Cosmetic samples are often treated as low-risk small consignments. In practice, if samples are sold, gifted, used on consumers or commercially circulated, the importer must review product notification, labeling, HS code, duty, VAT, origin documents and purpose-of-import evidence. This guide provides an E2E compliance map for cosmetic samples, testers, exhibition goods and research samples.

TERMS AND PROCEDURAL IMPORTANCE

Cosmetic samples

Small-quantity cosmetic products imported for market evaluation, testing, R&D, B2B offering or internal reference.

Tester

Products used at retail points, showrooms, exhibitions or sales channels. If consumers directly use them, circulation compliance must be reviewed.

Research / lab sample

Samples for R&D, laboratory testing, formula evaluation or stability testing, not for sale and not for market circulation.

Cosmetic product notification receipt number is the pre-market management data for cosmetic products in Vietnam. For samples/testers, the key question is not only whether the goods are sold, but whether they reach consumers, are gifted, are used for trials, or remain under controlled internal use.

DETAILED PRODUCT CLASSIFICATION AND IDENTIFICATION

This guide applies to cosmetic samples/testers/exhibition/research goods including skincare, makeup, haircare, bodycare, perfume, fragrance mist, cosmetic oral care, sample sets, mini sizes, sachets, vials and tester bottles. It does not automatically apply to drugs, oral beauty supplements, medical devices, disinfectants or products with claims beyond cosmetic scope.

Scope warning: sample goods for sale/giveaway, exhibition testers and internal research samples follow different compliance logic. Review artwork, original label, INCI, claims, quantity, usage plan and actual import purpose.

DETAILED PRODUCT CLASSIFICATION TABLE

Product group / scenario	Technical signs to check	Example model / function	Supporting documents	Possible policy	Documents to compare	Application note
Retail tester	Tester label, small size, direct consumer use	Lip tester, perfume tester, serum tester	Artwork, label, INCI, product photos, usage plan	Cosmetic notification if market use occurs	Notification, Vietnamese label, invoice, packing list	Not internal if consumers use it.
Free sample / promotion gift	Sachet, mini size, vial, gift sample	Serum sachet, mini cream, travel size lotion	Distribution plan, campaign, label	Usually reviewed as circulated cosmetic if given to consumers	Notification, label, import file	Not sold does not mean not circulated.
R&D / lab sample	Small quantity, internal use, no sale/gift	Lab sample, stability sample, formula sample	Purpose letter, test protocol, internal recipient	Internal sample route if controlled and justified	Technical file, MSDS if any, non-circulation statement	Control quantity, storage and disposal/re-export if needed.
Exhibition display goods	Display use, booth demo, re-export/recovery plan	Display set, booth tester bottle	Invitation, booth contract, temporary import list	Temporary import/re-export; sale or gift triggers cosmetic compliance	Customs file, goods list, post-event plan	Separate display goods from giveaway goods.
Alcohol/aerosol/battery sample	Alcohol %, aerosol, pressurized container, battery device	Body mist, perfume sample, spray, beauty device sample	MSDS, SDS, DG declaration, battery documents	Transport dangerous goods and device-related review	MSDS, packing instruction, catalogue, HS of accessories	Transport risk often arises before customs.
Sensitive-claim sample	Acne treatment, antibacterial, healing or medical-like claims	Acne cream sample, antibacterial wash sample	Artwork, claim list, web/social content	Boundary review: cosmetic, drug, disinfectant, medical device	INCI, claim evidence, notification/explanation	Sample status does not change legal nature.

HS CODE – DUTY – C/O

HS code for cosmetic samples/testers is not determined by the words “sample”, “tester” or “no commercial value”. It must be classified by the actual product nature: main use, composition, dosage/form, area of application, packaging, accessories, circulation status and import purpose. Even non-payment samples should have a reasonable customs value basis supported by the invoice and explanatory documents.

Control point: serum sachets, lip testers, perfume vials, shampoo samples, toothpaste samples, cleansing bars and alcohol/aerosol items may fall under different HS headings, duty rates, transport controls and dossier requirements. Avoid describing all items as generic “cosmetic samples”.

