Tiếng Việt
中文 (中国)
Butter cookies are straightforward commercially but compliance must lock the biscuit/wafer nature, cocoa content, butter–milk–egg ingredients, self-declaration dossier, import food-safety inspection, nutrition label, C/O and HS code as one consistent data set. A mismatch among formula, label, origin document and customs declaration can delay release or remove tariff preference.
The article follows an E2E review map: identify the exact butter-cookie SKU and recipe, lock HS/tax/C/O, prepare food-safety and labelling files, control documents before ETA, process customs, and retain the post-clearance audit trail.
Operational reference for importers, procurement, legal, compliance, operations and documentation teams.
Scope: finished sweet butter cookies packed for retail or commercial distribution in Vietnam. It does not automatically cover wafers, savory crackers, special-diet foods, products for young children, health supplements or goods of a different nature.
QUICK FACTS
1905.31.10: sweet biscuits not containing cocoa; 1905.31.20: sweet biscuits containing cocoa.
Reference MFN 15%; ordinary rate 22.5% where the ordinary tariff regime applies.
8% if eligible for the VAT reduction under Decree 174/2025 through 31 Dec 2026; otherwise the statutory rate applies.
Ordinary butter cookies are prepacked processed foods generally subject to self-declaration under Articles 4–5 of Decree 15/2018.
HS 1905.31.10/.20 are listed under Circular 28/2026 for state food-safety inspection managed by MOIT.
Circular 30/2026 applies from 10 July 2026; butter cookies with added sugar must also review the total sugars declaration requirement.
2. KEY TERMS & WHY THE PROCEDURE MATTERS
The business self-declares eligible prepacked processed food and bears responsibility for product safety; this is not a separate “butter-cookie import licence”.
State inspection of imported food. Decree 15 provides three methods: reduced, normal and strict inspection.
Estimated Time of Arrival. HS, C/O, labels and food-safety documentation should be substantially locked before ETA.
Origin evidence used to establish origin and, if all conditions are met, claim special preferential import duty.
A product variant code. Changes in recipe, cocoa, net weight or artwork may change the dossier comparison scope.
Demurrage/Detention – possible logistics costs when cargo is held because documents or approvals are incomplete.
3. DETAILED PRODUCT CLASSIFICATION
Before fixing policy, obtain at least the ingredient list/formula, specification, original artwork/label, product photos, sufficient process information to distinguish baked/fried, manufacturer, origin, SKU and import purpose.
| Product/situation | Technical signs to check | Example | Evidence | Potential policy | Documents to reconcile | Application note |
|---|---|---|---|---|---|---|
| Sweet butter cookie, no cocoa | Baked sweet biscuit; no cocoa/chocolate/cocoa powder in formula | Danish butter cookies, shortbread | Ingredients, spec, artwork, photos | HS 1905.31.10; self-declaration; food-safety inspection; label | Formula, test report, self-declaration, label | Primary reference branch if the product is genuinely a sweet biscuit. |
| Butter cookie with cocoa/chocolate | Cocoa powder, chocolate chips/coating or cocoa-containing ingredient | Chocolate butter cookie | Formula, ingredient breakdown, label | HS 1905.31.20; self-declaration; inspection; label | Ingredients, cocoa information, test report | Confirm actual cocoa content rather than relying on product name. |
| Sandwich/filled/coated butter biscuit | Filling or coating; must still distinguish biscuit from wafer | Cream-filled butter biscuit | Cross-section photos, spec, formula | May remain within 1905.31 but classification depends on actual nature | Spec, formula, catalogue | Do not copy the plain-cookie code across every variant. |
| Butter wafer/waffle | Layered wafer/waffle structure | Butter wafer | Photos, catalogue, spec | May move to 1905.32.xx | Spec and cross-section image | Outside the core 1905.31 scope. |
| Savory/non-sweet cracker | Not a sweet biscuit | Savory butter cracker | Formula/spec | May fall under 1905.90.xx | Spec, label | Do not use 1905.31 merely because the name says biscuit. |
| Sample/R&D/export-production use | Not for domestic commercial circulation; purpose documented | R&D sample | Purpose letter, contract, production records | Possible self-declaration/inspection exemption if exact conditions are met | Purpose documents | Small quantity alone does not create an exemption. |
4. HS CODE – TAX – C/O
Heading 19.05 covers bread, pastry, cakes, biscuits and other bakers’ wares, whether or not containing cocoa. For a genuine sweet butter biscuit, the first two branches to review are 1905.31.10 and 1905.31.20. Circular 28/2026 also directly lists both codes for MOIT food-safety inspection.
