Imported goods bearing foreign-language original labels but lacking mandatory Vietnamese contents may face dossier clarification, delayed market circulation, relabeling costs or unplanned warehousing expenses. This operational reference helps importers review the E2E flow: HS code, duty, C/O, original label, specialized dossier and post-clearance obligations.

SUPPLEMENTARY LABELING FOR IMPORTED GOODS: RISK SCOPE AND REVIEW MAP

Problem: many shipments are reviewed for labeling only after arrival or right before market distribution.

Agitate: incorrect Vietnamese labels can delay handover, trigger DEM/DET, require reprinting/relabeling by SKU/model, or create market-inspection exposure.

Solution: the importer should review four layers before ETA: product nature, HS/duty/C/O, specialized policy and Vietnamese supplementary label contents.

Scope: this guide applies to imported goods requiring Vietnamese supplementary labels before market circulation. It should not be automatically applied to transit, transshipment, temporary import for re-export, non-commercial samples, used goods or special-purpose imports without checking specialized rules.

TERMS AND OPERATIONAL IMPORTANCE

Original label

The label first affixed by the manufacturer or responsible party, usually in the exporting country’s language.

Supplementary label

A Vietnamese label showing mandatory contents absent or insufficient on the original label for circulation in Vietnam.

Mandatory contents

Minimum label contents such as product name, responsible entity, origin and product-specific required information.

CNHQ/CBHQ

Conformity certification/declaration proving product conformity with applicable technical regulations.

Quality inspection

State quality inspection for Group-2 goods or other specialized regulated goods.

C/O

Certificate of Origin used for preferential tariff review and cross-checking label origin information.

Supplementary labeling mainly affects the stage after customs clearance and before market circulation, but the data needed to label correctly must be collected before ETA.

PRODUCT CLASSIFICATION AND IDENTIFICATION FOR SUPPLEMENTARY LABELING

Do not determine labeling duty by trade name alone. Review catalogue, datasheet, model, principal function, configuration, retail packaging, original-label language, accessories, goods condition and import purpose.

Mandatory warning: generic goods names may lead to wrong HS code, wrong specialized policy, wrong QCVN/TCVN application, wrong permit treatment and incorrect market label. The actual catalogue, datasheet, model, function and import purpose must be checked.

DETAILED PRODUCT CLASSIFICATION TABLE

Product group / shipment situation	Technical signs to check	Example model/function	Supporting documents	Possible policy trigger	Documents to compare	Application note
General consumer goods imported for retail distribution	Foreign-language original label; retail packaging; manufacturer, origin, composition or use instructions	Household items, small electrical appliances, personal care goods, packaged consumer goods	Original-label photos, packing list, invoice, catalogue, packaging photos	Vietnamese supplementary labeling before market circulation	Original label, label translation, importer information, SKU/model code	Do not conclude from the trade name only; review actual packaging and distribution purpose.
Food, beverages, additives and health supplements	Ingredients, quantity, manufacturing/expiry date, storage instruction, warning, product declaration number if applicable	Snacks, noodles, sauces, seasonings, non-alcoholic beverages, food additives, supplements	Specification, COA, original label, declaration dossier, ingredient translation	Supplementary label plus food safety/product declaration if triggered	Food safety dossier, declaration, original label, supplementary label, C/O	Supplementary label must match the product declaration; do not mistranslate function claims.
Cosmetics and personal care goods	Product name, ingredients, function, usage, warning, cosmetics notification number if imported as cosmetics	Serum, cream, cleanser, shampoo, fragrance	Cosmetics notification, INCI ingredient list, original label, catalogue	Supplementary label plus cosmetics notification before circulation	Notification receipt, original label, supplementary label, invoice, packing list	Do not state claims beyond the notification dossier or turn the product into a drug/medical claim.
Electrical, electronic and ICT equipment	Model, electrical rating, Wi-Fi/Bluetooth/4G/5G, adapter, battery, safety warning, conformity mark if applicable	Router, access point, scanner, network device, household appliance	Datasheet, user manual, test report, label photos, model list	Supplementary label plus quality inspection/conformity/energy label if triggered	Catalogue, applicable QCVN, quality inspection registration, conformity documents	Wireless, encryption, battery or adapter modules must be reviewed by actual model.
Machinery, equipment and project cargo	Model, serial number, power rating, year of manufacture, new/used condition, safety instructions	Production machinery, line equipment, lab equipment	Catalogue, datasheet, serial list, nameplate photos, project contract	Supplementary label plus used-machinery policy or quality inspection if triggered	Technical documents, year of manufacture, quality certificate, customs declaration	Used/refurbished goods must not be treated automatically as new goods.

