For imported cosmetics such as perfume, fragrance mist, aerosol products, nail polish, nail remover, alcohol/solvent-based products or kits containing batteries, the risk is not limited to cosmetic product notification. If SDS/MSDS, flash point, UN number, transport labels and booking conditions are not reviewed before ETA, the cargo may be rejected by the airline/carrier, rerouted, charged DG surcharges, stored longer or delayed at customs. This article provides an E2E review map covering HS code, duties, C/O, cosmetic notification, DG classification, transport documents, customs clearance and post-clearance records.

OVERVIEW OF IMPORT PROCEDURE FOR COSMETICS WITH DG TRANSPORT RISK

This article applies to imported cosmetics and personal-care goods that may be treated as dangerous goods during international or domestic transport, especially products containing alcohol, flammable solvents, pressurised aerosol containers, lithium batteries or oxidising substances. It does not apply automatically to all cosmetics; each SKU should be reviewed against its formula, SDS/MSDS, package size, import purpose and transport lane.

Policy scope

Cosmetics may require cosmetic notification, labelling review, HS/C/O review and DG transport compliance when triggers exist.

Pre-ETA checkpoints

SDS/MSDS, flash point, UN number, packing group, limited quantity, transport label, carrier acceptance and notification file.

No automatic conclusion

Perfume, aerosol, nail products, samples, testers, gift sets with batteries and fragrance materials must not be grouped into one conclusion.

Note: Review against the catalogue, formula/ingredient list, SDS/MSDS, SKU, packaging size and actual import purpose before application.

TERMS AND WHY THE PROCEDURE MATTERS

Term	Meaning in this article	Why it matters
DG – Dangerous Goods	Goods with flammable, corrosive, toxic, compressed-gas or similar hazards in transport.	Determines packing, marking, labelling, declaration, booking and carrier acceptance.
SDS/MSDS	Safety data sheet showing hazardous ingredients, flash point, UN number, packing group and handling guidance.	Primary evidence to determine whether the product is DG.
Flash point	The lowest temperature at which vapour from a liquid can ignite under test conditions.	Alcohol/solvent cosmetics with low flash point may be strictly controlled.
UN number	A UN identification code for dangerous substances/articles in transport.	If a UN number applies, DG booking and declaration may be required.
Cosmetic notification	The receipt number for imported cosmetics before market circulation.	It does not replace DG transport requirements.
Limited Quantity	A DG transport mechanism for small quantities when packaging/labelling conditions are met.	It must not be applied without SDS and carrier-rule review.

DETAILED PRODUCT CLASSIFICATION AND IDENTIFICATION

Avoid generic descriptions such as “cosmetics”, “beauty product” or “personal care set”. The product should be separated by ingredients, package form, SDS/MSDS, function, volume and import purpose.

Product group / situation	Technical signs to check	Examples	Evidence	Possible policy	Documents to review	Application note
Perfume, EDP/EDT, fragrance mist	Ethanol content, flash point, bottle volume, retail pack, SDS.	Perfume spray 30–100ml.	Formula, SDS, COA, label artwork.	Cosmetic notification, possible Class 3 DG, supplementary label.	Invoice, PL, SDS, notification, C/O.	Do not classify only by trade name.
Aerosol cosmetics	Pressurised container, propellant, pressure, possible UN1950.	Deodorant spray, hair spray, shaving foam.	SDS, pressure spec, label artwork.	DG transport, cosmetic notification, labelling.	SDS, packing instruction, product photos.	Carrier may require DG declaration.
Nail products	Acetone/ethyl acetate, flash point, product type.	Nail polish, nail remover.	SDS, ingredient list, COA.	Possible Class 3 DG, cosmetic notification.	SDS, COA, notification, C/O.	Wrong description may affect HS and transport.
Alcohol/solvent skincare or makeup	Alcohol ratio, liquid/spray form, retail size.	Setting spray, alcohol-based toner.	Formula, SDS, label artwork.	Cosmetic notification; DG if low flash point.	Formula, SDS, label, notification.	DG depends on SDS, not product name.
Cosmetic gift set with batteries/devices	Lithium battery, device, aerosol, charger/adapter.	Beauty device + serum set.	Battery spec, UN38.3, manual.	Battery DG, possible ICT, cosmetic notification.	UN38.3, SDS, catalogue, invoice.	Separate cosmetic and accessory policy layers.
Samples/testers/returns	Purpose, quantity, sample label, product condition.	Tester perfume, sample kit.	Purpose letter, SDS, label.	Customs regime, DG, cosmetic notification/exception review.	Purpose evidence, SDS, invoice.	Samples do not automatically mean no dossier.

