Food additives require simultaneous control of HS code, import duty, VAT, C/O preference and food safety declaration, import food safety inspection, supplementary Vietnamese labelling and permitted-use limits. A generic description such as “food additive” is not sufficient; enterprises must check INS/CAS, composition, technological function, target food category, technical specifications and intended use before shipment arrival.

Policy groupF&B – Food additives

FocusHS, duties, C/O, food safety, label, pre-ETA dossier

AuthoritiesCustoms, food safety inspection authority, Ministry of Health/assigned local authority

This article provides an end-to-end operational map for importing food additives into Vietnam: product classification, HS and tax review, C/O control, food safety declaration/registration, import inspection, labelling and post-clearance record retention.

TERMS AND PROCEDURE SIGNIFICANCE

Food additive

A substance intentionally added to food for a technological purpose such as preservation, sweetening, colouring, acidity regulation, anti-caking, stabilization or fortification.

INS/E-number

An international identification code used to verify whether an additive is permitted and under which food category and usage limit.

Self-declaration

A product self-declaration dossier under Decree 15/2018/ND-CP, generally applicable to many ordinary food additives unless registration is required.

Product declaration registration

A registration procedure with official receipt, relevant to additives with new uses, additives not in the permitted list or additives not used for the permitted food category.

Import food safety inspection

State inspection of imported food safety, applicable at import stage unless the shipment falls under an exemption.

C/O

Certificate of Origin, used to consider preferential import duty under an FTA if form, origin criterion and direct transport are valid.

Legal note: Food additives should not be treated as ordinary food ingredients. The key checkpoints are permitted list, technological function, target food category, usage limit, declaration dossier, import inspection dossier and label consistency.

DETAILED PRODUCT CLASSIFICATION AND IDENTIFICATION

This article applies to food additives imported for trading, distribution, food manufacturing or supply to F&B factories in Vietnam. It does not automatically apply to medicines, pharmaceutical materials, industrial chemicals not intended for food, flavourings not declared as additives, processing aids or finished food products.

Enterprises must verify catalogue, specification, COA, MSDS, original label, INS/CAS, composition, function and actual import purpose at the time of application.

DETAILED PRODUCT CLASSIFICATION TABLE

Product group / situation	Technical signs to check	Examples	Supporting documents	Possible policy	Dossier to cross-check	Application note
Single-substance additive	INS/CAS, purity, food-grade standard, technological function	Citric acid, sodium benzoate, potassium sorbate	COA, MSDS, specification, original label	Self-declaration, import food safety inspection, supplementary label; chemical declaration may need review	Invoice, PL, B/L, COA, MSDS, C/O	Do not use only a trade name for customs declaration.
Blended additive	Composition ratio, primary function, whether there is a new use	Preservative blend, stabilizer mix	Composition sheet, formula breakdown	May require product declaration registration if it has a new use or wrong target use	Composition, specification, test report, label	Each component must be checked.
Fortificant premix	Vitamins/minerals, dosage, carrier, fortification purpose	Vitamin premix, mineral premix	COA, specification, quantified formula	HS 2106 may apply; declaration and target food category must be reviewed	COA, formula, label, C/O	Distinguish from health supplement ingredients.
Colourant/sweetener/preservative	INS, function, permitted food category, warning	Food colour, sweetener, preservative	Specification, test report, compliance statement	Food safety, label, possible chemical review for certain single substances	MSDS, COA, original label	Wrong function or target food category may trigger explanation requests.
Sample/R&D goods	Quantity, purpose, no market circulation	Lab trial sample	Purpose letter, sample invoice	May qualify for exemption/reduced procedure if conditions are met	Sample invoice, AWB, technical description	Do not use sample status for commercial goods.
EPE/FDI factory imports	Internal use, export production, no domestic sale	Factory additive	BOM, manufacturing records	Customs regime and food safety duties depend on final use	BOM, import dossier, production records	Domestic transfer may trigger additional obligations.

HS CODE – DUTIES – C/O

There is no single HS code for all food additives. Classification depends on chemical nature, technological function, composition, blending level, packing, intended use and technical dossier. The figures below are initial references and must be verified against the applicable tariff schedule, final HS code, origin and declaration date.

