Health supplements should not be treated as ordinary prepackaged foods. Key risks usually arise from product classification, product declaration registration, testing reports, scientific substantiation, Vietnamese labeling, advertising claims and C/O eligibility. If the review starts only after ETA, shipments may incur storage, document supplementation requests or delayed market release.

Operational reference for importers, procurement, legal, compliance, operations and logistics documentation teams. The Vietnamese legal documents and the actual shipment dossier should prevail at the time of customs declaration.

1. TERMS AND WHY THIS PROCEDURE MATTERS

For health supplements, import clearance is only one part of the control chain. Businesses must manage food safety requirements, product declaration registration, state inspection of imported foods, Vietnamese labeling and advertising clearance where applicable.

Health supplementA product presented in capsules, tablets, powder, granules, liquid or other small dosage forms, used to supplement the daily diet and support body functions.

Functional foodA broad commercial term that may include supplemented foods, health supplements, medical nutrition and foods for special dietary uses. The applicable procedure depends on the actual dossier.

Product declaration registrationThe submission process to obtain a receipt for product declaration registration before the product is circulated under the applicable category.

CFS / Health CertificateA free sale certificate, export certificate or health certificate issued by the competent authority of the country of origin/export. Consular legalization may be required for imported products.

GMPGood Manufacturing Practice. For imported health supplements, a GMP certificate or equivalent manufacturing qualification may be required in the product declaration dossier.

ETA / DEM / DETETA means estimated time of arrival; DEM/DET refers to demurrage/detention. Delayed regulatory documents may create unplanned logistics costs.

The procedure affects pre-clearance, customs clearance, post-clearance and market circulation. The technical file, label, claims and commercial documents should be locked before ETA.

2. PRODUCT SCOPE AND DETAILED IDENTIFICATION

SCOPE. This guide covers imported health supplements/functional foods such as vitamins, minerals, collagen drinks, probiotics, gummies, capsules, tablets, powder supplements, herbal supplements and dosage-form health products. It should not be automatically applied to medicines, ingestible cosmetics, medical nutrition, infant products or ordinary beverages unless the product dossier supports the same regulatory nature.

Classification should be based on catalogue/specification, original label, formula, active ingredients, serving size, intended use, claims, country of origin and free-sale status. Samples, testing goods, promotional goods, project goods, EPE/FDI imports and goods with special storage conditions may require different handling.

DETAILED PRODUCT CLASSIFICATION TABLE

Product group / situation	Technical signs to check	Examples	Evidence	Potential policy	Documents to compare	Application notes
Vitamins/minerals in tablets, capsules or softgels	Dosage form, active content, serving size, user group	Vitamin C, D3, Zinc, Multivitamin	Specification, COA, original label	Product declaration registration; food import inspection; health supplement labeling	CFS/Health Certificate, test report, scientific evidence, GMP	Avoid disease-treatment claims; verify active levels and warnings.
Collagen drink / liquid supplement	Liquid dosage, collagen content, additives, sugar, flavor, beauty/health claim	Collagen beauty drink, peptide shot	Label, formula, shelf-life, storage condition	May be classified as health supplement or beverage; affects HS and declaration	Formula, claim, free-sale certificate, testing report	Do not classify by the word “drink” alone.
Probiotics	Strain, CFU, storage temperature, stability	Probiotic capsule, powder, synbiotic gummies	COA, stability data, storage instructions	Product declaration; cold-chain control if required	Batch COA, testing report, temperature records	Cold-chain design may be required to protect quality.
Herbal/natural extract products	Botanical source, extract ratio, active content, medicinal boundary	Ginseng, turmeric extract, herbal capsules	Formula, botanical name, extraction ratio	Boundary with medicines/traditional medicines; scientific substantiation	CFS/Health Cert, evidence of effect, ingredient list	Review restricted/prohibited ingredients and treatment-like claims.
Gummies / chewable supplements	Candy-like form but supplement claims; gelatin, color, sweetener	Vitamin gummies, kids gummies	Label, ingredients, claims, age group	Health supplement registration if claims support health functions	Testing report, CFS, scientific evidence	Do not treat as confectionery when labeling/claims show health supplement nature.
Samples for testing/registration	Small quantity, non-commercial purpose	Sample for testing or registration	Sample invoice, purpose letter	Purpose control; no market sale before compliance is completed	Sample documents, testing plan	Samples should not be sold before declaration and labeling are completed.

Generic product names such as “vitamin”, “collagen”, “food supplement” or “functional food” may lead to incorrect HS code, declaration route, Vietnamese label, advertising claim and C/O treatment.