| Reference HS | Suitable description | Classification basis | Condition | Ordinary duty | MFN duty | VAT | C/O/FTA to review | Evidence |
|---|---|---|---|---|---|---|---|---|
| 1905.31.10 | Sweet biscuits – not containing cocoa | Heading 19.05; sweet biscuit branch | Actual butter cookie is a sweet biscuit and contains no cocoa | 22.5% reference | 15% | 8% if VAT-reduction conditions are met through 31/12/2026 | ATIGA, ACFTA, RCEP, VKFTA/AKFTA, VJEPA/AJCEP, CPTPP, EVFTA, UKVFTA… | Ingredients, spec, label, invoice, C/O |
| 1905.31.20 | Sweet biscuits – containing cocoa | Heading 19.05; sweet biscuit branch with cocoa | Recipe/label confirms cocoa/chocolate | 22.5% reference | 15% | 8% if eligible through 31/12/2026 | Relevant FTA by origin | Formula, cocoa data, spec, label, invoice, C/O |
Reconfirm tariff rates on the customs-registration date using the final HS code, origin and legislation then in force. The 22.5% ordinary rate is a reference under Decision 15/2023 where applicable; MFN 15% follows the tariff under Decree 26/2023 and current amendments.
SPECIAL-PREFERENTIAL C/O/FTA MATRIX BY IMPORT ORIGIN
| Origin/route | FTA | C/O/origin evidence | Preferential rate where supported | Conditions | Documents | Note |
|---|---|---|---|---|---|---|
| China | ACFTA; compare RCEP | Form E or valid origin evidence under the applicable mechanism | ACFTA: 0% for 1905.31.10/.20 when all conditions are met | Origin rule, transport/document conditions under Decree 118/2022 | C/O, invoice, B/L, PL, HS, origin criterion | Do not assume RCEP is always more favorable than ACFTA. |
| ASEAN | ATIGA | Form D/e-Form D or applicable origin evidence | Check 2026 ATIGA schedule by country and final HS | ASEAN origin and valid PSR | Origin evidence, invoice, transport docs | Confirm the actual exporting/origin country. |
| EU – e.g. Denmark | EVFTA | EUR.1 or EVFTA origin evidence as applicable | Check 2026 EVFTA schedule | Valid PSR and documentary conditions | Origin proof, invoice, transport docs, BOM/recipe where needed | Danish branding does not itself prove EVFTA origin. |
| Korea | VKFTA/AKFTA/RCEP | Evidence under the selected FTA | Check 2026 schedule | Correct PSR/origin/documentation | C/O, BOM if needed, invoice, B/L | Select the useful FTA only when its evidence is available. |
| Japan | VJEPA/AJCEP/CPTPP/RCEP | Evidence under each agreement | Check 2026 schedule | Correct PSR and documents | Origin proof, invoice, B/L | Do not use one certificate format for every agreement. |
5. DOSSIER & OPERATIONAL SUBMISSION PRINCIPLES
Commercial Invoice, Packing List, B/L or AWB, Contract/PO if any, C/O if preference is claimed.
Ingredient list/formula, product specification, original artwork/label, images, test report, self-declaration, nutrition data.
Self-declaration, inspection registration, shipment documents and evidence for the applicable inspection method/exemption.
Operational filing principle: separate the product self-declaration file, the import food-safety inspection file and the customs dossier, then prepare each set according to the method applicable to the actual shipment. This article stays at operational level and does not replace the competent authority’s filing instructions in force at the time of submission.
