Non-electric beauty packaging, tools and accessories should not be declared under a single generic description. The customs and compliance route depends on whether the goods are empty packaging, dry tools, a multi-component set, or accessories filled/impregnated with cosmetics. 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.

QUICK SUMMARY

Nature of goods

Usually empty packaging, applicators or non-electric beauty accessories; not automatically finished cosmetics.

Main risk

Confusing empty packaging/accessories with filled cosmetic products or cosmetic sets.

HS focus

Classify by material, function, construction and condition: plastic, paper, glass, metal, brushes, puffs, combs, nail tools.

Policy route

Empty/non-electric goods focus on HS, labeling and technical documents; filled/impregnated goods may trigger cosmetics notification.

Featured image

Use thutuc3.png for Cosmetics & personal care.

TERMS & WHY THIS PROCEDURE MATTERS

Non-electric beauty packaging, tools and accessories may look simple under a commercial name, but import clearance requires a clear split between empty packaging, dry accessories, makeup tools, personal-care tools and goods already filled or impregnated with cosmetics. This distinction directly affects HS code, duties, labeling, technical documents and possible cosmetic notification requirements.

Empty cosmetic packaging

Bottles, jars, tubes, caps, pumps, droppers, paper boxes or trays used for cosmetic packing but imported without cosmetic product inside.

Non-electric beauty accessories

Makeup brushes, puffs, sponges, eyelash curlers, tweezers, combs, mirrors without lights and manual nail/hair tools; no battery, power source, LED, motor or wireless function.

Technical dossier

Documents proving material, structure, function, condition, model/specification and import purpose to support HS classification, labeling and policy review.

Key control point: do not conclude based on names such as “beauty kit”, “cosmetic tool set” or “makeup accessories”. One set may include empty plastic bottles, funnels, spatulas, mirrors, brushes and puffs; each item may fall under a different HS line and duty treatment. If wipes, pads, sponges or masks are impregnated with remover, serum or active ingredients, they must be separated from dry accessories and reviewed as finished cosmetics.

SCOPE & DETAILED PRODUCT CLASSIFICATION

Covered goods

Empty cosmetic packaging, non-electric beauty tools/accessories, dry accessory sets, salon-use or retail-use goods that are not filled or impregnated with cosmetic preparations.

Not automatically covered

Electrical beauty devices, LED masks, massagers, facial cleansing devices, battery-powered items, RF/ultrasonic/heating devices, filled/impregnated products or therapeutic-claim goods.

Separate before ETA

Multi-material sets, goods imported together with cosmetics, accessories with liquid/gel/glue, samples, EPE/FDI goods or project cargo may require different declaration and documents.

Application principle: review catalogues, actual images, material composition, model/specification, original labels, import purpose and selling method at the time of application. Do not apply one common HS/policy conclusion to all “beauty accessories”.

DETAILED PRODUCT CLASSIFICATION TABLE

Product group/situation	Technical signs to check	Examples/use	Evidence documents	Possible policy	Documents to cross-check	Application note
Empty cosmetic packaging	Bottles, jars, tubes, caps, pumps, sprayers, droppers, paper boxes; plastic/glass/metal/paper materials	Empty serum bottle, cream jar, plastic tube, dropper cap	Catalogue, photos, material breakdown, packing specification	HS by material/function; product labeling; not automatically a cosmetic notification if empty	Invoice, packing list, B/L/AWB, catalogue, product photos, original label	If filled with cosmetics or imported as a retail set, reassess as finished cosmetics/cosmetic set.
Non-electric makeup accessories	No battery, motor or power source; used for applying, blending, brushing, clipping or shaping	Makeup brushes, puffs, foundation sponges, eyelash curlers, tweezers, brow razors/combs	Catalogue, product photos, material composition, usage instructions	HS for brushes/puffs/personal tools; labeling; SDS may be needed if adhesive/coating is present	Photos, catalogue, material description, composition list	Avoid therapeutic skin/hair claims; if liquid/gel/serum is included, split the policy review.
Non-electric nail/eyelash/hair tools	Hand-operated tools without electricity for personal care/salon use	Nail file, nail cutter, cuticle pusher, tweezers, combs, hair clips	Catalogue, metal/plastic composition, packaging photos	HS for manicure tools/combs/hair accessories; goods labeling	Commercial docs, catalogue, label, material description	Sharp tools may require additional carrier packing control.
Disposable beauty supplies	Dry cotton pads, dry cosmetic wipes, spatulas, cream scoops, mixing sticks; not impregnated	Dry cotton pad, plastic spatula, mask bowl, mixing stick	Specification, material declaration, photos, intended use	HS by textile/plastic/paper; labeling; review skin-contact claims	Material description, label, packing list, PO	If impregnated with lotion, serum or remover, reassess as finished cosmetics.
Packaging/accessory kits	Multiple items packed together, often with different materials/functions	Travel bottle set with funnel and spatula; brush and sponge kit	Detailed BOM/packing list, set photos, separate invoice lines when needed	Classify by GIR/essential character or split line items; review C/O by HS	Invoice, packing detail, item catalogues, C/O	Do not use one generic HS when the set has multiple components and no clear essential character.