PROPOSED HS CODE – DUTY – C/O TABLE

Reference HS code	Suitable product group	Classification basis	Application condition	Ordinary import duty	MFN duty	VAT	C/O/FTA to review	Documents to compare
3304.99.xx	Skin-care samples: serum, essence, cream, lotion, mask, body lotion, sachet skincare	Skin-care preparations, not medicines and not disease-treatment products	Cosmetic claims only; INCI, artwork, original label and sample-use purpose are available	Check the current tariff schedule according to the final HS code	Working reference for many cosmetics: around 20%; verify at declaration time	10%	ACFTA, RCEP, AKFTA/VKFTA, AJCEP/VJEPA, EVFTA, CPTPP depending on origin	INCI, artwork, original/Vietnamese label if circulated, invoice, packing list, C/O draft, sample use plan
3304.10	Lipstick testers, lip tint, tinted lip balm and retail lip samples	Lip make-up preparations	Notification and labeling must be reviewed if customers directly use or receive samples	Check by final HS code	Common working reference around 20%	10%	FTA by actual country of origin	Shade list, SKU, artwork, INCI, quantity per shade, tester allocation plan
3304.20	Mascara, eyeliner, eyeshadow testers or eye make-up samples	Eye make-up preparations	Review safe-use instructions, shelf life and warnings if consumers will test the product	Check current tariff	Common working reference around 20%	10%	FTA by import route	INCI, shade list, label, artwork, use instructions, notification if circulated
3304.30	Nail polish and nail-care samples/testers	Manicure or pedicure preparations	Review flammable solvents and transport conditions where applicable	Check current tariff	Common working reference around 20%	10%	RCEP/ACFTA/CPTPP where applicable	MSDS/SDS if solvent-based, label, composition, packing instruction, C/O
3305.10 / 3305.90	Shampoo sachets, mini conditioner, hair mask, hair serum and hair-care samples	Hair preparations	No disease-treatment, pathological hair-loss or drug-like scalp treatment claims	Check current tariff	Common working reference around 20%	10%	RCEP/ACFTA/AKFTA/VKFTA where relevant	INCI, claims, label, capacity, sample quantity, notification if circulated
3303.00.xx	Perfume vials, fragrance testers, body mist samples, mini perfume	Perfumes and fragrance preparations	Review alcohol %, aerosol/pressurized container status and carrier DG rules	Check current tariff	Verify by final HS code; do not infer from free-sample status	10%	FTA by route and origin	MSDS/SDS, alcohol %, packing, DG declaration, invoice, C/O, display/distribution plan
3306.xx	Toothpaste, mouthwash and breath spray samples within cosmetic scope	Oral hygiene preparations	Claims must not turn into dental disease treatment; active ingredients and warnings should be reviewed	Check current tariff	Common working reference around 20%	10%	FTA by origin	Formula/INCI, label, claims, CFS/authorization if notified, C/O
3307.20 / 3307.30 / 3307.90	Deodorant, bath preparations, shaving cream and personal-care samples	Toilet, shaving or bath preparations within cosmetic scope	Not disinfectant, medical antiseptic or antibacterial product beyond cosmetic scope	Check current tariff	Verify by final HS code	10%	FTA if origin criteria are met	INCI, claims, label, MSDS if aerosol/alcohol, notification dossier if circulated
3401.xx	Soap, cleansing bar or solid cleansing samples where appropriate	Soap/cleansing-bar characteristics	Distinguish from facial cleanser gel/cream or other cosmetic forms under different headings	Check by final HS code	Check current tariff	10%	FTA by origin	Composition, function, product form, label and product photos

Duty and valuation note: MFN figures in the table are working references for common cosmetic groups and do not replace checking the official tariff schedule by final HS code. If the invoice states no commercial value, the importer should still prepare a reasonable declared value basis, Incoterms, valuation explanation and reason for non-payment.