3. HS CODE – DUTIES – C/O REVIEW

HS classification must be determined by composition, main function, dosage form, product presentation, intended use, original label and declaration dossier. For health supplements, Chapter 21, especially heading 2106.90, is commonly reviewed. Beverage-style products, medical nutrition, child products or micronutrient premixes may require a different HS analysis.

PROPOSED HS CODE – DUTY – C/O TABLE

Reference HS code	Suitable description	Classification basis	Condition of use	Ordinary import duty	MFN duty	VAT	C/O/FTA to review	Documents to compare
2106.90.72	Other health supplements	Food preparations in tablets, powder, liquid, gummies or dosage forms, not elsewhere specified	Use when label, claims and foreign documents show health supplement nature	Reference 22.5% if 150% of MFN applies; verify current tariff	15%	Generally 10% if not under 5%/non-taxable group	ACFTA, RCEP, VKFTA, EVFTA, AJCEP/VJEPA, ATIGA, CPTPP	Specification, label, declaration, CFS/Health Cert, test report, C/O
2106.90.71	Health supplements from ginseng	Ginseng-based supplement products	Only where the product nature matches “from ginseng”	Reference 22.5% if 150% of MFN applies	15%	Generally 10%	Form E, AK/VK, AJ/VJ, EVFTA, RCEP	Formula, COA, botanical name, extraction ratio, label, C/O
2106.90.73	Micronutrient mixtures for food fortification	Vitamin/mineral premixes or micronutrient blends used as ingredients	Use for ingredient premixes, not retail health supplement finished goods	Reference 22.5% if 150% of MFN applies	15%	Generally 10%	FTA based on final HS and origin rule	Formula, intended use, COA/SDS, catalogue, C/O
To be reviewed	Collagen drink / functional beverage	May be a health supplement or ordinary beverage depending on claims and presentation	Do not determine by trade name only	Verify by final HS	Verify by final HS	Generally 10% for processed foods	FTA based on final HS	Original label, formula, claims, packaging and intended declaration

SPECIAL PREFERENTIAL C/O/FTA TABLE BY IMPORT ROUTE

Origin route	FTA	C/O or origin document	Special preferential rate where supported	Conditions	Documents to compare	Notes
ASEAN	ATIGA	Form D	Many food lines may be 0%; verify final HS	Valid ATIGA origin and direct transport	C/O, invoice, B/L, packing list, HS, description	Check WO/RVC/CTH/CTSH and third-party invoicing.
China	ACFTA or RCEP	Form E or RCEP origin document	For 2106.90.72, ACFTA may be 0%; RCEP 2026 reference 7.5%	Valid C/O, correct origin rule and transport route	C/O, CIPL, B/L, transit documents	ACFTA may be more favorable than RCEP if all conditions are met.
Korea	AKFTA / VKFTA / RCEP	Form AK, VK or RCEP	VKFTA reference for 2106.90.72: 0%; RCEP 2026 reference 7.5%	Origin rule and transport requirements	C/O, invoice, packing list, B/L, catalogue	Match C/O description with label and declaration dossier.
Japan	VJEPA / AJCEP / CPTPP / RCEP	Form VJ, AJ, CPTPP origin document, RCEP	AJCEP/VJEPA for 2106.90.72 may be 0%; RCEP 2026 reference 7.5%	FTA-specific origin rules	Origin document, invoice, transport document	CPTPP origin documents follow a separate mechanism.
EU	EVFTA	EUR.1 or origin statement	For 2106.90.72, EVFTA 2026 reference 0%	EVFTA origin rule and valid document	EUR.1/statement, invoice, B/L, description	Verify exporter eligibility and statement wording.
Australia / New Zealand	AANZFTA or CPTPP	Form AANZ or CPTPP origin document	Verify by final HS and year	FTA origin and direct transport	Origin document, B/L, invoice	Check both tariff advantage and health certificate/CFS requirements.
India / Hong Kong	AIFTA / AHKFTA	Form AI or AHK	Verify by final HS	Origin rule compliance	C/O, transport document, invoice	Do not claim preference if HS or description is inconsistent.

C/O checklist: form, origin criterion, third-party invoice, direct transport, description, HS, quantity, weight, origin country, stamp/signature, issue date and validity period.

4. DOCUMENT SET AND SUBMISSION METHOD

The dossier should be organized into commercial documents, technical/regulatory documents and authority-submission documents. For imported health supplements, the product declaration registration dossier is submitted to the Vietnam Food Administration under the Ministry of Health via online public service, postal service or direct submission.

Commercial fileCommercial Invoice, Packing List, B/L or AWB, contract/PO, C/O, shipment and arrival documents.