HS CODE – DUTIES – C/O

The HS–duty–C/O section below is a practical review framework only. Do not finalize duties before the 8-digit HS code, current tariff and valid C/O conditions are confirmed.

PROPOSED HS CODE – DUTIES – C/O TABLE

Reference HS	Description/group	Classification basis	Conditions	Ordinary duty	MFN duty	VAT	C/O/FTA to review	Documents to review
3303.00.00	Perfumes and toilet waters.	Fragrance function on body; often alcohol based.	Finished retail products; review if fragrance raw material.	Usually 150% of MFN if no preference applies; check current tariff.	Reference may be around 18%; confirm on declaration date.	Commonly 10%.	ATIGA, ACFTA/RCEP, VKFTA/RCEP, CPTPP, EVFTA, UKVFTA.	Invoice, PL, SDS, ingredient list, label, C/O, cosmetic notification.
3304.30.00	Manicure/pedicure preparations.	Nail product function; may contain flammable solvents.	Nail polish/gel/remover if description fits.	Usually 150% of MFN if no preference.	Reference may be around 20%; check current tariff.	Commonly 10%.	Review by origin lane.	SDS, formula, label, catalogue, C/O, notification.
3304.99.xx	Other skincare/makeup preparations.	Function, form, ingredients and packing.	Not for pharmaceuticals or disinfectants.	Usually 150% of MFN if no preference.	Often 10%–20% depending on final 8-digit code.	Commonly 10%.	Review EVFTA, CPTPP, RCEP, ACFTA, VKFTA.	Formula, SDS if relevant, label, C/O, notification.
3305.30 / 3305.90	Hair preparations, hair spray, styling products.	Hair-use function; aerosol/alcohol may trigger DG.	Separate shampoo, conditioner, hair spray and mousse.	Usually 150% of MFN if no preference.	Reference may be around 20%; verify final code.	Commonly 10%.	Review C/O by origin.	SDS, aerosol data, label, C/O, notification.
3307.xx	Deodorants, shaving foam, body/fragrance preparations.	Use as deodorant/fragrance/personal-care product.	Distinguish from household chemicals or disinfectants.	Usually 150% of MFN if no preference.	Often 10%–20% depending on subheading.	Commonly 10%.	Review suitable FTA and C/O description.	SDS, label, catalogue, notification, C/O.
3302.90.00	Mixtures of odoriferous substances for cosmetics.	Fragrance raw material / mixture use.	Not for finished retail cosmetics.	Usually 150% of MFN if no preference.	Check current tariff by final HS.	Commonly 10%.	Review FTA by material origin.	SDS, COA, specification, C/O.

