct form with wrong criterion can still be rejected. |
| HS and description | HS and goods description must match invoice, packing list, label and customs declaration. | Mismatch may trigger consultation or duty adjustment. |
| Third-party invoice | If used, the C/O must show the required indication/box for the relevant agreement. | The C/O may be challenged or rejected. |
| Direct transport | Review B/L/AWB, transit route and non-manipulation evidence if transshipment occurs. | Failure to prove direct transport may lose preference. |
| Quantity, weight, issue date | Must match the commercial documents and remain valid. | Customs may request correction before clearance. |
APPLICABLE SPECIALIZED POLICIES
| Goods scenario | Potential policy | Documents | Authority/portal | Timing | Risk note |
|---|---|---|---|---|---|
| Imported health supplement | Registered product declaration before circulation/import for commercial sale | CFS/Health Certificate, GMP, test report, label, formula | Ministry of Health / Vietnam Food Administration online public service | Before commercial shipment | Missing receipt may block clearance or circulation. |
| Common supplemented beverage | Self-declaration or registration depending on product nature | Test result, declaration, label | Local food safety authority or MOH | Before market placement | Wrong filing authority delays the dossier. |
| Therapeutic claims | Drug-boundary review | Claim matrix, active ingredients, label, leaflet | MOH and competent departments | Before contract and label printing | Functional foods must not claim to cure disease. |
| Testing/R&D samples | Proper HS, value and purpose declaration; possible specialized review | Sample invoice, PO, technical documents | Customs / food safety authority if requested | Before ETA | Do not assume automatic exemption. |
LEGAL DOCUMENTS TO REVIEW
| Group | Document | Issuer | Effectiveness | Role | Key points | Review note |
|---|---|---|---|---|---|---|
| Law | Law on Food Safety No. 55/2010/QH12 | National Assembly | Check current validity | Framework for food safety and labeling | Food labeling and safety obligations | No disease-treatment claim for foods. |
| Decree | Decree 15/2018/ND-CP | Government | Currently applied; check amendments | Product declaration and imported food safety inspection | Articles 6, 7, 8 and annexes | Health supplements are usually registered with MOH. |
| Circular | Circular 43/2014/TT-BYT | Ministry of Health | Effective from 15 Jan 2015 | Management of functional foods | Scope, definitions, labeling and usage instructions | Check “not a medicine” disclaimer. |
| Labeling | Decree 43/2017/ND-CP and Decree 111/2021/ND-CP | Government | Decree 111 effective from 15 Feb 2022 | Goods labeling and Vietnamese supplementary labels | Mandatory label contents | Supplementary label must match declaration dossier. |
| Tariff/VAT | Decree 108/2025/ND-CP and Decree 174/2025/ND-CP | Government | 108 effective 19 May 2025; 174 effective 01 Jul 2025 | Import tariff and VAT reduction review | Chapters 21, 22 and VAT exclusion annexes | Do not finalize tax without confirming 8-digit HS. |
VIEW / DOWNLOAD SOURCE DOCUMENTS
Enterprises should cross-check source documents on official legal databases or issuing authority websites before applying them.
CUSTOMS CLEARANCE DOSSIER
Commercial documents
- Commercial Invoice and Packing List.
- Bill of Lading / Air Waybill.
- Sales Contract / Purchase Order.
- C/O if preferential duty is claimed.
- Catalogue, original label, product photos and SKU list.
Specialized documents
- Registered product declaration receipt or self-declaration if applicable.
- COA/testing report for food safety indicators.
- CFS/Health Certificate/GMP for imported health supplements if applicable.
- Vietnamese supplementary label and claim documents.
