Tinned cookies require more than a commercial product name. Importers should lock the cookie composition, cocoa/non-cocoa status, gift-set configuration, HS code, C/O, product self-declaration, state food-safety inspection and labelling before arrival.

Operational reference updated through 8 September 2026.

1. OVERVIEW OF THE IMPORT PROCEDURE

PRODUCT

Main scope

Finished sweet biscuits, prepacked in a metal tin for retail/gifting.

First codes to review

1905.31.10 without cocoa; 1905.31.20 containing cocoa.

FOOD SAFETY

Specialized policy

Product self-declaration and state food-safety inspection, subject to the applicable case.

TAX

Base scenario

Reference MFN 15%; current VAT 8% if eligible; FTA rate depends on valid origin proof.

ETA

Operational gate

Lock ingredients, label, test report, origin documents and SKU structure before ETA.

GIFT SET

No automatic bundling

Mixed gifts with chocolate/candy/tea/coffee require a separate classification review.

2026 legal status: Resolution 15/2026/NQ-CP suspends Decree 46/2026 and states that Decree 15/2018/NĐ-CP and its implementing rules continue to apply during the suspension. Circular 28/2026/TT-BCT, effective 17 July 2026, lists HS 1905.31.10/20 among imported food lines subject to state food-safety inspection under MOIT management.

Compilation note: operational reference for import-export enterprises; not an official legal translation.

2. KEY TERMS & WHY THE PROCEDURE MATTERS

HS code

Customs classification used for duties, commodity policy and origin treatment. The metal tin does not itself create a separate cookie HS line.

Food safety

Requirements governing product compliance, self-declaration, import inspection and market circulation.

SELF-DEC

Product self-declaration

A mechanism under Decree 15/2018 whereby the enterprise declares and takes responsibility for eligible products.

C/O

Certificate of Origin

Origin proof used to claim preferential FTA duty when origin rules and documentary conditions are met.

ETA

Estimated Time of Arrival

The planning anchor for working backwards on compliance documents before cargo reaches port.

SKU

Stock Keeping Unit

Each variant/item in an assorted tin should be identifiable to avoid mixing unlike products.

LABEL

Goods/food label

Original and Vietnamese supplementary labelling must be checked together with nutrition rules where applicable.

GIFT SET

Retail set

A mixed retail gift set may require analysis of each component and the customs rules for sets.

Why it matters: errors in cocoa status, SKU structure, origin proof or label can change the HS line, tax treatment or food-safety file.

Key rule: do not use only “gift cookie”, “cookie tin” or “holiday gift set” as the customs product description.

3. DETAILED PRODUCT IDENTIFICATION & CLASSIFICATION

This article mainly covers finished sweet biscuits prepacked in metal tins. It does not automatically cover wafers, unsweetened biscuits, chocolate/candy gift boxes, health supplements or empty tins.

Product/situation	Technical signs to check	Example	Evidence	Potential policy	Files to cross-check	Application note
Sweet biscuits without cocoa	Ingredient list confirms no cocoa/cacao	Butter/Danish-style cookies	Ingredients; specification; label; catalogue	Food safety; self-declaration; label; origin	Invoice; PL; test report; self-declaration	Review 1905.31.10 first.
Sweet biscuits containing cocoa	Cocoa/cacao in formula; still sweet biscuits	Cocoa/chocolate-chip cookies	Formula; ingredients; specification	Food safety; self-declaration; label; origin	Same as above	Review 1905.31.20 first.
Assorted cookie tin	Variants differ by cocoa status/ratio	4–8 varieties per tin	SKU/BOM breakdown; inside-pack photos	May require deeper classification review	SKU breakdown; invoice/PL	Do not force all variants into one 8-digit code without support.
Mixed gift set	Cookies plus independent chocolate/candy/tea/coffee	Holiday hamper	BOM; packaging/value/weight breakdown	Multiple HS/policies may arise	Detailed invoice/PL; specs	Apply set-classification rules to the actual configuration.
Empty tin imported separately	No cookies; material/dimensions/function	Decorative empty tin	Material spec; dimensions; photos	Separate HS/policy review	Spec; invoice; PL	Cookie HS does not apply.

Warning: generic names can lead to incorrect HS, specialized policy, C/O and labels. Review the actual ingredients, SKU configuration, origin and import purpose.

4. HS CODE – DUTY – C/O

Classification should start from the nature of the biscuit, formula, cocoa status and actual packing configuration, not the tin material.