SPECIAL PREFERENTIAL C/O/FTA REVIEW BY IMPORT LANE

Lane/origin	FTA/agreement	C/O or origin proof	Special preference if supported	Conditions	Documents	Notes
ASEAN	ATIGA	Form D	May be 0% if eligible.	Meet origin rule and direct transport.	C/O, invoice, B/L, PL, description.	Match cosmetic/DG description and HS.
China	ACFTA/RCEP	Form E or RCEP C/O	Special preference if eligible.	Origin criteria and third-party invoice if any.	C/O, invoice, B/L.	Avoid generic product description.
Korea	AKFTA/VKFTA/RCEP	Form AK/VK/RCEP	Preference if HS is covered.	Review PSR and product description.	C/O, catalogue, SDS, invoice.	Check SKU/brand/model consistency.
Japan	VJEPA/AJCEP/CPTPP/RCEP	Form VJ/AJ or CPTPP/RCEP document	Preference if requirements met.	Review CTH/CTSH/RVC where relevant.	Origin document, invoice, B/L.	Do not claim if HS/description mismatch.
EU/UK	EVFTA/UKVFTA	EUR.1 or origin declaration	Preference if valid.	Eligible exporter and transport conditions.	Origin document, invoice, transport evidence.	Review origin-proof rule by agreement.
AU/NZ	AANZFTA/CPTPP	Form AANZ or CPTPP proof	Preference if covered.	Origin rule and transport evidence.	C/O, invoice, B/L, PL.	Check transshipment documents.
India/Hong Kong	AIFTA/AHKFTA	Form AI/AHK	Preference if covered.	Review route and origin file.	C/O, invoice, B/L, description.	Check validity and origin criteria.

C/O review checklist: C/O form or origin proof; WO/RVC/CTH/CTSH criteria; third-party invoice; direct transport; product description; HS; quantity/weight; country of origin; stamp/signature; issue date and validity.

DOSSIER SET AND SUBMISSION METHOD

File group	Required documents	Used for	Prepared by	Common error	Pre-ETA check
Commercial	Invoice, Packing List, B/L/AWB, Sales Contract/PO, C/O if claiming preference.	Customs declaration, value and C/O.	Shipper, importer, forwarder.	Product name, quantity, origin and SKU mismatch.	Cross-check with label, SDS and notification.
Technical / DG	SDS/MSDS, flash point, UN number, packing group, LQ statement, battery documents.	Booking, DG classification, transport declaration.	Manufacturer/shipper.	SDS lacks transport section or SKU mapping.	Check SDS section 14, package and volume.
Cosmetics	Cosmetic notification, ingredient list, authorization/CFS if applicable, original/supplementary label.	Market circulation and customs explanation.	Importer/RA, manufacturer.	Product name/function does not match notification.	Review receipt number, product name, form and label.
Customs	Declaration, HS code, customs value, C/O, catalogue and explanations.	Declaration and customs channel handling.	Docs/customs broker/importer.	HS code not sufficiently supported.	Prepare SKU – HS – SDS – notification mapping.
Post-clearance	Shipment file, product/label photos, DG documents and notification file.	Post-clearance audit, market inspection.	Importer/compliance.	SDS or label version not retained.	Save PDF by shipment/SKU/date.

LEGAL BASIS AND SPECIALIZED-POLICY MATRIX

1. LEGAL BASIS TO REVIEW

Document group	Name/code	Issuer	Effective timing	Role	Key article/appendix	Review note
Law	Customs Law 2014	National Assembly	Effective 01/01/2015	Customs procedure and inspection basis.	Review by customs regime.	Does not replace cosmetic/DG rules.
Circular	06/2011/TT-BYT on cosmetic management	Ministry of Health	Effective 01/04/2011, partly amended.	Cosmetic notification and circulation basis.	Review notification dossier and retention duties.	Check latest amendments.
Amending circular	34/2025/TT-BYT	Ministry of Health	Effective 18/08/2025.	Amends cosmetic management rules.	Review dossier/submission updates.	Apply by filing date.
Decrees	43/2017/NĐ-CP and 111/2021/NĐ-CP	Government	Effective dates 01/06/2017 and 15/02/2022.	Goods labelling and Vietnamese supplementary labels.	Review mandatory label content.	DG cosmetics still require market labels.
DG decree	34/2024/NĐ-CP	Government	Effective 15/05/2024.	Domestic road/inland-waterway DG transport.	Review after-clearance inland delivery.	International air/sea still follows IATA/IMDG.
International rules	IATA DGR / IMDG Code	IATA / IMO	Updated by edition/year.	DG classification, packing, marking, labelling and declaration.	Review by transport mode and carrier.	Check the edition in force at booking.
Tariff	26/2023/NĐ-CP and current tariff schedules	Government	Effective 15/07/2023.	Import duty and HS schedule.	Review final HS.	Do not finalize tax before HS.

