For household kitchenware that directly contacts food, compliance risks are not limited to HS classification and import duty. Food containers, cookware, glassware, ceramic tableware, cutlery and multi-material kitchen sets may trigger review of food-contact materials, applicable QCVNs, self-declaration/import food-safety inspection, supplementary labels, C/O and market circulation purpose. This guide provides an end-to-end checklist to lock the file before ETA and reduce unplanned storage or document amendment costs.

QUICK SUMMARY

Product scope

Food-contact kitchen utensils/kitchenware: containers, water bottles, cutlery, cookware, trays, plastic/glass/ceramic/stainless/silicone articles.

Control points

Material, applicable QCVN, labeling, self-declaration or import food-safety inspection if applicable.

TERMS & WHY THE PROCEDURE MATTERS

This product group is controlled at the intersection of household goods and food safety. A commercial name such as “kitchenware” is not enough; material, food-contact use and import purpose must be checked.

Food contact material

Material or surface directly contacting food under normal use.

QCVN

Vietnamese national technical regulation.

Self-declaration

Product declaration mechanism under Decree 15/2018 if applicable.

Import food-safety inspection

State inspection of imported food-safety-controlled goods.

ETA

Estimated time of arrival; the milestone for locking documents.

Test report

Laboratory report matching sample, material and QCVN criteria.

DETAILED PRODUCT CLASSIFICATION

This guide applies to household kitchen utensils and kitchenware whose food-contact surfaces are intended for direct food contact. Electrical appliances, industrial food-processing equipment and decorative-only items must be reviewed separately.

DETAILED PRODUCT CLASSIFICATION TABLE

Product group / situation	Technical signs to check	Examples	Supporting documents	Possible policy	Documents to cross-check	Application note
Plastic/silicone food-contact kitchenware	PP/PE/PET/PC plastics or silicone; heat, microwave or freezer use	Lunch boxes, food trays, water bottles, silicone spoons, plastic cutting boards	Catalogue, material datasheet, migration test report, original label	QCVN 12-1:2011/BYT; self-declaration if classified as food containers; import food-safety inspection if applicable	Material datasheet, QCVN 12-1 test report, original label and photos of food-contact areas	Do not declare only “plastic goods”; state material and food-contact use.
Rubber food-contact parts	Gaskets, nipples, rings or rubber parts directly contacting food	Bottle nipples, water-bottle sealing rings, rubber parts in kitchen tools	Composition, test report, catalogue, detailed photos	QCVN 12-2:2011/BYT; review whether rubber is an accessory or main product	Rubber material composition, QCVN 12-2 test report and photos of direct-contact accessories/components	Separate food-contact rubber parts even if imported as part of a larger item.
Metal/stainless steel/aluminium kitchenware	SUS 201/304/316, steel, aluminium, coating/non-stick layer	Cookware, trays, bowls, spoons, forks, stainless bottles	Material grade, metal migration test, catalogue, label	QCVN 12-3:2011/BYT; labeling; coating may need separate review	Metal grade, QCVN 12-3 test report, coating/non-stick layer details and user instructions	Non-stick surfaces must be reviewed as food-contact material, not just the metal body.
Glass/ceramic/porcelain/enamel kitchenware	Glass, ceramic, porcelain, enamel; decoration in contact area	Bowls, plates, cups, jars, enamel cookware	Lead/cadmium test report, photos, catalogue, label	QCVN 12-4:2015/BYT	QCVN 12-4 test report, lead/cadmium results, decoration photos and food-contact surface photos	Decorated areas contacting food require close review.
Multi-material kitchenware set	Plastic, stainless steel, silicone, glass, wood, coating in one set	Kitchen tool set, cutlery set, box + lid + gasket	BOM, packing list by item, photos, test reports by material	Multiple QCVNs may apply; HS may need item-level classification	Material BOM, item-level packing list and test reports for each food-contact component	Do not force one HS code if materials and functions differ materially.
Kitchenware with electric/battery parts	Heating, motor, sensor, battery, charger or adapter	Portable blender, electric lunch box, heated container	Electrical catalogue, voltage, battery/adapter data, labeling	Food-contact policy plus electrical/household goods policy may apply	Electrical datasheet, safety/energy-labeling documents if any, and food-contact documents for contact parts	This article only covers food-contact aspects; electrical policy must be reviewed separately.

