Fruit hard candy can look simple, yet a change in composition or function — cough lozenges, gelatin gummies, cocoa-containing confectionery, or products containing special plant materials — can change the HS classification and the compliance route. A 2026 dossier must also reflect two important updates: Circular 28/2026/TT-BCT, effective 17 July 2026, and the mandatory nutrition-label implementation milestone from 1 January 2026.

This article maps the end-to-end route from product identification → HS/tax/origin → self-declaration → state food-safety inspection → customs clearance → labeling and post-clearance records. It is written for retail-packed fruit-flavoured hard candy with no cocoa, no gelatin gummy texture, and no medicinal claim.

Operational reference for importers and supply-chain teams. Final conclusions must be locked against the actual ingredient list, specification, label artwork, origin and shipment dossier. This English text is not an official legal translation.

QUICK FACTS

SCOPE

Product scope

Retail-packed hard fruit candy based mainly on sugar/glucose syrup, fruit flavour/extract, food acids and permitted additives; excluding cocoa confectionery, gelatin gummies and medicinal lozenges.

Reference HS

1704.90.99 – Other, under sugar confectionery not containing cocoa. Confirm only after reviewing formula, physical form and function.

Specialized control

Confectionery is under food-safety control of the Ministry of Industry and Trade; HS 1704.90.99 appears in the list under Circular 28/2026/TT-BCT.

TAX

2026 tax reference

For HS 1704.90.99: reference MFN 15%; ordinary import duty 22.5%. Standard VAT is 10%; 8% may apply through 31 Dec 2026 where the item is eligible for the temporary reduction.

LABEL

2026 label point

Imported food for circulation in Vietnam must satisfy goods-label rules; from 1 Jan 2026, food within Circular 29/2023/TT-BYT must comply with nutrition-label requirements.

2026

Critical legal transition

Resolution 15/2026/NQ-CP suspends Decree 46/2026 and Resolution 66.13/2026; during the suspension, Decree 15/2018 and relevant effective rules remain the operational basis.

Do not classify from the trade name “fruit candy” alone. Cocoa, gelatin-gummy texture, cough-lozenge positioning or special ingredients can change both HS and compliance requirements.

2. KEY TERMS & WHY THEY MATTER

HS Code

Customs classification used to determine tariff treatment and product-policy requirements. For hard candy, the decisive facts include cocoa/gelatin content and actual product function.

State food-safety inspection

Import food-safety control conducted under reduced, normal or strict inspection depending on statutory conditions and compliance history.

Self-declaration

The self-declaration route for processed prepackaged food under Article 4 of Decree 15/2018; the dossier includes the declaration and a qualifying food-safety test report under Article 5.

C/O

Certificate/proof of origin

Origin evidence that can support a preferential FTA duty rate when the relevant rules of origin and documentary conditions are fulfilled.

MFN

MFN duty

Preferential import duty applied under Vietnam’s MFN framework when no special FTA rate is claimed.

ETA

Estimated Time of Arrival. Product declaration, label data and the selected food-safety inspection route should be locked before ETA to reduce storage and amendment risk.

Why this matters: the import is not only a customs declaration. The compliance chain links formula, testing, self-declaration, import food-safety inspection, labeling, tax, origin and post-clearance recordkeeping.

3. DETAILED PRODUCT IDENTIFICATION

Lock the product scope before reading the tariff or preparing a self-declaration. Minimum supplier data should include the technical product name, percentage ingredient list, specification, retail packing, claims, label artwork, finished-product photos and origin.