2. SPECIALIZED-POLICY MATRIX BY CARGO SITUATION

Situation	Basis to review	Possible policy	Authority/portal if known	Trigger
Standard cosmetic, no DG trigger	Cosmetic circulars and labelling rules.	Cosmetic notification, supplementary label, HS/C/O.	Public service portal/cosmetic authority; Customs.	Imported for sale or circulation.
Alcohol-based perfume/fragrance	SDS/MSDS, IATA DGR, IMDG Code, carrier rules.	DG declaration, packing/labelling, DG booking.	Carrier/airline/forwarder.	Low flash point, UN number or DG class.
Aerosol cosmetics	SDS/MSDS and DG transport rules.	Possible Class 2 DG, booking and labels.	Carrier/airline/forwarder.	Pressurised container and propellant.
Gift set with batteries/devices	Battery/DG rules, possible ICT policy.	Battery/UN38.3 documents and accessory review.	Carrier, Customs, competent body if triggered.	Lithium battery or wireless module.
Samples/testers	Customs law, cosmetics rules, DG if triggered.	Customs regime, purpose evidence, DG file.	Customs and carrier.	Non-commercial purpose but hazardous properties remain.
Inland delivery after clearance	Decree 34/2024/NĐ-CP if hazardous goods.	Vehicle, documents, packaging/labels.	Transport provider/authority by route.	Hazard remains after import.

PROCESSING TIME, FEES AND COST-RISK POINTS

Step	Recommended timing	Time/fee reference	Delay cost risk	Control point
SDS/DG review	Before order or ETD	Depends on supplier file completeness.	Booking rejection or extra DG declaration.	SDS section 14, flash point, UN number.
Cosmetic notification	Before circulation; prepare before ETA	As publicly announced by the online procedure and fee schedule.	Delayed sales or missing compliance file.	Notification, label, ingredient list, authorization.
DG booking	Before ETD/closing	Carrier rules; DG surcharge may apply.	Missed booking, rerouting, higher freight cost.	DG declaration, packing instruction, transport labels.
Customs declaration	When transport documents and file are ready	By customs channel.	Storage, DEM/DET and document amendments.	HS, C/O, value, product description, notification, SDS.
Post-clearance	Before market circulation	Internal compliance timing.	Market-inspection and audit risk.	Supplementary label, notification, SDS, DG file.

PRACTICAL E2E WORKFLOW

Pre-ETA review

Lock product group, HS, notification, SDS/MSDS, DG triggers, C/O, labels and route.

Document lock

Lock invoice, PL, B/L/AWB, SDS, ingredient list, label, SKU/model list and package details.

Policy branching

Separate cosmetic notification, air/sea DG, lithium battery, supplementary label and sample/tester cases.

Booking and filing

Declare/book DG if required; prepare cosmetic notification and customs explanations.

Customs filing and channels

Green, Yellow and Red channels are handled based on system/file/physical inspection; watch label, SDS and SKU issues.

Delivery and post-clearance

Move cargo to warehouse, apply labels, retain notification, SDS, DG file and post-clearance records.

CONTROL POINTS TO COMPLETE BEFORE ETA

Checkpoint	Recommended timing	Workstream to lock	Risk if after ETA
SDS/MSDS and DG classification	Before ETD	Flash point, UN number, class, packing group, LQ.	Rejected booking or additional DG file.
HS – C/O – duties	Before final documents	8-digit HS, MFN/FTA, C/O form and description.	Loss of C/O preference or declaration amendment.
Cosmetic notification	Before circulation; prepare before ETA	Product name, form, ingredient list, label.	Delayed sales or incomplete file.
Labels	Before market release	Original label, Vietnamese supplementary label, safety warning.	Relabelling or warehouse delay.
Delivery/warehouse plan	Before arrival	Storage condition, DG segregation if any, delivery schedule.	Higher storage cost and safety risk.

