Legal note: This article applies only to empty makeup sponges used to apply or dab cosmetics. It should not be automatically applied to cotton pads, wipes, body cleansing sponges, facial cleansing devices, brushes, electrical devices, impregnated cosmetics or medical-use items. Review catalogue, label, material composition and actual import purpose before use.

SCOPE OF APPLICATION

This guide applies to makeup sponges used for foundation, cushion, concealer, liquid/cream makeup and similar beauty applications. Related commercial names may include beauty sponge, cosmetic puff, latex-free makeup sponge, teardrop sponge, triangle sponge and cosmetic pad.

Do not apply this guide to facial cleansing machines, massage devices, LED mask devices or battery-powered items.
If the sponge is impregnated with cosmetic liquid, cream or cleansing formula, review finished-cosmetic requirements.
If the product is cotton pad, nonwoven pad, wipe or textile pad, review 5601/5603/6307 according to actual material.
If it is natural sponge or used goods, review separately based on the actual dossier.

CLASSIFICATION & PRODUCT IDENTIFICATION

Technical identification

Review catalogue, photos, material composition, size/specification, label claim and instructions. The key point is to prove that the item is designed for applying or dabbing cosmetics, not a general foam material.

Operational identification

Before ETA, lock the product name as: “Makeup sponge/cosmetic puff, material…, size…, for applying cosmetics, brand…, new 100%”. This reduces HS and policy queries.

Criteria	Documents to check	Risk if wrong	Suggested declaration description
Main use	Catalogue, label, user instruction	Confusion with cleaning sponge, cotton pad or foam material	Makeup sponge/cosmetic puff for applying cosmetics
Material	Material composition, COA if available	Wrong classification among 9616.20.00, 3926, 5603	Polyurethane foam makeup sponge, latex-free
Shape/size	Specification, product photos	Difficult physical inspection explanation	Teardrop/round/triangle makeup sponge, size…
Impregnated or not	Label, ingredient list, SDS	Missing cosmetic declaration if cosmetic is present	Empty cosmetic applicator sponge, not impregnated
Packing	Packing list, carton photos	Quantity/unit mismatch	Set of … pcs/box; … boxes/carton
Condition of goods	Invoice, supplier declaration, photos	Used goods/sample/tester may require a different review	Brand-new makeup sponge, new

HS CODE – DUTY – C/O

For makeup sponge, HS classification should not be based on the generic commercial name “sponge”. It must be reviewed against the intended use, material composition, finished form, and whether the item is impregnated with cosmetics. If the goods are pads/puffs used to apply or dab cosmetics, the key reference code is usually 9616.20.00. If the actual goods are makeup brushes, cotton pads, nonwoven wipes, ordinary plastic/foam articles, or sponges pre-filled with cosmetics, the HS and policy treatment may change.

Legal note: The duty rates below are indicative for import planning. Before customs declaration, the importer must re-check the effective tariff schedule, actual origin, C/O conditions and product description.

Reference HS – import duty – VAT table

Review group	Reference HS	Application conditions	Indicative MFN	Indicative ordinary duty	Base VAT	Dossier to check
Main code for makeup sponge	9616.20.00	Pads/puffs for applying, blending or dabbing cosmetics; empty goods, not impregnated with cream, powder or liquid.	25%	37.5%, generally calculated as 150% of MFN if no separate ordinary rate applies.	10%	Catalogue, product photos, original label, material composition, packing specification, user instruction.
If the product is a makeup brush	9603.30.00	Makeup brush with handle and bristle/fiber head; not an empty sponge pad.	25%	37.5%	10%	Product structure photos, material list, catalogue, description “make-up brush/cosmetic brush”.
If it is an ordinary plastic/foam article	3926.90.99 or relevant 3924/3926 subheading	Only where the article is made of plastic/foam and is not specifically designed as a cosmetic applicator.	12% for 3926.90.99; other subheadings must be checked separately.	18% for 3926.90.99.	10%	Material sheet, polymer composition, catalogue, principal use, sample images.
If it is cotton pad/wipe/textile pad	6307.90.90 or 5601/5603 depending on nature	For cotton pads, nonwoven pads, wipes or textile pads; not a sponge used for makeup blending.	20% for 6307.90.90; 5601/5603 must be checked by fiber/fabric structure.	30% for 6307.90.90.	10%	Composition, GSM/grammage, woven/nonwoven structure, intended use, retail packaging.
If the sponge is pre-filled with cosmetics	Review under the relevant cosmetic heading, for example 3304 if the essence of the goods is makeup	Applies where the sponge contains foundation, powder, cleanser or cosmetic active for market circulation.	Do not default to 9616.20.00; classify by the actual cosmetic product.	Review by actual cosmetic HS.	10% or VAT policy at declaration date.	Cosmetic notification, formula/INCI, label, CFS, LOA, PIF, product claims.

