VIETNAM IMPORT PROCEDURE FOR PEANUT / SESAME / NUT BRITTLE: HS, DUTY, FOOD SAFETY, C/O AND DOCUMENTS
Peanut, sesame and nut brittle can be misclassified between Chapter 17 sugar confectionery and Chapter 20 prepared nuts/seeds. Where sugar/caramel forms a hard candy matrix binding peanuts, sesame or nuts into brittle bars, slabs or pieces, the core reference is 1704.90.99. Where the product remains essentially a roasted/prepared nut or seed with only a sugar coating, 20.08 may be more appropriate; chocolate-dominant variants require review under 18.06. The wrong product reading changes HS, duty, origin preference, import food-safety controls and labeling. This guide maps formula + sugar:nut ratio + process + product form → HS/tax/C/O → self-declaration & food-safety inspection → customs → labeling → post-clearance.
Operational reference for importers; reviewed against the legal framework through 9 Sep 2026. Main scope: retail-ready peanut brittle, sesame brittle and mixed nut brittle; loose seasoned nuts and bulk raw/semi-processed ingredients require separate review.
2. KEY TERMS & WHY THE PROCEDURE MATTERS
Customs classification based on sugar/caramel ratio, nut/seed ratio, hard-brittle texture, shaping process, coating and the finished product’s essential character.
A hard/crisp candy in which sugar, glucose, maltose, caramel or syrup binds peanuts, sesame or nuts into bars, slabs or pieces.
Specialized compliance covering self-declaration, testing, State inspection of imported food and market-circulation requirements.
Mechanism under Decree 15/2018/ND-CP for processed prepackaged foods within scope.
Certificate/proof used to claim special preferential FTA duty where origin rules are met.
Preferential tariff framework requiring the applicable product-specific origin rule and valid documentation.
Preferential import duty generally used when no special FTA rate is claimed.
Milestone by which HS, origin, food-safety dossier and labels should be locked.
Exact product version; nut/seed ratio, sugar, honey, gelatin, cocoa, coating or texture changes may alter classification.
Nut roasting → sugar/caramel cooking → mixing → rolling/pressing/forming → cutting → coating if any → packing. Critical to separate 17.04 from 20.08.
3. DETAILED PRODUCT IDENTIFICATION & CLASSIFICATION
Main scope: finished retail-ready peanut, sesame and mixed nut brittle. Loose seasoned nuts, bulk ingredients, peanut butter, chocolate-coated nuts and heterogeneous hampers require separate review.
| Product group/cargo scenario | Technical indicators to review | Example | Supporting documents | Possible policy triggers | Documents to reconcile | Application note |
|---|---|---|---|---|---|---|
| Peanut brittle | Hard sugar/caramel candy matrix binds peanuts; bar/slab/piece format | Peanut brittle bar, peanut candy slab | Formula %, sugar:nut ratio, process, cross-section, texture | Reference HS 1704.90.99; Circular 28/2026; self-declaration; label; C/O | Formula, process, tests, declaration, label, commercial docs | Core branch where confectionery character dominates. |
| Sesame brittle | Sesame distributed through a sugar/maltose/caramel matrix; hard/crisp finish | Sesame brittle / sesame candy bar | Formula %, process, form, photos | Reference 1704.90.99 where it is sugar confectionery | Formula, process, sesame %, label | A high sesame ratio does not automatically move the product to 20.08. |