HS CODE – DUTY – C/O

HS classification follows the main material and function: plastic, wood/bamboo, ceramic, glass, stainless/steel, aluminium or cutlery. Multi-material sets require GIR and packaging review.

Pre-declaration control point: for multi-material kitchenware or retail sets, confirm whether the goods should be declared item-by-item or as a set; cutlery/knife groups under 8211/8215 must be split to the final 8-digit HS before duty is finalized. Do not use one generic HS for all “kitchenware” when material and function differ.

Important: Duty rates below are planning references only and must be checked against the effective tariff and final 8-digit HS at declaration date.

PROPOSED HS CODE – DUTY – C/O TABLE

Reference HS	Applicable goods	Classification basis	Conditions	Ordinary duty	MFN duty	VAT	C/O/FTA to review	Documents to check
3924.10.90	Plastic tableware/kitchenware, plastic or silicone food boxes/trays/bottles	Chapter 39; material and kitchenware function	Main product of plastic/silicone, not transport packaging	Indicative 33% if ordinary = 150% MFN	Indicative 22%; re-check current tariff	Indicative 10%	ATIGA/ACFTA/RCEP/AKFTA/VKFTA/AJCEP/VJEPA/EVFTA/UKVFTA if origin qualifies	Catalogue, material, food-contact use, QCVN 12-1 test report, label
4419.90.00	Wood/bamboo tableware and kitchenware	Chapter 44; wood/bamboo material and kitchen use	Applies to food-contact wooden/bamboo kitchenware	Indicative 37.5% if MFN 25%	Indicative 25%	Indicative 10%	FTA subject to origin rules	Material description, photos, surface treatment, label
6911.10.00	Porcelain tableware/kitchenware	Chapter 69; porcelain vs other ceramic	Porcelain bowls, plates, cups, kitchenware	Indicative 52.5% if MFN 35%	Indicative 35%	Indicative 10%	ACFTA/RCEP/AKFTA/VKFTA/AJCEP/VJEPA/EVFTA/UKVFTA if origin qualifies	Lead/cadmium test, QCVN 12-4, product photos
6912.00.00	Ceramic tableware/kitchenware other than porcelain	Chapter 69; non-porcelain ceramic	Ceramic bowls, dishes, cookware	Indicative 52.5% if MFN 35%	Indicative 35%	Indicative 10%	FTA by origin route	QCVN 12-4 test report, catalogue, label
7013.49.00	Glassware for table/kitchen use, other	Chapter 70; household/kitchen glassware	Cups, glasses, jars, kitchen glass containers	Indicative 52.5% if MFN 35%	Indicative 35%	Indicative 10%	FTA by import route	QCVN 12-4, material data, capacity, original label
7323.93.10 / 7323.93.90	Stainless steel table/kitchen household articles	Chapter 73; iron/steel household kitchen articles	Cookware/trays/bowls/spoons if not classifiable in Chapter 82	Indicative 45% if MFN 30%	Indicative 30%	Indicative 10%	FTA if origin qualifies	Steel grade, QCVN 12-3, catalogue, label
7615.10.90	Aluminium table/kitchen household articles	Chapter 76; aluminium kitchenware	Aluminium cookware/trays; coating must be reviewed	Indicative 45% if MFN 30%	Indicative 30%	Indicative 10%	FTA by origin	Aluminium/coating datasheet, test report, use instructions
8211 / 8215	Knives, spoons, forks and metal cutlery	Chapter 82; cutting tools or cutlery	Knives/cutlery sets, distinct from Chapter 73 household articles	Check final 8-digit HS tariff	Check final MFN rate	Indicative 10%	FTA by import route	Catalogue, material composition, safety label, food-contact test if needed

