IMPORT PROCEDURE GUIDE FOR COSMETIC GIFT SETS AND PRODUCT COMBOS

A cosmetic gift set should not be treated as a simple commercial box. One set may simultaneously trigger cosmetic notification, HS classification, C/O, Vietnamese labeling, product claims, promotional items and post-clearance file-retention risks. This guide follows the specialized procedure logic: identify the goods first, then control dossier, policy, timeline and E2E clearance.

PRE-ETA RISKS TO CONTROL

Operational issue

A combo may contain serum, cream, cleanser, lipstick, mascara, mini perfume, samples, pouch/brush/sponge. These items may differ in HS, notification, claim, value and origin.

Operational consequence

If the documents only state “cosmetic gift set”, customs may request HS explanation, declaration amendment, notification supplement, C/O review, label correction, or the shipment may incur DEM/DET due to delayed dossier handling.

Professional reference for import/export enterprises; not a substitute for case-specific legal advice.

KEY TERMS AND WHY THE PROCEDURE MATTERS

Cosmetic gift set

A retail pack or promotional combo containing multiple cosmetic products, sometimes across several functions or HS headings.

Product notification

The cosmetic product notification number/receipt required before imported cosmetics are placed on the Vietnamese market.

PIF

Product Information File, a technical and safety dossier to be retained for post-market control.

POA

Power of Attorney authorizing the Vietnamese responsible party to place the cosmetic product on the market.

C/O

Certificate of Origin used to claim special preferential import duty under an FTA.

Supplementary label

Vietnamese label added to imported goods when the original label does not fully satisfy Vietnamese labeling requirements.

The procedure affects pre-clearance preparation, customs clearance, market circulation and post-clearance audit. A set must be controlled as a legal and customs structure, not merely as a marketing package.

PRODUCT CLASSIFICATION AND DETAILED IDENTIFICATION

Review must be made against catalogue, datasheet, SKU list, formula, original label, declared function, set composition and actual import purpose. A multi-item set does not automatically mean one HS code or one notification receipt.

DETAILED PRODUCT CLASSIFICATION TABLE

PROPOSED HS CODE – DUTY – C/O REVIEW

HS classification should be based on the product’s function, composition, retail packaging, item value and set structure. Where products in the set belong to different HS subheadings, the importer should prepare a multi-line declaration option to match quantity, value, notification and C/O data.

The HS and tax figures below are operational references for common product groups. Final declaration must follow the tariff schedule and FTA tariff in force at the time of import. The ordinary duty is commonly calculated at 150% of the MFN rate unless a specific ordinary rate applies.

Reference HS code	Relevant product group	Classification basis	Condition	Ordinary duty	MFN duty	VAT	C/O/FTA to review	Dossier to check
3304.99.90	Other skincare products such as serum, cream, lotion, mask	Beauty or skincare preparation, not a drug	No therapeutic claim	30% if 150% of MFN applies	20%	10%	ATIGA, ACFTA, RCEP, VKFTA/AKFTA, EVFTA, UKVFTA, CPTPP	Notification, formula, label, catalogue, C/O
3304.10.00	Lipstick, lip tint, lip gloss	Lip makeup preparation	Shade/color list and quantity separated	30%	20%	10%	Review applicable FTA	Shade list, label, C/O, invoice
3304.20.00	Mascara, eyeliner, eyeshadow	Eye makeup preparation	Not accessory/brush	30%	20%	10%	Review C/O form	Catalogue, color chart, packing list
3304.91.00	Beauty powders	Powder form for makeup/beauty	Powder, not cream/liquid skincare	30%	20%	10%	Review by final HS	Formula, product form, label
3305.10.90 / 3305.90.00	Shampoo, conditioner, hair mask, hair serum	Hair preparation	No medical hair-loss/disease claim	30% if MFN is 20%	Commonly 20%	10%	FTA by origin	Label, claim, formula, notification
3303.00.00	Perfume and fragrance mist	Fragrance preparation	Review alcohol content and transport conditions	Check current tariff	Commonly 18%–20% depending line	10%	FTA and DG review	SDS/MSDS, label, C/O
3401.30.00	Facial cleanser, cleansing gel, rinse-off skin wash products	Organic surface-active products for washing the skin, liquid/cream, retail packed	Use when the main nature is skin washing; review 3401.30.00 vs 3304.99.30 based on dossier	Check current tariff by final HS	Check current tariff by final HS	10%	Review FTA by final HS and origin	Formula, use, label, rinse-off nature, notification
9603.29.00 / 9603.30.00	Makeup brush, applicator, cosmetic brush in makeup set	Accessory/tool, not cosmetic; classified by material and use	Do not apply cosmetic HS if accessory has separate value and description	Check current tariff	Check current tariff	10%	Review C/O separately if accessory has different origin	Accessory catalogue, material, value, packing breakdown
3923.xx / 4202.xx / 4819.xx	Box, pouch, retail bag or gift packaging included in set	Packaging/accessory may be part of the set or a separate item depending on value/sale format	Review when bag/box has commercial value or is sold independently	Check by final packaging/accessory HS	Check by final packaging/accessory HS	10%	Review C/O by material and origin	Packing spec, material declaration, invoice value
3307.20.00 / 3307.90.90	Deodorant, body mist, bath preparations or shaving products in the set	Other perfumery/toilet preparations	Review aerosol/alcohol and transport conditions if applicable	Check current tariff by final HS	Often around 18%–20%, subject to current tariff	10%	Review FTA and DG transport requirements	SDS/MSDS, packing specification, label, C/O