| Mixed nut brittle | Multiple nuts/seeds in a sugar/caramel matrix | Peanut–almond–sesame brittle | BOM %, sugar:nut ratio, process | May remain 1704.90.99 if the candy matrix gives essential character | BOM, process, photos, label | Support the confectionery essential character. |
| Roasted sugar-coated peanuts | Individual nuts remain separate; sugar is coating/seasoning, not a candy matrix | Sugar-coated roasted peanuts | Process, coating %, product photo | Review 2008.11.10 or 2008.11.90 depending final processing | Formula, process, nut form, label | Do not use 1704 if the finished article remains a prepared peanut product. |
| Roasted/seasoned seeds or nuts, not brittle | Loose roasted/prepared seeds or nuts; no hard candy matrix | Roasted sesame/nut snack | Species, roasting process, seasoning/coating | Review 2008.19.91 / 2008.19.99 where appropriate | Species, process, formula, label | Exclude raw or only dried material under other chapters first. |
| Soft gelatin nut candy | Soft/chewy texture and gelatin performs a gelling role | Soft nut candy with gelatin | Formula %, gelatin spec, texture | Potential 1704.90.91 instead of 1704.90.99 | Formula, gelatin %, process | Not the usual hard brittle scenario. |
| Chocolate-coated brittle/nuts | Material chocolate/cocoa coating or chocolate gives essential character | Chocolate-coated peanut brittle | Cocoa/chocolate %, coating %, photos | Review 18.06 and determine the final 8-digit line from the dossier | Chocolate spec, formula, process, label | Chapter 17 excludes cocoa-containing sugar confectionery. |
| Mixed gift box | Brittle plus chocolate/cookies/tea/coffee | Seasonal confectionery hamper | BOM by weight/value, retail-set structure | Retail-set/essential-character analysis or separate classification | BOM, value ratio, photos, Packing List | Do not default the whole box to the nut-brittle HS. |
4. HS CODE – TAX – C/O
Where peanut/sesame/nut brittle is genuinely non-cocoa sugar confectionery, 1704.90.99 is the core reference line. Vietnam’s 2026 tariff shows 15% MFN, 22.5% ordinary duty and 10% standard VAT. If the finished article remains a prepared nut/seed product, move to 20.08; if cocoa/chocolate dominates, review 18.06.
| Reference HS code | Suitable description/product group | Classification basis | Application condition | Ordinary import duty | MFN import duty | VAT | C/O/FTA to review | Documents to reconcile |
|---|---|---|---|---|---|---|---|---|
| 1704.90.99 | Other sugar confectionery, not containing cocoa | Heading 17.04 – Other / Other | Hard/crisp brittle whose sugar/caramel matrix gives essential character; no cocoa | 22.5% | 15% | Tariff standard 10%; review 8% eligibility at declaration date | ATIGA, ACFTA/RCEP, Korea/Japan FTAs, EVFTA/UKVFTA, AIFTA, AHKFTA | Formula, sugar:nut ratio, process, photos, label, C/O |
| 1704.90.91 | Soft, containing gelatin | Specific 17.04 line | Only where the candy is soft/chewy and contains gelatin in the described manner | 22.5% | 15% | Standard 10%; review 8% eligibility | FTA by origin | Formula, gelatin %, process, texture |
| 2008.11.10 | Roasted ground-nuts | Prepared/preserved peanut line | Nut remains essential character; roasting is core processing and coating does not create confectionery | 45%* | 30% | Standard 10%; review 8% eligibility | FTA by origin | Roasting process, formula, coating %, photos |
| 2008.11.90 | Other prepared ground-nuts | Other prepared/preserved peanut line | Still a prepared peanut rather than a candy matrix | 30%* | 20% | Standard 10%; review 8% eligibility | FTA by origin | Process, formula, nut form, label |