HS CODE – DUTY – C/O

HS classification should be based on main material, function, condition and kit structure. Do not use one HS for all beauty accessories.

Duty control: duty rates below are operational reference ranges only. Final duty must be verified by final 8-digit HS, origin, C/O and customs declaration date.

PROPOSED HS CODE – DUTY – C/O TABLE

Reference HS	Suitable product group	Classification basis	Conditions	Ordinary duty	MFN duty	VAT	C/O/FTA to review	Documents to cross-check
3923.xx	Plastic cosmetic packaging: empty bottles, jars, tubes, caps and packaging parts	Plastic material; packaging/containment function; empty goods	For empty packaging only, not filled cosmetics	Indicative 15%–30%; final by 8-digit HS	Indicative 10%–20%; check current tariff	Usually 10%	ATIGA/ACFTA/RCEP/VKFTA/EVFTA/CPTPP depending on origin	Catalogue, photos, material declaration, invoice, C/O
3926.90	Other plastic beauty accessories: spatulas, cream scoops, mask bowls, funnels, trays	Plastic accessory not more specifically covered elsewhere	Use only when no more specific HS applies	Indicative 15%–30%	Indicative 10%–20%	Usually 10%	Review FTA and PSR by final HS	Catalogue, material, photos, use description
4819.xx	Paperboard boxes and printed retail packaging for cosmetics	Paper/paperboard material; retail/transport packaging	For empty paper boxes; reassess if imported as cosmetic set	Indicative 20%–30%	Indicative 15%–20%	Usually 10%	Review C/O for China/ASEAN/Korea/EU routes	Artwork, material spec, invoice, packing list
7010.xx	Glass bottles/jars for cosmetics, serum or perfume, imported empty	Glass material; container function	For empty glass containers only	Indicative 10%–20%	Indicative 5%–15%	Usually 10%	Review FTA by origin	Photos, capacity, material, catalogue, invoice, C/O
8309.xx	Metal caps, stoppers and closures for cosmetic containers	Metal closure part	Where metal material determines the nature	Indicative 15%–25%	Indicative 5%–15%	Usually 10%	Review CTH/CTSH/RVC requirements	Material spec, drawings/photos, invoice, C/O
9603.30	Makeup/cosmetic brushes	Brushes used for cosmetic application; non-electric	For separate brush or brush set	Indicative 30%–37.5%	Indicative 20%–25%	Usually 10%	C/O may reduce duty if eligible	Catalogue, brush material, packing list, C/O
9616.20	Powder puffs and cosmetic pads	Pads/puffs used to apply cosmetics; not impregnated	If impregnated with serum/lotion, reassess as cosmetics	Indicative 30%–37.5%	Indicative 20%–25%	Usually 10%	Review FTA by origin	Photos, material spec, label, invoice, C/O
8214.20	Manicure/pedicure tools	Hand-operated personal care tools	Not for electric salon devices	Indicative 20%–30%	Indicative 10%–20%	Usually 10%	Review preferential C/O by final HS	Catalogue, material, photos, instruction, invoice
9615.xx	Combs, hair clips and non-electric hair accessories	Combing/holding/styling function	Electric styling tools fall outside this group	Indicative 20%–37.5%	Indicative 15%–25%	Usually 10%	Review FTA route	Catalogue, photos, material list, invoice, C/O
7009.xx	Non-electric handheld/table cosmetic mirrors	Glass mirror; no LED, battery or charger	If LED/battery is integrated, reassess as electrical goods	Indicative 20%–30%	Indicative 15%–20%	Usually 10%	Review FTA and origin	Photos, catalogue, material, label, packing list

