Raw pumpkin seeds and roasted pumpkin seeds should not share one HS/policy conclusion. Where pumpkin seeds remain oil seeds and are unroasted/not deeply processed, the core reference is 1207.99.90. Vietnam Customs previously guided that pumpkin seeds for sowing also remain under 1207.99.90 because Chapter 12 contains a specific rule for heading 12.07. Once the seeds are roasted and sold as a ready-to-eat snack, the core branch changes to 2008.19.91 – roasted; if prepared/preserved but not fitting the roasted description, review 2008.19.99. That distinction affects duty, origin preference, plant quarantine, food-safety authority and labeling. This guide follows species + raw/roasted + shell status + process + seasoning/coating + intended use → HS/tax/C/O → plant quarantine/food safety → customs → labeling → post-clearance.

Operational reference for importers; reviewed against the legal framework through 9 Sep 2026. Main scope: edible raw/unroasted pumpkin seeds and roasted/flavored pumpkin seed snacks in commercial packaging.

2. KEY TERMS & WHY THE PROCEDURE MATTERS

HS classification

Customs classification. The major split is between raw/unroasted oil seeds and roasted/otherwise prepared snack products.

RAW

Raw pumpkin seeds

Seeds not roasted or deeply cooked; they may be in-shell or shelled but still retain the character of oil seeds.

ROAST

Roasted pumpkin seeds

Seeds processed by roasting for direct consumption; where roasted seed remains essential character, heading 20.08 is central.

Plant quarantine

Plant-health control for regulated plant materials, especially relevant to raw pumpkin seeds under 1207.99.90.

Food safety

Specialized food-control layer including self-declaration/testing and State inspection under the competent authority.

SELF

Product self-declaration

Mechanism for processed prepackaged foods within Article 4 of Decree 15/2018/ND-CP.

PSR

Product Specific Rules

FTA-specific origin rules; C/O preference only applies if the relevant rule is met.

C/O

Origin proof

Evidence used to claim special preferential tariff treatment; HS, description, invoice and transport must reconcile.

ETA

Estimated Time of Arrival

HS, PQ/food safety, C/O, label and technical records should be locked before ETA.

SKU

Stock Keeping Unit

Raw, roasted, salted, honey, cheese, shelled/in-shell variants may require separate dossiers and conclusions.

Why this matters: the same words “pumpkin seeds” can refer to raw 1207.99.90 oil seeds or roasted 2008.19.91 snacks, which sit in different HS chapters and may trigger different specialized controls.

Key point: do not classify from the commercial name alone. Obtain the botanical name, raw/roasted status, process, intended use and product photos.

3. DETAILED PRODUCT IDENTIFICATION & CLASSIFICATION

This article covers edible raw/unroasted pumpkin seeds and roasted/flavored pumpkin-seed snacks. Sowing seed, flour/meal, mixed products and thick sugar-coated products require separate review.

