Food-contact packaging, utensils and materials must be reviewed not only by HS code and duty, but also by food safety requirements, applicable technical regulations, declaration dossiers, import food safety inspection and labelling obligations. A wrong material description, missing test report or inconsistent intended use may lead to dossier supplementation, specialized inspection, storage charges and production delays. The guidance focuses on policy conditions, required dossiers, filing timing, and the risks that commonly lead to document supplements or customs delays. Before execution, the company should confirm the goods description, HS classification, model or technical composition, identify the competent authority, and align specialist filings with the customs document set.

OPERATIONAL OVERVIEW

Operational reference for importers, procurement, compliance, QA/QC and logistics teams in the F&B sector.

Scope

Bottles, boxes, films, bags, trays, cups, spoons, forks, containers, lids and materials that may directly contact food.

Policy focus

Food safety, material QCVN, declaration/self-declaration dossier, import inspection and Vietnamese labelling.

Technical dossier

Catalogue, datasheet, material composition, manufacturing standard, test report, original label and C/O if claiming preferential duty.

WordPress metadata

Category ID 1566; Image: thutuc1.png.

Illustration for Import procedure guide for food-contact packaging, utensils and materials — Illustration of the product group and document review before customs clearance.

TERMINOLOGY AND WHY THE PROCEDURE MATTERS

The core compliance issue is proving that the product is safe for food contact under actual use conditions.

Term	Operational explanation
FCM (Food Contact Materials)	Packaging, containers, utensils or material layers designed to directly contact food during filling, storage, transport, processing or consumption.
Food safety dossier	A set of technical, testing and declaration documents used to demonstrate that the product is safe for food contact.
QCVN	Vietnamese national technical regulation. Food-contact materials must be checked against the QCVN applicable to the actual contact material.
Self-declaration / declaration	The market-entry dossier mechanism applicable to certain food-related goods under the food safety framework in force at the time of filing.
State food safety inspection	Import inspection that may include document review, physical inspection and sampling depending on the inspection method.
ETA	Estimated Time of Arrival; the point by which HS, policy, testing and C/O should be reviewed.

Key control point: the goods description should state material, function and food-contact use.

PRODUCT CLASSIFICATION AND TECHNICAL IDENTIFICATION

Product group / situation	Technical indicators to check	Examples	Supporting documents	Possible policy trigger	Application note
Synthetic resin packaging	PE/PP/PET/PS/PC, bottle, tray, box, bag, film, cap, multilayer structure, food-contact temperature.	PE bag, PET bottle, PP food box, plastic tray.	Datasheet, material composition, test report, catalogue, label.	Food safety, QCVN 12-1:2011/BYT, declaration dossier and import inspection.	Do not use one test report for products with different resin, colour, additive or use condition.
Rubber food-contact items	Rubber type, additives, vulcanization system, migration risk and contact temperature.	Gasket, seal, rubber part in a food line.	Datasheet, migration test report, manufacturer standard.	Food safety and QCVN 12-2:2011/BYT.	Separate food-contact rubber parts from non-contact technical parts.
Metal food-contact items	Stainless steel, steel, aluminium, coating, contact surface and heavy metal migration.	Metal can, lid, tray, spoon, fork, kitchen utensil.	Material certificate, test report, catalogue and photos.	Food safety and QCVN 12-3:2011/BYT.	Industrial packaging and household utensils may follow different HS and compliance evidence.
Glass, ceramic, porcelain, enamel	Depth, drinking rim, enamel/glaze layer, lead/cadmium migration risk.	Glass jar, cup, bowl, plate, ceramic container.	QCVN test report, catalogue, photos and label.	Food safety and QCVN 12-4:2015/BYT.	Pay special attention to glazed or enamelled food-contact surfaces.
Paper, carton and multilayer materials	Direct-contact layer, PE/PLA/wax coating, ink, adhesive, hot/oily/acidic food use.	Paper cup, paper bowl, carton tray, coated paper bag.	Layer structure, datasheet, test report.	Food safety review under the actual material and current rules.	If the contact layer is plastic, review the plastic layer as a food-contact material.