SPECIAL PREFERENTIAL C/O/FTA ROUTES TO REVIEW

Route/origin	FTA/agreement	C/O or origin proof	Possible preferential duty	Conditions	Documents to check	Application note
ASEAN	ATIGA	Form D or valid origin document	May be 0% if HS and rules are satisfied	WO/RVC/CTH/CTSH and direct transport	C/O, invoice, packing list, B/L, product description	Check that goods are empty packaging/accessories, not finished cosmetics.
China	ACFTA or RCEP	Form E / RCEP C/O	May reduce to 0%–5% depending on HS	Correct form, PSR and third-party invoicing if any	C/O, invoice, B/L, catalogue	Common issue: C/O HS/description does not match the customs declaration.
Korea	AKFTA / VKFTA / RCEP	Form AK / VK / RCEP	Many lines may reduce to 0% if eligible	PSR by final HS and direct transport	C/O, invoice, material declaration if needed	Review kits with brushes/sponges/boxes carefully.
Japan	VJEPA / AJCEP / CPTPP / RCEP	Relevant C/O or CPTPP origin statement	Depends on HS and schedule	Origin rule, transport documents and item description	Origin proof, invoice, B/L/AWB, catalogue	Do not use one form for all items if HS lines differ.
EU / UK	EVFTA / UKVFTA	EUR.1 or self-certification where applicable	Preferential rate follows treaty schedule	Meet origin and documentary conditions	Origin proof, invoice, HS description, transport docs	Check actual production origin if purchased via trader.
Australia – New Zealand	AANZFTA or CPTPP	AANZ form or CPTPP origin document	Preferential rate by schedule	Eligible origin, direct transport, PSR	C/O, B/L, invoice	Review private-label goods made in third countries.
India / Hong Kong	AIFTA / AHKFTA	Form AI / Form AHK	Depends on HS and schedule at declaration date	Valid form and origin criteria	C/O, invoice, packing list, catalogue	Quality certificate is not a substitute for origin proof.

C/O checklist before ETA: form, origin criterion WO/RVC/CTH/CTSH, goods description, HS, quantity, weight, origin country, third-party invoice if any, direct transport, signature/stamp, issue date and validity.

DOSSIER & FILING METHOD

For empty/non-electric goods, the core dossier is commercial documents, product technical evidence and labeling documents. If filled/impregnated cosmetics or cosmetic sets are involved, a cosmetic notification dossier may be triggered.

Dossier group	Required documents	Used for	Common errors
Commercial documents	Commercial Invoice, Packing List, B/L/AWB, Sales Contract/PO, C/O if claiming preference	Customs declaration, value, quantity, origin and delivery terms review	Generic item name; missing material/function; no line split for kits
Technical/product documents	Catalogue, photos, material declaration, packing specification, capacity/size, user instruction	HS classification and explanation that goods are empty/non-electric/not impregnated	No proof that goods are empty, non-electric or not impregnated
Label documents	Original label, proposed Vietnamese supplementary label, artwork, manufacturer/origin details	Post-clearance circulation control	Foreign-only label, missing origin or responsible entity
Specialized cosmetic documents if triggered	Cosmetic notification, CFS, LOA, PIF, formula and cosmetic label	Only when goods are filled/impregnated cosmetics or sold as cosmetic set	Treating filled cosmetics as mere accessories or vice versa

OPERATIONAL DOSSIER CHECKLIST

Dossier group	Documents	Used for	Owner	Common errors	Pre-ETA check
Commercial	Invoice, Packing List, Contract/PO, B/L/AWB	Customs declaration and valuation	Importer / Supplier / Forwarder	Generic description; quantity mismatch; missing UOM	Match item names, line items, packages, gross/net weight and Incoterms before ETA
HS – technical	Catalogue, photos, material breakdown, use, capacity/size	HS classification and policy explanation	Importer / Compliance / Supplier	Cannot prove empty/non-electric/non-impregnated status	Obtain supplier confirmation on material, function and condition
C/O	Valid C/O form or origin document	Special preferential duty claim	Supplier / Exporter / Importer	HS/description mismatch; missing direct transport proof	Check form, origin criterion, invoice, B/L, issue date and origin country
Labeling	Original label, supplementary label, artwork, packaging photos	Domestic circulation	Missing origin/responsible party or misleading cosmetic claim	Review label before printing or affixing supplementary label
Cosmetic dossier if triggered	Notification, CFS/LOA/PIF, formula, cosmetic label	For filled/impregnated goods or cosmetic sets	No notification although the product contains cosmetics	Separate empty accessory lines from finished cosmetic lines

LEGAL BASIS & SPECIALIZED POLICY MATRIX

Legal review should follow product classification. The same “beauty accessory” name may lead to a different route if the product is filled, impregnated, electric, imported for sale or imported for factory use.