Basis for HS determination

Main use: applying/blending/dabbing cosmetics on skin, not foam material sold as raw material.
Condition: cut/shaped and packed as a makeup tool; foam sheets as raw material must be reviewed by material.
Material: polyurethane, latex-free foam, hydrophilic sponge, silicone sponge or other materials support the review, but intended use remains decisive.
Packaging: sold by piece/set, with labels such as “makeup sponge/cosmetic puff/blending sponge”.
Classification risk: confusing makeup sponge with makeup brush, cotton pad, wipe or nonwoven pad can change HS and duty.

Preferential C/O/FTA review before ETA

Origin route	C/O or origin proof	Preferential treatment to review for 9616.20.00	Application conditions	Dossier to check	Risk if incorrect
ASEAN	Form D – ATIGA	May reach 0% if the ATIGA tariff schedule in the declaration year and HS 9616.20.00 are eligible.	ASEAN origin, direct transport, valid origin criterion.	Form D, Invoice, Packing List, B/L, clear description “makeup sponge/cosmetic puff”.	Wrong description or HS mismatch may lead to preference rejection.
China	Form E – ACFTA or RCEP origin document	Compare ACFTA and RCEP; use the better rate only when HS, origin and documents match.	Correct origin rule, direct transport or supporting documents for third-country transit.	Form E/RCEP C/O, third-party invoice if any, production/origin declaration.	Third-party invoice issue, HS mismatch, or overly generic “sponge” description.
Korea	AKFTA / VKFTA / RCEP	Compare schedules to select the lowest eligible rate at declaration date.	Correct C/O form and CTH/CTSH/RVC criterion if applicable.	C/O, origin explanation, catalogue, transport documents.	Insufficient origin rule proof or wrong agreement selection.
Japan	VJEPA / AJCEP / CPTPP / RCEP	Review by actual origin and applicable agreement; do not apply one rate to all shipments.	Origin criterion, direct transport, matching HS and description.	C/O or self-certification if allowed, invoice, packing list.	Goods made in a third country but declared as Japan origin.
EU / UK	EVFTA / UKVFTA	Review the preferential schedule; may be lower than MFN if origin proof is valid.	Valid statement on origin/C/O and compliance with origin rules.	Statement on origin, exporter reference, invoice, transport document.	Invalid origin proof or wrong HS declaration.
Australia – New Zealand / India / Hong Kong	AANZFTA/CPTPP/RCEP; AIFTA; AHKFTA	Review route by route because rates vary by agreement and year.	Correct C/O form, member-country origin and compliant transport route.	C/O, transport documents, invoice, packing list, contract.	Wrong C/O form or failure to prove direct transport.

C/O checklist before ETA

Check the correct C/O form: Form D, Form E, AK/VK, EUR.1/statement on origin, CPTPP/RCEP…
HS on C/O must match the planned declaration code, especially 9616.20.00 or another actual code if classification changes.
Product description should clearly state makeup sponge, cosmetic puff or blending sponge; avoid only “sponge”.
Check origin criterion: WO, RVC, CTH, CTSH or the product-specific rule of the relevant FTA.
Check country of origin, port of loading, transport route, third-party invoice, C/O issue date and validity.
Match quantity, weight, value, invoice number and B/L number among C/O, Invoice, Packing List and customs declaration.