DETAILED PRODUCT CLASSIFICATION TABLE

Product group/cargo scenario	Technical indicators to review	Example	Supporting documents	Possible policy triggers	Documents to reconcile	Application note
Raw pumpkin seeds for food/material	Unroasted/not deeply cooked; oil-seed character; in-shell or shelled	Raw pumpkin seeds / pumpkin kernels	Scientific name, COA, moisture, process, photos	HS 1207.99.90; plant quarantine; plant-origin food safety; label; C/O	Phytosanitary docs, COA, process, label, commercial docs	Core branch for raw pumpkin seed.
Pumpkin seeds for sowing	Sowing purpose; still an oil seed	Pumpkin seed for sowing	Seed certificate, intended use, species, contract	Base HS 1207.99.90; review seed-law/PQ controls and Chapter-98 tariff treatment if qualified	Seed docs, phytosanitary, contract, permit/registration where applicable	Customs guidance 7952/TXNK-PL previously placed pumpkin seed for sowing under 1207.99.90.
Plain roasted pumpkin seeds	Clear roasting step; ready-to-eat; no material coating	Roasted pumpkin seeds	Process flow, roast parameters, photos	HS 2008.19.91; Circular 28/2026; self-declaration; label; C/O	Process, test, self-declaration, label	Core branch for roasted snack.
Salted/flavored roasted pumpkin seeds	Roasted; salt/spice is seasoning	Salted/spiced roasted pumpkin seeds	Formula, salt %, process, nutrition	Usually still review 2008.19.91; nutrition label should review sodium	Formula, process, test, label	Seasoning does not automatically move goods to 2008.19.99.
Light honey/caramel coating	Roasted with sugar/syrup coating while seed still dominates	Honey roasted pumpkin seeds	Sugar %, coating %, process, photos	Review 2008.19.91; if sugar matrix creates confectionery character, review 17.04	Formula, photos, process, label	Distinguish coated seed from sugar confectionery.
Prepared but not roasted seeds	No roasting; steamed, seasoned, preserved or otherwise processed	Prepared pumpkin seed snack	Process, final state, texture	Review 2008.19.99 if within 20.08 but not roasted	Process, spec, photos	Residual line after excluding roasted.
Pumpkin seed flour/meal	Ground into meal or flour	Pumpkin seed flour/meal	Particle size, fat content, process	Review 1208.90.00 or another appropriate heading	Spec, process, use	Do not use 1207.99.90 once transformed into flour/meal.
Mixed seeds/nuts	Pumpkin plus sunflower, almonds, cashews etc.	Mixed roasted seed/nut snack	BOM %, process, retail pack	May remain in 2008.19 where appropriate; review subheading/essential character	BOM, process, label	Do not default the whole mixture to pumpkin seed.

Mandatory classification warning: a generic “pumpkin seeds” description can cause a wrong choice between 1207.99.90 and 2008.19.91, with downstream duty, plant-quarantine and food-safety consequences.

4. HS CODE – TAX – C/O

Raw and roasted pumpkin seeds should be split at classification stage: 1207.99.90 for raw/unroasted oil seed and 2008.19.91 for roasted seed snack where the dossier supports that result. Reference MFN rates are 10% for raw and 18% for roasted.

PROPOSED HS – TAX – C/O TABLE

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
1207.99.90	Other oil seeds and oleaginous fruits – other	Heading 12.07; pumpkin seed treated as other oil seed where not deeply processed	Raw/unroasted pumpkin seed, including sowing scenarios under prior Customs guidance	15%	10%	Review under agricultural/preliminarily processed rules; commonly a 5% or non-taxable analysis where conditions are met	ATIGA, ACFTA, EVFTA and other FTAs may reach 0% by route	Botanical name, process, intended use, phytosanitary docs, C/O
2008.19.91	Other nuts/ground-nuts/seeds – other – roasted	Heading 20.08, “Other, including mixtures – Other – Roasted”	Roasted pumpkin seed snack; seasoning/coating does not displace roasted-seed essential character	27%	18%	Standard 10%; review 8% eligibility in 2026	ATIGA, ACFTA, AKFTA/VKFTA, AJCEP/VJEPA/CPTPP, AANZFTA, AIFTA, EVFTA/UKVFTA, AHKFTA, RCEP	Process, roast evidence, formula, label, C/O
2008.19.99	Other prepared/preserved nuts/seeds – other	Residual prepared/preserved line in 20.08	Prepared/preserved but not fitting the roasted description	27%	18%	Standard 10%; review 8% if eligible	FTA by origin	Process, final state, formula, label
1208.90.00	Flours/meals of other oil seeds	Heading 12.08	Pumpkin seed ground into flour/meal, no longer whole seed form	Verify current ordinary rate	25% MFN reference under Decree 26/2023	Review by actual dossier	FTA by final HS	Particle size, fat content, process, use

HS principle: lock species + raw/roasted + shell status + process + intended use + seasoning/coating + final product photo. Sowing purpose does not automatically move pumpkin seed to heading 12.09; prior Customs guidance still placed it under 1207.99.90.