Technical fileSpecification, formula, COA, original label, usage instructions, Vietnamese label draft, scientific evidence, testing report and storage conditions.

Declaration fileProduct declaration form, CFS/Export Certificate/Health Certificate, testing report within 12 months, scientific evidence and GMP/equivalent certificate where required.

OPERATIONAL DOCUMENT CHECKLIST

Document group	Required documents	Used for	Usually prepared by	Common error	Pre-ETA check
Commercial documents	Invoice, Packing List, B/L/AWB, contract/PO, arrival notice	Customs declaration, value, delivery	Supplier, importer, forwarder	Generic description; inconsistent quantity/weight/Incoterms	Cross-check item name, specification, lot, expiry, origin and packages.
HS – duty – C/O file	Catalogue, label, formula, C/O, direct transport documents	HS classification, tax and FTA claim	Importer, broker, supplier	Wrong C/O form, inconsistent description, suboptimal FTA	Finalize HS before asking supplier to issue C/O.
Product declaration file	Declaration form, CFS/Health Cert, testing report, scientific evidence, GMP	Product declaration registration	Importer/authorized holder, supplier, lab	Unlegalized CFS, expired testing report, unsupported claim	Complete regulatory checklist before shipment arrival.
Labeling file	Original label, Vietnamese supplementary label, directions, warnings	Market circulation and post-clearance review	Importer, brand owner, regulatory team	Missing “Health Supplement” group name; medicine-like claim	Compare label with accepted declaration dossier.
Logistics/storage file	Booking, cold-chain record if any, temperature record	International transport, warehouse and delivery	Forwarder, warehouse, importer	No temperature control for sensitive goods	Check storage condition on label and COA.

5. LEGAL BASIS AND SPECIALIZED POLICY MATRIX

LEGAL BASIS TABLE TO REVIEW

Document group	Legal document	Issuing authority	Effective timing	Role in procedure	Key provisions to review	Review note
Law	Food Safety Law 55/2010/QH12	National Assembly	Effective from 01 Jul 2011; partial effectiveness should be checked	General framework on food safety, import, labeling, traceability and recall	Imported foods, labeling, recall and responsibilities	Check current consolidated status.
Decree	Decree 15/2018/ND-CP	Government	Effective from 02 Feb 2018	Product declaration, food import inspection, labeling and advertising	Articles 6, 7, 8 and import inspection provisions	Core basis for health supplement product declaration registration.
Circular	Circular 43/2014/TT-BYT	Ministry of Health	Effective from 15 Jan 2015	Functional food management and health supplement labeling	Definitions and health supplement labeling requirements	Review amendments where relevant.
Circular	Circular 18/2019/TT-BYT	Ministry of Health	Effective from 17 Jul 2019	GMP guidance for health supplement production/business	GMP principles and maintenance requirements	Important for foreign manufacturer GMP evidence.
Labeling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	01 Jun 2017 and 15 Feb 2022	Goods labeling and amendments	Mandatory label contents and supplementary labels	Apply together with health supplement-specific labeling rules.
Sanctions	Decree 115/2018/ND-CP, amended by Decree 124/2021/ND-CP	Government	20 Oct 2018 and 01 Jan 2022	Administrative sanctions in food safety	Declaration, safety conditions, labeling, advertising, recall	Specific penalty amount should be checked by conduct.
Tariff	Decree 26/2023/ND-CP and FTA tariff decrees	Government	NĐ 26 effective from 15 Jul 2023; partially amended	MFN and special preferential tariffs	Chapter 21, heading 2106.90 and FTA schedules	Check tariff on customs declaration date.
VAT	VAT Law 48/2024/QH15	National Assembly	Effective from 01 Jul 2025	VAT basis	Standard VAT if not under 0%, 5% or non-taxable group	Health supplements generally require a 10% VAT review.

SPECIALIZED POLICY MATRIX BY SHIPMENT SITUATION

Shipment situation	Legal basis to compare	Potential policy	Authority/platform	Triggering condition
Commercially imported health supplement	Decree 15/2018; Circular 43/2014	Product declaration registration, food import inspection, health supplement labeling	Vietnam Food Administration; public service portal/post/direct	Product is presented as health supplement and circulated in Vietnam.
Unclear supplemented food vs health supplement	Circular 43/2014; Decree 15/2018	Review self-declaration vs product declaration registration	VFA or competent local authority depending on product	Added nutrients/probiotics/active substances but unclear dosage form or claim.
Collagen/beauty drink	Decree 15; tariff schedules; labeling rules	Review beverage vs health supplement classification	VFA if health supplement; customs for HS	Drink format with health/beauty claims or dosage presentation.
Advertising claims	Decree 15 and advertising rules	Advertising content confirmation before advertising	Competent advertising receiving authority	Online/offline advertisement, KOL, landing page or sales material with functional claims.
Special storage requirement	Food Safety Law; technical file; COA; label	Cold-chain/humidity control and storage records	Forwarder, warehouse, importer	Probiotic, enzyme, liquid or temperature-sensitive products.
Testing/registration samples	Decree 15; customs rules; import purpose dossier	Purpose control; no market sale before compliance completion	Customs, laboratory, VFA	Small quantity imported for testing/registration.