HS CODE – DUTY – C/O FOR GOODS REQUIRING SUPPLEMENTARY LABELS

“Goods requiring supplementary labels” is not a separate HS code. HS classification must be based on principal function, structure, operating principle, material, condition, accessories and technical dossier.

PROPOSED HS CODE – DUTY – C/O TABLE

Reference HS code	Suitable description/product group	Classification basis	Application condition	Ordinary import duty	MFN preferential import duty	VAT	C/O/FTA to review	Documents to compare
Chapter 84	Machinery, mechanical appliances and production-line equipment	Classify by principal function, operating principle and accessories	Applicable to mechanical machinery/equipment; catalogue and technical structure required	Under current tariff schedule, commonly 150% of MFN where an MFN rate exists	By final HS code under the preferential import tariff	Usually 10% or 8% if eligible for current VAT reduction; verify by item	Review ATIGA, ACFTA, RCEP, VKFTA, VJEPA, EVFTA…	Catalogue, datasheet, invoice, packing list, C/O, nameplate photos
Chapter 85	Electrical, electronic, ICT equipment, adapters, power supplies and electrical parts	Classify by electrical/electronic function, connectivity, power supply and data modules	Applicable to electrical, telecom and IT goods	Under current tariff schedule, commonly 150% of MFN where an MFN rate exists	By final HS code; ICT lines have different MFN rates	Usually 10%; some goods may or may not be reduced to 8% depending on VAT policy	Review Form D, E, RCEP, AK/VK, AJ/VJ, EUR.1…	Datasheet, user manual, test report, C/O, original label, model list
Chapter 90	Measuring, testing, optical, medical or laboratory instruments	Classify by measuring/testing/diagnostic function and intended sector	Applicable to instruments and lab equipment; may trigger specialized control	Under current tariff schedule, commonly 150% of MFN where an MFN rate exists	By final HS code and specialized policy	Usually 10% or as specifically provided for the equipment group	Review by origin and final HS; C/O does not replace specialized dossier	Catalogue, technical specifications, intended use, permit if any
Chapter 33 / 34	Cosmetics, toiletry preparations and personal care products	Classify by composition, function, product form and use method	Applicable to cosmetics/personal care goods; notification dossier must be checked	Under current tariff schedule, commonly 150% of MFN where an MFN rate exists	By final HS code; cosmetics have rates by subheading	Usually 10%, verify at declaration time	Review FTA by import route; origin must match label and notification	Notification receipt, formula/ingredient list, original label, C/O
Chapter 19 / 20 / 21 / 22	Processed foods, beverages, sauces, seasonings, health supplements	Classify by ingredients, processing, packaging and intended use	Applicable to F&B; may trigger food safety and product declaration	Under current tariff schedule, commonly 150% of MFN where an MFN rate exists	By final HS code; F&B has many different rates	Usually 10% or 8% if eligible for VAT reduction, excluding exempted groups	Review C/O by origin and origin criteria WO/RVC/CTH/CTSH	Specification, COA, Health Certificate if any, C/O, original label, declaration dossier