SPECIAL PREFERENTIAL C/O/FTA ROUTES TO REVIEW

Origin route	FTA	C/O or origin document	Preferential duty basis	Conditions	Dossier	Note
ASEAN	ATIGA	Form D	May be 0% for many lines if eligible	ASEAN origin, direct transport, valid rule of origin	C/O, invoice, B/L	Descriptions and HS must match.
China	ACFTA/RCEP	Form E or RCEP proof	Check FTA tariff by HS/year	Valid origin rule and third-party invoicing where applicable	C/O, invoice, B/L	Form E is sensitive to description mismatch.
Korea	AKFTA/VKFTA/RCEP	Form AK/VK or RCEP proof	Review each agreement	CTH/RVC or relevant origin rule	C/O, invoice, BOM if needed	Compare VKFTA and AKFTA.
Japan	VJEPA/AJCEP/CPTPP/RCEP	Relevant proof	Check by agreement	Valid origin and transport documents	C/O, invoice, transport docs	No automatic rate for all Japan-origin goods.
EU/UK	EVFTA/UKVFTA	EUR.1 or statement of origin where eligible	Check relevant tariff schedule	Correct origin certification and direct transport	Origin statement/EUR.1, invoice, B/L	Check exporter eligibility.
Australia/New Zealand	AANZFTA / CPTPP / RCEP	Form AANZ, CPTPP origin certification or RCEP origin document	Review by final HS and year schedule	Origin criteria, direct consignment and third-party invoicing if any	C/O/origin document, B/L, invoice, packing list	Cosmetic sets should align description and quantity with item breakdown.
India	AIFTA	Form AI	Review by final HS and year schedule	Origin criterion and direct transport must be satisfied	Form AI, invoice, B/L, HS description	Check HS description carefully where set contains accessories.
Hong Kong (China)	AHKFTA	Form AHK / origin declaration where applicable	Review by final HS and year schedule	Must meet origin rules and direct consignment conditions	Origin document, invoice, transport document	Useful when sourcing through Hong Kong trading hubs; verify actual origin.

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

DOSSIER AND SUBMISSION METHOD

For imported cosmetics intended for market circulation, the importer must control both the cosmetic notification dossier and the customs dossier. The public administrative procedure states that the notification dossier for imported cosmetics is submitted to the Drug Administration of Vietnam through the National Single Window.

Commercial documents

Commercial Invoice.
Packing List with item-level breakdown.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order if any.
C/O if claiming preferential duty.

Cosmetic/specialized documents

Valid cosmetic product notification receipt/number.
POA from manufacturer or product owner.
Original label, proposed Vietnamese supplementary label, formula/ingredient data.
PIF and safety documents retained for post-market control.
SDS/MSDS for alcohol, aerosol or DG-risk products.

COSMETIC NOTIFICATION CONTROL PRINCIPLES FOR GIFT SETS

Circular 06/2011/TT-BYT sets the baseline that each cosmetic product is notified in one notification form, while products under the same product owner, packed under a common name and sold as a set may be notified in one form. Therefore, do not mechanically assume “one set equals one notification” or “each item must always have a separate notification” without reviewing product name, owner, manufacturer, formula, sales format and actual dossier.

Notification scenario	Conditions to review	Evidence required	Risk if wrong	Operational recommendation
Same owner and common set name	Items are packed and sold as a set; owner/manufacturer information aligns	Notification receipt, POA, set name, item list, outer label	Incomplete notification scope and post-market explanation risk	Confirm eligibility before using one receipt for the whole set.
Mixed skincare/makeup/haircare/fragrance	Different product functions may mean different notification and HS logic	Receipt by item or clear evidence supporting combined notification	Missing receipt for an item inside the set	Create a mapping table: item – receipt – HS – label – value.
Free sample/tester in a commercial combo	Is it placed on market, used for promotion or given to consumers?	Sales program, invoice, packing list, sample/tester label	Mistaking “free of charge” as no notification/labeling duty	Review as market-circulation goods when linked to sales promotion.
Set composition changed after notification	Added/removed item, new set name, volume/shade/manufacturer change	Existing receipt, change dossier, new artwork	Old receipt no longer matches actual imported goods	Check Appendix 05-MP before importing the revised set.