| 2008.19.91 | Other nuts/seeds – roasted | Prepared nuts/seeds under 20.08 | Loose roasted/prepared nut/seed product without confectionery character | 27%* | 18% | Standard 10%; review 8% eligibility | FTA by origin | Species, roast flow, seasoning, photos |
| 2008.19.99 | Other prepared nuts/seeds/mixtures | Other line under 2008.19 | Prepared nut/seed product not fitting the roasted line | 27%* | 18% | Standard 10%; review 8% eligibility | FTA by origin | BOM, process, formula, label |
| 18.06 – final 8-digit line required | Chocolate and other food preparations containing cocoa | Chapter 17 exclusion for cocoa-containing sugar confectionery | Chocolate/cocoa gives essential character | Verify by final HS | Verify by final HS | Review by final HS | FTA by final HS | Cocoa %, coating %, formula, process, photos |
| Route/origin | FTA/agreement | C/O form or origin proof | Special preferential rate where substantiated | Application conditions | Documents to reconcile | Application note |
|---|---|---|---|---|---|---|
| ASEAN | ATIGA | Form D / e-Form D or qualifying proof | For 1704.90.99: 0% in the 2026 schedule | Correct HS; meet PSR; valid proof | C/O, Invoice, B/L, origin support | Confirm member state and origin criterion. |
| China | ACFTA / RCEP | Form E / qualifying RCEP proof | For 1704.90.99: ACFTA 0%; check RCEP by partner/origin schedule | Correct HS, PSR, invoice/transport and proof | C/O/origin proof, Invoice, B/L, BOM/cost sheet where needed | Compare ACFTA and RCEP before filing. |
| Korea | AKFTA / VKFTA / RCEP | Form AK / VK / RCEP proof | For 1704.90.99: AKFTA/VKFTA 0% in the 2026 schedule; review RCEP separately | Meet the selected agreement’s PSR | Origin proof, BOM/formula, commercial docs | Compare both tax and origin-evidence feasibility. |
| Japan | VJEPA / AJCEP / CPTPP / RCEP | Agreement-specific origin proof | For 1704.90.99: several 2026 schedules show 0% | Meet PSR, proof and transport rules | Origin proof, Invoice, B/L | No single form applies to every agreement. |
| EU / UK | EVFTA / UKVFTA | EUR.1 or qualifying proof | For 1704.90.99: approximately 1.8% under the 2026 EVFTA/UKVFTA schedules | Qualifying origin, PSR and proof | Origin proof, formula/BOM, Invoice, transport docs | Sugar/nut formulations can make PSR support important. |
| Australia / New Zealand | AANZFTA / CPTPP | Agreement-specific proof | For 1704.90.99: several 2026 schedules show 0% | Meet origin rules | Origin proof, commercial docs | Use the agreement that is both advantageous and supportable. |
| India | AIFTA | Form AI / qualifying proof | For 1704.90.99: 5% in the 2026 schedule | Meet AIFTA PSR/documentary conditions | C/O, Invoice, B/L, origin support | Compare against 15% MFN. |
| Hong Kong | AHKFTA | AHKFTA origin proof | For 1704.90.99: 15% in the 2026 schedule | Meet PSR/documentary conditions | Origin proof, Invoice, transport docs | The special rate may not improve on MFN; compare before claiming. |
5. DOSSIER & SUBMISSION LOGIC
For nut brittle, the dossier must prove both the confectionery character and the commercial identity. This is a group where invoices are often too generic, while classification depends directly on the sugar:nut ratio and manufacturing process.
Invoice, Packing List, B/L/AWB, Contract/PO if any and C/O where preference is claimed; SKU, quantity and origin must reconcile.
Formula/BOM, sugar:nut ratio, process, specification, product photos, artwork, test report, self-declaration and food-safety file.
Map SKU ↔ formula ↔ process ↔ product form ↔ HS ↔ self-declaration ↔ test ↔ label ↔ C/O ↔ commercial documents.