SPECIAL FTA / ORIGIN REVIEW BY IMPORT ROUTE

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	2008.19.91: 0%; for 1207.99.90, verify the current ATIGA line, with many oil-seed lines already at 0%	Correct HS, PSR and valid proof	C/O, Invoice, B/L, BOM/process where needed	Raw and roasted use different HS tariff lines.
China	ACFTA / RCEP	Form E / qualifying RCEP proof	2008.19.91: ACFTA 0%; 1207.99.90: ACFTA 0%; compare RCEP separately for 2026	Correct HS, PSR, invoice/transport	C/O, process, commercial docs	ACFTA is often the first route to compare for China origin.
Korea	AKFTA / VKFTA / RCEP	Form AK / VK / RCEP proof	2008.19.91: AKFTA/VKFTA 0%; verify 1207.99.90 in the selected schedule	Meet PSR	Origin proof, process, Invoice, B/L	Do not use one tax conclusion for both raw and roasted.
Japan	AJCEP / VJEPA / CPTPP / RCEP	Agreement-specific origin proof	2008.19.91: AJCEP/VJEPA/CPTPP 0%; verify 1207.99.90 in the current schedule	Meet PSR and transport rules	Origin proof, commercial docs	Choose the most favorable and supportable agreement.
EU / UK	EVFTA / UKVFTA	EUR.1 or qualifying proof	1207.99.90: EVFTA 0%; 2008.19.91: EVFTA/UKVFTA about 2.2% in 2026	Meet PSR; sweetened Chapter-20 SKUs should review sugar-related rule conditions	Origin proof, formula, BOM, process	Raw and roasted follow different tariff phase-outs.
Australia / New Zealand	AANZFTA / CPTPP	Agreement-specific proof	2008.19.91: 0%; verify 1207.99.90 in the relevant schedule	Meet origin rule	Origin proof, commercial docs	RCEP is not always the lowest route.
India	AIFTA	Form AI / qualifying proof	2008.19.91: 0%; verify 1207.99.90 under AIFTA	Meet PSR/document conditions	C/O, Invoice, B/L	Compare against MFN before landed-cost modeling.
Hong Kong	AHKFTA	AHKFTA origin proof	2008.19.91: 4% in 2026; verify raw 1207.99.90 separately	Meet PSR/document conditions	Origin proof, Invoice, transport docs	Phase-down changes by year.

C/O checklist: form/proof; WO/RVC/CTH/CTSH/CC; description; HS; quantity/weight; origin; third-party invoice; transport; authentication; issue date and validity.

5. DOSSIER & SUBMISSION LOGIC

Raw/roasted pumpkin seeds require dossier management by product state, not just product name. The raw-seed file and roasted-snack file should not be interchanged.

Commercial dossier

Invoice, Packing List, B/L/AWB, Contract/PO if any and C/O; description should show raw/roasted status, pack, origin and intended use.

Technical / specialized dossier

Species, process, roast evidence, formula, COA/test, phytosanitary records for raw, self-declaration/food-safety file for roasted, artwork/label.

Registration & reconciliation pack

Map SKU ↔ species ↔ raw/roasted ↔ HS ↔ PQ/food safety ↔ test ↔ label ↔ C/O ↔ commercial documents.

Dossier principle: Invoice, PL, B/L/AWB, C/O, species, process, phytosanitary/test records, specialized documents, labels and customs filing should match 100%. No click-by-click filing portal instructions are included.