FAQ – FREQUENTLY ASKED QUESTIONS

1. Are alcohol-based cosmetics automatically DG?

No. Review SDS/MSDS, flash point, UN number, volume and packaging.

2. Does cosmetic notification replace DG documents?

No. Notification is for cosmetic circulation; DG documents are for transport and booking.

3. What should be checked for perfume by air?

Alcohol content, flash point, bottle volume, quantity, packing instruction and carrier acceptance.

4. Can aerosol cosmetics be shipped as normal cargo?

Only after SDS, propellant, UN number, volume and carrier conditions are reviewed.

5. Why are nail polish and nail remover sensitive?

They may contain flammable solvents and may trigger Class 3 DG requirements.

6. Do samples/testers need a cosmetic file?

It depends on purpose, quantity and whether the goods enter market circulation.

7. Can C/O reduce duty?

Yes, if the final HS is covered and the C/O meets form, origin criteria and transport rules.

8. Can the shipment proceed without SDS?

It may create high booking and explanation risk; SDS is a core document for DG review.

9. What records should be retained?

Declaration, invoice, PL, B/L/AWB, C/O, notification, label, SDS/MSDS and DG documents.

10. Does DG cosmetics require special warehousing?

It depends on hazard, quantity and applicable storage/transport rules.

OUTPUTS AND POST-CLEARANCE OBLIGATIONS

Typical outputs

Cosmetic notification receipt, customs declaration, accepted C/O if eligible, DG booking file, supplementary label and SKU-level shipment file.

Post-clearance duties

Apply Vietnamese label, retain notification and SDS/MSDS, control storage safety and prepare post-clearance/market inspection records.

TGIMEX SOLUTION

For cosmetics with dangerous-goods transport risk, the key task is not only customs filing or cosmetic notification. The importer must control HS, C/O, notification receipt, SDS/MSDS, DG classification, labels, booking and warehouse/port planning to avoid booking rejection, rerouting, storage cost or delayed market release.

A safe approach is to lock the file before ETA along three tracks: cosmetic regulatory compliance, DG transport safety and clearance – delivery – post-clearance record keeping. When these tracks are reviewed in parallel, the importer reduces queries on formula, SKU, labels, C/O and hazardous properties.

1. HS and cosmetic-policy review

Review HS, product form, function, ingredient list, notification, supplementary label and circulation policy.

2. SDS/MSDS and DG-trigger review

Check flash point, UN number, packing group, LQ, aerosol, lithium battery and carrier conditions.

3. Cosmetic notification file

Review product name, form, label, ingredient list, authorization/CFS if any and submission file.

4. C/O and landed-cost control

Review C/O form, origin criteria, HS on C/O, MFN/FTA duty, VAT and preference risks.

5. Booking – clearance – delivery coordination

Track ETD/ETA, pre-alert, D/O, customs filing, channels, truck and warehouse plan.

6. Post-clearance records

Set up shipment/SKU records: declaration, C/O, notification, SDS, labels, DG file and photos.

SUPPORT FLOW BY PHASE

Support phase	Key workstream	Output for importer
Before purchase / ETD	Review formula, SDS, DG triggers, HS/C/O and supplier technical documents.	Supplier-data checklist and suitable transport plan.
Before ETA	Lock documents, notification, labels, DG booking and delivery/warehouse plan.	Ready import file for clearance and market release.
Customs filing	Coordinate filing, channel handling, HS/SDS/label/notification explanations and D/O.	Clear workflow among Docs, Ops, Customs, Warehouse and importer.
Post-clearance	Control labelling, retain notification/DG files and prepare future shipments.	Complete file for market inspection and traceability.

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