Fruit Jelly / Jelly Cup Import Procedure into Vietnam 2026: HS 2106.90.99 vs 2007.99.20, Food Safety and Labeling

F&B IMPORT PROCEDURE · UPDATED 08 SEP 2026

FRUIT JELLY / JELLY CUP IMPORT PROCEDURE INTO VIETNAM 2026: DISTINGUISHING HS 2106.90.99 VS 2007.99.20, FOOD SAFETY, SELF-DECLARATION & LABELING

“Fruit jelly / jelly cup” is a commercial name that can easily lead to the wrong HS. A water–sugar gel cup made with agar/carrageenan/konjac and fruit flavor may lean toward 2106.90.99; a true fruit jelly obtained by cooking fruit/purée may fall under 2007.99.20.

If the importer relies only on “fruit jelly” in the invoice, the error can cascade into HS – duty – C/O – food-safety authority – self-declaration – label – import inspection. This guide maps the E2E process for retail jelly cups consumed directly as an ordinary dessert/snack, while separating scenarios that require a different conclusion.

Operational reference for importers · Final conclusions must be locked against the ingredient list, fruit/purée ratio, gelling system, production process, product structure, claims, label and actual shipment records.

QUICK FACTS

SCOPE
Main scope

Water–sugar jelly cups set with agar/carrageenan/konjac/gellan/pectin, with fruit flavor/juice, retail packed and ready to eat.

HS 1
2106.90.99

Primary indicative route when the product is an other food preparation not elsewhere specified. A Vietnamese customs notice classified retail “Mango Fruit Jelly Agar” under this code.

HS 2
2007.99.20

Relevant only where the product is a fruit jelly obtained by cooking fruit/purée, with or without added sugar or sweetener.

FS
Circular 28/2026/TT-BCT

From 17 Jul 2026, Circular 28/2026 expressly lists headings 20.07 and 20.08 in the confectionery group. HS 2106.90.99 is not expressly listed, so import food-safety inspection must not be inferred from that HS alone.

DECLARE
Self-declaration

Ordinary processed prepacked jelly cup generally follows the self-declaration mechanism of Decree 15/2018 unless it belongs to a product-registration category.

LABEL
2026 label

Review Decree 43/2017, Decree 111/2021 and Circular 29/2023/TT-BYT. Added-sugar jelly should control total sugars plus mandatory nutrition items.

Main split: “fruit-flavored jelly” is not automatically the same as “fruit jelly” of heading 20.07. Confirm whether the product is a water/flavor gel or jelly cooked from fruit/purée.

2. TERMS & WHY THE PROCEDURE MATTERS

JELLY CUP
Jelly cup

A small retail cup of gel food consumed directly. It may contain water, sugar, gelling agents, flavors/colors, juice or fruit pieces.

FRUIT JELLY
Fruit jelly under heading 20.07

The classification concept is tied to fruit jelly obtained by cooking fruit/purée. Fruit flavor alone does not establish 2007.99.20.

HS
HS Code

Customs classification drives duty, C/O and commodity policy. For jelly cup, composition + process + structure matter more than the trade name.

FS
State food-safety inspection

Imported-food control applied according to the inspection method and exemption/reduced/strict conditions under current law and shipment facts.

SELF
Product self-declaration

The mechanism under Decree 15/2018 for eligible food. The file must match the SKU, formula, test parameters and marketed label.

ETA
ETA

Estimated Time of Arrival. HS draft, test, self-declaration, label and C/O should be substantially locked before cargo arrival.

Why it matters: two products both labeled “mango jelly cup” can be different: a water–agar gel versus a mango/purée jelly obtained by cooking. That difference can change HS, duty and the customs explanation.

3. PRODUCT CLASSIFICATION & IDENTIFICATION

This guide primarily covers ordinary jelly cups without treatment or health-supplement claims. Before import, obtain at least the ingredient list, specification/COA, process flow or manufacturing description, fruit/purée percentage, gelling agent, final label artwork, product photos and manufacturer data.

