Massage devices are often declared too generally as “beauty devices” or “massage machines”, while the real compliance risk depends on the massage function, vibration/impulse/heating mechanism, lithium battery, adapter, Bluetooth/Wi‑Fi module and claims on label or marketing materials. If the product is confused with fitness equipment or medical devices, the shipment may face HS explanation, specialized-policy review, C/O rejection or storage cost. This guide provides an E2E map before ETA: HS Code, duty, VAT, C/O, label, battery/adapter dossier, technical documents and risk checkpoints.

9019.10.10Key HS reference

0%MFN reference

5%Normal duty

10%Standard VAT

QUICK FACT

Item	Fast review point	Operational note
Product scope	Massage devices for personal care/beauty: face, eye, neck, shoulder or mini body massagers; vibration/heating/light electrical impulse products where the actual purpose is ordinary massage.	Do not automatically apply this guide to facial cleansing devices, LED masks, facial steamers, makeup brushes or sponges.
HS reference	Main reference: 9019.10.10 for electronic massage apparatus; review 9019.10.90 for other types, 9506.91.00 for fitness/weight-loss equipment, and medical-device rules if treatment claims exist.	Review catalogue, datasheet, model, structure, operating principle and actual claims.
Tax reference	For 9019.10.10: MFN 0%, normal duty 5%, standard VAT 10%.	VAT 8% is reviewed only if the product is eligible for VAT reduction and not excluded.
Specialized policy	Ordinary personal-care massagers mainly require HS, tax, label, battery/adapter and transport dossier review. Medical/treatment/pain relief/rehabilitation claims require medical-device review.	Do not conclude “no licence required” without model, catalogue, label, user manual and marketing claims.
C/O	C/O may still be useful for origin proof and compliance records even where the main MFN rate is 0%.	Wrong form, origin criterion, description, HS or model may still cause rejection.

Legal note: This is an operational review framework. Apply it only after checking the actual catalogue, datasheet, model, label claims, battery/adapter, condition, origin and customs policy at declaration date.

Illustration for Import Procedure Guide for Massage Devices — Illustration of the product group and document review before customs clearance.

SCOPE OF APPLICATION

Covered products

Face, eye, neck, shoulder, hand or mini body massage devices used for personal care/beauty; new goods for trading, display, sample sales or spa/salon use.

Not automatically covered

Large massage chairs, physical-therapy devices, rehabilitation devices, medical pain-relief equipment, weight-loss belts or physical-training equipment.

Separate review triggers

Lithium battery, adapter/charger, Bluetooth/Wi‑Fi, app control, heating, electrical impulse, EMS/TENS, LED or attached accessories.

Application rule

Review according to the actual catalogue, datasheet, model and import purpose. Do not group all variants into one conclusion.

PRODUCT CLASSIFICATION & IDENTIFICATION

The technical identity of a massage device must be assessed by its main mechanism and intended use. Customs may compare the commercial name with the function, structure, technical file, label and declaration wording.

Criterion	Documents to review	Risk if wrongly described	Suggested declaration wording
Main function	Catalogue, user manual, product photos and operation videos if any.	Confusion between personal-care massager, mechano-therapy apparatus, fitness equipment or medical device.	“Electronic massage device for personal care, model…, brand new, not for medical purpose” if factually correct.
Operating mechanism	Datasheet: vibration, rotation, tapping, heating, EMS/TENS, roller, massage head, motor.	“Weight loss/exercise” claims may lead to heading 95.06; “therapy/pain relief” claims may trigger medical-device review.	Describe the actual massage mechanism and avoid claims beyond the dossier.
Power/battery	Battery specification, adapter, charger, MSDS/UN38.3 for lithium battery.	Missing battery documents may delay booking or trigger DG review.	Declare battery/adapter as included if actually packed with the device.
Condition	Invoice, packing list, contract, photos, new/used/refurbished statement.	Used/refurbished goods may have different policy treatment.	State the actual condition correctly.
Label/claims	Original label, Vietnamese sub-label draft, brochure, sales website.	Treatment, rehabilitation or disease-related claims may trigger medical-device management.	Use personal-care/beauty claims only where the product is not a medical device.

HS CODE – DUTIES – C/O

This section has been rewritten to remove repetition: HS classification now explains the classification basis, the duty table gives specific tax levels, and the C/O part focuses on FTA eligibility and documentary risks. For massage devices, the key issue is not the commercial term “beauty device”, but the massage function, operating mechanism, product claims, and accessories such as lithium battery, adapter or wireless module.