SPECIAL PREFERENTIAL C/O/FTA ROUTES TO REVIEW

Origin route	FTA	C/O or origin proof	Preferential duty basis	Application conditions	Documents to check	Application note
ASEAN	ATIGA	Form D	Current ATIGA tariff	Origin rule and direct transport	C/O, invoice, packing, HS	Check sample/tester description.
China	ACFTA / RCEP	Form E or RCEP C/O	Current ACFTA/RCEP tariff	Origin rule and transport route	C/O, invoice, third-party invoice if any	Check SKU and origin consistency.
Korea	AKFTA / VKFTA / RCEP	Form AK, VK or RCEP C/O	Relevant tariff schedule	Select applicable agreement	C/O, invoice, transport docs	Do not select C/O form by habit only.
Japan	VJEPA / AJCEP / CPTPP / RCEP	VJ, AJ or CPTPP/RCEP origin proof	Relevant tariff schedule	Rule of origin and valid documents	Origin proof, HS, product description	Review each shade/SKU if multiple items.
EU / UK	EVFTA / UKVFTA	EUR.1 or origin statement if eligible	EVFTA/UKVFTA tariff schedule	Origin rule and valid proof	Statement, invoice, transport docs	Review transshipment and split consignment.

DOSSIER AND SUBMISSION METHOD

The dossier should be divided into commercial documents, technical/purpose documents and specialized documents if the goods are circulated. For free samples, valuation and import purpose should still be documented.

OPERATIONAL DOSSIER CHECKLIST

Dossier group	Required documents	Used for	Usually prepared by	Common errors	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB, contract/PO if any, free sample document	Customs declaration, value and tax	Shipper, buyer, logistics/docs	“No commercial value” without reasonable customs value	Lock product name, value, Incoterms and quantity before shipment.
Technical	INCI, artwork/label, catalogue, product photos, volume, SKU/shade list	HS and cosmetic/claim review	Brand, supplier, regulatory team	Missing INCI or inconsistent claims	Compare label, website, catalogue and invoice.
Import purpose	Purpose letter, sample usage plan, internal recipient list	Customs and specialized explanation	Importer, marketing, R&D, compliance	Large sample quantity without justification	Standardize purpose, location, quantity and usage timeline.
Notification/labeling	Notification receipt, Vietnamese label, CFS/authorization if circulated	Before market circulation	Regulatory, importer	Consumer tester without notification or label	Separate internal samples from consumer-facing goods.
Transport special control	MSDS/SDS, DG declaration, battery document if any	Booking and international transport	Supplier, forwarder, carrier	Alcohol perfume shipped without DG check	Review alcohol %, aerosol, battery and pressurized packaging.

LEGAL BASIS AND SPECIALIZED POLICY MATRIX

Legal documents to review

Document group	Document	Issuer	Effective timing	Role	Key point	Review note
Circular	Circular 06/2011/TT-BYT	Ministry of Health	Still applied as amended	Cosmetic notification, circulation, claims and responsibility	Notification, labeling, claim annexes	Review with latest amendments.
Amending circular	Circular 34/2025/TT-BYT	Ministry of Health	18 August 2025	Amends Circular 06/2011/TT-BYT	Forms and amended dossier obligations	Check when filing notification.
DAV SOP	QT.MP.01.03	Drug Administration of Vietnam	As publicly available	Receipt and processing of imported cosmetic notification dossiers	Notification processing flow	Used when samples become circulated products.
Commercial law	Commercial Law 2005	National Assembly	In force within scope	Exhibition, sale and gift at trade fairs	Fair and exhibition goods	Temporary import or sale/gift must be separated.
Foreign trade decree	Decree 69/2018/ND-CP	Government	Effective from signing date	Foreign trade management, temporary import/re-export	Prohibited/restricted goods and specialized control	Does not replace cosmetic regulations.