Product/scenario	Technical signs to check	Example/function	Evidence	Possible policy	Documents to review	Application note
Standard fruit hard candy	Hard/brittle; sugar/glucose base; no cocoa; no gelatin gummy texture; no medicinal claim	Hard fruit candy / fruit drops	Ingredient list, spec, product photos, label artwork	Food safety; self-declaration; labeling; tax/origin	Formula, COA/spec, test report, label	Primary scenario of this article; reference HS 1704.90.99.
Cough candy/lozenge	Cough-relief or throat-soothing positioning; functional ingredients	Cough drops / lozenges	Label, claims, composition, catalogue	Separate HS branch; additional product-function review may arise	Artwork, claim file, ingredient dossier	Do not automatically apply 1704.90.99; check 1704.90.10.
Gelatin gummy candy	Soft/chewy texture; gelatin used as gelling agent	Gummy candy	Formula, gelatin specification	HS 1704.90.91 branch; food safety; labeling	Ingredient list, testing, label	Separate from hard candy.
Cocoa/chocolate confectionery	Contains cocoa powder/mass or chocolate coating	Chocolate-coated fruit candy	Formula, BOM, label	Potential Chapter 18 classification; tariff must be rechecked	Composition, spec, artwork	Do not keep heading 17.04 if the product is legally a cocoa preparation.
Candy with special fruit/herbal inclusions	Visible fruit pieces, seeds or herbs that may retain plant-quarantine relevance	Candy with fruit pieces/herbal inclusions	Composition, ingredient origin, photos	Potential additional quarantine/food-safety checks depending on ingredient	Raw material COA/spec, label	Do not assume quarantine exemption solely because the finished product is candy.

Classification warning: a generic commercial name can cause a wrong HS code, wrong duty, wrong food-safety route and incorrect labeling. Tax figures below apply only to the standard hard-candy scenario.

4. HS CODE – TAX – ORIGIN

Main reference HS: 1704.90.99. The basis is sugar confectionery not containing cocoa and not falling into a more specific line for gum, cough drops, white chocolate or gelatin gummies. The final HS must be confirmed from the technical dossier.

PROPOSED HS – DUTY – C/O TABLE

Reference HS	Product group	Classification basis	Condition	Ordinary duty	MFN	VAT	FTA/origin to review	Evidence
1704.90.99	Other sugar confectionery, no cocoa	Heading 17.04; not gum, cough lozenge, white chocolate or gelatin gummy	Standard fruit hard candy under this article	22.5%	15%	10% standard; currently 8% through 31 Dec 2026 if eligible	ACFTA/ATIGA/AKFTA/VKFTA/AJCEP/VJEPA/RCEP/EVFTA etc.	Ingredient list, spec, photos, label
1704.90.10	Cough drops and lozenges	Separate tariff description	Cough/lozenge function	Check 2026 tariff	Check 2026 tariff	8%/10% subject to eligibility	FTA by origin	Claims, formula, label
1704.90.91	Soft, containing gelatin	Separate gelatin gummy line	Chewy/gummy product with gelatin	Check tariff	Check tariff	8%/10% subject to eligibility	FTA by origin	Formula, gelatin spec
Heading 18.06	Chocolate/cocoa food preparations	Cocoa changes legal character	Candy containing chocolate/cocoa	Determine 8-digit code	Determine code	8%/10% subject to eligibility	FTA by origin	BOM, cocoa content, spec

FTA / ORIGIN MATRIX BY SOURCE MARKET

Origin	FTA	Origin proof	Special rate to review	Conditions	Evidence	Note
China	ACFTA / RCEP	Form E or qualifying RCEP proof	For 1704.90.99, ACFTA reference 0% if all conditions are met	Product-specific origin rule, origin, transport and documentary compliance	C/O/proof, invoice, B/L, packing list	Compare ACFTA and RCEP; do not assume RCEP is automatically better.
ASEAN	ATIGA	Form D / e-Form D	ATIGA reference 0% for 1704.90.99 if eligible	ATIGA rules of origin	Proof of origin, invoice, B/L	Check description, HS, quantity and country of origin.
Korea	AKFTA / VKFTA / RCEP	Form AK / KV or RCEP proof	Potential very low/0% rate; verify the 2026 schedule and actual origin	Correct PSR and documentary route	Proof, invoice, transport docs	Select the best agreement only when its rules are met.
Japan	AJCEP / VJEPA / RCEP / CPTPP	Agreement-specific proof	Verify the applicable 2026 special tariff	PSR + proof + transport conditions	Origin proof, invoice, B/L	Do not transfer a rate from one agreement to another.
EU / UK	EVFTA / UKVFTA	EUR.1/statement/proof as applicable	Verify 2026 schedule and origin rule	Preferential origin and valid proof	Origin proof, invoice, transport docs	Review carefully where supplier uses self-certification.