Classification note: the HS codes below are references for ordinary imported massage devices. The importer should review catalogue, datasheet, product photos, manual, claims, condition and accessories before customs declaration. Do not apply one HS code to all personal-care devices.

1. HS classification by actual product nature

Reference HS	Product nature	When applicable	Do not use when	Documents to review
9019.10.10	Electronic/electric massage apparatus.	Devices generating vibration, rotation, tapping, air compression, mild heat, light EMS/TENS or electric massage for personal care/beauty, without disease-treatment claims.	The product is fitness/slimming equipment under 9506, a medical device with treatment claims, or respiratory/aerosol therapy equipment under 9019.20.	Catalogue, datasheet, manual, product photos, label, claims, electrical specifications and model list.
9019.10.90	Other mechano-therapy or massage apparatus.	Used where the product remains a massage apparatus but does not fit the electronic/electric subheading or requires structural review.	The product is clearly electronic; or its claims/functions point to medical, fitness, respiratory or steam therapy categories.	Mechanical/electrical structure, operating principle, detailed photos and technical file.
9506.91.00	Physical exercise, gymnastics or slimming/fitness equipment.	Review only where the product is positioned as exercise, muscle training, slimming belt or fitness equipment.	The product is only for relaxation/personal massage and is not fitness equipment.	Marketing claims, usage videos, manual and functional description.
9019.20.xx	Ozone/oxygen/aerosol therapy, artificial respiration or therapeutic respiration apparatus.	Review only if the device is actually a steam/aerosol/respiration therapy apparatus; not for ordinary massagers.	The device only has massage heads, vibration/rotation/mild heat and no respiration/aerosol therapy function.	Datasheet, steam/gas mechanism, masks/tubes, therapy claims.
Medical-device route	Devices with treatment, rehabilitation, pathological pain-relief, physiotherapy or clinical positioning.	Review under medical-device regulations if label, IFU or catalogue indicates medical purpose.	The product is only a personal-care/beauty device with no medical claims.	IFU, CFS, ISO/CE/FDA if any, medical-device classification and circulation documents.

2. Specific duty table for declaration review

HS / situation	MFN duty	Normal duty	VAT	When to use	Operational note
9019.10.10 – electronic/electric massager	0%	5%	10%; review 8% only if VAT reduction conditions are met.	For electronic massage apparatus not reclassified as medical, fitness or respiration equipment.	Even with 0% MFN duty, HS must be correct to avoid VAT, policy and post-clearance risks.
9019.10.90 – other massage apparatus	0%	5%	10%; 8% only if eligible and not excluded.	For other massage apparatus within heading 9019.10.	Do not use this subheading for every electric product simply because the commercial name says “massager”.
9506.91.00 – fitness/exercise equipment	Check Chapter 95 at declaration date.	Check the normal duty schedule at declaration date.	Determine based on final HS.	Where the principal function is exercise, slimming or fitness.	Do not apply heading 9019 tax rates once the product is determined to be sports/fitness equipment.
Medical-claim device	Depends on HS after medical-device policy review.	Depends on HS and preferential status.	Review medical-device VAT policy if applicable.	Where label/manual claims treatment, rehabilitation or pathological pain relief.	Do not treat as ordinary beauty goods if documents show medical purpose.
Massager with lithium battery/adapter	Based on the main device HS if imported as a set; separate accessories require separate review.	Based on final HS.	Based on final HS.	Where battery/adapter is included or imported separately.	Lithium battery may require MSDS, UN38.3 and booking/DG review.

3. FTA/C/O – how to apply when 9019.10 MFN is already 0%

For 9019.10.10 and 9019.10.90, the reference MFN duty is currently 0%. Therefore, preferential C/O may not create additional import-duty savings in many shipments. However, C/O remains important for origin compliance, supplier control, valuation review, third-party invoice handling and post-clearance explanation.