Legal group	Document	Issuing body	Effective date	Role	Articles/clauses/appendices to note	Review note
Cosmetics management	Circular 06/2011/TT-BYT	Ministry of Health	Effective from 01/04/2011	Basis for cosmetic definition, notification and dossier retention	Appendix 01-MP and rules on cosmetic notification, product information file and record responsibility; triggered only when the goods are actually cosmetics.	Only triggered if goods are finished cosmetics or filled/impregnated accessories
Cosmetics amendment	Circular 34/2025/TT-BYT	Ministry of Health	Effective 18/08/2025	Amends Circular 06/2011/TT-BYT	Amended requirements on notification dossier, CFS/LOA, e-filing or market-responsible entity where applicable.	Review at filing date if cosmetic element exists
Goods labeling	Decree 43/2017/ND-CP and Decree 111/2021/ND-CP	Government	Decree 43 effective 01/06/2017; Decree 111 effective 15/02/2022	Basis for labels and Vietnamese supplementary labels	Mandatory labeling contents for imported goods; supplementary label before circulation; goods name, origin and responsible entity.	Check item name, origin, responsible entity, quantity and warnings
Import duty	Decree 26/2023/ND-CP, Decree 108/2025/ND-CP and current tariff schedules	Government	Decree 26 effective 15/07/2023; Decree 108 effective 19/05/2025	MFN and duty review by final HS	Tariff schedule by final 8-digit HS; verify duty at declaration date and effective amendments.	Do not finalize duty without final 8-digit HS and declaration date
FTA/C/O	Special preferential tariff decrees by FTA	Government/MOIT	By agreement and period	Basis for special preferential duty	Special preferential tariff schedules and origin rules under each FTA; check C/O form, WO/RVC/CTH/CTSH criteria and direct transport.	Check C/O form, origin criteria and direct transport

Goods situation	Legal basis to review	Possible policy	Authority/portal if identified	Policy trigger
Empty packaging/non-electric accessories/no cosmetics	HS, Decree 43/2017, Decree 111/2021, tariff schedule	Customs clearance by HS, labeling and technical documents; not automatically cosmetic notification	Customs; enterprise label control	Catalogue, material and confirmation of empty/non-electric/non-impregnated status are available
Packaging imported together with finished cosmetics	Circular 06/2011, Circular 34/2025, cosmetic labeling	Review cosmetic notification for the filled product; accessory may be part of set	DAV/public service portal or competent authority	Cosmetic product is included and sold under one set/SKU
Impregnated or filled beauty accessory	Circular 06/2011, Circular 34/2025	May be treated as finished cosmetics	Cosmetics authority	Pads/wipes/masks/sponges impregnated with serum, lotion, cleanser or remover
Accessory with battery, charger, LED, motor or RF	Electrical/ICT/battery policy if any	Outside non-electric group; switch policy review	Customs and relevant authority	Adapter, lithium battery, charger, Bluetooth/Wi-Fi or LED exists
Sample/R&D goods not for sale	Sample purpose and customs supporting documents	May differ from commercial circulation; purpose must be evidenced	Customs/internal compliance	Invoice/PO states sample/R&D and quantity is reasonable
EPE/FDI/factory imports for production packaging	Import type, production use and records	Review import type and retention of packaging/material records	Enterprise customs branch	Imported for production/packing with production plan or contract

Circular 06/2011/TT-BYT Circular 34/2025/TT-BYT Decree 43/2017/ND-CP Decree 111/2021/ND-CP

PROCESSING TIME, FEES & RISK COSTS

If the goods are merely empty/non-electric accessories, there is usually no separate cosmetic state fee at import. Main cost drivers are duty, VAT, local charges, supplementary labeling and storage if documents must be corrected.

Timing	Action	State fee/cost if any	Risk cost if delayed
Before booking / before ETD	Collect catalogue, photos, material, function and confirmation of empty/non-electric/non-impregnated status	No separate state fee for internal review	Insufficient data delays HS and landed cost confirmation
5–7 days before ETA	Lock invoice, packing list, B/L/AWB, C/O, goods description and label	Depends on forwarder/carrier	Document errors delay D/O, customs filing and increase storage cost
At customs declaration	Declare HS, value, origin and description; submit documents by channel	Duty/VAT by declaration; local charges by port/carrier	Wrong HS or vague description may trigger catalogue request
After clearance	Affix supplementary label if needed; retain shipment records, C/O and technical documents	Label/storage cost by actual case	Insufficient label/claim control may create market surveillance risks

PRACTICAL E2E PROCESS

Pre-ETA review

Identify whether the goods are empty packaging, dry accessories, multi-component kits or filled/impregnated cosmetics; collect catalogue, photos and material data.