Dossier group	Required document	Used for	Usual preparer	Common error	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB	Customs declaration and valuation	Seller/buyer/forwarder	Generic gift-set description without item quantity	Match SKU list, weight and value by line.
Cosmetic notification	Notification, POA, product data	Market circulation condition	Importer/compliance team	Product name, form or responsible party mismatch	Match notification with label and invoice.
Labeling	Original label, Vietnamese label	Market circulation	Importer/brand owner	Missing responsible party or quantity per item	Check outer box and inner items.
HS–tax–C/O	C/O, catalogue, descriptions	Duty assessment and FTA treatment	Docs/customs broker	C/O description or HS mismatch	Review HS by item before arrival.
Transport	SDS/MSDS, packing declaration	Booking and carrier acceptance	Seller/forwarder	Undeclared DG risk	Request SDS before booking.

OUTER BOX AND INNER ITEM LABEL CONTROL

Label level	Mandatory content to check	Source documents	Common error	Pre-ETA control
Outer gift set box	Set name, responsible organization, origin, quantity/item list, warnings if any	Outer artwork, packing specification, notification receipt	Outer box shows set name but lacks item/volume details	Request six-side box photos before shipment.
Primary packaging of each item	Product name, volume/weight, batch, expiry, ingredients, instructions/warnings	Original label of each SKU, batch/COA info if any	Individual item may be circulated with incomplete label	Check every SKU, not outer box only.
Vietnamese supplementary label	Correct translation of original label and required Vietnamese contents	Original label, translation, notification dossier, importer details	Wrong claim, ingredient, origin or responsible party	Finalize label before ETA to avoid rushed relabeling.
Claims/marketing on set	Must stay within cosmetic scope; avoid treatment claims without basis	Artwork, e-commerce content, notification, ASEAN claim guidance	Acne treatment, antibacterial or skin repair claims may trigger review	Review claims before label approval and online listing.

LEGAL BASIS AND SPECIALIZED POLICY MATRIX

LEGAL DOCUMENTS TO REVIEW

Document group	Document	Issuing authority	Effective/application date	Role	Key points	Review note
Cosmetic regulation	Circular 06/2011/TT-BYT as amended	Ministry of Health	Effective from 01 Apr 2011, partly amended	Cosmetic management and product notification	Notification dossier and receipt validity	Check consolidated/latest version.
Amending circular	Circular 34/2025/TT-BYT	Ministry of Health	Effective 18 Aug 2025	Amends Circular 06/2011	Electronic dossier/submission updates	Apply according to submission date.
Administrative procedure	Procedure 1.002088	Drug Administration of Vietnam	Publicly available on National Public Service Portal	Receipt of imported cosmetic notification	Submission via National Single Window	Check procedure status before filing.
Labeling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Decree 43 effective 01 Jun 2017; Decree 111 effective 15 Feb 2022	Goods labeling and supplementary labels	Mandatory contents and importer responsibility	Check both outer set box and each inner product.
Tariff	Decree 26/2023/ND-CP	Government	Effective 15 Jul 2023	MFN import tariff and goods classification basis	Chapter 33 and relevant chapters	Check current tariff and FTA tariff.
Customs	Circular 38/2015/TT-BTC, Circular 39/2018/TT-BTC and amendments	Ministry of Finance	Check current effect by provision	Customs dossier and procedures	Import dossier, channels, valuation, duty	Check applicable customs rules at declaration date.

POLICY MATRIX BY SHIPMENT SCENARIO

Shipment scenario	Documents to review	Possible policy	Authority/portal	Trigger condition
Finished cosmetic gift set for sale	Circular 06/2011, Circular 34/2025, procedure 1.002088	Cosmetic notification before market placement	DAV via National Single Window	Imported cosmetics placed on Vietnamese market.
Set with multiple product groups	Notification, HS and labeling rules	Review by item or by set where justified	DAV and customs	Multiple products, functions or HS lines.
Medical/antibacterial treatment claims	Cosmetic claim guidance and other sector laws	Risk of falling outside cosmetic scope	DAV or relevant authority	Therapeutic or disinfectant-like claims.
Perfume/body mist/aerosol set	Cosmetic regulation and DG transport rules	Cosmetic notification plus DG transport review	Carrier/forwarder/customs	Alcohol, aerosol or SDS-classified DG.
Research or testing samples	Procedure 1.002238 and Circular 06/2011	Confirmation for research/testing import order	DAV	Not placed on market; limited purpose and quantity.