PROPOSED HS CODE – DUTIES – C/O TABLE

Reference HS	Suitable goods	Classification basis	Conditions	Ordinary duty	MFN duty	VAT	C/O/FTA to review	Dossier
2106.90.73	Micronutrient mixtures for food fortification	Food preparation/premix, not classified as a single chemical	Clear formula and intended food use	22.5%	15%	8% or 10% depending on the VAT policy at declaration time	ATIGA, ACFTA, VKFTA, AKFTA, VJEPA, AJCEP, CPTPP, EVFTA, UKVFTA, RCEP	Specification, COA, formula, label, C/O
2106.90.69	Other food preparations / additive premixes	Mixtures not more specifically classified	Composition and use must be clear	22.5%	15%	8% or 10%	Depending on route and C/O	COA, MSDS, composition
2918.14.00	Citric acid	Organic chemical single substance	Only if the product is citric acid, not a blend	Check current tariff	5% reference	10% basic; review VAT reduction if applicable	FTA by origin	CAS, MSDS, COA, purity, food-grade label
3203/3204	Natural or synthetic colouring matters	Based on colourant nature	Use only where dossier supports colourant classification	Check tariff	Check tariff	8% or 10%	FTA by route	INS, colour index, COA, MSDS
3505/3913	Thickeners/stabilizers from starch, cellulose, gums or natural polymers	Based on material nature	Where not a multi-component premix	Check tariff	Check tariff	8% or 10%	FTA by route	Specification, source material, COA

Warning: HS 2106 is only a reference for certain preparations/premixes. Single chemicals, colours, gums, enzymes or other additives may fall under Chapters 13, 29, 32, 35, 39 or others.

SPECIAL PREFERENTIAL C/O/FTA REVIEW BY IMPORT ROUTE

PREFERENTIAL C/O/FTA TABLE TO REVIEW BY IMPORT ROUTE

Origin/route	FTA	C/O or origin document	Preferential rate if supported	Conditions	Dossier to check	Note
ASEAN	ATIGA	Form D	May be 0% for many lines	Origin rule and direct transport	C/O, invoice, B/L, HS	Review RVC/CTH/CTSH under PSR.
China	ACFTA/RCEP	Form E or RCEP proof	May be 0% or scheduled rate	Valid form and origin	C/O, invoice, B/L	Form E is often scrutinized.
Korea	AKFTA/VKFTA/RCEP	Form AK/VK or RCEP proof	May be 0% or scheduled rate	Valid origin criterion	C/O, HS, description	Compare VKFTA and AKFTA.
Japan	VJEPA/AJCEP/CPTPP/RCEP	Form VJ/AJ or eligible origin proof	May be 0% or scheduled rate	Correct FTA and origin rule	C/O, transport docs, invoice	Do not assume CPTPP is always best.
EU/UK	EVFTA/UKVFTA	EUR.1 or origin statement if eligible	May be 0% or staged rate	Origin document and rule compliance	Origin statement/EUR.1, invoice, B/L	Check value threshold and exporter status.
Australia/New Zealand	AANZFTA/CPTPP/RCEP	Form AANZ or eligible proof	May be 0% or scheduled rate	PSR and direct transport	C/O, invoice, B/L	Review transshipment route.
India/Hong Kong	AIFTA/AHKFTA	Form AI/HK	Reduced rate may apply; some lines are not 0%	Valid form and criterion	C/O, description, HS	Do not assume all additives are duty-free.

C/O checklist: form, WO/RVC/CTH/CTSH, third-party invoice, direct transport, goods description, HS, quantity, weight, origin country, signature/stamp, issuance date and validity.

DOSSIER AND SUBMISSION METHOD

Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
C/O if duty preference is claimed.

Technical / specialized documents

COA, MSDS, specification, catalogue.
Composition sheet.
Original label and planned Vietnamese label.
Food safety test result.
Self-declaration or product declaration registration dossier if required.

OPERATIONAL DOSSIER CHECKLIST

Dossier group	Required documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, PL, B/L/AWB, Contract/PO	Customs declaration	Importer, shipper, forwarder	Inconsistent name, quantity, Incoterms	Lock final versions before ETA.
Technical	COA, MSDS, specification, INS/CAS	HS, declaration, food safety	Manufacturer/supplier	No formula or food-grade evidence	Request official signed or system-issued copies.
Declaration	Self-declaration, test result, product standard	Market circulation and import inspection	Importer/product owner	Wrong form or insufficient test indicators	Review under Decree 15 and product risk.
Import inspection	Inspection registration, declaration dossier, shipment docs	Import clearance/release	Importer/service provider	Late filing after ETA	Define exemption/inspection method before arrival.
Labelling	Original label, Vietnamese supplementary label	Post-clearance circulation	Importer/product owner	Wrong function or missing content	Compare with declaration, COA and invoice.

Control principle: product name, quantity, lot, manufacture date, expiry date, origin, composition, function and HS must match across commercial documents, technical documents, declaration dossier, label, import inspection dossier and customs declaration.