Reference HS	Suitable description	Classification basis	Condition	Ordinary import duty	MFN	VAT	FTA/C/O to review	Evidence
1905.31.10	Sweet biscuits – not containing cocoa	Bakers’ ware + ingredients	Actual product fits non-cocoa subheading	22.5%*	15%	8% if currently eligible; otherwise rate applicable on declaration date	ATIGA/ACFTA/RCEP/AKFTA/VKFTA/CPTPP etc. by route	Ingredients; spec; label; C/O
1905.31.20	Sweet biscuits – containing cocoa	Bakers’ ware + cocoa ingredient	Actual product fits cocoa subheading	22.5%*	15%	8% if currently eligible; otherwise rate applicable on declaration date	ATIGA/ACFTA/RCEP/AKFTA/VKFTA/CPTPP etc. by route	Ingredients; spec; label; C/O

* Ordinary duty: 22.5% follows the 150% of MFN principle under Decision 15/2023/QĐ-TTg where the ordinary rate applies. Always re-check the tariff in force for the final HS and actual origin.

Route/origin	FTA	Origin proof	Special preferential rate	Conditions	Files	Note
ASEAN	ATIGA	Form D / valid origin proof	May reach 0% if all conditions are met	Origin rule + transport + document conditions	C/O, invoice, B/L/AWB, PL	Check 8-digit HS and PSR before costing.
China	ACFTA or RCEP	Form E or applicable origin proof	Check the 2026 preferential tariff for the final HS	PSR and documentary conditions	C/O + commercial documents	Compare ACFTA vs RCEP; do not assume the lower scheme.
Korea	AKFTA/VKFTA/RCEP	Origin proof under selected FTA	Check 2026 special preferential tariff	PSR + document conditions	C/O + commercial set	Select FTA based on actual origin and document availability.
Japan	VJEPA/AJCEP/CPTPP/RCEP	Origin proof under selected FTA	Check 2026 special preferential tariff	PSR + document conditions	Origin proof + commercial set	Do not transfer a rate schedule from one FTA to another.
EU/UK	EVFTA/UKVFTA	Origin proof under applicable FTA	Check 2026 special preferential tariff	Origin rules + documentary conditions	Proof of origin + invoice + transport	Review route-specific origin rules.

C/O checklist: form/proof; WO/RVC/CTH/CTSH as applicable; third-party invoice; direct consignment/transport rules; description; HS; quantity/weight; country of origin; signature/authentication; issue date and validity.

5. DOCUMENT SET & SUBMISSION PRINCIPLES

Use a single source of truth for product name, SKU, manufacturer, origin, ingredients and packing throughout customs and food-safety files.

Commercial documents

Invoice, Packing List, B/L or AWB, Contract/PO where used, and C/O when claiming FTA treatment.

Technical/specialized file

Ingredient list, specification, original label, test report, self-declaration, nutrition/allergen data and food-contact packaging information where relevant.

Registration/cross-check file

Evidence for the applicable food-safety inspection route/exemption, SKU identification and origin support used before clearance.

Preparation principle: the receiving method is described only at operational level. The competent authority and intake method should be confirmed for the actual shipment.

File group	Documents	Used for	Typical owner	Common error	Pre-ETA check
Commercial	Invoice; PL; B/L/AWB; Contract/PO; C/O	Document lock, customs, tax	Importer + supplier + forwarder	Generic name; quantity/net weight/origin mismatch	Cross-check field by field.
Product ID	Ingredients; specification; photos; SKU breakdown	HS & policy	Supplier + importer	Cocoa status missing; “gift set” only	Obtain official per-SKU specs.
Food safety	Self-declaration; test report; inspection evidence	Product/shipment compliance	Importer/compliance	Expired/inconsistent testing	Match product identity, manufacturer, origin and test scope.
Labels	Original/supplementary label; nutrition data	Market circulation	Brand/importer	Responsible entity or composition mismatch	Freeze label before circulation.
Origin	C/O/origin proof + commercial documents	FTA duty	Exporter + importer	HS/invoice mismatch; PSR not met	Review PSR and document conditions.

100% consistency principle: Invoice, PL, B/L/AWB, C/O, ingredients/specification, labels, food-safety file and customs declaration must tell the same product story.