Product scenario Technical signs to check Example Evidence Potential policy Documents to review Application note
Water-based jelly cup + gelling agent Water/sugar base; agar/carrageenan/konjac/gellan; flavor/juice; cup gel Mango jelly cup, lychee jelly cup Ingredients, spec, process, label, photo Food safety, self-declaration, label, additives Review 2106.90.99, test, C/O Main branch of this guide.
Fruit jelly obtained by cooking Fruit/purée base; cooking step; jam/jelly texture Cooked fruit jelly cup/spread Recipe, fruit %, flow chart, spec Food safety, self-declaration, label Review 2007.99.20 Do not use for fruit-flavored gel only.
Jelly with significant fruit pieces Fruit species, fruit %, preservation method, syrup/gel Peach chunks in jelly, mixed fruit cup Formula, photos, fruit % Heading 20.08 or another route may arise Review HS by fruit and preparation Do not force 2106/2007 if fruit dominates.
Jelly candy/gummy texture Chewy, solid elastic confectionery Jelly candy, gummy jelly Ingredients, texture, packaging Chapter 17 may apply Review 1704.90.91/99 depending on gelatin Separate from spoon-eaten cup jelly.
Vitamin/functional jelly Vitamins/minerals/botanicals; dosage; health claims Vitamin jelly, beauty jelly Formula, claim, dosage, label May shift to health-supplement registration Reclassify product before import Do not automatically apply this guide.
Classification warning: a 2016 customs notice classified “U.MAY Mango Fruit Jelly Agar” under 2106.90.99. It is a useful technical precedent for a similar product, but not a blanket ruling for all jelly cups.

4. HS CODE – DUTY – C/O

Do not select 2007.99.20 merely because the label says “fruit jelly.” That code is tied to fruit jelly obtained by cooking; a mixed gel food preparation not elsewhere specified often requires review under 2106.90.99.

Indicative HS Suitable description Classification basis Application condition Ordinary duty MFN duty VAT FTA/C/O to review Documents
2106.90.99 Other food preparations not elsewhere specified Suitable for a mixed cup-gel preparation; customs precedent exists for retail jelly agar Water/sugar + gelling system; no more specific heading 22.5% indicative 15% indicative 8% if eligible for the Decree 174/2025 reduction through 31 Dec 2026; otherwise apply the current standard rate ACFTA/RCEP, ATIGA, AKFTA/VKFTA, CPTPP, EVFTA… Ingredients, process, spec, label, photo, C/O
2007.99.20 Jams and fruit jellies Heading 20.07 requires fruit jelly obtained by cooking Fruit/purée base; cooking process fits the heading 60% indicative if the 150%-of-MFN ordinary-rate rule applies 40% indicative 8% if eligible for the Decree 174/2025 reduction through 31 Dec 2026; otherwise apply the current standard rate ACFTA/RCEP, ATIGA and other FTAs by origin Fruit %, flow chart, recipe, spec, label, C/O
2008.xx Prepared/preserved fruit or edible plant parts Consider where preserved fruit pieces are the essential character Depends on fruit type and preservation method Determine exact 8-digit HS Determine exact 8-digit HS Check by final HS FTAs by origin Formula, fruit %, process, label
1704.90.xx Sugar confectionery without cocoa Consider for jelly candy/gummy rather than jelly cup Texture, gelatin, use and packaging Check exact 8-digit HS Check exact 8-digit HS Check by final HS FTAs by origin Ingredients, texture, label

Rates are planning references only. Re-check the tariff and the final HS on declaration date.