Origin route	C/O or origin document	Potential duty benefit	Conditions to verify	Common risks
ASEAN	Form D – ATIGA	If MFN is already 0%, there may be no direct duty difference; still useful for origin file.	Origin criterion, direct consignment, goods description, HS, quantity, weight and issuance date.	Generic “beauty device” description, mismatch with invoice/catalogue, incomplete third-party invoice data.
China	Form E – ACFTA or RCEP	Check the preferential tariff at declaration date; duty benefit may be limited if MFN is 0%.	Actual Chinese origin, producer/exporter, CTH/CTSH/RVC where applicable, transport route.	Confusion between China and Hong Kong/Taiwan origin; C/O not matching model or packing list.
Korea	Form AK, Form VK or RCEP	Review AKFTA/VKFTA/RCEP and choose the document route matching the transaction.	Origin criterion, third-party invoice, direct transport and model description.	Wrong agreement selected, missing model, late issuance or invoice mismatch.
Japan	AJCEP, VJEPA, CPTPP or RCEP	Check each agreement; do not assume every route is better than MFN.	Origin criterion, exporter/producer, routing, description and HS consistency.	Confusing exporting country with origin country; HS mismatch without explanation.
EU / UK	EUR.1 or valid origin statement under EVFTA/UKVFTA	Check EVFTA/UKVFTA tariff schedule; may mainly support origin compliance where MFN is 0%.	Exporter status, valid statement, direct consignment and description.	Invalid origin statement, missing exporter data, description/HS mismatch.
Australia – New Zealand / CPTPP / RCEP	AANZFTA, CPTPP or RCEP	Review based on actual origin and chosen agreement.	Origin document, RVC/CTH/CTSH if applicable, invoice, bill and packing list.	Direct consignment not proven; origin document not matching shipment.

4. Pre-ETA HS – duty – C/O locking checklist

Item to lock	Question to answer	Documents to check	Required pre-ETA conclusion	Risk if missed
Main HS	Is it 9019.10.10, 9019.10.90, 9506 or a medical-device route?	Catalogue, datasheet, manual, photos, claims, model list.	Confirm HS based on principal function and invoice/declaration wording.	HS explanation, channel change, tax correction or post-clearance adjustment.
Import duty	Apply MFN 0%, normal 5% or a specific FTA schedule?	Tariff schedule, origin, C/O, contract, invoice.	Record duty rate used for quotation and declaration.	Incorrect cost estimate or insufficient basis during customs review.
VAT	Apply standard 10% or eligible 8% VAT reduction?	Final HS, VAT policy at declaration date, actual product type.	Do not assume 8%; document eligibility and exclusions.	Wrong VAT declaration and later correction/recovery.
C/O	Does C/O reduce duty, or is it mainly origin/compliance evidence?	C/O, invoice, packing list, bill, origin criterion, issuance date.	Decide whether to use preferential C/O and lock form/agreement.	C/O rejection, loss of preference if any, insufficient origin explanation.
Accessories	Do battery, adapter, massage heads, gel, remote or Bluetooth/Wi-Fi module affect policy?	Packing list, catalogue, MSDS, UN38.3, module datasheet.	Decide set classification or separate accessory review.	Booking delay, wrong description, missing battery/wireless documents.

SPECIALIZED POLICY MATRIX

Goods scenario	Possible policy	Documents	Authority/portal if identifiable	Timing	Risk note
New personal-care massage device	HS, duty, label, battery/adapter review.	Catalogue, datasheet, label, invoice, packing list, C/O.	Customs; market surveillance for domestic circulation.	Before ETA.	Do not conclude no licence without claim/model review.
Medical/treatment/pain relief claims	Possible medical-device management under Decree 98/2021/ND-CP as amended.	IFU, CFS, classification, circulation dossier if any.	Ministry of Health / relevant public service portal.	Before purchase or booking.	High risk with “medical/therapy/pain relief/rehabilitation” claims.
Lithium battery included	Transport safety dossier: MSDS, UN38.3, packing instruction, DG review.	MSDS, UN38.3, Wh rating, packing details.	Carrier/airline/forwarder; IATA/IMDG.	Before booking.	Booking may be rejected without battery documents.
Adapter/charger included	Review electrical specs, label, technical documents; separate HS if imported separately.	Input/output specs, adapter model, label photos.	Customs/specialized authority if applicable.	Before ETA.	Do not merge independently imported adapters into the main device line.
Bluetooth/Wi‑Fi/app control	Radio/ICT review if wireless transmitter exists.	Wireless module datasheet, frequency, manual.	MIC/CVT if applicable.	Before PO confirmation.	Possible conformity or licence obligations.
Used/refurbished goods	Used-goods policy review by product nature, age and import purpose.	Condition, production year, inspection documents if any.	Customs/specialized authority by case.	Before purchase.	Not treated as new goods.
Samples, warranty, projects, EPE/FDI	Policy may differ by import type and purpose.	Contract, PO, import purpose, EPE/FDI dossier if any.	Managing customs authority.	Before declaration.	Name, model and serial must match 100%.