SPECIAL PREFERENTIAL C/O/FTA TABLE BY IMPORT ROUTE

Route/origin	FTA/agreement	C/O form or origin proof	Special preferential rate if supported	Application condition	Documents to compare	Application note
ASEAN	ATIGA	Form D C/O	May be 0% for many tariff lines if the commitment schedule and origin rules are met; verify final HS	Valid C/O, direct transport and eligible origin criteria	C/O, invoice, packing list, B/L, transit documents if any	Description, HS, quantity and origin must match label and declaration.
China	ACFTA or RCEP	Form E C/O or RCEP proof of origin	Preferential rate may apply under ACFTA/RCEP; not automatically 0%	Correct origin criteria and direct transport	C/O, third-party invoice if any, B/L, catalogue	Form E is often checked for goods description, third-party invoice and country of origin.
Korea	AKFTA/VKFTA/RCEP	Form AK, VK or RCEP proof	Review by HS; VKFTA may provide deeper preference than AKFTA for some lines	Correct form and WO/RVC/CTH/CTSH criteria	C/O, invoice, packing list, transport documents	Do not apply one preferential rate to every model/SKU.
Japan	VJEPA/AJCEP/CPTPP/RCEP	Form VJ, AJ, CPTPP statement or RCEP proof	Review by agreement and product-specific rules	Product qualifies under origin criteria and proof format	C/O/proof of origin, invoice, B/L	Check CPTPP self-certification conditions when applicable.
EU / UK	EVFTA / UKVFTA	EUR.1 or proof of origin under relevant rules	Preferential rate may apply if origin rules and proof are valid	Check REX/self-certification, EUR.1 and direct transport	Proof of origin, invoice, B/L, transit evidence	Description and HS must link clearly to the imported shipment.
Australia–New Zealand / India / Hong Kong	AANZFTA/CPTPP, AIFTA, AHKFTA	Form AANZ, CPTPP statement, AI, AHK	Review commitment schedule by final HS	Correct form, origin criteria and direct transport	C/O, invoice, packing list, transport document	No preference if the C/O form or origin criteria are incorrect.

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

DOSSIER SET AND SUBMISSION METHOD

The dossier should be divided into three layers: commercial documents, technical/specialized documents and authority-submission documents if a permit, declaration, inspection or conformity procedure is triggered.

Commercial documents: Commercial Invoice, Packing List, Bill of Lading/Air Waybill, contract/PO if any, C/O if preferential tariff is claimed.
Technical/specialized documents: catalogue, datasheet, user manual, original-label photos, label translation, model/serial list, test report and declaration/conformity dossiers if any.
Authority-submission documents: permit, quality inspection registration, conformity declaration, product declaration/self-declaration, food safety/quarantine/cosmetics/ICT dossiers depending on product group.

OPERATIONAL DOSSIER CHECKLIST

Dossier group	Required documents	Used for which step	Usually prepared by	Common error	Pre-ETA check method
Commercial dossier	Commercial Invoice, Packing List, Sales Contract/Purchase Order if any	Customs declaration, value, goods description and quantity check	Shipper/Importer/Procurement	Generic goods name, mismatch in SKU/model or origin	Match against original label, catalogue, PO and draft declaration.
Transport documents	Bill of Lading/Air Waybill, Arrival Notice, Pre-alert	Delivery order, declaration and ETA tracking	Forwarder/agent/carrier/airline	Wrong consignee, package/weight mismatch, missing pre-alert	Compare B/L/AWB with Packing List and warehouse/port data.
Origin documents	C/O or origin self-certification if preferential tariff is claimed	Special preferential tariff and origin explanation	Shipper/Exporter/Importer	Wrong form, criteria, HS, goods description or direct-transport evidence	Check form, reference number, issuance date and WO/RVC/CTH/CTSH criteria.
Labeling dossier	Original-label photos, supplementary-label artwork, Vietnamese translation, importer and origin information	Post-clearance circulation control	Importer/Compliance/Legal	Mistranslated function, missing warning, covered original label, wrong origin	Compare every label line with original label, product declaration and catalogue.
Technical/specialized dossier	Catalogue, datasheet, user manual, test report, declaration/conformity/food-safety dossier if any	Specialized policy and mandatory label content review	Supplier/Compliance/Ops	Missing model list, specifications, test report or product declaration	Finalize model/serial, specifications and import purpose before ETA.
Authority-submission dossier if triggered	Permit, quality inspection registration, conformity declaration, product self-declaration/registration	Submission via public service portal, national single window or specialized system if applicable	Importer/service provider/Compliance	Late submission after ETA leading to storage delay or circulation blockage	Identify procedures during booking/PO stage, not after cargo arrival.