PROPOSED HS CODE – DUTY – C/O REVIEW

HS codes are review anchors only. Final duty must be confirmed against the valid tariff schedule, final 8-digit HS code and actual origin document.

Reference HS	Relevant goods	Classification basis	Application condition	Ordinary duty	MFN duty	VAT	C/O/FTA to review
3923.10 / 3923.21 / 3923.29 / 3923.30 / 3923.50 / 3923.90	Plastic packaging articles such as boxes, bags, bottles, closures and other packing goods.	Material, form, packing/containing function and import condition.	Final rate must be checked under the valid tariff schedule.	Check MFN by final 8-digit HS.	Reference VAT 10%, subject to policy at declaration time.	ATIGA, ACFTA/RCEP, AKFTA/VKFTA, AJCEP/VJEPA/CPTPP/RCEP, EVFTA, UKVFTA, AANZFTA, AIFTA, AHKFTA.	Catalogue, material structure, photos, invoice, packing list and C/O.
3924.10	Plastic tableware and kitchenware such as cups, spoons, forks and food containers.	Function as tableware/kitchenware rather than transport packaging.	Use when imported as food-use utensils.	Check MFN by final HS.	Reference VAT 10%.	Review origin document by import route.	Catalogue, function, material, food safety test report and label.
4819 / 4823	Paper or paperboard cartons, boxes, sacks, cups, trays and coated paper containers.	Shape, paper grade, coating and direct-contact layer.	If plastic-coated, review the contact layer separately.	Check MFN by final HS.	Reference VAT 10%.	Review C/O and origin criterion for paper or packaging.	Layer structure, paper grammage, coating and test report.
7010	Glass bottles, jars and containers for food or beverages.	Glass material and food/beverage containing function.	Not for decorative glassware without food-contact use.	Check MFN by final HS.	Reference VAT 10%.	Review C/O by route.	Catalogue, QCVN 12-4 test report and label.
6911 / 6912	Porcelain, ceramic and similar tableware or kitchenware.	Material and function as food-contact tableware/kitchenware.	Applicable when directly contacting food.	Check MFN by final HS.	Reference VAT 10%.	Review C/O, especially China, ASEAN and EU routes.	Lead/cadmium test report, catalogue and label.
7323 / 7615 / 7607	Kitchen utensils, trays, containers or foil made of steel, stainless steel or aluminium.	Metal, function and article form.	Not applicable to machinery or production lines.	Check MFN by final HS.	Reference VAT 10%.	Review C/O by import route.	Material data and heavy-metal/migration test report.

SPECIAL PREFERENTIAL C/O/FTA TABLE BY IMPORT ROUTE

Route / origin	FTA	Origin document	Preferential duty basis	Conditions	Documents	Note
ASEAN	ATIGA	Form D or accepted origin document	Special preferential duty if the final HS is covered.	Direct transport, matching description and eligible origin criterion.	C/O, invoice, packing list, B/L, catalogue and final HS.	Check transshipment evidence if any.
China	ACFTA or RCEP	Form E or RCEP origin document	Preferential duty if tariff schedule and C/O are valid.	Check CTH/CTSH/RVC and third-party invoice if any.	C/O, invoice, B/L, packing list and goods description.	Plastic, paper and ceramic goods often have description mismatch risk.
Korea	AKFTA / VKFTA / RCEP	Form AK, Form VK or RCEP document	Preferential rate depends on HS and chosen agreement.	Choose the agreement by actual duty benefit and available origin evidence.	C/O, origin documents and final HS.	Do not select an FTA only by habit.
Japan	VJEPA / AJCEP / CPTPP / RCEP	Form VJ, AJ, CPTPP statement or RCEP document	Preferential rate depends on HS.	Compare product-specific rules under each agreement.	Origin document, invoice and transport document.	CPTPP has its own statement requirements.
EU / UK	EVFTA / UKVFTA	EUR.1, origin declaration or approved self-certification	Preferential rate if origin and HS qualify.	Check exporter code, goods description and transport condition.	Origin document, invoice, packing list and B/L.	Avoid overly generic origin descriptions.
Australia – New Zealand / India / Hong Kong	AANZFTA / CPTPP / AIFTA / AHKFTA	AANZ, CPTPP statement, AI or AHK form	Preferential rate depends on route and HS.	Check origin criterion and direct transport.	C/O or origin document, HS, invoice and B/L.	Verify C/O validity and quantity/weight consistency.