Lock documents

Align invoice, packing list, B/L/AWB, C/O, item names, quantities, SKU/model and origin before pre-alert.

Finalize HS, duty and C/O

Classify by material/function; check MFN, VAT, FTA preference and C/O conditions before declaration.

Check specialized triggers

Confirm whether cosmetics notification, electrical policy, battery controls or labeling requirements are triggered.

Customs filing and channel handling

Prepare technical evidence for green/yellow/red channel review, especially photos and material/function explanation.

Release and record retention

Control supplementary labeling and retain HS, C/O, technical and labeling records for post-clearance review.

FAQ

Does empty cosmetic packaging need cosmetic notification?

If it is empty, not filled and not impregnated with cosmetics, it is generally not treated as a finished cosmetic product. HS, labeling and technical documents still need review.

Are makeup brushes, sponges and powder puffs cosmetics?

They are usually non-electric beauty tools/accessories if they do not contain or carry cosmetic preparations. If impregnated with serum, powder, lotion or remover, reassess under cosmetics rules.

Do empty bottles, pumps and droppers need CFS or cosmetic notification?

When imported separately as empty packaging, the focus is HS, labeling and technical documentation. CFS/notification arises when the actual product is cosmetic or part of a cosmetic set.

How should a travel bottle set be classified?

Review whether the set has an essential character or whether each item should be declared separately. A detailed packing list and separate invoice lines reduce HS risk.

Is an LED cosmetic mirror still non-electric?

No. A mirror with LED, battery, charging port or adapter must be reassessed as electrical goods and may involve battery/shipping controls.

Do beauty accessories require Vietnamese supplementary labels?

Imported goods circulated in Vietnam need labeling review under Decree 43/2017 and Decree 111/2021. Required content depends on the product and retail packaging.

Can the declaration describe the goods as beauty accessories only?

Avoid generic descriptions. Use specific item names, material, function and condition such as empty plastic cosmetic bottle, makeup brush set or cosmetic powder puff.

Can C/O reduce import duty?

Potentially yes, depending on final HS and origin. Check C/O form, origin criterion, direct transport, item description and HS before claiming preference.

Do R&D/sample accessories follow commercial procedures?

Customs declaration and supporting documents are still needed. The sample/R&D purpose should be evidenced and quantities should be reasonable.

What should an EPE/factory importer retain?

Retain shipment records, import type, internal use/production records, catalogue, BOM/usage plan and technical supporting documents.

OUTPUTS & POST-CLEARANCE OBLIGATIONS

Output	Operational meaning	Post-clearance obligation/record
Cleared customs declaration	Basis for releasing goods to warehouse/circulation	Keep declaration, invoice, packing list, transport document and C/O
HS and technical dossier	Evidence for customs review or post-clearance audit	Keep catalogue, material declaration, photos and use description
Labeling dossier	Supports compliant circulation	Keep original label, supplementary label, artwork and post-labeling photos
Cosmetic dossier if triggered	Only for filled/impregnated cosmetics or cosmetic sets	Keep notification, CFS/LOA/PIF, labels and related documents

EXECUTION SUPPORT FROM TGIMEX

For non-electric beauty packaging and accessories, the key control point is to confirm the actual nature of goods before ETA: empty or filled, non-electric or electrical, dry accessory or impregnated cosmetic, commercial sale or factory use.

HS – duty – C/O review

Split HS by material/function and review MFN, VAT, FTA preference and C/O conditions.

Technical dossier control

Prepare catalogue, photos, material declaration and confirmation of empty/non-electric/non-impregnated condition.

Labeling review

Check original label, Vietnamese supplementary label, origin, responsible party and claims.

Cosmetic route separation

If cosmetics are included or impregnated, switch to cosmetic notification and PIF/CFS/LOA review.

Clearance coordination

Coordinate documentation, customs filing, D/O, trucking and warehouse delivery.

Post-clearance records

Retain customs, C/O, catalogue, label and technical evidence by shipment.

Execution scope: HS review, policy review, C/O review, labeling review, technical dossier preparation, import logistics coordination and post-clearance record control.

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