SPECIAL PREFERENTIAL C/O/FTA TABLE BY IMPORT ROUTE

Route/origin	FTA/agreement	C/O form or origin proof	Special preferential duty if substantiated	Conditions	Documents to check	Application note
ASEAN	ATIGA	C/O Form D or applicable proof of origin	May qualify for special preferential duty if the HS-specific origin rule is met	Check WO/RVC/CTH/CTSH, direct consignment and third-party invoicing if any	C/O, Invoice, Packing List, B/L, goods description and 8-digit HS	Do not use one generic C/O description for a set with multiple HS codes if the description is insufficient.
China	ACFTA or RCEP	C/O Form E or RCEP C/O/proof of origin	May qualify by HS line; check the current ACFTA/RCEP special tariff schedule	Meet the applicable PSR; description, HS and quantity must match the customs dossier	C/O, catalogue, Invoice and through B/L if transshipment occurs	Common issues include third-party invoices, overly generic English descriptions or HS mismatch with the declaration.
Korea	AKFTA / VKFTA / RCEP	C/O Form AK, Form VK or RCEP proof	May qualify depending on HS and the selected agreement	Choose the agreement with better duty only when origin criteria are fully satisfied	C/O, origin BOM if required, Invoice and transport document	Korean origin alone is not enough; form type and origin criteria must be checked.
Japan	VJEPA / AJCEP / CPTPP / RCEP	C/O Form VJ, AJ, CPTPP origin certification or RCEP proof	May qualify if the HS-specific rule is met	Check certification method, exporter declaration and PSR by HS	Origin documents, Invoice, B/L and material/process explanation if needed	Do not choose an agreement only by name; compare duty rate and documentary conditions.
EU / UK	EVFTA / UKVFTA	EUR.1 or origin statement/self-certification where applicable	May qualify for special preferential duty if the origin proof and PSR are valid	Check registered/exporter conditions, invoice wording and direct transport	Origin proof, commercial invoice, transport route and product description	High attention is needed for mixed-material sets and third-country logistics routing.
Australia – New Zealand	AANZFTA / CPTPP	Form AANZ or CPTPP origin certification	May qualify depending on HS and origin criteria	Check CTH/CTSH/RVC and direct consignment	C/O/origin certification, Invoice, Packing List and B/L	CPTPP origin declarations require strict wording and issuer eligibility.
India / Hong Kong	AIFTA / AHKFTA	Form AI or AHKFTA C/O	Check only if the import route and origin are relevant	Meet the agreement-specific origin criteria	C/O, Invoice, B/L, goods description and HS	Not every shipment from these routes has a usable preferential C/O; check before costing.

DOSSIER & SUBMISSION METHOD

Files should be separated into commercial documents, technical/food-safety documents and authority submission files if specialized inspection is triggered.

OPERATIONAL DOSSIER CHECKLIST
This checklist is used to lock documents before ETA, clarify who prepares each item and detect common errors before customs declaration.

File group	Required documents	Used for	Usually prepared by	Common errors	Pre-ETA check
Commercial documents	Invoice, Packing List, B/L/AWB, contract/PO, C/O	Customs declaration and duty preference	Shipper / Importer / Docs	Generic description, quantity mismatch, inconsistent origin	Check product name, material, model/size, unit and origin before ETA
Technical documents	Catalogue, datasheet, photos, material data, use instructions, original label	HS classification, QCVN and food-safety review	Supplier / Procurement / Compliance	No food-contact material data or temperature range	Request material grade and food-contact confirmation
Food-safety/QCVN file	Migration test report, COA if any, self-declaration/import inspection file	Self-declaration, specialized inspection, market circulation	Importer / QA / Legal / Lab	Test report not aligned with Vietnamese QCVN	Match QCVN to material group
Labeling file	Original label, Vietnamese supplementary label, manufacturer/importer/origin, material and warnings	Post-clearance and market circulation	Importer / Marketing / Compliance	Missing origin/material/use instructions	Finalize supplementary label before release for sale
Logistics/customs file	Arrival notice, D/O, declaration, payment docs, through B/L if transit	Customs clearance and cargo release	Ops/Forwarder/Broker	Late pre-alert; missing food-safety docs; late C/O	Lock minimum documents before arrival