DOSSIER AND SUBMISSION METHOD

Dossier group	Required documents	Used for which step	Usually prepared by	Common error	Pre-ETA check
Commercial dossier	Commercial invoice, packing list, B/L or AWB, contract/PO and payment documents if needed.	Customs declaration, D/O and value/quantity checking.	Importer, documentation team and logistics sales.	Generic goods name such as “packing material”; missing size, material or model.	Lock the name by material + function + food-contact use before ETA.
Technical material dossier	Catalogue, datasheet, material composition, production standard, photos, original label and size list.	HS classification and QCVN/test indicator review.	Supplier, QA and compliance.	No information on contact layer or use temperature.	Request supplier to confirm contact layer and hot/cold/oily/acidic use condition.
Food safety / declaration dossier	Declaration/self-declaration dossier under current rules, test report, internal standard if any.	Market circulation and import compliance.	Importer, QA and compliance.	Test report is for a different material or lacks required indicators.	Compare QCVN by material and report date.
Import inspection dossier	Food safety inspection registration where applicable, inspection result and shipment dossier.	Submission to the competent authority and Customs.	Operations, customs broker and compliance.	Filing after ETA and discovering missing reports.	Prepare under the expected inspection method before ETA.
Preferential duty dossier	C/O or origin document, transport document, invoice, packing list and transit evidence if any.	Claiming special preferential duty.	Shipper, exporter and importer.	C/O description, HS or transport condition is incorrect.	Check C/O before transmitting the customs declaration.

LEGAL BASIS AND SPECIALIZED POLICY MATRIX

Because of the 2026 food safety transition, legal effectiveness must be checked again right before filing: under Resolution 15/2026/NQ-CP, Decree 46/2026/ND-CP and Resolution 66.13/2026/NQ-CP are suspended until the amended Food Safety Law and its guiding decree take effect; during the suspension, Decree 15/2018/ND-CP continues to apply.

Document group	Legal instrument	Issuing authority	Effectiveness / timing	Role	Key articles / appendices	Review note
Law	Law on Food Safety 55/2010/QH12	National Assembly	Effective from 01/07/2011; partly amended.	Base law for food safety, import inspection and food-contact packaging/utensils.	Chapters on food safety conditions and imported food.	Check consolidated/amended version at application time.
Decree	Decree 15/2018/ND-CP	Government	Effective from 02/02/2018; continues to apply during the suspension of Decree 46/2026 and Resolution 66.13/2026 under Resolution 15/2026/NQ-CP.	Details declaration, import food safety inspection and management allocation.	Article 4, Article 14 and Appendix II.	Apply during the suspension period under Resolution 15/2026/NQ-CP; check for any replacement/amending instrument at filing time.
Suspended 2026 instruments	Decree 46/2026/ND-CP and Resolution 66.13/2026/NQ-CP	Government	Issued in early 2026; suspended by Resolution 15/2026/NQ-CP until the amended Food Safety Law and its guiding decree take effect.	Introduce a new framework for food product declaration/registration and food safety management, but should not be applied during the suspension period.	Monitor future replacement rules.	Do not apply mechanically during the suspension period; keep them as monitored legal instruments.
Resolution	Resolution 15/2026/NQ-CP	Government	Effective from signing date 06/04/2026; replacing Resolution 09/2026/NQ-CP.	Suspends Decree 46/2026/ND-CP and Resolution 66.13/2026/NQ-CP; states that Decree 15/2018/ND-CP continues to apply during the suspension.	Articles 1, 2, 4 and 5.	Critical to prevent applying the wrong 2026 framework.
Circular / QCVN	Circular 34/2011/TT-BYT issuing QCVN 12-1, 12-2 and 12-3	Ministry of Health	Effective from 01/03/2012.	Technical regulations for synthetic resin, rubber and metal food-contact packaging/utensils.	QCVN 12-1:2011/BYT, 12-2:2011/BYT, 12-3:2011/BYT.	Select test indicators by contact material.
Circular / QCVN	Circular 35/2015/TT-BYT issuing QCVN 12-4:2015/BYT	Ministry of Health	Effective from 01/05/2016.	Technical regulation for glass, ceramic, porcelain and enamel food-contact items.	QCVN 12-4:2015/BYT.	Important for cups, bowls, plates, jars and glass/ceramic containers.
Labelling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Decree 43 effective 01/06/2017; Decree 111 effective 15/02/2022.	Imported goods labelling and Vietnamese supplementary labels.	Mandatory label contents, original label and supplementary label.	Review by goods type and material/use warnings.