OPERATIONAL DOSSIER CHECKLIST
| Dossier group | Required documents | Used at | Typical owner | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, PL, B/L/AWB, Contract/PO | Customs, inspection, C/O | Shipper/Importer/Docs | Description/qty/weight/origin mismatch | Compare against one SKU master-data sheet and draft declaration. |
| Formula & technical | Ingredients, formula/spec, images, process info | HS, declaration, label | Supplier/Brand/QA | Cocoa unclear; formula revision differs from artwork | Freeze the formula and artwork revision for the exact SKU. |
| Self-declaration | Form 01 + food-safety test report within 12 months | Self-declaration and import dossier | Importer/Compliance | Expired test, product-name mismatch, missing safety parameters | Check test date, lab scope, product name and limits. |
| Import food-safety inspection | Documents required by the applicable method | Before/at arrival | Importer/Forwarder/Compliance | Late registration or wrong inspection method | Determine exemption/reduced/normal/strict status before ETA. |
| C/O | FTA-specific origin evidence | Preferential duty claim | Exporter/Docs | HS/description/invoice/date mismatch | Pre-check draft C/O against invoice, B/L and draft entry. |
| Label | Original label, Vietnamese supplementary label, nutrition data | Customs/market circulation | Supplier/Brand/Importer | Missing origin/manufacturer; outdated nutrition panel | Review Decree 43/2017, Decree 111/2021 and Circular 30/2026 before printing/importing. |
6. LEGAL BASIS & SPECIALIZED-POLICY MATRIX
6.1. LEGAL BASIS TO REVIEW
| Document group | Instrument | Authority | Effective/application | Role | Key provisions | Review note |
|---|---|---|---|---|---|---|
| Law | Food Safety Law 55/2010/QH12 | National Assembly | 01/07/2011 | Food-safety framework and imported food | Articles 38–40 and related provisions | Read together with Decree 15 and specialized rules. |
| Decree | Decree 15/2018/NĐ-CP | Government | 02/02/2018; continues during Resolution 15/2026 suspension period | Self-declaration; exemptions; import-inspection method, dossier and process | Arts. 4–5; 13; 16–19 | Core butter-cookie procedure framework in 2026. |
| 2026 Resolution | Resolution 15/2026/NQ-CP | Government | 06/04/2026 | Suspends Decree 46/2026 and Resolution 66.13/2026 | Articles 1–2 | Decree 15 and related guidance continue during the suspension. |
| MOIT Circular | Circular 28/2026/TT-BCT | Ministry of Industry and Trade | 17/07/2026 | HS list for state food-safety inspection | 1905.31.10; 1905.31.20; Arts. 3–5 | Clause 1 Article 2 and Annex 2 of Decision 1182/QĐ-BCT cease to apply under Article 4; transition applies to earlier-filed dossiers. |
| MFN tariff | Decree 26/2023/NĐ-CP and current amendments | Government | From 15/07/2023 | Preferential import tariff | Chapter 19 / 19.05 | Reference MFN for 1905.31.10/.20: 15%. |
| Ordinary tariff | Decision 15/2023/QĐ-TTg | Prime Minister | 15/07/2023 | Ordinary import tariff mechanism | By HS/eligibility | Reference 22.5% for the two codes where ordinary tariff applies. |
| VAT | Resolution 204/2025/QH15 + Decree 174/2025/NĐ-CP | National Assembly/Government | 01/07/2025–31/12/2026 | 2-point VAT reduction for eligible 10% goods/services | Arts. 1–2 | Review exclusion lists; eligible butter cookies are 8%. |
| General label | Decree 43/2017 + Decree 111/2021 | Government | 01/06/2017; amendment from 15/02/2022 | Imported-goods labels/supplementary labels | Mandatory label particulars | Reconcile original and Vietnamese label before circulation. |
| Nutrition label | Circular 30/2026/TT-BYT | Ministry of Health | 10/07/2026 | Nutrition components and values on food labels | Arts. 5, 7, 8 | Circular 29/2023 ceased; transitional rule only covers Article 8 cases. |
| Food additives | Circular 24/2019/TT-BYT – remaining effective provisions plus current amendments/replacements | Ministry of Health | Effective 16/10/2019; partially expired | Additive authorization/use limits | Review actual ingredients | Use the legislation currently in force for the exact additive and food category. |