VIEW / DOWNLOAD ORIGINAL LEGAL SOURCES

Circular 06/2011/TT-BYT Circular 34/2025/TT-BYT Imported cosmetic notification procedure Decree 43/2017/ND-CP Decree 111/2021/ND-CP Decree 26/2023/ND-CP

PROCESSING TIME, FEES AND RISK COSTS

Step	Recommended timing	Indicative time/fee	Risk cost if delayed	Control note
SKU and set breakdown	Before purchase/booking	Internal preparation	Wrong HS, notification or label	Lock item list and value split.
Product notification review	Before ETA, preferably before shipment	Public procedure refers to 01–03 working days where dossier and fee are valid	Market circulation restriction, supplementation	Actual time depends on dossier completeness.
Supplementary label review	Before release to market	Internal preparation	Relabeling, delayed sale, post-market risk	Check outer and inner labels.
C/O review	Before ETA/declaration	Depends on exporting country issuance time	Loss of preferential duty	Check form, origin rule and direct transport.
Customs clearance	Upon arrival with complete documents	Depends on Green/Yellow/Red channel	DEM/DET, storage and amendment costs	Prepare explanation dossier in advance.

PRACTICAL E2E PROCESS

Step 1 – Pre-ETA review

Lock SKU list, set composition, product function, HS, notification status, label and C/O route before cargo arrival.

Step 2 – Notification dossier lock

Match product notification, POA, label, formula, product name, manufacturer and responsible party.

Step 3 – Commercial document lock

Finalize invoice, packing list, B/L or AWB, item value, quantity, origin and Incoterms.

Step 4 – HS, duty and C/O review

Classify by item or by set where justified; check C/O form, origin criterion and direct transport.

Step 5 – Customs declaration

Green channel generally relies on system processing; Yellow channel checks documents; Red channel checks documents and physical goods.

Step 6 – Release and post-clearance file

Collect cargo, control Vietnamese labels, retain PIF and prepare post-clearance explanations if required.

FAQ

1. Can the whole gift set be declared under one HS code?

Not automatically. If items differ in nature, function and HS, a multi-line declaration should be reviewed. Classification by set requires a clear legal basis.

2. Does one set need one or several notification receipts?

It depends on packaging, common name, product group, formula and current filing rules. Do not assume one gift set always equals one notification.

3. Do free gifts in a combo require review?

Yes, if the gift is a cosmetic placed on the market or used in commercial promotion, notification and labeling obligations may still apply.

4. How are brushes, pouches or sponges handled?

Accessories should be reviewed separately for HS, value and labeling. Non-cosmetic accessories should not be forced into cosmetic HS without basis.

5. What is the risk with perfume or body mist?

Alcohol, aerosol and SDS information must be checked. Some products may trigger dangerous goods acceptance requirements for air or sea transport.

6. Can C/O be issued for the whole set?

C/O data must match description, HS, quantity, value and origin. Sets with multiple HS lines require careful C/O presentation.

7. Are testers exempt from notification?

If sold, gifted or used commercially in Vietnam, they may still require review. Research/testing samples have a separate procedure.

8. Where should the Vietnamese label appear?

Both the outer box and inner products should be checked, especially when the consumer may use the inner product separately.

9. Are acne-treatment or antibacterial claims risky?

Yes. Claims close to therapeutic or disinfectant language may push the product outside the cosmetic scope.

10. What should be retained after clearance?

Declaration, invoice, packing list, B/L/AWB, C/O, notification, POA, labels, PIF and transport documents should be retained by shipment.

OUTPUTS AND POST-CLEARANCE OBLIGATIONS

Expected outputs

Valid cosmetic product notification receipt/number.
Cleared customs declaration.
Import dossier, C/O and HS explanation file.
Vietnamese supplementary label ready for market circulation.

Post-clearance obligations

Retain notification dossier and PIF by product/set.
Control labels, claims, ingredients and quantity.
Manage samples/testers/gifts placed on market.
Prepare documents for post-clearance or post-market inspection.

GIẢI PHÁP TỪ TGIMEX

Pre-ETA set review

Check SKU list, combo composition, item quantity, capacity, value, origin, function and import purpose before cargo arrival.

Notification & label control

Reconcile notification receipts, POA, original labels, Vietnamese labels, claims, expiry, responsible party and PIF retention duties.

HS – duty – C/O review

Separate skincare, makeup, fragrance, haircare and accessories; review MFN, VAT, FTA, C/O form, origin criteria, description and direct transport.

Logistics – customs coordination

Monitor pre-alert, ETA, transport documents, customs channeling, trucking/warehouse/port plan and explanation dossier when requested.

Discuss shipment dossier More cosmetic procedures

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