| Document group | Required documents | Used for | Usually prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice; Packing List; B/L/AWB; Contract/PO if any; C/O if preference claimed | Customs, valuation, origin | Importer + supplier + forwarder | Description only says “peanut snack” or “sesame candy”; pack/SKU/origin mismatch | Specify nut brittle/candy, nut/seed type, net weight, pack size, manufacturer and origin. |
| Product identification / HS | Ingredient list; quantitative formula/BOM; sugar:nut ratio; process flow; product spec; cross-section/texture photos | HS/tax/C/O | Manufacturer + importer compliance | Missing percentages or unclear candy-matrix versus coated-nut structure | Lock the exact formula/process revision per SKU. |
| Food safety – self-declaration | Self-declaration; suitable food-safety test report; product dossier | Pre-market compliance | Importer/product-responsible entity | Test differs from SKU/formula; product/manufacturer mismatch | Review Decree 15 Articles 4–5; test result within 12 months at filing. |
| State food-safety inspection | File for applicable method; Form 04, self-declaration, Packing List and case-specific Article-18 documents | Pre/during clearance | Importer + inspection authority | Missing 1704.90.99 under Circular 28/2026; using one dossier for all methods | Review Decree 15 Articles 13 and 16–19 plus Circular 28/2026 by final HS and lot history. |
| Label | Original label; Vietnamese supplementary label; ingredients; nutrition; total sugars if applicable; dates; importer info; storage instructions | Before circulation | Importer + supplier/brand | Ingredient order mismatch; peanut/sesame/nut description inconsistent with formula; missing required nutrition data | Reconcile formula with goods-label rules and Circular 30/2026. |
| C/O/FTA | Origin proof; Invoice; B/L; BOM/cost sheet where needed | Preferential duty | Exporter + importer | HS, origin criterion, third-party invoice or transport mismatch | Compare every field with planned customs filing. |
6. LEGAL BASIS – SPECIALIZED POLICY MATRIX
| Legal group | Instrument | Issuing authority | Effective/application status | Role | Key article/annex | Review note |
|---|---|---|---|---|---|---|
| Food safety | Law on Food Safety No. 55/2010/QH12 | National Assembly | Foundational law; check amendments at application date | General food-safety framework | General obligations | Read with current implementing instruments. |
| 2026 transition | Resolution 15/2026/NQ-CP | Government | Effective 6 Apr 2026 | Suspends Decree 46/2026 and Resolution 66.13/2026; maintains transitional framework | Articles 1–2 | Decree 15/2018 and related guidance continue during the suspension. |
| Self-declaration / import inspection | Decree 15/2018/ND-CP | Government | Effective 2 Feb 2018; continues in the 2026 transition | Self-declaration, exemptions and import food-safety inspection methods | Articles 4–5, 13, 16–19 | Article 5 requires a food-safety test result within 12 months at filing. |
| MOIT food-safety HS list | Circular 28/2026/TT-BCT | Ministry of Industry and Trade | Effective 17 Jul 2026 | HS-coded list of imported goods subject to State food-safety inspection under MOIT | Heading 17.04 expressly lists 1704.90.91 and 1704.90.99; relevant 20.08 nut/seed preparations are also listed | New: Circular 28/2026. Previous: Clause 1 Article 2 and Appendix II of Decision 1182/QD-BCT cease from its effective date. |
| Goods labeling | Decree 43/2017/ND-CP as amended by Decree 111/2021/ND-CP | Government | Amendment effective 15 Feb 2022 | Imported-goods and supplementary labels | Mandatory contents, origin, responsible entity | Artwork must reconcile with formula and product description. |
| Nutrition labeling | Circular 30/2026/TT-BYT | Ministry of Health | Effective 10 Jul 2026 | Nutrition composition/value labeling | Article 5 and Appendix I; added-sugar foods within scope should review total sugars | New: Circular 30/2026. Previous: Circular 29/2023/TT-BYT ceased on 10 Jul 2026. |
| Customs | Customs Law 54/2014/QH13; Decree 08/2015/ND-CP as amended by Decree 167/2025/ND-CP | National Assembly / Government | Decree 167 amendment effective 15 Aug 2025 | Customs declaration, inspection and supervision framework | Current provisions by declaration scenario | Goods description and classification dossier must be consistent. |
| MFN tariff | Decree 26/2023/ND-CP and current tariff instruments | Government | Use tariff in force on declaration date | MFN basis | 1704.90.99: MFN 15%; 2008.11.10: 30%; 2008.11.90: 20%; 2008.19.91/99: 18% | Check amendments and final HS. |