| Veterinary guidance | Official Letter 1002/TY-KD dated 29/05/2017 | Department of Animal Health | Operational guidance | Clarifies confectionery containing dairy/animal ingredients | Item 2 | Reference guidance only; reassess when the product nature changes. |
6.2. SPECIALIZED-POLICY MATRIX BY GOODS SITUATION
| Situation | Basis | Possible policy | Competent authority / regulator (high level) | Trigger |
|---|---|---|---|---|
| No-cocoa butter cookie – commercial import | Decree 15/2018; Circular 28/2026 | Self-declaration + import food-safety inspection + label + customs | Food-safety inspection authority/customs | HS 1905.31.10; commercial circulation; no exemption. |
| Butter cookie with cocoa/chocolate | Same | Same controls, different cocoa/HS branch | Same | Recipe/label contains cocoa; reference HS 1905.31.20. |
| Recipe uses additives | Current effective provisions of Circular 24/2019 and amendments | Review permitted additive, food category and use level | Food-safety compliance | Color, preservative, sweetener, emulsifier, raising agent, etc. |
| Contains butter/milk/egg | Letter 1002/TY-KD + actual dossier | No automatic veterinary quarantine solely because confectionery contains animal ingredients | Recheck with animal-health authority if nature is unclear | Only while the actual good remains confectionery; separate dairy/animal products require reassessment. |
| R&D sample | Article 13 Decree 15/2018 | Potential food-safety inspection exemption if exact conditions are met | Authority/customs per dossier | Purpose confirmed and quantity suitable for testing/research. |
| New label after 10/07/2026 | Decree 43; Decree 111; Circular 30/2026 | Supplementary label + nutrition label requirements | Food safety/market surveillance/customs by stage | Food circulating in Vietnam; Article 8 transition checked. |
OFFICIAL LEGAL SOURCES FOR CROSS-CHECKING
7. PROCESSING TIME, FEES & LOGISTICS-RISK COSTS
| Task | Grounded time reference | Operational meaning | Cost/risk |
|---|---|---|---|
| Self-declaration | Not an approval-wait procedure; follow Article 5 of Decree 15 | Form 01 and a suitable test report must be ready for the product/import dossier | Testing cost; SKU mismatch risk. |
| Reduced inspection | Customs reviews selected dossiers within 3 working days | Article 19 of Decree 15; not every reduced-inspection shipment is selected | Delay if file is incomplete. |
| Normal inspection | State authority issues result within 3 working days from complete dossier | Clock assumes a complete dossier | Storage/DEM/DET if filing is late. |
| Strict inspection | Within 7 working days from dossier; sampling/testing involved | Triggered under Article 17 | Testing cost + storage/container delay. |
| Tax/VAT/C/O | At customs-registration time | Lock HS and origin before transmitting declaration | Invalid C/O may remove preference; wrong HS may lead to reassessment. |
Actual lead time varies with dossier completeness, customs channel, supplementation requests and shipment condition. No unofficial fee or fixed processing time is assumed.
8. END-TO-END PRACTICAL WORKFLOW
Preferably 10–20 days before ETA: collect formula, spec, artwork, manufacturer, origin and SKU; distinguish biscuit/wafer and cocoa/no-cocoa. Stop point: do not finalize HS/C/O while the formula is unclear.
Review 1905.31.10/.20, MFN/FTA schedules and origin evidence. Pre-check C/O before issuance. Stop point: HS and description on origin documents must align logically with the goods and customs declaration.
Prepare Form 01, a test report within 12 months and product master data. Do not freely reuse tests or declarations across a materially different SKU.
Reconcile original and Vietnamese supplementary labels, ingredients/allergens and nutrition panel under Circular 30/2026. Added-sugar cookies review total sugars; fried foods review saturated fat.
Determine exemption/reduced/normal/strict method under Decree 15; prepare and file the dossier before or at arrival as applicable. Previous reduced-inspection history does not automatically decide a new shipment.
Declare HS, product description, brand/SKU, origin, quantity, value, C/O and commodity policy consistently. Green/Yellow/Red channels respectively mean system release under applicable rules, documentary review, or documentary/physical inspection as required.