SPECIAL PREFERENTIAL FTA / C/O CHECK

Origin route FTA C/O / origin evidence Special preferential rate where verified Conditions Documents Application note
China ACFTA / RCEP Form E or appropriate RCEP evidence ACFTA 0% indicative for both 2106.90.99 and 2007.99.20 under the 2022–2027 schedule PSR and documentary conditions met C/O, Invoice, B/L, Packing, formula/spec Pre-check the HS on the draft C/O before issuance.
ASEAN ATIGA Form D / applicable evidence Check the 2026 ATIGA schedule against the final HS Origin rules met C/O, commercial docs Do not assume the same origin criterion for 2106 and 2007.
Korea AKFTA / VKFTA / RCEP AK/VK form or RCEP evidence Compare 2026 schedules and select the best qualifying route Correct PSR per agreement C/O, Invoice, B/L, origin support Lock the FTA before origin document issuance.
Japan/EU/UK VJEPA/AJCEP/CPTPP/RCEP, EVFTA, UKVFTA Evidence under the relevant agreement Check the 2026 schedule against the final HS Correct PSR and evidence Origin proof, Invoice, transport docs One form/evidence type does not fit all FTAs.
Australia–New Zealand / India / Hong Kong AANZFTA/CPTPP/RCEP, AIFTA, AHKFTA Per the applicable agreement Check the 2026 schedule against the final HS PSR and consignment conditions Origin proof + commercial docs Compare preference against MFN before choosing a route.
C/O checklist: origin form/evidence, WO/RVC/CTH/CTSH criterion where applicable, HS, description, invoice number, quantity/weight, origin country, third-party invoice, direct consignment, issue date and validity.

5. DOCUMENT PACKAGE & SUBMISSION PRINCIPLE

Manage the jelly-cup file in three layers: commercial documents for customs, a product file to establish the actual nature of the food, and food-safety records for circulation/import inspection. Do not wait for a Customs question before asking the supplier how the jelly is manufactured.

01
Commercial file

Commercial Invoice, Packing List, B/L/AWB, Contract/PO where relevant, C/O for preference, manufacturer/origin data.

02
Technical / specialized file

Ingredients, recipe summary, specification, COA, process/flow chart, fruit %, gelling-agent data, test report, self-declaration, label and imported-food inspection records where applicable.

03
Registration / cross-check file

Documents for imported-food safety control where applicable, customs, HS/C/O review and explanations distinguishing 2106.90.99 from 2007.99.20.

Preparation rule: product name, net weight, cups/carton, fruit %, gelling agent, manufacturer, origin, lot/date and SKU/variant must align across Invoice – Packing List – C/O – self-declaration – test – label.
File group Documents Used for Typical owner Common error Pre-ETA check
Commercial Invoice, Packing List, B/L/AWB, Contract/PO Customs, value, logistics Supplier + Importer + Forwarder Only “fruit jelly”; cups/net weight mismatch Use a clear cup-jelly description and SKU.
HS/product Ingredients, formula summary, flow chart, fruit %, spec, photo HS classification Manufacturer/QA No cooking/process data; fruit content unclear Get written confirmation: water-gel vs cooked fruit jelly.
Food safety Self-declaration, test report, import-inspection file Specialized control Importer/Compliance Test not covering product; wrong variant/size Check name, manufacturer, formula and test date.
C/O Origin evidence Preferential duty Exporter/Supplier C/O says HS 2007 while declaration plans 2106, or vice versa Pre-check draft C/O with HS memo.
Label Original label + Vietnamese supplemental label + nutrition panel Market circulation Brand owner/Importer Missing total sugars; gelling ingredients unclear Artwork QA before printing/shipment.