Control rule: goods name, quantity, model, serial, origin and technical specifications must match across commercial documents, catalogue, label, specialized dossier and customs declaration.

LEGAL BASIS – SPECIALIZED POLICY MATRIX

The legal review comes after dossier collection so that the importer has enough data to apply the correct rules. Do not state “no permit required” without reviewing model, function, specifications and import purpose.

Legal basis table

Document group	Document name/number	Issuing authority	Effective date/application timing if identified	Role in procedure	Key article/clause/appendix if any	Review note
Law	Law on Product and Goods Quality 05/2007/QH12	National Assembly	Effective from 01 July 2008; review amendments if any	General basis for quality management and responsibility tracing	Provisions on responsible entities for product/goods quality	Relevant where labeling overlaps with quality control.
Law	Commercial Law 36/2005/QH11	National Assembly	Effective from 01 January 2006	General framework for goods trading, import and circulation	Review by transaction/contract	Does not replace specialized labeling rules.
Decree	Decree 43/2017/ND-CP on goods labels	Government	Issued 14 Apr 2017, effective 01 Jun 2017	Core regulation on content, presentation and state management of goods labels	Articles 1, 7, 10 and Appendix I should be checked	Amended and supplemented by Decree 111/2021/ND-CP.
Decree	Decree 111/2021/ND-CP amending Decree 43/2017/ND-CP	Government	Issued 09 Dec 2021, effective 15 Feb 2022	Amends mandatory label contents, labeling responsibility and import-label rules	Amendments to Articles 7, 9, 10 and original/supplementary label rules	Key source for imported goods requiring Vietnamese supplementary labels.
Sanction decree	Decree 119/2017/ND-CP and Decree 126/2021/ND-CP	Government	Decree 119 effective 15 Dec 2017; Decree 126 effective 01 Jan 2022	Administrative sanction framework for standards, measurement and product/goods quality	Review label-related violation groups by case	Do not state a fixed penalty without identifying act, goods value and circumstances.
Tariff	Decree 26/2023/ND-CP and tariff-amending decrees if any	Government	Decree 26 issued 31 May 2023; review latest amendments	Basis for MFN import duty by final HS code	Export/import preferential tariff schedules	Supplementary labeling does not have a separate duty rate.
VAT	Resolution 204/2025/QH15 and Decree 174/2025/ND-CP	National Assembly/Government	Applicable from 01 Jul 2025 to 31 Dec 2026	Basis for reviewing possible VAT reduction from 10% to 8%	Scope of application and excluded groups	Do not assume all imported goods are VAT-reduced.
Specialized regulations	Food safety, cosmetics, ICT, energy, quarantine, medical device or chemical regulations if triggered	Specialized ministries	By product group and applicable date	Specific label content, declaration, permit or inspection duties	Appendix/list by product group	Further review required by actual goods/dossier.