| 2026 tariff / FTAs | Vietnam Customs Tariff Schedule 2026 + special preferential schedules | Finance/customs authorities | By year/agreement | Ordinary/MFN/FTA/VAT reference | 1704.90.99: ordinary 22.5%; MFN 15%; standard VAT 10% | FTA preference requires qualifying origin and proof. |
| VAT reduction | Resolution 204/2025/QH15 + Decree 174/2025/ND-CP | National Assembly / Government | 1 Jul 2025–31 Dec 2026 | 2-percentage-point reduction for eligible 10% goods outside exclusions | Conditions and exclusion appendices | Do not assume every SKU qualifies for 8%. |
| Cargo scenario | Instrument to review | Possible policy | Authority (high level) | Trigger condition |
|---|---|---|---|---|
| Nut brittle correctly under 1704.90.99 | Circular 28/2026 + Decree 15/2018 | Self-declaration before circulation; State food-safety inspection under applicable method | MOIT/inspection authority + Customs | Final HS 1704.90.99 and no exemption applies. |
| Product remains a prepared nut/seed under 20.08 | Circular 28/2026 + Chapter 20 tariff | Food-safety review remains relevant, but HS/duty shift to 2008.11/2008.19 | MOIT + Customs | Product form/process shows nut/seed essential character. |
| Cocoa/chocolate dominates | Chapter 17 note + Chapter 18 + Circular 28/2026 | Shift to 18.06 and reassess HS/duty/origin | MOIT + Customs | Chocolate/cocoa changes essential character. |
| Sample / R&D | Decree 15/2018 Article 13 | May qualify for food-safety inspection exemption where conditions are met | Food-safety authority + Customs | Purpose, quantity and evidence fit the statutory case. |
| Eligible reduced-inspection history | Decree 15/2018 Articles 16–19 | Reduced inspection may apply where legal criteria are met | Food-safety inspection authority + Customs | Compliance/history criteria are satisfied. |
| Bulk/raw or insufficiently processed peanuts/sesame/nuts | Plant-quarantine rules + commodity-specific lists | Separate plant-quarantine review may arise | Plant-quarantine authority + Customs | Only where actual goods remain within a regulated plant-material scope; do not infer this from ingredients in finished candy. |
| Mixed gift box | Classification rules + policy by component | Retail-set/essential-character analysis or separate classification | Customs + specialized authorities | Packaging, value/weight and independent sale characteristics. |
| Formula/process/manufacturer/origin change | Food safety + labeling + tariff + FTA | Reassess HS, testing/declaration, label and C/O for future lots | Importer/compliance | Change affects product character, dossier or origin. |
7. TIMING, FEES & COST RISK
Timing depends on inspection method and file completeness. Under Decree 15/2018, normal inspection is processed within 3 working days; tight inspection within 7 working days, including sampling/testing, once the file is valid. These are not the total logistics lead time for the shipment.
| Step | Recommended timing | Required output | Fees/costs to review | Delay risk |
|---|---|---|---|---|
| Product – HS – C/O review | Before quotation/PO or booking | Brittle vs prepared nut/seed vs chocolate branch, planned HS, MFN/FTA and landed cost | Advisory/classification cost if outsourced | Wrong 1704/2008 branch distorts duty and origin plan. |
| Testing – self-declaration – label | Before shipment and before circulation | Suitable test, self-declaration file, artwork/label | Lab/label costs by provider | Cargo arrives before SKU file is locked. |
| Determine food-safety method | Before ETA | Know exemption/reduced/normal/tight route and file | Inspection/testing fees if legally triggered | Wrong method or weak evidence. |
| Lock C/O and commercial file | Before ETA | Commercial/origin/product records reconcile | Amendment costs if any | Loss of FTA preference or delayed explanation. |
| Customs declaration / channel | When filing conditions are met | Declaration, taxes and specialized records ready | Import duty, VAT, terminal/warehouse/trucking | Yellow/red channel or HS challenge. |
| Post-clearance / circulation | Before sale and during retention period | Final label, lot/SKU dossier, audit trail | Storage/label/record cost | Weak support for formula–test–label–HS. |
8. PRACTICAL E2E WORKFLOW
Obtain quantitative formula/BOM, sugar:nut ratio, ingredients, process, cross-section photos, texture and artwork; determine candy matrix versus prepared nut/seed.
Compare 1704.90.99 with 1704.90.91, 2008.11/2008.19 and 18.06 where cocoa applies; model MFN/ordinary and FTA.