Specialized policy matrix

Goods scenario	Documents to compare	Possible policy	Authority / platform	Triggering condition
Consumer giveaway sample/tester	Circular 06/2011, Circular 34/2025, labeling rules	Cosmetic notification, Vietnamese label, retained product file	DAV/competent authority and customs	Sold, gifted, trialed or circulated in Vietnam.
Internal research sample	Cosmetic rules, customs rules, purpose evidence	Purpose explanation and non-circulation control	Customs and internal compliance	Reasonable quantity and controlled use.
Exhibition display only	Commercial Law, Decree 69/2018, customs rules	Temporary import/re-export or post-event handling	Customs and exhibition organizer if relevant	Invitation, goods list and recovery/re-export plan.
Sale/gift at exhibition	Commercial Law and cosmetic regulations	Market circulation compliance, tax and specialized review	Customs and cosmetic authority	Goods are sold or gifted to visitors in Vietnam.

PROCESSING TIME, FEES AND RISK COSTS

Step	Action	Recommended timing	Official/other fees	Cost risk	Control note
Before PO	Classify sample purpose, claim and DG status	Before purchase order	Not fixed	Change of import plan, testing/explanation cost	Separate internal and circulation routes.
Before ETD	Lock invoice, packing, HS, MSDS and label	Before shipment	As logistics cost	Document revision and booking delay	Important for alcohol/aerosol goods.
Before ETA	Prepare sample explanation and notification if circulated	5–10 days before ETA	Dossier/notification cost if any	Storage, DEM/DET, supplementary dossier	Do not wait until port arrival.
Clearance	Customs declaration, channel handling, value explanation	When documents are ready	Duties/VAT by HS and value	Valuation query, inspection, storage	Free sample value must be justified.
Post-clearance	Sample control and non-circulation management	Immediately after warehousing	Storage/disposal/re-export cost if any	Post-clearance and market surveillance risk	Keep batch-level records.

PRACTICAL E2E PROCESS

Step	Recommended timing	Items to lock	Risk control point	Output / records to keep
1	Before PO/booking	Classify the purpose: internal use, retail tester, consumer giveaway, exhibition, R&D or lab testing.	Do not mix “research” and “marketing giveaway” purposes in one lot without separate records.	Purpose letter, sample use plan, SKU/shade list and quantity by purpose.
2	Before supplier issues invoice	Lock cosmetic nature, INCI, artwork, claims, original label, capacity, packaging and goods status.	Treatment, antibacterial, medical-like, ingestible beauty or beauty-device claims must be routed for separate policy review.	INCI/artwork file, label photos, claim list, catalogue, MSDS/SDS if alcohol/aerosol is involved.
3	Before ETD	Confirm HS code, duty, customs value, Incoterms, C/O/FTA and goods description on documents.	Do not describe everything as “cosmetic sample”; do not treat “no commercial value” as zero customs value.	Draft invoice, packing list, C/O draft, valuation explanation and HS comparison sheet.
4	Before ETA	Review cosmetic notification, Vietnamese labeling, sample control, circulation or non-circulation obligations.	Retail testers, consumer giveaway samples and exhibition products used by consumers should not be handled as purely internal samples.	Notification receipt if required, Vietnamese label/artwork, allocation plan, recall/re-export plan if applicable.
5	Upon arrival	Open customs declaration, handle Green/Yellow/Red channel and prepare purpose/value explanations.	Common issues: vague description, large sample quantity, labels, claims, value, C/O and purpose documents.	Customs declaration, clearance dossier, explanations and inspection photos if any.
6	After clearance	Warehouse and segregate internal samples, testers, exhibition goods, R&D samples and goods eligible for circulation.	Goods imported as research samples must not be distributed to the market without proper dossier.	Warehouse receipt, sample allocation list, sample release form and handover record.
7	After use/event/campaign	Complete post-clearance obligations: archive, reconcile, destroy, recall or re-export where applicable.	Lack of usage trail, destruction/re-export record or evidence that samples did not circulate.	Lot archive, destruction/re-export minutes, sample use report and post-clearance file.

FAQ

1. Do cosmetic samples need notification?

Not an absolute yes or no. If the sample reaches consumers, notification and labeling should be reviewed. Internal/lab samples need purpose proof and non-circulation control.