C/O checklist: proof type, PSR, HS, goods description, third-party invoice where relevant, transport route, quantity/weight, origin country, issue date, authentication and consistency with the customs declaration.

5. DOSSIER & PREPARATION METHOD

Manage documents in three layers so the file is not merely “complete” but also data-consistent. This article stays at operational-principle level; the exact filing channel and competent receiving body must be checked for the actual shipment.

Commercial dossier

Sales Contract/PO where applicable; Commercial Invoice; Packing List; B/L or AWB; origin proof for preference; freight/insurance evidence where needed for customs value.

Technical & specialized dossier

Ingredient list; product specification/COA; original and Vietnamese label artwork; food-safety test; self-declaration; import food-safety inspection file; additive/flavour documents when relevant.

Registration & reconciliation set

Self-declaration Form 01; test report within the legal time limit; food-safety registration file according to the inspection method; evidence for reduced inspection if applicable; HS/origin/label reconciliation sheet.

Document-control rule: goods description, packing, quantity/weight, origin, manufacturer, batch references where used, HS logic and label data must be consistent across Invoice – Packing List – B/L/AWB – origin proof – self-declaration – labeling.

OPERATIONAL DOSSIER CHECKLIST

Dossier group	Required document	Used for	Typical owner	Common error	Pre-ETA control
Commercial	Invoice, Packing List, B/L/AWB, Contract/PO	Customs value and declaration	Importer + supplier + forwarder	Name/weight/origin mismatch	Use one master-data sheet to compare key fields.
Product	Ingredient list, spec, COA, photos, artwork	HS, self-declaration, label, food safety	Supplier + importer/QA	Only marketing catalogue; no percentage composition	Request controlled technical revision/date and supplier confirmation.
Self-declaration	Declaration + qualifying test report	Product self-declaration	Importer/brand owner	Test report expired or wrong parameters	Check the report date; Decree 15 requires a report within 12 months at filing.
Import food safety	Registration + documents for reduced/normal/strict route	State import food-safety inspection	Importer + operations provider	Wrong route selected; no evidence for reduced inspection	Review Articles 13 and 16–19 of Decree 15 before ETA.
Origin	C/O/proof + transport documents	Preferential duty	Supplier/exporter + importer	HS/description/date/transport mismatch	Field-by-field check against invoice, B/L and customs data.
Label	Original label, Vietnamese supplemental label, nutrition panel	Clearance/market circulation	Importer + supplier + regulatory	Missing nutrition data or inconsistent translation	Lock artwork against Decree 43/2017, Decree 111/2021 and Circular 29/2023 before printing.