6. ORIGINAL LEGAL SOURCES

Businesses should verify the original Vietnamese legal texts and effective status before applying them to a shipment.

Food Safety Law 55/2010/QH12 Decree 15/2018/ND-CP Circular 43/2014/TT-BYT Circular 18/2019/TT-BYT Imported product declaration procedure – VFA Decree 26/2023/ND-CP tariff schedule

7. TIMELINE, FEES AND COST RISKS

TIMELINE, FEES AND COST-RISK TABLE

Step	Reference timing/fee	Preparation	Risk if delayed	Operational recommendation
Product and policy review	3–7 working days depending on dossier complexity	Label, formula, specification, claim, CFS/Health Cert, GMP, draft HS	Wrong declaration route or HS	Review before booking or ETD.
Imported health supplement product declaration	Reference 21 working days from complete dossier; VFA procedure currently states VND 1,500,000/product	One complete Vietnamese dossier	Supplementation request, delayed release	Do not leave declaration too close to ETA.
State inspection of imported foods	Depends on inspection method and dossier completeness	Accepted declaration, shipment documents, inspection documents	Customs/storage delay	Review pre-alert and arrival notice immediately.
Customs declaration	Depends on green/yellow/red channel	HS, value, C/O, commercial and regulatory documents	Channel escalation, explanation request	Prepare HS explanation and technical evidence in advance.
Post-clearance and market circulation	Depends on distribution plan and labeling/advertising status	Supplementary label, records, storage, advertising file	Labeling or advertising violation	Maintain lot-based records and claim control.

8. PRACTICAL END-TO-END PROCEDURE

Step 1 – Pre-ETA reviewConfirm product nature, HS, duties, C/O, declaration, import food inspection, label and storage conditions.

Step 2 – Lock documentsAlign Invoice, Packing List, B/L/AWB, C/O, original label, specification, formula, test report, CFS/Health Cert and GMP.

Step 3 – Submit regulatory fileSubmit product declaration registration where applicable and prepare import food inspection documents by shipment.

Step 4 – Customs declarationGreen channel is system release, yellow is document check, red is document and physical inspection. HS, value, C/O, label and declaration dossier are common review points.

Step 5 – Delivery and storageCoordinate carrier/airline, port/CFS, trucking and warehouse. Temperature/humidity control should follow label and COA.

Step 6 – Post-clearance obligationsApply supplementary labels, control advertising, retain lot records and prepare for post-clearance or food safety review.

9. FAQ

1. Can imported health supplements be self-declared?

In general, health supplements require product declaration registration before market circulation. The boundary with supplemented foods must be reviewed case by case.

2. Does the product declaration receipt replace shipment inspection?

No. The receipt is not always a substitute for state inspection of imported foods by shipment where applicable.

3. How recent must the testing report be?

The imported declaration dossier generally requires a food safety testing report issued within 12 months before dossier submission.

4. Is consular legalization required for CFS/Health Certificate?

For imported health supplement dossiers, CFS, Export Certificate or Health Certificate is a core document and consular legalization may be required.

5. Can collagen drink use HS 2106.90.72?

Possibly, but not automatically. Product presentation, claims, serving size and declaration dossier must be reviewed.

6. Can advertising claim disease treatment effects?

Advertising must be consistent with the accepted declaration and must not present the product as a medicine.

7. Can Form E or RCEP reduce duty?

Yes, if the origin document is valid and the product satisfies the applicable origin rules. The best FTA should be selected by route and evidence.

8. What should Vietnamese supplementary label include?

It should reflect the product group, ingredients, function, user group, instructions, warnings, responsible entity, origin and other mandatory contents, aligned with the declaration dossier.

9. Can registration samples be sold?

No. Samples for testing/registration should not be sold before declaration, labeling and circulation conditions are completed.

10. What records should be retained after clearance?

Declaration, commercial documents, C/O, product declaration dossier, testing reports, labels, warehouse records, storage documents and advertising clearance if any.