6. LEGAL BASIS & SPECIALIZED-POLICY MATRIX

6.1. Legal basis to review

Type Instrument Authority Effective/application date Role Article/annex to watch Review note
Food-safety law Law on Food Safety 55/2010/QH12 National Assembly From 01 Jul 2011 Food-safety framework Imported-food control principles Read with Decree 15/2018 and specialized rules.
Food-safety decree Decree 15/2018/ND-CP Government 02 Feb 2018 Self-declaration and imported-food inspection Arts. 4–5; Art. 13; Chapter VI; Appendix IV, Section VII items 9–11 Self-declaration test report: within 12 months under Art. 5. Appendix IV places fruit jams/jellies and “other confectionery products” within MOIT’s product-management scope.
2026 NEW – OLD Resolution 15/2026/NQ-CP Government 06 Apr 2026 Suspends Decree 46/2026 and Resolution 66.13/2026 Do not reuse early-2026 workflows built on suspended instruments As of 08 Sep 2026, review Decree 15/2018 plus current effective instruments.
Food-safety HS list Circular 28/2026/TT-BCT MOIT 17 Jul 2026 HS list for imported-food state inspection The Appendix expressly lists 20.07 and 20.08; it does not expressly list 21.06/2106.90.99 For 2007.99.20, the code is expressly listed. For 2106.90.99, separately determine management scope/inspection requirements rather than inferring them from Circular 28.
Food-safety decentralization Decree 146/2025/ND-CP Government 01 Jul 2025 Decentralizes food-safety functions under MOIT Clause 4 Article 37: authority to designate the state inspection body for imported food safety is decentralized to the provincial People’s Committee Describe authority at a general level; identify the actual local body for the shipment when needed.
Classification reference Notice 3281/TB-TCHQ (2016) General Department of Customs Issued 2016 Specific classification of “Mango Fruit Jelly Agar” under 2106.90.99 Soft retail gel containing sugar, dairy product, thickener, flavor and additives Technical reference only; not a blanket ruling.
MFN tariff Decree 26/2023/ND-CP and current amendments Government From 15 Jul 2023 MFN import tariff 2106.90.99: 15%; 2007.99.20: 40% indicative Re-check on declaration date.
Ordinary duty Decision 15/2023/QD-TTg Prime Minister 15 Jul 2023 Ordinary duty principle Where applicable: 150% of MFN Indicatively 22.5% and 60% for the two main codes where conditions fit.
VAT Resolution 204/2025/QH15 + Decree 174/2025/ND-CP National Assembly / Government 01 Jul 2025–31 Dec 2026 2-point VAT reduction for eligible goods 8% where within the reduction scope Lock by final HS and current policy.
Goods label Decree 43/2017, amended by Decree 111/2021 Government Decree 111 from 15 Feb 2022 Original/supplemental label and mandatory particulars Name, quantity, ingredients, dates, origin, responsible entity QA each SKU.
Nutrition label Circular 29/2023/TT-BYT MOH Key date 01 Jan 2026 Nutrition declaration Added-sugar food: review total sugars Check nutrition panel before import.
Food additives Circular 24/2019/TT-BYT, amended by Circular 17/2023/TT-BYT MOH Current amended version Additive-use control Gelling agents, colors, flavors, acids and preservatives must fit the food category and use conditions Check actual INS/ingredients; do not invent limits.
Customs Customs Law 54/2014/QH13 and current implementing instruments National Assembly/Government/MOF Current as of 08 Sep 2026 Declaration, inspection, risk management, post-entry review Files, classification and customs channel Law 11/2026/QH16 takes effect only on 01 Mar 2027.
Future instrument Decree 336/2026/ND-CP Government 15 Oct 2026 National/ASEAN Single Window procedures Not applicable before effective date Update workflow for shipments from 15 Oct 2026.
NEW – OLD as of 08 Sep 2026: Decree 46/2026 and Resolution 66.13/2026 are suspended; Circular 28/2026 is already effective; Law 11/2026/QH16 and Decree 336/2026/ND-CP have been promulgated but are not yet effective.

6.2. Policy matrix by jelly-cup scenario

Scenario Basis Potential policy Authority Trigger
Water-gel jelly cup, proposed 2106.90.99 Decree 15/2018 Appendix IV Section VII.11; Circular 28/2026 for list cross-check; HS file Self-declaration, label and customs. Do not automatically conclude imported-food inspection from Circular 28, because 2106.90.99 is not expressly listed in its Appendix. Food-safety authority within the MOIT scope under local decentralization + Customs Confirm product nature, management category and actual inspection requirement before ETA.
Cooked fruit/purée jelly, proposed 2007.99.20 Circular 28/2026; heading 20.07; Decree 15/2018 Self-declaration + imported-food inspection under Decree 15/2018, unless exempt under Article 13; label + customs Locally designated food-safety inspection body + Customs Fruit ratio/process establish genuine cooked fruit jelly; HS 2007.99.20 is expressly listed in Circular 28.
Fruit pieces dominate Heading 20.08 + Circular 28/2026 Reassess HS by fruit species; food safety and label remain relevant MOIT/Customs Prepared/preserved fruit is the essential character.
Vitamin/health-claim jelly Decree 15/2018 and health-food rules Possible product registration and different route Health authority depending on classification Claims, dosage and active ingredients.
Samples/gifts/research Art. 13 Decree 15/2018 + customs rules Possible inspection exemption where conditions are met Specialized authority / Customs Correct purpose, quantity and exemption conditions.