OPERATIONAL DOSSIER CHECKLIST

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	Customs, valuation, origin	Importer + supplier + forwarder	Invoice only says pumpkin seeds; raw/roasted/salted omitted	Add state, pack, manufacturer, origin and intended use.
Product identification / HS	Botanical name; shell status; process; roast confirmation; formula; photos	HS/tax/policy	Manufacturer + importer compliance	No proof of raw vs roasted; confusion with melon seeds	Lock exact species and process by SKU.
Raw seed – plant quarantine	Phytosanitary certificate/PQ records as applicable; intended-use file	Pre-clearance	Supplier + importer	Missing phytosanitary evidence or country/species mismatch	Review Circular 01/2024 and 1207.99.90 status before shipment.
Raw seed – plant-origin food safety	Applicable specialized-inspection file; COA/test and product records	Pre/during clearance	Importer + specialized authority	Using roasted-snack dossier for raw seed or vice versa	Separate authority/control path by final HS and food use.
Roasted snack – self-declaration / FS	Self-declaration; test report; Decree-15/Circular-28 food-safety file	Pre-market / clearance	Importer + inspection authority	Wrong flavor/SKU test; missing 2008.19.91 under Circular 28	Review Decree 15 Articles 4–5, 13, 16–19 and final HS.
Label	Original/supplementary label; ingredients; nutrition; sodium/total sugars where applicable	Before circulation	Importer + supplier/brand	Label does not identify raw/roasted; nutrition inconsistent with flavor	Reconcile formula with labeling rules and Circular 30/2026.

6. LEGAL BASIS – SPECIALIZED POLICY MATRIX

6.1. LEGAL INSTRUMENTS TO REVIEW

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	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 transition	Articles 1–2	Decree 15/2018 and related guidance continue during suspension.
Processed-food declaration/inspection	Decree 15/2018/ND-CP	Government	Effective 2 Feb 2018; continues in 2026 transition	Self-declaration, exemptions and import food-safety inspection	Articles 4–5, 13, 16–19	Particularly relevant to roasted/prepackaged foods.
MOIT food-safety HS list	Circular 28/2026/TT-BCT	Ministry of Industry and Trade	Effective 17 Jul 2026	HS list under MOIT food-safety inspection responsibility	Heading 20.08 includes 2008.19.91 and 2008.19.99	Applies where final HS is roasted/prepared seed snack.
Agriculture/PQ HS lists	Circular 01/2024/TT-BNNPTNT	Ministry of Agriculture and Rural Development	Effective 20 Mar 2024	HS lists for agricultural management and specialized inspection	Appendix I includes plant-quarantine and plant-origin food sections; 1207.99.90 appears in the relevant heading	Replaced Circular 11/2021; raw seed must be reviewed by actual state/use.
Pumpkin seed for sowing classification	Official Letter 7952/TXNK-PL (2019)	Import-Export Tax Department – General Department of Customs	Case-specific classification guidance	Pumpkin seed for sowing guided to 1207.99.90	Legal Note 3 to Chapter 12	Reference for classification logic; final HS still depends on current nomenclature and actual goods.
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 content, origin, responsible entity	Apply according to packaging/circulation form.
Nutrition labeling	Circular 30/2026/TT-BYT	Ministry of Health	Effective 10 Jul 2026	Nutrition composition/value labeling	Article 5; added sugar → total sugars; salted products → sodium	Most relevant to roasted/flavored packaged snacks.
MFN / ordinary duty	Decree 26/2023/ND-CP; Decision 15/2023/QD-TTg and current tariff	Government / Prime Minister	At declaration date	MFN and ordinary duty basis	1207.99.90: MFN 10%, ordinary 15%; 2008.19.91: MFN 18%, ordinary 27%	Check amendments and final HS.