SPECIALIZED POLICY MATRIX BY GOODS SITUATION

Goods situation	Legal basis	Potential policy	Authority / portal	Triggering condition
Food-contact packaging/utensils imported for trading	Food Safety Law, Decree 15/2018, material QCVN, Decree 43/2017 and 111/2021	Declaration/self-declaration, import food safety inspection and supplementary labelling.	Assigned food safety inspection authority, Customs, National Single Window/specialized portal if applicable.	Goods are placed on the market and directly contact food.
Packaging imported for internal production	Decree 15/2018, Customs/food safety guidance and purpose-of-use documents	Handling may differ by purpose, customs regime and legal effectiveness.	Customs and food safety authority by goods group.	Imported for internal production, not direct sale; purpose must be evidenced.
Sample, lab test or exhibition goods	Decree 15/2018 and exemption/reduced inspection rules where eligible	May be exempted or handled differently if purpose and quantity are justified.	Customs and specialized authority.	Clear sample purpose, appropriate quantity and no commercial circulation.
Goods with coating, ink or adhesive near food contact	Material QCVN and layer-structure technical dossier	Migration testing may be required by contact layer, not just base material.	Testing laboratory and food safety authority.	PE/PLA/wax coating, ink, adhesive or additive may contact food.
Metal, ceramic, glass or enamel utensils	QCVN 12-3 or QCVN 12-4	Heavy metal/migration testing, labelling and use instruction control.	Food safety authority and testing laboratory.	Eating/drinking/containing use or contact with hot/acidic/oily food.
Original label lacks Vietnamese information	Decree 43/2017 and 111/2021	Vietnamese supplementary label before circulation.	Importer and market surveillance/customs authority if inspected.	Foreign original label lacks mandatory Vietnamese information.

VIEW / DOWNLOAD SOURCE LEGAL DOCUMENTS

Decree 15/2018/ND-CP Resolution 15/2026/NQ-CP Decree 46/2026/ND-CP Resolution 66.13/2026/NQ-CP Circular 34/2011/TT-BYT Circular 35/2015/TT-BYT

PROCESSING TIME, FEES AND RISK COSTS

Stage	Operational timing	Action	Fee / cost	Risk if delayed
Pre-ETA review	Preferably 7–14 days before ETA	Confirm material, HS, QCVN, food safety dossier, label and C/O.	Internal review cost; no fixed state fee.	Late detection of missing test report or wrong material may cause storage.
Testing / test report	Depending on lab capacity and indicators; usually several days to weeks	Sample and test according to QCVN or applicable standard.	Testing cost by lab and number of indicators.	Wrong material or missing indicators may invalidate the dossier.
Declaration or dossier update	Before circulation or as required by current rules	Complete quality/safety dossier for market circulation.	Dossier preparation, testing and translation costs.	Using an old dossier for a different specification or material.
Import food safety inspection	Before or upon arrival depending on workflow	Submit import inspection dossier if applicable.	Official fee/service fee if supported by legal basis.	Late filing or missing documents may extend storage time.
Customs declaration and channel handling	According to schedule and locked dossier	Transmit declaration and handle green/yellow/red channel.	DEM/DET/storage if free time is exceeded.	HS, C/O, name or specification mismatch may trigger inquiry/inspection.
Post-clearance / circulation	After delivery and before market circulation	Apply Vietnamese label, archive dossier and prepare for post-clearance/market inspection.	Labelling, warehousing and record management costs.	Cargo is cleared but not ready for legal circulation.