6. LEGAL BASIS & SPECIALIZED POLICY MATRIX

Document group	Document	Issuer	Effective/status	Role	Key provision	Review note
Law	Food Safety Law 55/2010/QH12	National Assembly	Effective 1 Jul 2011	Framework for food safety/imported food	Review imported-food obligations	Read together with Decree 15/2018.
Decree	15/2018/NĐ-CP	Government	Effective 2 Feb 2018	Self-declaration and import food-safety inspection	Articles 4–5 and import-inspection provisions	Continues during suspension under Resolution 15/2026.
Resolution	15/2026/NQ-CP	Government	Effective 6 Apr 2026	Suspends Decree 46/2026 and Resolution 66.13/2026	Articles 1–2	Article 2 keeps Decree 15/2018 and guidance in force during suspension.
Circular	28/2026/TT-BCT	MOIT	Effective 17 Jul 2026	HS list for state food-safety inspection	Appendix: confectionery/bakery lines incl. 1905.31.10/20	Apply by actual HS/description.
Circular	30/2026/TT-BYT	Ministry of Health	Effective 10 Jul 2026	Nutrition-content labelling guidance	Review scope and transitions	Do not copy one nutrition label across all SKUs.
Labelling	43/2017/NĐ-CP + 111/2021/NĐ-CP	Government	2017; amendment effective 15 Feb 2022	Imported-goods labels	Mandatory label particulars	Apply together with food-specific rules.
Customs	Customs Law 54/2014/QH13; Decree 08/2015 as amended	NA/Government	Decree 167/2025 effective 15 Aug 2025	Customs procedures & control	Declaration, channeling, inspection	Use the rules in force on declaration date.
VAT	Resolution 204/2025/QH15 + Decree 174/2025/NĐ-CP	National Assembly/Government	VAT reduction policy through 31 Dec 2026	Two-percentage-point VAT reduction for eligible goods/services	Check exclusions and application date	Confirm actual HS/product is within the eligible scope.
Tax	Decision 15/2023/QĐ-TTg	Prime Minister	Effective 15 Jul 2023	Ordinary import duty mechanism	150% of corresponding MFN where applicable	Re-check current tariff.

Resolution 15/2026 Circular 28/2026

Situation	Legal basis	Potential policy	Authority (high level)	Trigger
Standard prepacked sweet biscuits for sale	Decree 15/2018; Circular 28/2026	Self-declaration + state food-safety inspection as applicable	MOIT/assigned inspection authority at high level	HS/description is listed and no exemption applies.
Shipment meeting an exemption	Decree 15/2018	Possible exemption from import inspection	Food-safety authority	Statutory conditions and evidence are met.
Mixed gift set	AHTN/GRI + Decree 15/2018 + item-specific rules	Multiple HS/policies may arise	Customs + relevant sector authority	Independent items with different nature/policy.
Metal tin in direct food contact	Applicable food-contact safety rules	Review food-contact metal packaging compliance	Relevant food-safety authority	Tin directly contacts the biscuits.
Samples/testing	Decree 15/2018	Different/exempt route may apply if conditions are met	Sector authority	Purpose, quantity and proof; not normal commercial sale.

No blanket conclusion: final policy depends on ingredients, set configuration, HS, origin, purpose and actual shipment documents.

7. PROCESSING TIME, FEES & DELAY COST

Do not use one fixed “days/fee” figure for all cookie imports. Timing and cost vary with food-safety inspection method, completeness, customs channel, port/warehouse and transport plan.

Step	Recommended timing	Fees	Delay exposure
Product/HS/C/O review	Before order/booking	Internal review; no state fee as such	Wrong HS changes tax/policy.
Testing + self-declaration	Before cargo moves/ETA	Lab cost varies by test scope	Missing/inconsistent test report delays compliance.
Determine inspection route	Before ETA	Use current official fee schedule if any	Wrong route/exemption can create storage.
Food-safety import inspection	According to applicable method	Do not invent a flat fee	Storage/DEM/DET and delivery delay.
Customs channeling	After declaration	Import duty, VAT and real logistics charges	Yellow/red channel may extend release.
Post-clearance	After release	Labelling/record cost if incurred	Audit/post-clearance exposure.

Separate logistics cost from state fees: storage, DEM/DET, testing, handling and inland transport are operational costs and vary by shipment.

8. PRACTICAL E2E WORKFLOW

STEP 01

Identify the product

Collect ingredients, specification, label, photos, net weight, manufacturer, origin and per-SKU breakdown.