Specialized policy matrix by goods situation

Goods situation	Legal basis/documents to compare	Possible policy	Authority/portal if identified	Policy trigger condition
Imported goods with foreign-language original label for Vietnam market	Decree 43/2017/ND-CP; Decree 111/2021/ND-CP	Vietnamese supplementary label before circulation; keep original label intact	Customs/Market surveillance/specialized authority when inspected	Original label lacks mandatory Vietnamese contents.
F&B, additives, health supplements	Food safety regulations; Decree 43/2017 and 111/2021	Supplementary label plus product declaration/food-safety procedures if triggered	Food safety authority, Customs, public service/single-window portal if applicable	Goods for human consumption with ingredients, claims, dates or warnings.
Imported cosmetics	ASEAN/Vietnam cosmetics notification rules; Decree 43 and 111	Supplementary label plus cosmetics notification; label must match notification	Health authority/relevant public service portal	Goods intended for cleaning, perfuming, protecting or caring for skin/hair/body.
ICT/electronic equipment with Wi-Fi/Bluetooth/4G/5G	MIC regulations on Group-2 ICT/QCVN; Decree 43 and 111	Supplementary label plus quality inspection/conformity/ICT mark if triggered	VNTA/specialized system/Customs	Wireless module, frequency band, transmission power or listed model.
Household/energy-using appliances	Energy labeling regulations; Decree 43 and 111	Supplementary label plus energy label/energy performance if listed	Ministry of Industry and Trade/public service portal/Customs	Goods listed for energy labeling or performance control.
Goods with battery, adapter, charger or safety warning	Lithium-battery transport rules, electrical safety, QCVN/TCVN if applicable	Supplementary label must show mandatory warning/instruction if required	Carrier/specialized authority/Customs	Battery, charger, power supply or manufacturer safety warning exists.
Used/refurbished/warranty/sample goods	Decree 111/2021 and import policy by product group	Do not treat as new goods; review import conditions and labeling separately	Customs/specialized authority by goods group	Goods condition is not standard new commercial goods.

View / download original legal documents

Importers should verify original texts on the Government Portal, the legal document database or the issuing authority’s website before applying them to a shipment.

Decree 43/2017/ND-CP Decree 111/2021/ND-CP Resolution 204/2025/QH15

PROCESSING TIME, FEES AND RISK COSTS

Processing step	Recommended timing	Official fee/cost	Potential logistics cost	Control note
Review original and supplementary label content	Around 5–10 working days before ETA or upon draft documents	No separate state fee if self-reviewed and self-printed	Translation, design, printing and labeling labor costs	Finalize before cargo arrival to avoid rushed labeling errors.
Review HS, duty, C/O and specialized policy	From PO/booking stage and before ETA	No separate fee; testing/certification fees may arise if triggered	DEM/DET and storage if specialized dossier is late	Do not wait until arrival to determine declaration/conformity duties.
Apply supplementary labels at warehouse	After customs clearance and before market circulation	No state fee for labeling work itself	Warehouse, labor, reprinting and SKU counting costs	Keep original label visible and do not cover mandatory content.
Correct label if non-compliance is detected	During dossier review, market inspection or post-clearance audit	Penalty must be reviewed under current sanction rules by specific act	Storage, recall, relabeling and delayed handover	Label error may trigger product declaration or specialized dossier issues.

PRACTICAL E2E PROCESS

Step 1 · Pre-ETA review

Finalize HS, specialized policy, original label, Vietnamese mandatory contents, C/O, duty, technical dossier and label requirement before circulation.

Step 2 · Lock documents and technical files

Lock invoice, packing list, B/L/AWB, catalogue, datasheet, label photos and model/serial list; ensure names, models, origin and specifications match.

Step 3 · Identify specialized procedures

Check whether supplementary labeling alone is sufficient or product declaration, quality inspection, conformity, permit, energy label, quarantine or food safety is triggered.

Step 4 · Open customs declaration

Green channel: system-based clearance; Yellow: document check; Red: document and physical inspection. Label, catalogue, HS and C/O are key review points.

Step 5 · Move cargo and label

After clearance, move cargo to warehouse and apply Vietnamese supplementary labels by SKU/model/batch before sale or project handover.

Step 6 · Complete and archive

Archive original label, supplementary label, declaration/conformity dossier, C/O, customs declaration, tax documents and post-labeling photos.