10. OUTPUTS AND POST-CLEARANCE OBLIGATIONS

OUTPUTS AND POST-CLEARANCE OBLIGATION TABLE

Output	Operational meaning	Next obligation	Risk if omitted
Receipt for product declaration registration	Legal basis for market circulation under the registered dossier	Maintain the registered name, origin, ingredients, functions, label and dossier	Changes in name/origin/composition may require re-registration.
Shipment food inspection file	Basis for customs/warehouse handling where applicable	Retain results and shipment records	Difficult to explain during post-audit.
Cleared customs declaration	Customs and tax completion evidence	Retain declaration, tax, C/O and HS analysis	Incorrect HS/C/O/value may trigger reassessment.
Vietnamese label and advertising clearance	Market circulation and claim-control basis	Apply labels and advertise only within accepted content	Label or claim violations are common risks.

GIẢI PHÁP TỪ TGIMEX

For imported health supplements / functional foods, shipment risks usually arise before the container arrives: inconsistent product names, insufficient HS rationale, mismatched C/O data, invalid CFS/Health Certificate, outdated testing report, incomplete product declaration dossier, or labels and advertising claims exceeding the approved scope. The operational priority is a pre-ETA review to lock documents, identify specialized procedures and reduce unplanned storage, demurrage, detention and dossier amendment costs.

Pre-shipment control

Review product name, ingredients, dosage form, intended function, packaging, original label, country of origin and storage conditions before booking is finalized.

Legal – customs – logistics alignment

Connect product declaration, food safety inspection, HS code, C/O, Invoice, Packing List, B/L/AWB and trucking/warehouse/port planning.

Post-clearance risk governance

Retain shipment records, control Vietnamese supplementary labels, advertising claims, traceability documents and evidence for possible post-clearance or market inspection.

OPERATIONAL SUPPORT SCOPE BY CHECKLIST

Control item	Review scope	Documents to cross-check	Expected output
HS code – duty – C/O review	Classify the goods by ingredients, function, product form, use instruction and packaging; separate possible headings such as 2106, 2202 or other headings where the actual dossier supports another classification.	Specification, ingredient list, label artwork, catalogue, COA, Invoice, Packing List and C/O draft if available.	Reference HS table, MFN duty, VAT, relevant C/O/FTA route and classification rationale for declaration.
Food safety policy and product declaration review	Determine whether the product is a health supplement, food supplement, supplemented drink, food for special medical purposes or another food category requiring a different procedure.	Product dossier, formula, function claims, scientific evidence, CFS/Health Certificate/Certificate of Exportation, testing report within 12 months, GMP where applicable.	Product declaration checklist, import food safety inspection conditions and missing points to be completed before arrival.
C/O/FTA preferential review	Check C/O form, origin criterion, third-party invoicing, direct consignment, description, HS, quantity, weight and issue date.	C/O draft/original, Invoice, Packing List, B/L/AWB, through transport documents, shipping marks and country of origin on labels.	Recommendation on whether to use the C/O for the shipment and a correction list before customs submission.
Original label, Vietnamese supplementary label and advertising claims	Review product name, ingredients, net quantity, manufacturing date, expiry date, use instruction, warnings, responsible trader information and the non-medicine warning where applicable.	Original label artwork, Vietnamese supplementary label, box/bottle mock-up, website/e-commerce content and advertising approval dossier if applicable.	Label correction checklist before market circulation, reducing risks of relabeling or excessive claims.
Specialized dossier preparation	Organize the authority submission dossier, verify translations, consular legalization where required and consistency between product declaration and import documents.	Application form, product declaration, CFS/Health Certificate, test report, GMP, scientific evidence, proposed label and authorization letter if any.	Structured specialized dossier, fewer amendment rounds and clearer status tracking.
Freight – port – warehouse coordination	Track vessel/flight schedule, pre-alert, arrival notice, D/O, trucking plan, storage conditions and inspection plan if the shipment is red-channel or subject to specialized inspection.	Booking, B/L/AWB, Arrival Notice, D/O, debit note, truck/warehouse plan, storage instruction and MSDS if special transport applies.	Aligned clearance, trucking and warehouse plan, reducing DEM/DET and storage risks.
Post-clearance record retention	Build a shipment-by-shipment dossier for traceability, post-clearance audit, market inspection, food safety inspection or regulatory explanation.	Customs declaration, tax documents, C/O, product declaration, testing report, labels, transport documents, cargo photos and handover records.	Shipment dossier folder, post-clearance obligation tracker and evidence set for regulatory requests.

Enterprises should work with a unit experienced across logistics, documents, customs and specialized regulatory policy to control the shipment from pre-ETA through post-clearance. The objective is not to process each document separately, but to build a consistent data chain across product identity, trade documents, product declaration, customs and warehouse/port operations.

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