STEP 02

Lock HS/tax/origin

Compare 1905.31.10 vs 1905.31.20; cost on MFN and FTA scenarios; confirm origin-document availability.

STEP 03

Prepare specialized file

Complete self-declaration, testing, labels, nutrition/allergen data and food-contact packaging review where relevant.

STEP 04

Determine the applicable inspection route

Assess exemption/reduced/normal/strict treatment under the legal framework and prepare evidence.

STEP 05

Lock documents before ETA

Cross-check Invoice, PL, B/L/AWB, C/O, food-safety file, labels and SKU breakdown.

STEP 06

Declare customs & handle channel

Green/yellow/red channel as applicable; keep ingredients/specification ready to support HS and policy.

STEP 07

Complete inspection/tax/release

Coordinate food-safety result where required, tax payment, supplementation and release.

STEP 08

Post-clearance obligations

Finalize labels before circulation where required and keep an auditable shipment/SKU file.

Pre-ETA milestone: at minimum, lock product scope, ingredients, tentative HS, origin plan, self-declaration/testing and label configuration before arrival.

Main gates: HS 1905.31.10/20, cocoa, gift-set configuration, testing/self-declaration, C/O, labels and food-safety inspection result.

9. FAQ

1) Is a separate import licence generally required for tinned sweet biscuits?

For ordinary sweet biscuits, the core issues are food safety, self-declaration, import inspection, labelling and customs; mixed/regulated items must be reviewed separately.

2) Does the metal tin change the cookie HS code?

Not merely because it is metal packaging. Empty tins imported separately or mixed gift sets require separate analysis.

3) What HS should be reviewed for butter cookies without cocoa?

Review 1905.31.10 first when the product is a sweet biscuit without cocoa.

4) What about cocoa/chocolate-chip cookies?

Review 1905.31.20 first if the product meets the description “sweet biscuits containing cocoa”.

5) Is product self-declaration required?

Ordinary prepacked processed food generally follows the Decree 15/2018 self-declaration mechanism within its scope; product-specific exceptions must be checked.

6) Is state food-safety inspection required?

Circular 28/2026 includes HS 1905.31.10/20 in the MOIT-managed list. The shipment still needs the applicable inspection method/exemption review under Decree 15/2018.

7) Can China-origin goods claim FTA duty?

ACFTA/RCEP may be considered if origin rules and documentation are met. Confirm the 2026 special preferential tariff for the final HS.

8) Is nutrition information required on the supplementary label?

Review Decrees 43/2017, 111/2021 and Circular 30/2026/TT-BYT based on product scope and circulation timing.

9) Can an assorted cookie tin use one HS?

Not automatically. Obtain SKU/BOM breakdown and review cocoa status and the set configuration.

10) What should be retained after clearance?

Keep the commercial set, origin proof, self-declaration, test report, food-safety evidence/result, labels, product specs/ingredients and customs declaration by shipment/SKU.

10. OUTPUTS & POST-CLEARANCE OBLIGATIONS

Product file

Version-controlled ingredients, specification, SKU/BOM and original label.

Shipment file

Invoice, PL, B/L/AWB, declaration, tax and delivery records aligned with the product file.

Specialized file

Self-declaration, test report and food-safety inspection/exemption evidence where applicable.

Labelling & circulation

Supplementary/nutrition labelling completed before circulation where required.

Retention & audit

Audit trail linking supplier, origin, ingredients, testing, C/O and customs declaration.

CHECK

Change control

Reassess HS, food-safety file, labels and origin when manufacturer, ingredients, origin, SKU or packaging changes.

Target end-state: clearance is not the only outcome; the importer should retain an evidence chain fit for accounting, distribution and post-clearance audit.

Clearance is not the end: later product changes can invalidate assumptions used for the previous shipment.

11. TGIMEX SOLUTION

The operational focus is to lock compliance before ETA and maintain one consistent data chain from product to customs declaration.

Pre-ETA review

Review product scope, HS 1905.31.10/20, duties, C/O/FTA, ingredients, SKU breakdown, labels, self-declaration and food-safety policy.

Compliance document control

Cross-check Invoice, PL, B/L/AWB, C/O, testing, food-safety records, labels and customs data; flag inconsistencies early.

Logistics coordination

Coordinate specialized procedures, customs clearance, port/warehouse/trucking and post-clearance record retention to reduce unplanned delay/cost.

For mixed gift sets, request ingredient list + specification + label + item-by-item breakdown from the supplier before ordering.

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