Operational conclusion: For an empty makeup sponge not impregnated with cosmetics, the priority HS to review is 9616.20.00, indicative MFN duty 25%, indicative ordinary duty 37.5%, and base VAT 10%. Preferential import duty may be reduced under a valid C/O, but only when HS, origin, C/O form and origin rule are all compliant.

SPECIALIZED POLICY MATRIX

Situation	Possible policy	Documents	Authority/portal	Timing	Risk note
Empty makeup sponge	Standard customs, labeling, HS and C/O review.	Invoice, PL, B/L/AWB, catalogue, label, photo.	Customs authority.	Before ETA.	Not a finished cosmetic if no cosmetic is present.
Impregnated sponge	May trigger finished cosmetic policy.	Ingredients, label, CFS/LOA if any, cosmetic declaration.	Drug Administration/health authority if applicable.	Before arrival/market release.	Do not declare as empty accessory.
Retail goods	Labeling requirements.	Original label, Vietnamese label, artwork.	Customs/market authority.	Before clearance/market circulation.	Wrong label may cause post-clearance issue.
Sample/tester/promotion	HS, duty and label still need review.	PO, invoice, campaign plan.	Customs or trade authority if relevant.	Before ETA.	“Sample” does not remove compliance obligations.
EPE/FDI/factory/project import	Standard customs review plus internal asset/material-use control.	Import purpose, warehouse receipt, PO/contract, accounting documents.	Customs / importer internal control.	Before shipment and customs declaration.	Wrong import purpose may affect tax, accounting and later audits.

LEGAL DOCUMENTS TO REVIEW

Group	Document	Issuer	Effective date	Role	Key section	Review note
Tariff	Decree 26/2023/ND-CP and amendments	Government	15/07/2023	MFN tariff basis.	Import tariff schedule.	Check at declaration date.
Customs	Decree 167/2025/ND-CP	Government	15/08/2025	Customs procedure framework.	Amendments to customs procedures.	Apply by shipment dossier.
Customs/tax	Circular 121/2025/TT-BTC	Ministry of Finance	01/02/2026	Customs and import tax procedure updates.	Relevant appendices/forms.	Apply by declaration date.
Labeling	Decree 43/2017/ND-CP, amended by 111/2021/ND-CP	Government	15/02/2022 for Decree 111	Goods labeling.	Mandatory label information.	Check origin and responsible entity.
Cosmetics	Circular 06/2011/TT-BYT and 34/2025/TT-BYT	Ministry of Health	18/08/2025 for Circular 34	Only if cosmetic content is present.	Declaration/PIF/label/claim.	Not applied to empty sponge only.
VAT	Decree and applicable VAT regulations	Government	Effective from	VAT policy review.	Base VAT ; check any reduction at declaration date.	Do not apply reduced VAT mechanically.
Foreign trade management	Decree	Government	In force; review current amendments if any	General import/export management framework.	Goods subject to prohibition/conditional import if any.	For empty makeup sponge, mainly for reference; still review actual dossier.

VIEW / DOWNLOAD ORIGINAL DOCUMENTS

Businesses should verify each document on the Government portal, legal document database or issuing authority website before application.

Decree 26/2023 Decree 167/2025 Circular 121/2025

CUSTOMS CLEARANCE DOCUMENTS

Commercial documents

Commercial Invoice.
Packing List.
B/L or AWB.
Sales Contract or PO if any.
C/O if preferential duty is claimed.
Catalogue, photos, original label, material composition.

Specialized documents if any

Label dossier.
Material composition, COA/SDS if available.
Cosmetic declaration if impregnated with cosmetic product.
Campaign documents for sample/tester/promotion.
HS explanation dossier where needed.

Document group	Required document	Used for which step	Usually prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO	Declaration, value and quantity check	Shipper/importer	Generic product name or inconsistent quantity	Compare all lines before pre-alert
Transport	B/L or AWB, Arrival Notice, delivery order dossier	Taking delivery and customs clearance	Forwarder/carrier	Wrong consignee or package count	Check against Packing List and Invoice
Technical	Catalogue, photos, material composition, size/model list	HS explanation and inspection	Supplier/importer	No material data	Request supplier confirmation before ETA
C/O	Certificate of Origin if claiming preference	Preferential duty treatment	Exporter/importer	Wrong HS, description or origin criterion	Review C/O draft before issuance
Conditional dossier	Cosmetic declaration dossier if sponge is impregnated with cosmetics	Specialized compliance if applicable	Importer / responsible entity	Treating impregnated goods as empty tools	Check label, ingredient and SDS before shipment
Labeling	Does original label / Vietnamese label show product name, origin and responsible party?	Original label, artwork, label plan	Post-clearance market circulation risk	Prepare label review before release.