LEGAL BASIS AND SPECIALIZED POLICY MATRIX

Legal documents to review

LEGAL BASIS REVIEW TABLE

Group	Document	Issuing authority	Effective date	Role	Key points	Review note
Law	Food Safety Law 55/2010/QH12	National Assembly	01/07/2011	General food safety basis	Safety conditions, label, traceability	Check amendments if any.
New decree to review	Decree 46/2026/ND-CP	Government	Issued on 26 Jan 2026, effective from 26 Jan 2026	Details several provisions and implementation measures of the Food Safety Law	Review its specific provisions when determining declaration, import food-safety inspection and management obligations	Included as a 2026 update; do not rely solely on Decree 15/2018/ND-CP.
Food product declaration/registration	Resolution 66.13/2026/NQ-CP	Government	Issued on 27 Jan 2026, effective from 27 Jan 2026	Regulates declaration and registration of food products	Review applicable self-declaration or registration route, dossier and receiving authority for each additive group	Apply carefully based on the actual dossier because food additives differ by form, function and intended food category.
Decree	Decree 15/2018/ND-CP	Government	02/02/2018	Self-declaration, registration, import inspection	Articles 4, 5, 6, 13–15	Distinguish self-declared vs registered additives.
Circular	Circular 24/2019/TT-BYT	Ministry of Health	16/10/2019; partly expired	Food additive list, use and management	Permitted list, use principles	Read with amendments.
Amending circular	Circular 17/2023/TT-BYT	Ministry of Health	09/11/2023	Amends food safety regulations including Circular 24	New-use blended additive definition	Check consolidated text if available.
Traceability	Circular 25/2019/TT-BYT	Ministry of Health	16/10/2019	Traceability for food products	One step back – one step forward	Important for recall/post-audit.
Labelling	Decree 43/2017/ND-CP and 111/2021/ND-CP	Government	01/06/2017; 15/02/2022	Original and supplementary labels	Mandatory label content	Review Vietnamese label before circulation.
Tariff	Decree 26/2023/ND-CP, 73/2025/ND-CP, 108/2025/ND-CP	Government	By document	MFN duty and tariff schedule	Tariff by HS	Verify at declaration date.
Chemicals	Decree 113/2017/ND-CP, 82/2022/ND-CP	Government	22/12/2022 for Decree 82	Chemical import declaration if applicable	List and exemptions	Only if chemical scope is triggered.

Specialized policy matrix

SPECIALIZED POLICY MATRIX BY CARGO SCENARIO

Goods situation	Documents to review	Possible policy	Authority/portal	Trigger
Permitted additive, correct use	Decree 15; Circular 24; Circular 17	Self-declaration, import food safety inspection, label, post-audit	Assigned food safety authority; Customs	Commercial import for Vietnam market
Blended additive with new use	Decree 15; Circular 17	Product declaration registration	MoH/VFA or assigned authority	New technological function
Unlisted or wrong-use additive	Circular 24 and amendments	Do not treat as ordinary additive; regulatory review required	Food safety authority	Not in list or wrong food category/limit
Food-grade chemical single substance	Decree 113; Decree 82; MSDS/CAS	Chemical import declaration may apply	National Single Window	Substance listed as declarable chemical
Sample/R&D	Decree 15 and purpose dossier	Possible exemption/reduced procedure	Customs/food safety authority	Appropriate quantity, non-commercial purpose
EPE/FDI export production	Customs regime, Decree 15	Depending on final use and domestic transfer	Customs; food safety authority if domestic sale	Change of use or domestic circulation

VIEW / DOWNLOAD OFFICIAL DOCUMENTS

Enterprises should cross-check official sources before application.

Nghị định 15/2018/NĐ-CP
Thông tư 24/2019/TT-BYT
Thông tư 17/2023/TT-BYT
Nghị định 43/2017/NĐ-CP
Nghị định 111/2021/NĐ-CP
Nghị định 26/2023/NĐ-CP

PROCESSING TIME, FEES AND RISK COST

PROCESSING TIMELINE – FEES – RISK COST TABLE

Step	Recommended timing	Action	Fee/cost note	Delay risk
Classify additive	15–20 days before ETA	Confirm group, INS/CAS, function and target use	Testing/consulting cost if any	Wrong policy/dossier
Testing/declaration	10–15 days before ETA or earlier	Prepare test result, self-declaration or registration	Testing fee depends on indicators	Insufficient import/circulation dossier
HS – duty – C/O	7–10 days before ETA	Finalize HS, MFN, VAT, FTA preference	Duty and C/O cost if any	No preference, customs query
Import food safety inspection	Before/upon arrival	Register inspection and submit shipment docs	Inspection/testing cost if required	DEM/DET and storage cost
Post-clearance	After cargo release	Supplementary label, record retention, traceability	Label/warehouse/QA cost	No legal circulation or post-audit risk

PRACTICAL E2E WORKFLOW

Pre-ETA review

Confirm HS, additive group, function, INS/CAS, food-grade status, C/O, label and declaration/registration/inspection requirement.