After customs conditions are met, coordinate delivery and complete Vietnamese supplementary labelling before market circulation where required; reconcile carton/SKU/expiry/label against declared documents.
Retain declaration, test, self-declaration, inspection result, C/O, invoice/PL/B/L, artwork and reconciliation record. Reassess any change in recipe, supplier, origin or packaging before the next shipment.
9. FAQ
Ordinary packed butter cookies are not handled through a product-specific “butter-cookie import licence”. The key layers are self-declaration, state food-safety inspection, labels, customs, tax and origin evidence; special-purpose products require separate review.
Generally yes if they are prepacked processed food circulated in Vietnam and are not in a registration or exemption category under Decree 15/2018.
HS 1905.31.10 and 1905.31.20 are listed in Circular 28/2026. Commercial shipments must review the state-inspection requirement unless a valid exemption applies under Decree 15.
4. Which HS code applies?
Reference 1905.31.10 for sweet biscuits without cocoa and 1905.31.20 with cocoa. Wafers, savory crackers and materially different products need separate classification.
5. Does butter/milk/egg trigger animal quarantine?
Not automatically. Department of Animal Health Letter 1002/TY-KD states confectionery containing milk or other animal products is not subject to quarantine. Reassess if the actual import is a dairy/animal product rather than confectionery.
6. What is the VAT rate in 2026?
If the goods fall within the 10% category eligible for Decree 174/2025 reduction and are not excluded, the reduced 8% rate runs through 31 December 2026. Check the final HS and exclusion annex at declaration date.
ACFTA may be reviewed: Decree 118/2022 shows 0% for 1905.31.10/.20 where all conditions are met. Origin rules and valid evidence, commonly Form E under the applicable mechanism, remain mandatory.
8. What nutrition information is required from July 2026?
Circular 30/2026 requires review of energy, protein, carbohydrate, fat and sodium; added-sugar foods also review total sugars; fried foods review saturated fat, subject to the small-value exceptions in Annex I.
9. Are a few sample boxes automatically exempt?
No. Apply the exact Article 13 exemption conditions and keep evidence of test/research purpose and a quantity consistent with that purpose.
10. Can a declaration/test report be reused for a similar SKU?
Do not assume so. A change in recipe, cocoa, brand/SKU, manufacturer, label or other core product data requires a fresh scope assessment before reuse.
10. FINAL OUTPUTS & POST-CLEARANCE / POST-APPROVAL OBLIGATIONS
Self-declaration, test report, ingredients/formula, specification and label artwork should match the exact imported SKU.
Invoice, Packing List, B/L/AWB, customs declaration and transport documents should align on product, quantity, origin and packing.
Retain the food-safety inspection result/notice and evidence supporting the applicable inspection method or exemption where relevant.
Complete the Vietnamese supplementary label, nutrition information and other mandatory particulars before market circulation.
Retain records by shipment and SKU version for reconciliation, post-clearance review and regulatory inspection.
Any change in manufacturer, origin, recipe/cocoa, additive, packaging, net weight or claim should be reviewed before the next shipment.
TGIMEX IMPLEMENTATION SUPPORT
For butter cookies, the main risk is not one isolated document but maintaining one consistent chain of HS – recipe/cocoa – self-declaration – food-safety inspection – C/O – label – transport documents from pre-ETA through post-clearance.
Review SKU, HS 1905.31.10/.20, tax/origin, self-declaration, testing, labels and nutrition data before arrival.
Reconcile Invoice, PL, B/L/AWB, C/O, formula/spec, artwork, test report and food-safety dossier against one master data set.
Track ETA, pre-alert, specialized inspection, customs channel, port/warehouse/delivery and post-clearance records.
The operational objective is to complete most compliance work before ETA, reducing late supplementation, storage, DEM/DET and distribution disruption.
Legal note: Updated to 8 September 2026 for operational reference. This English version is not an official legal translation. Final HS, tax, FTA, authority and inspection conditions must be rechecked against the actual dossier and Vietnamese legislation effective on the customs-registration date.
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