6. LEGAL BASIS & SPECIALIZED-POLICY MATRIX

5.1. LEGAL DOCUMENTS TO REVIEW

Document group	Instrument	Issuer	Effective point	Role	Key provisions	Review note
Law	Law on Food Safety 55/2010/QH12	National Assembly	Effective 1 Jul 2011; check current amendments	Framework for imported-food safety and ministerial responsibilities	Articles 38, 40 and 64	Apply together with current implementing rules.
2026 transition	Resolution 15/2026/NQ-CP	Government	6 Apr 2026	Suspends Decree 46/2026 and Resolution 66.13/2026; maintains the current regime during suspension	Articles 1–2	Key NEW–OLD point for 2026 files.
Food-safety decree	Decree 15/2018/NĐ-CP	Government	2 Feb 2018; continues as operational basis during the suspension	Self-declaration, exemptions and import inspection methods	Articles 4–5, 13, 16–19, 39	Standard hard candy generally follows self-declaration + import inspection unless exempt.
2026 circular	Circular 28/2026/TT-BCT	Ministry of Industry and Trade	17 Jul 2026	List of imported goods subject to state food-safety inspection under MOIT	Articles 1–5; Annex item 5 includes 1704.90.99	From 17 Jul 2026, Clause 1 Article 2 and Appendix 2 of Decision 1182/QĐ-BCT cease to be effective; transition applies to dossiers filed earlier.
Goods labeling	Decree 43/2017/NĐ-CP as amended by Decree 111/2021/NĐ-CP	Government	Decree 111 effective 15 Feb 2022	Original imported label and Vietnamese supplemental label before circulation	Review mandatory food-label particulars	Supplemental label must not conceal mandatory original-label information.
Nutrition labeling	Circular 29/2023/TT-BYT	Ministry of Health	Effective 15 Feb 2024; compliance milestone 1 Jan 2026	Nutrition composition/value labeling	Article 5 and transition rules	Added-sugar confectionery requires particular attention to total sugars and mandatory nutrition items.
Food additives	Circular 24/2019/TT-BYT as amended by Circular 17/2023/TT-BYT	Ministry of Health	Per each instrument	Permitted additives and use conditions	Check food category and additive	Relevant to colours, flavours, acids, sweeteners, anti-sticking agents where used.
Tax	Decree 26/2023/NĐ-CP and tariff amendments; Decree 174/2025/NĐ-CP	Government	Temporary VAT reduction runs through 31 Dec 2026	MFN import duty and import VAT	Final HS and VAT-exclusion list	Lock tax on the customs-registration date.
Customs	Current Customs Law / Consolidated Document 54/VBHN-VPQH; Decree 08/2015 as amended, most recently by Decree 167/2025/NĐ-CP	National Assembly / Government	Current instruments	Customs declaration, examination and supervision	Review by customs procedure and shipment data	Law 11/2026/QH16 has been enacted but is not yet applicable on 8 Sep 2026; effective 1 Mar 2027.

NEW – OLD 2026: do not use Decree 46/2026 or Resolution 66.13/2026 as if they were the active operating regime on 8 Sep 2026. Resolution 15/2026 suspends them; Decree 15/2018 and relevant effective guidance remain the working basis during the suspension.

5.2. POLICY MATRIX

Scenario	Legal basis	Possible policy	Authority (high level)	Trigger
Standard retail hard candy	Decree 15/2018 + Circular 28/2026 + label rules	Self-declaration; import food-safety inspection; labeling; customs/tax	Food-safety authority under current allocation + Customs	Product falls within processed prepackaged food and listed HS/description.
Shipment qualifying for reduced inspection	Articles 16–17 Decree 15	Reduced inspection; files may be selected at the statutory sampling rate	Food-safety inspection body	Evidence that reduced-inspection criteria are met.
Warning/non-compliance or previous failure	Articles 17–19 Decree 15	Strict inspection, potentially including sampling/testing	Food-safety inspection body	Trigger based on compliance history, warnings or violations.
Samples, gifts, research, transit, export production, etc.	Article 13 Decree 15	May qualify for inspection exemption if conditions are met	Competent authority + Customs	Purpose, quantity and statutory exemption must be evidenced; “sample” wording alone is insufficient.
Cough/health claims	Decree 15 + product-specific rules	Potential HS and regulatory-route change	Relevant sector authority	Claims, composition and intended user alter legal character.
Cocoa/gelatin/special plant materials	Tariff + Circular 28 + relevant sector rules	HS change; additional dossier may arise	Sector authority / Customs	Actual composition, processing level and product form.

7. TIMELINE, FEES & COST RISK

A single fixed timeline is not appropriate because timing depends on the food-safety inspection route, file quality, testing outcome and customs channel. Only legally supported milestones are stated as numbers.