7. TIMING, FEES & RISK COSTS

Actual timing depends on the quality of the product file and the food-safety inspection method. A specific jelly-cup risk is having to go back to the supplier for manufacturing-process and fruit-percentage evidence because commercial documents often say only “fruit jelly cup.”

Stage Work Recommended timing Target output Delay risk
1. Prepare file Lock ingredients, process, fruit %, gelling agent, HS draft, label, test/self-declaration Before shipment Product master file Wrong HS or label/declaration rework.
2. Submit/register specialized step if applicable Determine exemption/inspection method and prepare shipment file Before ETA File ready for acceptance Storage and clearance delay.
3. Review/cross-check Review product, file and applicable inspection method Per file status No gap or clear supplement request Longer lead time.
4. Amend/supplement Add process, fruit %, test, label or shipment documents Immediately after request Gap list closed Storage/DEM/DET and C/O/document amendments.
5. Obtain specialized result Complete result/condition under applicable method Before/in parallel with customs where allowed Ready for next step Cargo-release delay.
6. Customs – tax – clearance Declaration, channel, HS/C/O and tax handling When filing conditions are met Clearance/release Storage/detention.
7. Post-clearance / circulation Supplemental label, records and reconciliation of declaration–test–C/O–customs file Before circulation and after clearance Complete shipment file Post-entry/food-safety/label exposure.
Fees/costs: determine them from the actual file, inspection method and testing provider. Do not publish one fixed cost for every jelly cup.

8. PRACTICAL E2E PROCESS

STEP 01
Identify the product

Collect ingredients, process, fruit %, gelling agent and photos. First answer: water-gel or cooked fruit jelly?

STEP 02
Lock HS – duty – C/O

Compare 2106.90.99 vs 2007.99.20, and 2008/1704 where needed. Model MFN/ordinary/VAT and FTA by origin.

STEP 03
Prepare product compliance

Lock self-declaration, test report, additive data, nutrition panel, label artwork and SKU versions.

STEP 04
Determine food-safety method

For 2007.99.20, use Circular 28/2026 + Decree 15/2018 to determine inspection/exemption/method. For proposed 2106.90.99, additionally determine management scope and actual inspection requirements because the code is not expressly listed in Circular 28.

STEP 05
Freeze documents before ETA

Cross-check Invoice, Packing, B/L/AWB, C/O, manufacturer, origin, cup count, net weight, name and HS draft.

STEP 06
Customs declaration & channel

Green is lower-intervention system treatment; Yellow is document review; Red may include physical inspection. Keep the HS memo/product file ready.

STEP 07
Complete food safety – tax – clearance

Track specialized-control result, C/O, tax and cargo-release/pickup status.

STEP 08
Circulation & post-entry

Complete Vietnamese supplemental labeling, retain product master + shipment file, and control formula/factory/origin changes.

Before ETA: have at least ingredients + process + fruit % + HS draft + self-declaration/test + label artwork + C/O draft. Missing “process” is a frequent blocker in the 2106-vs-2007 decision.
Main blockers: supplier changes agar/carrageenan/konjac, fruit-juice percentage, fruit chunks, cooking process, or the C/O still uses the old HS after product scope changes.

9. FAQ

Does jelly cup normally use 2106.90.99 or 2007.99.20?

For a water/sugar gel with gelling agents, flavor/juice and no true cooked-fruit-jelly process, 2106.90.99 is usually the first route to review. Where fruit/purée is the base and cooking creates jelly consistent with heading 20.07, review 2007.99.20.