END-TO-END OPERATING PROCESS

Pre-ETA review

Confirm product description, food-contact material, indicative HS code, applicable QCVN, import food-safety requirements, declaration/self-declaration dossier and expected C/O before arrival.

Lock commercial documents

Align invoice, packing list, B/L or AWB, contract/PO, quantity, specification, material, origin and goods description before customs declaration.

Lock technical documents

Request catalogue, datasheet, test report, material composition, manufacturing standard, original label and actual product images from the supplier.

Prepare food-safety dossier

Determine whether declaration/self-declaration, QCVN testing and state food-safety inspection at import are required for the actual goods.

Customs declaration and channel handling

Prepare explanations for HS, customs value, goods description, C/O, food-safety dossier and technical documents if the shipment is routed to yellow/red channel.

Release cargo and close post-clearance obligations

Move cargo to warehouse, add Vietnamese supplementary label if required, archive lot dossiers, test reports/declarations and prepare for post-clearance review.

Control point: HS, C/O, label, QCVN and food-safety dossier should be checked before ETA to reduce storage, DEM/DET and unplanned supplementation risks.

FAQ

Is declaration/self-declaration required?

It may be required before circulation under the food safety framework in force. Because 2026 instruments are subject to suspension under Resolution 15/2026/NQ-CP, check legal effectiveness before filing.

Is import food safety inspection required?

It may be required if the product is a food-contact tool, container or packaging material.

Does empty packaging still fall under food safety management?

Yes, if it is designed to directly contact food.

Can foreign test reports be used?

They may support the dossier, but acceptance depends on testing method, laboratory, indicator set and the authority.

How to treat coated paper packaging?

Review the direct-contact layer; plastic coating may trigger plastic food-contact indicators.

Can samples be handled differently?

Samples may be handled differently if purpose and quantity are justified.

Can C/O reduce duty?

Yes, if the final HS is covered and origin rules are met.

What should be archived after clearance?

Commercial documents, food safety dossier, test report, labels, C/O, inspection results and traceability records.

What if one shipment contains multiple materials?

Split the review by material group and specification. Each group may have a different QCVN, testing indicator set, HS code and supporting dossier.

Are packaging materials imported by EPE/FDI or for export production handled differently?

They may differ depending on import type, actual use and specialized-management requirements. Review the dossier, purpose and customs regime instead of assuming the same treatment as domestic trading goods.

OUTPUTS AND POST-CLEARANCE OBLIGATIONS

Output / obligation	Control method
Import food safety inspection result or equivalent dossier	Use only for the correct shipment, product group and inspection method; archive with customs and transport documents.
Declaration/self-declaration dossier or applied standard	Must match product, material, specification, responsible entity and test report.
Vietnamese supplementary label	Apply before circulation; label content must not misrepresent material, function or use warning.
Lot traceability dossier	Archive invoice, packing list, B/L or AWB, C/O, catalogue, test report, photos, labels and inspection result.
Post-clearance/market inspection file	Prepare explanation on HS, C/O, use purpose, food safety dossier, label and origin.

SOLUTIONS FROM TGIMEX

Operational value lies in early review before ETA: correct material, correct food-safety policy, correct HS, valid C/O and sufficient technical dossier.

Pre-ETA policy review

Review material, import purpose, HS, QCVN, declaration dossier and import inspection risk before arrival.

Technical dossier control

Standardize catalogue, datasheet, test report, material composition, original label and food-contact layer evidence.

HS – duty – C/O control

Separate HS by material, review VAT/MFN/preferential duty and check C/O form and origin criterion.

Customs – port – warehouse coordination

Track ETA, D/O, specialized inspection, customs channel, delivery plan and free-time milestones.

Post-clearance completion

Support Vietnamese label, lot dossier filing and explanation package.

Legal change alerts

Monitor Decree 46/2026, Resolution 66.13/2026 and Resolution 15/2026/NQ-CP to avoid using the wrong food-safety framework.

Execution scope: HS review, policy review, C/O review, labelling review, technical dossier, food-safety dossier, result tracking, port/warehouse coordination and post-clearance archiving.

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