LEGAL DOCUMENTS TO REVIEW

Group	Document	Authority	Effective / timing	Role	Key point	Review note
Tariff	Decree 26/2023/ND-CP	Government	Effective 15 July 2023	Preferential import tariff schedule.	Chapter 90.	Check at declaration date.
HS/tax lookup	Vietnam Trade Portal – 9019.10.10, 9019.10.90	Vietnam Customs / VTIP	System lookup	MFN/VAT reference.	90191010 Electronic; 90191090 Other.	Actual dossier controls classification.
Normal duty	Decision 36/2016/QD-TTg and amendments	Prime Minister	Check validity when applied	Normal import duty when MFN/FTA is unavailable.	Heading 90.19 reference normal duty 5%.	Verify at declaration date.
Classification guidance	Official letters 1675/TCHQ-GSQL, 1895/TCHQ-TXNK	General Department of Vietnam Customs	Case-specific guidance	Massage vs fitness/therapy classification logic.	Headings 90.19 and 95.06.	Not a universal ruling for all models.
Labelling	Decrees 43/2017/ND-CP, 111/2021/ND-CP	Government	2017 / 2022	Imported-goods labeling.	Original label, sub-label, origin, responsible party.	Review actual label.
Medical devices	Decrees 98/2021/ND-CP, 07/2023/ND-CP	Government	2022 / 2023	Medical-device review when applicable.	Classification, circulation, announcement/registration.	Only if within medical-device scope.
VAT	Decree 174/2025/ND-CP	Government	01 Jul 2025–31 Dec 2026	VAT reduction review.	Exclusion appendices.	Do not assume reduced VAT.

ORIGINAL LEGAL SOURCES

Enterprises should cross-check the cited documents on official legal databases or authority websites before application.

HS 9019.10.10 HS 9019.10.90 Decree 26/2023 Decree 98/2021 Decree 174/2025

CUSTOMS DOSSIER

Commercial dossier

Commercial Invoice, Packing List, Bill of Lading/Air Waybill, Sales Contract/PO if any, C/O if claiming preference or proving origin, catalogue/datasheet and product images.

Technical / specialized dossier

MSDS, UN38.3, battery specs, adapter specs, user manual, website/package claims, medical-device dossier if medical claims exist, and Vietnamese sub-label draft.

Dossier group	Documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO, B/L/AWB.	Declaration, value and quantity check.	Importer, shipper, forwarder.	Generic “beauty device”, missing model, wrong package quantity.	Match model, quantity and origin with catalogue.
Technical	Catalogue, datasheet, manual, product photos, original label.	HS classification and policy review.	Supplier/brand owner.	No massage function shown or contradictory medical claims.	Obtain complete dossier before booking.
Battery/adapter	MSDS, UN38.3, packing instruction, adapter specs.	Transport booking and safety explanation.	Supplier/carrier.	No battery test, unclear Wh, adapter wrongly merged.	Lock accessory list per model.
Origin	C/O, origin statement, third-party invoice if any.	Preference or origin proof.	Supplier/exporter.	Wrong form, wrong HS, description mismatch.	Check form, origin criterion, issue date and direct transport.
Label	Original label, Vietnamese sub-label draft, user instruction if required.	Domestic circulation.	Importer/responsible party.	Missing name, origin, specs or responsible entity.	Review under Decrees 43/2017 and 111/2021.

Operational rule: product name, quantity, model, serial, origin and technical specifications must match 100% across commercial documents, catalogue, label, specialized dossier and customs declaration.