CUSTOMS DECISION POINTS

Decision point	Question	Evidence	Impact if unclear	Suggested action
HS basis	Is it 9616.20.00 or another material-based item?	Catalogue, label, photo, material data	HS query and duty risk	Prepare product explanation before declaration
Impregnation	Empty sponge or cosmetic-filled/impregnated?	Label, ingredients, SDS	Missing cosmetic compliance	Obtain supplier confirmation if empty
Document matching	Do invoice, PL, label and catalogue match?	Model/size list	Inspection query	Lock product description before ETA
C/O validity	Does HS/description/origin match?	C/O, invoice, B/L	Loss of preferential duty	Review draft C/O
Many colors/sizes not separated	Inspection and C/O matching issues	List SKU/color/size clearly	SKU list, invoice, packing list

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review

Confirm HS 9616.20.00 or alternative code, duty, VAT, C/O, labels and import purpose.

Step 2 – Lock documents

Finalize invoice, PL, B/L/AWB, catalogue, photos, material composition, model/size list.

Step 3 – Check specialized requirements

If the sponge is impregnated or bundled with cosmetics, review cosmetic compliance before arrival.

Step 4 – Customs declaration

Declare clear name, material, use, quantity and origin; prepare HS and C/O explanation.

Step 5 – Clearance and record keeping

Release goods, check labels if needed, store C/O, shipping documents, photos and technical dossier.

PRE-ETA RISK CHECKLIST

Risk	Consequence	Pre-ETA control	Documents
Generic “sponge” description	HS query	Use makeup sponge/cosmetic puff description	Invoice, catalogue
No material data	Possible shift to 3926/5603	Request composition	Material sheet
Impregnated product declared as empty	Cosmetic compliance risk	Check label and ingredients	Label, SDS
Wrong C/O	No preferential duty	Review draft C/O	C/O, invoice, B/L
Weak label	Market/post-clearance risk	Review label before import	Artwork, label

FAQ

Does makeup sponge need cosmetic declaration?

Empty sponge does not usually constitute a finished cosmetic. If impregnated with cosmetic product, review cosmetic declaration requirements.

What is the common HS code?

9616.20.00 is the main reference for puffs and pads for applying cosmetics.

Can C/O reduce duty?

Yes, if the C/O is valid and the origin rule is satisfied.

Is sample/tester import exempt from compliance?

No. Purpose and market release status must still be reviewed.

Should many colors/sizes be separated?

Yes, where price, quantity, inspection or C/O details are affected.

What if the invoice only says “sponge”?

Request a clearer description before shipment to reduce HS queries.

How is a makeup sponge different from cotton pads for HS review?

A makeup sponge is normally used to apply/dab cosmetics, while cotton pads or non-woven pads may need classification by material and use. Catalogue, label and material composition should be reviewed before declaration.

DEM/DET risks in import shipments

How to control container/storage costs when dossiers are delayed.

View article

IMPLEMENTATION SUPPORT FROM TGIMEX

For actual shipments, importers should review catalogue, material, intended use, label, C/O and import purpose before ETA.

60+ countriesWCA / WCA China GlobalVLA / HNLASea · Air · Road · Rail

Pre-ETA review

Confirm HS 9616.20.00 or alternative code.
Check C/O, duties, VAT, labels and material composition.

Compliance control

Match invoice, PL, B/L/AWB, C/O and catalogue.
Lock product description and origin.

Logistics & customs

Coordinate agents and carriers.
Declare customs and support HS explanation.

Do not wait until cargo arrival to verify HS, C/O, labels or cosmetic-related risks. Small inconsistencies may delay clearance or generate unplanned storage cost.

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