6.2. POLICY MATRIX BY CARGO SCENARIO

Cargo scenario	Instrument to review	Possible policy	Authority (high level)	Trigger condition
Raw 1207.99.90 for food	Circular 01/2024 + current FS/PQ rules	Plant quarantine and plant-origin food-safety controls may both arise	Agriculture/PQ authority + Customs	Goods remain raw/unroasted and are imported for food.
Pumpkin seed for sowing	Official Letter 7952 + Circular 01/2024 + seed law	Base HS 1207.99.90; review PQ, seed conditions and possible Chapter-98 tariff treatment	Agriculture authority + Customs	Sowing purpose is documented.
Roasted 2008.19.91	Circular 28/2026 + Decree 15/2018	Self-declaration; State food-safety inspection under applicable method	MOIT/inspection authority + Customs	Final HS 2008.19.91 and no exemption.
Prepared but not roasted 2008.19.99	Circular 28/2026 + Decree 15/2018	Similar food-safety layer, but HS/duty under 2008.19.99	MOIT + Customs	Process does not fit roasted description.
Salted/sweetened roasted SKU	Circular 30/2026	Nutrition label should review sodium; added sugar should review total sugars	Food-safety/market authority	Formula includes salt/added sugar and product is within scope.
Coating creates confectionery character	HS notes + Chapter 17 + Circular 28/2026	Possible shift to 17.04 with re-review of tax/origin/food safety	MOIT + Customs	Sugar matrix gives essential character.
Sample / R&D	Decree 15/2018 Article 13 + raw-specific controls if applicable	Food-safety exemption may be possible; raw seed still needs separate PQ review	Specialized authority + Customs	Purpose/quantity/evidence fit.
Supplier/origin/process change	Food safety + PQ + label + tariff + FTA	Reassess HS, C/O, phytosanitary, test/declaration and label	Importer/compliance	Change affects dossier or product character.

Key legal split: raw 1207.99.90 and roasted 2008.19.91 differ not only in HS but also in the specialized-control track: raw goods lean toward agriculture/PQ controls, while roasted snacks are expressly listed by Circular 28/2026 under MOIT.

7. TIMING, FEES & COST RISK

For roasted food under Decree 15/2018, normal inspection is processed within 3 working days and tight inspection within 7 working days once the file is valid. Raw-seed/PQ timing must be reviewed separately under the agricultural procedure and should not be inferred from roasted-food timelines.

TIMELINE & COST-RISK TABLE

Step	Recommended timing	Required output	Fees/costs to review	Delay risk
State – HS – C/O review	Before PO/booking	Raw/roasted/sowing status, HS, MFN/FTA and specialized authority	Classification/advisory fee if outsourced	Wrong 1207.99.90 vs 2008.19.91.
Raw seed: PQ / food safety	Before shipment/ETA	Phytosanitary and specialized food records where applicable	PQ/testing fees per actual regime	Cargo arrives without phytosanitary or correct species data.
Roasted: testing / declaration / label	Before shipment and circulation	Test, self-declaration, nutrition/artwork by SKU	Lab/label costs	New flavor lacks dossier.
Lock C/O & commercial file	Before ETA	Invoice–PL–B/L/AWB–C/O–process–specialized records reconcile	Amendment cost if any	Loss of tariff preference or explanation delay.
Customs filing/channel	When conditions met	HS, tax, PQ/food safety and docs ready	Duty, VAT, terminal/warehouse/trucking	Yellow/red channel or product-state dispute.
Post-clearance/circulation	Before sale	Final label, lot/SKU file, audit trail	Storage/label/records	Weak traceability in post-audit.

Separate cost buckets: import duty/VAT; PQ or specialized inspection if triggered; testing/self-declaration/label; terminal/warehouse/trucking; storage/DEM/DET due to late documents.

8. PRACTICAL E2E WORKFLOW

STEP 01

Identify the product

Lock species, raw/roasted, shell status, intended use, process, formula/coating and photos.

STEP 02

Lock HS – tax – C/O

Compare 1207.99.90 with 2008.19.91, 2008.19.99 and other headings for flour/heavy coating.

STEP 03

Prepare specialized records

Raw: phytosanitary/PQ plus plant-origin food-safety file where applicable. Roasted: test, self-declaration, nutrition, label.

STEP 04

Determine applicable method

Lock competent authority and method based on product state, final HS, intended use and lot history.

STEP 05

Lock documents before ETA

Reconcile Invoice–PL–B/L/AWB–C/O–species–process–phytosanitary/test–self-declaration–label.

STEP 06

Declare / handle customs channel

Describe raw pumpkin seeds or roasted pumpkin seeds accurately; green generally electronic, yellow checks docs, red checks docs plus goods as decided by Customs.

STEP 07

Complete specialized controls – tax – clearance

Coordinate PQ/food safety, C/O, taxes and physical inspection if triggered.