CLEARANCE DECISION POINTS

Decision point	Question	Evidence	Consequence	Recommended action
HS Code	Is it a massage device, fitness device or medical device?	Catalogue, datasheet, manual, claims, classification guidance.	HS explanation, wrong tax or policy.	Lock HS before ETA.
Medical claim	Any therapy, disease-related pain relief, rehabilitation or medical wording?	Label, brochure, website, IFU.	Medical-device review.	Align declaration with actual claims and dossier.
Lithium battery	Is a rechargeable lithium battery included?	MSDS, UN38.3, Wh rating.	Booking refusal or delay.	Prepare battery documents before booking.
Bluetooth/Wi‑Fi	Any wireless transmitter or app control?	Module datasheet, frequency, manual.	Potential radio/ICT policy.	Review before purchase.
C/O	Do HS/model/description/quantity match invoice and B/L?	Draft C/O, invoice, B/L/AWB.	C/O rejection.	Pre-check C/O draft.
Condition	New, refurbished, warranty or sample?	Invoice, contract, photos, warranty record.	Wrong import type or policy.	Declare actual condition and purpose.

E2E OPERATIONAL PROCESS

Step 1 – Pre-ETA review

Lock HS, policy, MFN/normal duty/VAT, C/O, label, battery/adapter and licence triggers.

Step 2 – Lock documents

Finalize Invoice, Packing List, B/L/AWB, catalogue, datasheet, model/serial list if any.

Step 3 – Specialized dossiers

Prepare files for medical claims, lithium battery, wireless module, used/refurbished goods or separately imported adapter.

Step 4 – Customs declaration

Prepare responses for Green/Yellow/Red channel queries on value, HS, name, model, C/O, catalogue and policy.

Step 5 – Clearance & records

Clear goods, deliver inland, check sub-labels and keep shipment dossier for post-clearance review.

Step 6 – Domestic circulation control

Check label, user instructions, safety warnings, marketing claims and legal dossier before sale.

PRE-ETA RISK CHECKLIST

Risk	Impact	Prevention	Documents
Generic product name	Wrong HS/policy.	Use technical product name with model and function.	Invoice, Packing List, catalogue.
Excessive medical claim	Medical-device review and delay.	Review label, manual and website before import.	Label, IFU, brochure, website.
Missing battery documents	Booking rejection or delay.	Obtain MSDS, UN38.3, Wh rating and packing instruction.	MSDS, UN38.3, battery spec.
Wrong C/O	Preference/origin rejection.	Check form, criterion, direct transport, HS, quantity and issue date.	Draft C/O, invoice, B/L/AWB.
Model mismatch	Amendment, inspection or explanation.	Lock model list before declaration.	Model list, packing list, label.
Unreviewed accessories	Missing declaration line or policy gap.	Clarify whether accessory is packed with device or imported separately.	Packing detail, accessory photos, adapter specs.

FAQ

Question	Answer
Does a massage device require an import licence?	It depends on model and claims. Ordinary personal-care devices mainly require HS/tax/label/battery review; medical claims require medical-device review.
What HS is commonly used?	9019.10.10 is the key reference for electronic massage apparatus, subject to actual dossier review.
What duties apply?	For 9019.10.10, reference MFN is 0%, normal duty 5%, standard VAT 10%; reduced VAT only if eligible.
Is C/O useful if MFN is 0%?	Yes, for origin proof, compliance records and post-clearance control.
What is needed for lithium battery?	MSDS, UN38.3, Wh rating, packing instruction and carrier acceptance.
What if Bluetooth/Wi‑Fi exists?	Review the wireless module, frequency and manual to determine radio/ICT policy.
What if invoice model differs from catalogue?	Do not declare until clarified; request corrected documents or a matching model list.
Are samples/warranty goods handled the same as commercial goods?	Not automatically. Review import type, value, purpose, condition and policy by actual dossier.

IMPLEMENTATION SUPPORT FROM TGIMEX

This guide provides the policy map for massage devices. In real shipments, the importer should still review the actual catalogue, datasheet, model, origin, battery/adapter and claims.

Pre-ETA review

HS, specialized policy, C/O, duty, label, catalogue/datasheet/model and battery/adapter dossier.

Compliance control

Cross-check Invoice, Packing List, B/L/AWB, C/O, catalogue, label, user manual and technical documents.

International logistics

Coordinate agents, carriers/airlines, ETA, pre-alert and transport documents, especially for lithium-battery shipments.

Customs and post-clearance

Prepare declaration dossier, handle Green/Yellow/Red channels, support HS/value/origin/claim explanation and keep records.

For shipments involving specialized policy, C/O, lithium batteries, Bluetooth/Wi‑Fi or labeling requirements, the dossier should be reviewed before cargo arrival to better control time, cost and compliance risk.

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