Step	Timing	Required output	Cost/risk control
Product/HS/label review	Before purchase order and at latest before ETA	Locked product scope, reference HS and artwork	Wrong HS/label may require declaration and document rework.
Testing & self-declaration	Before the commercial shipment; test report for self-declaration must be within 12 months under Article 5	Test report + self-declaration	Laboratory fee depends on parameters; no unsupported fixed fee should be quoted.
Inspection-route determination	Before ETA	Exempt/reduced/normal/strict route identified	Wrong route can lead to supplements and storage delay.
Normal inspection	Under Article 19, normal dossier review follows the statutory timeline after a complete file; reference 3 working days	Inspection result/notice	Longer if the file is incomplete or the route changes.
Strict inspection	Depends on sampling/testing and shipment status	Compliant food-safety result	Testing plus storage/DEM/DET risk.
Customs & delivery	After specialized and tax conditions are met under the assigned customs channel	Clearance/release as applicable	Yellow/Red channel, physical inspection, HS/value/origin review.

Budget in three layers: (1) import duty + VAT; (2) testing/specialized-control costs based on actual quotations; (3) logistics exposure such as storage, DEM/DET, handling, amended orders or sampling delay.

8. END-TO-END OPERATING PROCEDURE

STEP 01

Identify the product

Lock ingredient list, hard vs gummy texture, cocoa/gelatin, claims, retail pack and manufacturer. Do not finalize HS while technical data remains ambiguous.

STEP 02

Lock HS – tax – origin

Compare 1704.90.99 against exclusion branches; calculate MFN/FTA and VAT at filing date; decide whether preferential origin proof will be used.

STEP 03

Prepare product compliance

Testing, self-declaration, additive/flavour review and label/nutrition-panel control under the 2026 rules.

STEP 04

Select food-safety route

Review Article 13 and Articles 16–19 of Decree 15 to determine exemption, reduced, normal or strict inspection and supporting evidence.

STEP 05

Freeze documents before ETA

Reconcile Invoice – Packing List – B/L/AWB – C/O – label – self-declaration – spec. Resolve every mismatch before customs filing.

STEP 06

Customs filing & channel

Declare HS, value, origin and product policy. Green is primarily automated; Yellow focuses on documentary review; Red may include physical examination under risk-management decisions.

STEP 07

Complete food safety, tax & clearance

Track specialized result, pay duties/taxes, perfect origin proof where applicable and answer Customs requests.

STEP 08

Market circulation & post-audit

Complete Vietnamese supplemental label before circulation and retain product/shipment records for traceability, post-clearance customs and food-safety inspection.

Recommended pre-ETA milestone: complete product scope, HS draft, label artwork, self-declaration file, selected food-safety route and origin strategy before the shipment reaches the port/border.

Main blockers: formula changes while reusing an old declaration; missing nutrition panel; C/O mismatch; overly generic invoice description; changed manufacturer/origin not reflected in the product file.

9. FREQUENTLY ASKED QUESTIONS

Does standard fruit hard candy require a separate import licence?

For the standard scope of this article, no separate licence has been identified merely because the product is hard candy. Food-safety, self-declaration, labeling and customs obligations still apply. Reassess if claims/composition move the product into a special category.

Can HS 1704.90.99 be confirmed from “fruit hard candy” alone?

No. It is a reference when the product is hard sugar confectionery with no cocoa, no gelatin gummy texture and no cough-lozenge function. Review ingredient list, specification, photos and claims.

Is self-declaration required?

Processed prepackaged food under Article 4 of Decree 15/2018 normally follows self-declaration unless it falls into a product group requiring registration or another special case. Standard hard candy generally fits the self-declaration route.

Is every shipment subject to the same food-safety inspection?

No. Decree 15 provides reduced, normal and strict methods, and Article 13 contains exemptions. Determine the route from actual facts and compliance history.

How old may the test report be for self-declaration?

Article 5 of Decree 15 requires a food-safety test result within 12 months at the time of filing, from a designated laboratory or an ISO 17025-accredited laboratory within a suitable scope.

Can China-origin candy obtain 0% under Form E?

For reference HS 1704.90.99, the 2026 ACFTA rate is referenced at 0% when origin rules and documentary conditions are fully met. Form E alone is not enough; review PSR, HS, description, transport and file consistency.

What is new for candy labeling in 2026?