2. Does a non-sale tester need Vietnamese labeling?

If consumers directly use it at a point of sale, labeling and safety information should be reviewed. Internal reference samples depend on purpose documentation and control.

3. Can exhibition cosmetics be sold or gifted?

Sale or gift may trigger customs, tax and cosmetic circulation obligations. Display-only goods should be documented separately.

4. Are free samples taxable?

They may still require customs value declaration and duties/VAT. “No commercial value” does not automatically mean zero customs value.

5. Can many testers be imported for a store network?

Quantity must be justified by store count, usage plan and replacement cycle. Large quantities increase commercial-goods risk.

6. Do perfume/body mist samples require DG review?

Review MSDS/SDS, alcohol percentage, aerosol or pressurized container status and carrier rules before booking.

7. How to handle acne or antibacterial samples?

Review the boundary between cosmetic, drug, disinfectant, medical device or other regulated product. Sample status does not legalize a sensitive claim.

8. What should be kept after clearance?

Customs file, purpose letter, product documents, notification if any, INCI, MSDS, allocation log and disposal/re-export records if applicable.

FINAL OUTPUTS AND POST-CLEARANCE OBLIGATIONS

Possible outputs

Cleared customs declaration, product notification receipt if circulated, Vietnamese label file, sample allocation records, exhibition/re-export documents, storage or disposal records.

Post-clearance obligations

Use samples according to declared purpose, do not sell or distribute unless compliant, retain batch-level records and prepare for post-clearance explanation.

TGIMEX IMPLEMENTATION SOLUTIONS

For cosmetic samples, testers, exhibition goods and R&D shipments, the control point is not shipment size. The dossier must prove the import purpose, circulation scope, notification status, labeling plan, customs value and transport conditions. Even a small shipment may create clearance or post-clearance risk if it cannot show who will use the samples, whether they reach consumers and how they will be controlled after import.

1. Define the import-purpose branch first

Separate internal evaluation samples, retail testers, consumer giveaways, exhibition goods, R&D formula samples, lab samples and samples for product notification. Each branch is mapped to the relevant obligations on cosmetic notification, Vietnamese labeling, record retention, re-export/recall or non-commercial-use control.

2. Review product nature and claims before filing

Check INCI, function, artwork, claim list, product form, alcohol/aerosol content and technical files to confirm whether the item remains a cosmetic or may cross into drug, food, disinfectant, medical device or dangerous-goods treatment during transport.

3. Lock HS, value, duty and C/O by SKU

Classify by product nature such as skincare, makeup, haircare, fragrance, oral care or soap/washing preparations. Standardize customs value for free samples, gifts, sample sets and testers; review C/O where preferential duty or origin evidence is required.

4. Standardize documents before ETA

Cross-check Invoice, Packing List, AWB/B/L, catalogue, original label, SKU/shade list, import-purpose letter, sample-use plan and product notification files where the goods may circulate or be used by consumers.

5. Control transport, warehouse and sample allocation

Review SDS/MSDS, alcohol, aerosol, battery/accessory issues where applicable; coordinate booking, transport declaration, trucking, warehousing, sample/exhibition/R&D segregation and allocation records so samples are not confused with commercial stock.

6. Retain post-clearance records for audit readiness

Organize shipment-level records: customs declaration, invoice, packing list, transport document, C/O if any, INCI, artwork, claim list, label, MSDS, import-purpose letter, allocation record and recall/re-export/disposal evidence if applicable. The key is proving that the goods were used according to the declared purpose.

Recommended documents to send before shipment: catalogue/artwork, INCI table, claim list, original label photos, quantity by SKU/shade, import purpose, sample-use plan, invoice/packing draft, C/O draft, SDS/MSDS, alcohol/aerosol/battery information if any, recipient list or exhibition/R&D plan. The earlier these items are locked before ETA, the lower the risk of document supplementation, storage cost, demurrage/detention and post-clearance explanation.

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