Lock documents

Finalize Invoice, Packing List, B/L/AWB, COA, MSDS, specification, original label and composition sheet.

Define specialized procedure

Distinguish self-declared additive, registered additive, sample, export-production material and chemical-declaration case.

Submit dossiers if required

Prepare declaration, testing, import food safety inspection or chemical declaration dossier before ETA.

Customs declaration

Green channel: conditional system acceptance; Yellow: dossier check; Red: dossier plus physical inspection. Key questions: HS, value, C/O, COA/MSDS, declaration and label.

Release and post-clearance obligations

Move cargo to warehouse, apply supplementary label, retain records and prepare for post-clearance audit.

FAQ

1. Do imported food additives need self-declaration?

Generally yes if they fall within self-declaration scope under Decree 15/2018/ND-CP and are not subject to registration.

2. When is product declaration registration required?

For new-use blended additives, unlisted additives or additives used for wrong target food categories/limits.

3. Is import food safety inspection required?

It may be required unless an exemption applies. Review before ETA.

4. Is there one HS for all additives?

No. HS depends on chemical nature, composition and use.

5. Can C/O reduce duty?

Yes if form, origin criterion, HS, description and direct transport are valid.

6. What matters for supplementary labels?

Mandatory Vietnamese information must match declaration, COA and original label.

7. Can a food-grade chemical trigger chemical declaration?

Yes, if listed as declarable chemical under the chemical regulations.

8. What records should be retained?

Import documents, declarations, testing, labels, COA/MSDS, C/O, inspection results and lot traceability records.

OUTPUT RESULTS AND POST-CLEARANCE OBLIGATIONS

Common outputs

Self-declaration dossier.
Product declaration registration receipt if required.
Import food safety inspection result/notice.
Customs clearance/release.
Accepted C/O preference if eligible.

Post-clearance duties

Apply Vietnamese supplementary labels before circulation.
Retain lot-based records and traceability.
Do not change use/target food category from declared dossier.
Prepare for post-audit or market surveillance.

SOLUTIONS FROM TGIMEX

For food additives, the operational difficulty is not limited to customs clearance at the port. The key is to control the legal status of ingredients, intended use, dosage, COA/MSDS, labeling, C/O and commercial documents before cargo arrival. TGIMEX applies an E2E control approach, with a strong pre-ETA review to reduce storage exposure, repeated dossier supplementation and post-clearance circulation risks.

1. Pre-shipment HS – duty – C/O review

Review HS classification based on composition, function, product form, active substance ratio, packaging and import purpose.
Check ordinary import duty, MFN duty, VAT and possible special preferential duty under relevant FTAs.
Review C/O form, origin criterion, goods description, HS code, third-party invoice and direct consignment requirements.

2. Food safety policy and market circulation review

Distinguish permitted additives, compound additives, flavorings, processing aids and additive premixes.
Review whether self-declaration, product declaration registration, state food safety inspection or other specialized dossiers may apply.
Flag high-risk cases: additives outside the permitted list, incorrect target food category, excessive dosage or label claims beyond the permitted scope.

3. Supplier technical dossier standardization

Request and verify COA, MSDS/SDS, specification, ingredient list, INS/CAS where available, and manufacturer standards.
Cross-check product name, product code, batch/lot, shelf life, country of manufacture, manufacturer and exporter across documents.
Ensure consistency among catalogue/datasheet, original label, contract, invoice, packing list and transport documents.

4. Original label, Vietnamese sub-label and declaration consistency

Review original labels before shipment: additive name, ingredients, quantity, usage instruction, warnings, shelf life and manufacturer details.
Prepare Vietnamese supplementary label content before market circulation to avoid missing mandatory information or inaccurate translation.
Check that declaration dossier, label and COA are aligned to reduce post-clearance explanation risks.

5. Logistics – customs – warehouse/port coordination

Monitor booking, pre-alert, ETA, transport documents, delivery plan and DEM/DET free-time timeline.
Prepare customs declaration dossiers, handle Green/Yellow/Red channels and support explanation of HS, customs value, origin and specialized policy.
Coordinate with carrier/airline, warehouse, port, trucking team and consignee to reduce document waiting time and storage exposure.

6. Post-clearance obligation control

Track supplementation of inspection results, declaration or registration dossiers if required by the actual cargo situation.
Maintain shipment records: customs declaration, commercial documents, C/O, COA/MSDS, label, food safety dossier and transport documents.
Prepare traceability data for post-clearance audit, market surveillance or explanation requests from competent authorities.

The core of this approach is to lock shipment data before ETA: goods description, HS, origin, composition, intended use, label, COA/MSDS and transport documents must be consistent before customs declaration. This control layer helps enterprises reduce unplanned logistics costs and manage legal risk throughout the shipment lifecycle.

Review food additive dossiers Check the pre-ETA checklist

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