STEP 08

Post-clearance

Complete labels, retain lot/SKU records and manage raw↔roasted, supplier, origin and process changes.

Pre-ETA milestone: lock species + raw/roasted + HS + specialized authority + C/O + phytosanitary/test + label.

Main blockers: Invoice only says “pumpkin seeds”; no intended use; missing phytosanitary for raw goods; using 1207.99.90 for roasted goods; or using roasted-snack MOIT records for raw seeds.

9. FREQUENTLY ASKED QUESTIONS

1) Which HS should be reviewed for raw pumpkin seeds?

For unroasted/not deeply processed pumpkin seeds, 1207.99.90 is the core reference.

2) Which HS should be reviewed for roasted pumpkin seeds?

For a ready-to-eat roasted seed snack, 2008.19.91 is the core reference.

3) Do pumpkin seeds for sowing move to heading 1209?

Not automatically. Official Letter 7952/TXNK-PL previously guided pumpkin seed for sowing to 1207.99.90 under Chapter 12 rules.

4) Do raw pumpkin seeds require plant quarantine?

1207.99.90 appears within the plant-quarantine HS framework of Circular 01/2024; the actual lot should be reviewed by state, use and documentation.

5) Do raw edible seeds also trigger food-safety review?

Plant-origin food-safety control may arise under the agricultural-management framework; review Circular 01/2024 and the actual shipment file.

6) Are roasted pumpkin seeds listed in Circular 28/2026?

Yes. 2008.19.91 and 2008.19.99 are listed in Circular 28/2026/TT-BCT.

7) How do raw and roasted MFN rates differ?

2026 reference: 1207.99.90 MFN 10%; 2008.19.91 MFN 18%.

8) Can China Form E reduce duty?

Potentially. ACFTA schedules show 0% references for both 1207.99.90 and 2008.19.91 when PSR and proof are satisfied.

9) What should salted roasted pumpkin seeds show on nutrition labels?

Review ingredients and sodium; if added sugar exists, review total sugars under Circular 30/2026 where applicable.

10) Can the raw-seed dossier be reused after roasting?

Not safely. Roasting changes HS and the specialized-control track, so the dossier should be reassessed.

10. OUTPUTS & POST-CLEARANCE OBLIGATIONS

Product file

Species, raw/roasted status, shell status, process, formula/spec, COA, photos and artwork.

Shipment file

Invoice, PL, B/L/AWB, customs declaration, C/O, tax and delivery records.

Specialized-control file

Raw: PQ/plant-food safety where applicable. Roasted: self-declaration, test and food-safety file by lot.

Label & circulation

Supplementary label, ingredients, nutrition, sodium/total sugar where applicable, origin and responsible entity.

Retention & audit

SKU ↔ species ↔ raw/roasted ↔ HS ↔ PQ/food safety ↔ C/O ↔ label audit trail.

CHECK

Change control

Reassess raw↔roasted, supplier, origin, flavor/coating or intended-use changes.

Target output: the importer can explain why a raw lot uses 1207.99.90 or a roasted lot uses 2008.19.91, which authority applies, which C/O/tax route is used and which label is circulated.

Clearance is not the endpoint: process, intended-use or supplier/origin changes can alter PQ/food-safety, HS, C/O and labeling for future lots.

11. GIẢI PHÁP TỪ TGIMEX

The highest-value control is to split raw and roasted workflows at PO stage instead of waiting for arrival to determine specialized controls.

Pre-ETA review

Compare 1207.99.90 / 2008.19.91 / 2008.19.99; review PQ, food safety, duty, C/O and labels.

Compliance dossier control

Reconcile Invoice, PL, B/L/AWB, C/O, species, process, phytosanitary/test, self-declaration and label.

Operational / logistics coordination

Track specialized-control milestones, customs, port/warehouse/trucking and post-clearance records.

Obtain the supplier’s botanical name, process flow, raw/roasted confirmation, intended use, phytosanitary capability, COA/test and final artwork before shipment.

View Circular 01/2024 View Circular 28/2026

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