LEGAL BASIS – SPECIALIZED POLICY MATRIX

Document group	Document name/number	Issuing authority	Effective date/application time	Role in procedure	Key article/appendix	Review note
Law	Law on Food Safety 55/2010/QH12	National Assembly	Effective 01/07/2011	General legal framework for food safety and food-contact articles	Responsibilities of manufacturers/importers/traders	Base law; QCVNs remain decisive for material safety.
Decree	Decree 15/2018/NĐ-CP	Government	Effective 02/02/2018	Self-declaration and state food-safety inspection for imports	Articles 4–5, Chapter IV, Appendix II	Containers/packaging and utensils that only contact food may follow different logic.
2026 regulation status	Resolution 15/2026/NQ-CP; Decree 46/2026/NĐ-CP; Resolution 66.13/2026/NQ-CP	Government	Resolution 15 effective 06/04/2026	Suspends Decree 46/2026 and Resolution 66.13/2026	Suspension provisions	Do not mechanically apply the suspended framework.
Circular/QCVN	Circular 34/2011/TT-BYT	Ministry of Health	Effective 01/03/2012	QCVN for plastic, rubber and metal food-contact materials	QCVN 12-1, 12-2, 12-3	Core QCVNs for many household kitchenware items.
Circular/QCVN	Circular 35/2015/TT-BYT	Ministry of Health	Effective 01/05/2016	QCVN for glass, ceramic, porcelain and enamel food-contact materials	QCVN 12-4:2015/BYT	Important for bowls, plates, cups, glass jars and enamel cookware.
Labeling	Decree 43/2017/NĐ-CP and Decree 111/2021/NĐ-CP	Government	01/06/2017 and 15/02/2022	Imported goods labeling and supplementary Vietnamese labels	Mandatory label content and origin	Translate use/caution statements carefully.
Tariff	Decree 26/2023/NĐ-CP and Decree 108/2025/NĐ-CP	Government	15/07/2023 and 19/05/2025	MFN tariff schedule and amendments	HS code and tariff rates	Final tax must be checked at declaration date.

SPECIALIZED POLICY MATRIX BY GOODS SITUATION

Goods situation	Legal basis	Possible policy	Authority/portal if known	Trigger condition
Food containers imported for sale	Decree 15/2018 and material QCVNs	Self-declaration if under Article 4; import food-safety inspection if applicable	Food safety authority / applicable portal	Product is used to contain and directly contact food in Vietnam market
Utensils that contact but do not contain food	Decree 15/2018, government guidance, QCVN 12 series	May not be self-declaration products but still must meet QCVNs and import inspection if listed	Food safety authority / inspection body	Spoons, forks, chopsticks, knives, scissors, cooking utensils
Multi-material kitchenware	QCVN 12-1/2/3/4 and technical file	Review several QCVNs and test reports by material	Inspection body / testing organization	Plastic + steel + silicone + glass/ceramic in one item or set
Special claims on labels	Decree 43/2017 and Decree 111/2021	Supplementary label, use instructions, heat/microwave/freezer claims	Customs / post-market authorities	Technical claims and warnings shown on original label
Samples, warranty goods, gifts	Decree 15/2018 and customs policy	May follow separate treatment but no automatic exemption	Customs / specialized authority	Non-commercial purpose, small quantity, testing/evaluation
Kitchenware with electrical parts	Household/electrical policy, energy labeling if applicable	Food-contact plus electrical or quality inspection policy may arise	Relevant specialized authority by model	Heating, motor, battery, adapter, charger or electronic module

VIEW / DOWNLOAD ORIGINAL LEGAL SOURCES

Decree 15/2018/NĐ-CP Resolution 15/2026/NQ-CP Circular 34/2011/TT-BYT Circular 35/2015/TT-BYT Decree 43/2017/NĐ-CP

PROCESSING TIME, FEES & RISK COSTS

Stage	Recommended time	Tasks	Fees to note	Risk cost if delayed
Pre-ETA review	3–7 working days before ETA or earlier	Finalize HS, material, QCVN, C/O, labels and import purpose	No fixed state fee at this stage	Late review may create DEM/DET and storage risks
Food-safety/QCVN preparation	Depends on availability of test reports and files	Collect reports, self-declaration/import inspection file if required	Testing/certification fees depend on lab and scope	Do not invent processing time
Customs declaration	When cargo arrives and documents are ready	Declare HS, value, C/O and specialized policy	Customs fee if applicable under current rules	Yellow/Red channel may request catalogue, label, C/O and test report
Specialized inspection if triggered	Depends on inspection method and file completeness	Submit, amend and receive result	No absolute fee/time without official basis	Delay may lead to storage/container charges
Post-clearance circulation	Before sale/use in Vietnam market	Supplementary label and lot file retention	Labeling/storage/testing cost if any	Poor records create post-clearance risk

PRACTICAL E2E PROCESS

Pre-ETA review

Finalize HS, material, QCVN, C/O, labels, import purpose and whether self-declaration or food-safety inspection is triggered.