FAQ – PRACTICAL QUESTIONS

1. Must imported goods be supplementary-labeled before customs clearance?

There is no absolute answer for every shipment. Original imported labels must meet minimum customs-stage information, while Vietnamese supplementary labels are generally completed before market circulation. Specialized goods may have label dossier review during clearance.

2. May the supplementary label cover the original label?

No. The original label must be kept visible and mandatory information must not be covered.

3. What must a supplementary label show?

At minimum, mandatory Vietnamese contents such as product name, responsible entity, origin and product-specific information; some products also require ingredients, quantity, dates, warnings or specifications.

4. What if the original label lacks full manufacturer address?

Review Decree 111/2021/ND-CP and supporting documents. Missing foreign manufacturer/responsible-party details may need to be shown in accompanying documents.

5. Do goods imported for a factory/EPE require supplementary labels?

Review import purpose and actual use. Non-retail production inputs may be treated differently, but customs documents, original labels, traceability and specialized policy still need control.

6. Does a supplementary label replace product declaration or conformity?

No. Labeling is separate from product declaration, conformity certification/declaration, import permit or quality inspection.

7. Is C/O related to supplementary labeling?

C/O does not replace labels, but origin on C/O, original label, supplementary label, invoice and customs declaration must be consistent.

8. Can incorrect labels be sanctioned?

Yes, depending on the act and goods group. Penalties must be checked against current sanction decrees and actual circumstances.

9. Can QR code or electronic documents replace label content?

Some details may be supplemented electronically under specialized rules, but core mandatory label contents must still be reviewed under Decree 43/2017 and Decree 111/2021.

OUTPUTS AND POST-CLEARANCE / POST-CIRCULATION OBLIGATIONS

Output/result	Operational meaning	Next obligation	Documents to archive
Approved supplementary-label artwork	Basis for printing, labeling and SKU/model/batch control	Apply to correct goods, batch and position; do not cover original label	Artwork, translation, original-label photos and post-labeling photos
Cleared customs declaration	Goods may be moved to warehouse under customs rules	Do not circulate before supplementary labeling and specialized duties are completed	Declaration, tax documents, B/L/AWB, invoice and packing list
Specialized result if any	Basis for circulation or handover of regulated goods	Apply conformity mark, supplement test results and archive batch dossier	Permit, declaration, certificate, test report, acceptance notice
Post-clearance archive	Evidence for post-clearance or market surveillance explanation	Archive by batch, SKU, model, import date and distribution channel	C/O, catalogue, original label, supplementary label, emails and transport documents

GIẢI PHÁP TỪ TGIMEX

For goods requiring supplementary labels, the core value is not label printing itself, but simultaneous control of logistics documents, customs dossier, HS code, origin, specialized policy and Vietnamese label content before ETA.

HS and policy review

Review HS, duty, C/O, specialized product group and possible declaration, conformity, quality inspection or permit requirements.

Original and supplementary label review

Check original label, Vietnamese translation, origin, warning, specifications, claims and importer data before printing/labeling.

Pre-ETA document lock

Verify invoice, packing list, B/L/AWB, C/O, catalogue, datasheet, model/serial list and specialized dossier before arrival.

Port–warehouse–transport coordination

Monitor ETA, pre-alert, delivery plan, warehouse labeling, SKU counting and circulation readiness.

Post-clearance archive

Archive original label, supplementary label, post-labeling photos, declaration, C/O and compliance documents.

Risk-cost control

Reduce storage, relabeling, dossier supplementation, handover delay and circulation non-compliance risks.

Importers should work with a partner experienced in logistics, documents, customs and specialized policy. The focus is pre-ETA review to reduce storage, dossier supplementation and unplanned costs.

ELECTRICAL – ELECTRONICS – IT EQUIPMENT

F&B

MACHINERY

HOUSEHOLD GOODS

COSMETICS – PERSONAL CARE