In addition to Decrees 43/2017 and 111/2021, from 1 Jan 2026 food within Circular 29/2023 must use compliant nutrition labeling. Added-sugar products need particular review of total sugars and other mandatory nutrition items.

Can the Vietnamese supplemental label be added after arrival?

Distinguish the original import label from the supplemental label required for circulation. The original label must meet minimum import-label requirements, and Vietnamese labeling must be completed before market circulation without covering mandatory original information.

Does candy containing fruit pieces require plant quarantine?

Do not answer from the product name alone. Highly processed confectionery differs from raw plant material, but visible fruit/seeds/herbs that remain regulated may require a separate quarantine review.

Can a dossier prepared under Decree 46/2026 at the beginning of 2026 still be reused unchanged?

It should be reworked. As of 8 Sep 2026, Resolution 15/2026 has suspended Decree 46/2026 and Resolution 66.13/2026; the applicable route must be reconciled back to Decree 15/2018 and current instruments such as Circular 28/2026.

10. FINAL OUTPUTS & POST-CLEARANCE OBLIGATIONS

Product master file

Self-declaration, test report, ingredient list, spec/COA, label artwork and additive/flavour evidence under version control.

Shipment file

Invoice, Packing List, B/L/AWB, customs declaration, valuation evidence, origin proof where used and specialized-inspection result.

Food-safety file

Evidence of exemption/inspection method, registration/result per shipment and explanations where requested.

Label & circulation

Vietnamese supplemental label and compliant nutrition panel; consistent manufacturer/origin/date/ingredient data.

Retention & audit trail

Store product and shipment records for traceability, customs post-clearance, food-safety inspection and accounting reconciliation.

CHECK

Change control

When supplier, plant, formula, additives, artwork, origin or pack changes, reassess HS, self-declaration, label and origin before the next shipment.

Target state: maintain one stable product master file plus a shipment-specific file that can trace customs declaration → origin → food-safety inspection → self-declaration → testing → label → supplier.

Customs clearance is not the end. Incorrect labels, a declaration that no longer matches the formula, or weak traceability can still create downstream compliance exposure.

11. GIẢI PHÁP TỪ TGIMEX

For fruit hard candy, the operating challenge is to lock product – policy – documents – food safety – labeling – tax/origin – logistics timeline together before ETA.

Pre-ETA review

Reconcile ingredient list, specification, HS, tax, origin/FTA, labels, food-safety method and self-declaration before shipment/ETA.

Compliance document control

Cross-check Invoice, Packing List, B/L/AWB, origin proof, self-declaration, test report, label artwork and technical dossier; issue a missing-data list for the supplier.

Logistics coordination

Track documents, arrival, specialized inspection, customs filing/channel, tax and delivery; flag storage/DEM/DET or delivery-delay risk early.

Companies should work with a team that can coordinate logistics, customs documentation and specialized compliance in one operating timeline rather than treating each file as a separate task.

FOOTNOTES – SOURCES & APPLICATION NOTES

Resolution 15/2026/NQ-CP, Government, issued/effective 6 Apr 2026: Government Portal.
Circular 28/2026/TT-BCT, Ministry of Industry and Trade, issued 1 Jun 2026, effective 17 Jul 2026: Government Portal.
Decree 15/2018/NĐ-CP: Government Portal.
Decree 111/2021/NĐ-CP amending goods-label rules: Government Portal.
Circular 29/2023/TT-BYT, nutrition labeling; implementation guidance for 1 Jan 2026: Ministry of Health.
Decree 174/2025/NĐ-CP, VAT reduction through 31 Dec 2026: Government Portal.
HS/tax note: HS 1704.90.99, MFN 15%, ordinary 22.5% and referenced FTA rates are operational references for the standard product scenario as at 8 Sep 2026. Recheck the tariff, origin and shipment facts on the customs-registration date.
Scope limitation: not automatically applicable to health supplements, medicinal claims, cocoa confectionery, gelatin gummies, quarantine-sensitive ingredients, non-commercial shipments or statutory exemption cases.

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