Lock documents and technical file

Lock Invoice, Packing List, B/L/AWB, catalogue, datasheet, test report, original labels and item list.

Prepare specialized file

Prepare self-declaration, import inspection file or QCVN explanation if applicable.

Open customs declaration

Declare HS, value, C/O and specialized policy; be ready to explain material, use, QCVN and labels.

Clearance and cargo release

Monitor customs/specialized feedback, amend documents if required, and arrange trucking/warehouse plan.

Post-clearance completion

Apply supplementary labels, keep lot-based records and prepare for post-clearance review.

FAQ

Do food-contact kitchen utensils need self-declaration?

It depends. Food containers and food-contact packaging may fall under Article 4 of Decree 15/2018. Utensils that only contact but do not contain food, such as spoons, forks, chopsticks or knives, require a separate review; they still need to meet QCVNs and may be subject to import food-safety inspection.

Does stainless cookware need food-safety inspection?

It may. Review the HS code, steel grade, non-stick coating, QCVN 12-3 and test report.

Do decorated ceramic products need lead/cadmium testing?

Review QCVN 12-4, especially when decoration or glaze is in the food-contact area.

Should a plastic food box be classified under 3924 or 3923?

It depends on function and use. Table/kitchenware is usually reviewed under 3924, while transport/packing articles may differ.

Can C/O reduce import duty?

Yes, if the origin document is valid, matches the HS and product description, and meets the relevant origin rule.

Can samples be exempted?

Possibly, but do not assume. Review purpose, quantity and Decree 15/2018 exemptions.

Can foreign test reports be used?

They may support the file, but acceptance depends on method, lab, sample and QCVN alignment.

Can a multi-material set be declared under one HS code?

Not automatically. Review the GIR rules, packing, function and material composition.

What must be kept after clearance?

Commercial documents, declaration, C/O, catalogue, labels, test reports and food-safety files by lot.

Do electric kitchen appliances fall under this article?

Only for the food-contact aspect. Electrical safety, batteries, adapters and energy labeling must be reviewed separately.

OUTPUT RESULTS & POST-CLEARANCE OBLIGATIONS

Output	Operational meaning	When to note
Self-declaration if required	Importer is responsible for product compliance	For food containers/packaging under Article 4 of Decree 15/2018
Import food-safety inspection result if required	Result/confirmation under the applicable inspection mechanism	Important for clearance/circulation if inspection is triggered
Cleared customs declaration	Cargo can be released to warehouse	Does not replace labeling and post-market obligations
Supplementary label and circulation file	Vietnamese label, material, origin, responsible party, instructions/warnings	Required before market circulation when original label is insufficient
Lot-based record file	Declaration, C/O, test report, self-declaration/inspection, transport docs	For post-clearance audit and traceability

TGIMEX SOLUTIONS

Correct handling requires linking HS, food-safety/QCVN, C/O, labeling and port/warehouse operations into one pre-ETA control flow.

Pre-ETA compliance review

Review goods description, contact material, intended use, HS, import route, C/O draft and QCVN requirements before arrival.

HS – duty – C/O control

Separate plastic, wood/bamboo, ceramic, glass, stainless/steel, aluminium and cutlery lines; check MFN, VAT and special preferential duty.

Food-safety/QCVN file

Review test reports, self-declaration/import inspection files, label samples and material data to reduce amendment requests.

Label and document consistency

Check original/supplementary labels, instructions, warnings, origin and responsible party against Invoice, Packing List and declaration.

Customs – port – warehouse coordination

Monitor customs channel, specialized feedback, cargo release plan and DEM/DET/storage risks.

Post-clearance recordkeeping

Maintain declaration, C/O, test report, self-declaration/inspection file, catalogue, labels and transport documents by lot.

Execution scope: HS review, specialized policy review, C/O review, label review, technical file preparation, customs coordination, trucking/warehouse monitoring and post-clearance recordkeeping.

ELECTRICAL – ELECTRONICS – IT EQUIPMENT

F&B

MACHINERY

HOUSEHOLD GOODS

COSMETICS – PERSONAL CARE