- Imported food safety inspection dossier.
| Dossier group | Required documents | Used for | Prepared by | Common errors | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, PL, B/L/AWB, contract | Customs value and transport | Supplier, importer, forwarder | Product name differs from declaration | Match product name, SKU and quantity. |
| Declaration | Product declaration/self-declaration | Proof of eligibility for import/circulation | Importer, regulatory team | Dossier unfinished when goods arrive | Complete before commercial shipment. |
| Testing | COA, test report | Declaration and food safety inspection | Supplier, lab, importer | Missing safety indicators | Compare indicators against declaration dossier. |
| Labeling | Original label, supplementary label, artwork | Market circulation | Brand owner, importer | Therapeutic wording or missing disclaimer | Review artwork before import. |
DECISION POINTS THAT MAY HOLD THE SHIPMENT
| Decision point | Question | Evidence | Consequence | Recommended handling |
|---|---|---|---|---|
| Product classification | Health supplement, supplemented food or beverage? | Label, formula, declaration, claims | Supplementary dossier or reclassification | Lock classification before contract. |
| HS code | 2106.90.70 or 2202.90.xx? | Formula, dosage form, label | Wrong duty, C/O and policy | Match HS with product form and declaration. |
| Claims | Any treatment/disease claim? | Label, website, leaflet | Drug-boundary review | Use support claims only. |
| C/O | Correct HS, description and form? | C/O draft, invoice, B/L | Loss of preferential duty | Review C/O before issuance. |
PRACTICAL E2E PROCESS
- Pre-ETA review: lock classification, HS, duties, C/O, claims, label, declaration and food safety requirements.
- Document lock: invoice, PL, B/L/AWB, C/O, catalogue, label, COA, CFS/GMP and product declaration.
- Specialized filing: complete product declaration/self-declaration and imported food safety inspection where applicable.
- Customs declaration: control value, HS, product description, C/O and specialized dossier; handle green/yellow/red channels.
- Clearance and delivery: obtain D/O, inspect goods, deliver to warehouse and apply supplementary labels before distribution.
- Post-clearance archive: keep declaration, tests, C/O, import dossier, label and claim documents.
PRE-ETA RISK CHECKLIST
| Risk | Consequence | Pre-ETA control | Documents |
|---|---|---|---|
| Therapeutic claim | Reclassification or circulation issue | Review all labels, websites and ads | Label, leaflet, claim matrix |
| Missing declaration | Clearance/circulation delay | Complete before commercial shipment | Declaration receipt |
| Wrong 2106/2202 HS | Wrong duties and C/O | Review formula, form and usage | Formula, COA, label |
| C/O error | No preferential duty | Check draft C/O before ETA | C/O, invoice, B/L |
| Label mismatch | Relabeling or market delay | Compare label with declaration | Original and supplementary labels |
FAQ – COMMON BUSINESS QUESTIONS
| Question | Short answer |
|---|---|
| Is an oral beauty product a cosmetic? | Usually no. Oral products are reviewed under food/health supplement or beverage regulations depending on formula and claims. |
| Is a cosmetic notification required? | Generally no for oral products; a food/health supplement declaration route should be reviewed. |
| Should HS be 2106.90.70 or 2202.90.50? | It depends on whether the product is a food supplement or ready-to-drink beverage. |
| Can the label say “treat acne from within”? | Treatment claims should be avoided for foods and must be reviewed carefully. |
| Can C/O reduce duty? | Yes, if the origin document is valid and matches HS, description and origin rules. |
| Is VAT 8% or 10%? | Base VAT is commonly 10%; any 8% reduction must be checked against Decree 174/2025 and exclusion annexes at declaration date. |
RELATED ARTICLES
IMPLEMENTATION SOLUTION FROM TGIMEX
This article outlines HS code, duties, dossiers and specialized policies for oral beauty products. In real shipments, importers still need to review formula, label, claims, COA, CFS/GMP, documents, origin and import purpose.
Coordination capability
- Agent network in more than 60 countries.
- Member of WCA, WCA China Global, VLA and HNLA.
- Sea, air, road and rail logistics.
- Customs clearance, C/O, permits, warehousing and domestic transport.
Support scope
- Pre-ETA review: HS, policy, C/O, duties, label, claims and food safety dossier.
- Compliance control: invoice, PL, B/L/AWB, C/O, COA, CFS/GMP and declaration dossier.
- Coordination with agents, carriers, ETA and pre-alert.
- Customs declaration, green/yellow/red channel handling and post-clearance archiving.
For shipments that may involve specialized inspection, permits, C/O or labeling requirements, enterprises should not wait until cargo arrival to start dossier review. Even a minor discrepancy between invoice, packing list, catalogue, datasheet, C/O or label may trigger additional document requests, delayed clearance or unplanned storage costs.
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
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