Lock test report, self-declaration, nutrition/total sugars, label and exact-SKU product file.
Review Circular 28/2026 and Decree 15/2018 for exemption/reduced/normal/tight inspection.
Reconcile Invoice–PL–B/L/AWB–C/O–formula–process–test–self-declaration–label before filing.
Describe candy/brittle, nut/seed type and coating accurately; green generally processes electronically, yellow checks documents, red checks documents plus goods according to Customs’ decision.
Coordinate food-safety outcome, origin proof, tax and physical inspection if triggered.
Complete labels before circulation, retain lot/SKU records and manage formula/process/coating/manufacturer/origin changes.
9. FREQUENTLY ASKED QUESTIONS
1) Does peanut/sesame brittle automatically use 1704.90.99?
No. 1704.90.99 is the core branch where the finished article is hard/crisp sugar confectionery and the candy matrix gives essential character. Sugar-coated roasted nuts may belong to 20.08.
2) Which HS should be reviewed first for genuine peanut brittle?
Where it contains no cocoa, is not soft gelatin candy and no more specific description applies, 1704.90.99 is an important reference.
3) Are loose sugar-coated roasted peanuts always Chapter 17 candy?
No. Where individual nuts remain the essential product, review 2008.11.10/2008.11.90.
4) Can sesame candy fall under 2008.19.99?
Potentially, if the product is actually a prepared seed product rather than sugar confectionery. Sesame brittle in candy-bar form should generally be tested against 1704.90.99 first.
5) What is the 2026 MFN duty for 1704.90.99?
The 2026 tariff shows 15% MFN, 22.5% ordinary duty and 10% standard VAT.
6) Can China Form E reduce 1704.90.99 duty to 0%?
The 2026 ACFTA schedule shows 0% where HS, origin rules and the proof are correct.
7) Is product self-declaration required?
Processed prepackaged confectionery within Decree 15/2018 generally uses the self-declaration mechanism unless a statutory exception applies.
8) Is 1704.90.99 subject to State food-safety inspection?
From 17 Jul 2026, Circular 28/2026/TT-BCT expressly lists 1704.90.99 in the confectionery group under MOIT responsibility; each lot still requires exemption/method review under Decree 15/2018.
9) Do peanuts/sesame automatically trigger plant quarantine?
Do not infer plant quarantine merely from ingredients in a finished processed candy. Review it separately only where actual goods remain within a regulated raw/bulk plant-material scope.
10) What nutrition-label point matters in 2026?
Circular 30/2026/TT-BYT took effect on 10 Jul 2026; added-sugar foods within scope should review nutrition requirements including total sugars.
10. OUTPUTS & POST-CLEARANCE OBLIGATIONS
Formula/BOM, sugar:nut ratio, ingredients, process, specification, photos/texture and artwork for the exact SKU.
Invoice, Packing List, B/L/AWB, customs declaration, tax records, C/O and delivery records.
Self-declaration, test report and food-safety inspection file/result or exemption/reduced-inspection evidence.
Complete supplementary label, ingredients, nutrition/total sugars, dates, origin and responsible-entity information before sale.
Maintain lot/SKU audit trail supporting HS, origin, formula/process, tests, self-declaration, food safety and label.
Reassess nut/seed type, sugar:nut ratio, sweetener, gelatin, cocoa/chocolate, coating, manufacturer or origin changes.
11. GIẢI PHÁP TỪ TGIMEX
The highest-value control is locking quantitative formula + sugar:nut ratio + process + product form before ETA because those records directly drive the 17.04 versus 20.08 classification branch.
Compare 1704.90.99 against 20.08/18.06; review duty, C/O, Circular 28/2026, self-declaration, tests and labels by SKU.
Reconcile Invoice, PL, B/L/AWB, C/O, formula/BOM, process, test, self-declaration, label and planned customs filing.
Track cargo milestones and coordinate food-safety inspection, customs, port/warehouse/trucking and post-clearance records.
Obtain the supplier’s quantitative formula/BOM, manufacturing flow, product photos/cross-section and final artwork before confirming a large-volume PO.

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