Is there a Vietnam Customs precedent for jelly cup under 2106.90.99?

Yes. A 2016 classification notice for “U.MAY Mango Fruit Jelly Agar” retail soft gel—containing reducing sugar, dairy product, thickener, fruit flavor and additives—classified it under 2106.90.99. It is a technical reference, not an automatic ruling.

Does mango flavor mean 2007.99.20?

No. Mango flavor or a small amount of juice does not establish “fruit jelly obtained by cooking.” Obtain the flow chart and fruit percentage.

Does ordinary jelly cup require self-declaration?

Generally, an ordinary processed prepacked food follows Article 4 of Decree 15/2018 unless it belongs to a product-registration category.

How old can the self-declaration test report be?

Decree 15/2018 requires a food-safety test report within 12 months before filing, issued by a designated laboratory or one accredited to ISO 17025 within the relevant scope.

Does jelly cup require imported-food safety inspection?

There is no single answer for every jelly cup. HS 2007.99.20 is expressly listed in Circular 28/2026, so imported-food inspection under Decree 15/2018 must be reviewed unless an exemption applies. HS 2106.90.99 is not expressly listed in the Circular 28 Appendix; therefore determine product-management scope and the competent authority’s current requirement instead of copying the 2007.99.20 workflow.

Can China-origin jelly cup with Form E get 0% duty?

The ACFTA 2022–2027 schedule shows 0% for both 2106.90.99 and 2007.99.20. Preference still requires PSR, valid origin evidence, transport conditions and HS/description consistency.

What matters for 2026 jelly-cup labeling?

Besides Decree 43/2017 and Decree 111/2021, review Circular 29/2023/TT-BYT. Added-sugar jelly requires particular attention to total sugars.

Do agar, carrageenan and konjac need additive review?

Yes. Check the actual ingredient/INS and food category under Circular 24/2019 as amended by Circular 17/2023. Do not reuse one limit/condition across all gelling agents without confirming the applicable food category.

What if the cup contains large peach or mango pieces?

If prepared/preserved fruit is the essential character, Chapter 20.08 may need review instead of forcing 2106.90.99. Check fruit %, structure and preservation method.

10. OUTPUTS & POST-CLEARANCE OBLIGATIONS

01
Product file

Ingredients, process/flow chart, fruit %, gelling-agent data, spec/COA, test, self-declaration and artwork under version control.

02
Shipment file

Invoice, Packing, B/L/AWB, customs declaration, C/O, value documents and specialized records.

03
Food-safety file

Self-declaration, test report, inspection/exemption method and results where applicable.

04
Label & circulation

Vietnamese supplemental label, ingredients/additives, nutrition, net weight, dates, origin and responsible entity.

05
Retention & audit

Enable traceability from SKU → formula/process → HS → self-declaration/test → label → C/O → customs declaration.

CHECK
Change control

Fruit %, gelling system, cooking process, fruit pieces, supplier/factory, artwork or origin changes trigger a fresh HS/file review.

Target state: the importer should be able to explain “why 2106 or why 2007” from technical documents—not only from the commercial name on the Invoice.
Clearance is not the end. If the actual formula/process differs from the product file used for declaration or HS explanation, exposure remains in food safety, labeling and post-clearance review.

11. SOLUTIONS FROM TGIMEX

For jelly cup, the most valuable control point is to lock product scope – HS – process – food safety – self-declaration – C/O – label before ETA, because “fruit jelly” can hide at least two major HS routes.

01
Pre-ETA review

Review ingredients, process, fruit %, gelling agent, 2106/2007/2008, duty, FTA, label and food-safety route before shipment.

02
Compliance-file control

Cross-check Invoice, Packing, B/L/AWB, C/O, self-declaration, test, spec, flow chart and artwork; issue a supplier gap list.

03
Operations/logistics coordination

Track ETA – food safety – declaration – channel – tax – pickup, with early alerts for storage/DEM/DET when the product file or C/O is not locked.

Importers should work with a team capable of coordinating logistics, documentation, customs and specialized compliance together to avoid errors at the product-classification stage.

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