VIETNAM IMPORT PROCEDURE FOR SAVORY CRACKERS
Savory crackers may fall under different HS subheadings depending on sweetness, crisp texture, seasoning, filling/coating and formulation. Declaring only the trade name “savory cracker” may lead to an incorrect HS code, duty rate, food-safety dossier or label.
Operational reference for import-export enterprises. The workflow below follows an E2E map: product identification → HS/tax/C/O → self-declaration → imported-food inspection → customs → labeling → post-clearance control.
1. OVERVIEW & SCOPE
This article applies to prepacked savory crackers made from flour/cereals and imported for retail circulation in Vietnam. It does not automatically apply to sweet biscuits, wafers, infant biscuits, extruded snacks, rice crackers or health-claim products.
Review formulation, sugar, salt, seasoning, crispness, fillings/coatings, baking process and original label.
Key alternatives commonly include 1905.90.20, 1905.90.80, 1905.90.90; an actually sweet biscuit may move to 1905.31.xx.
Ordinary crackers are generally prepacked processed foods; review Decree 15/2018 and Circular 28/2026/TT-BCT unless an exemption applies.
For 1905.90.20/.80/.90, the commonly referenced 2026 MFN is 20% and ordinary rate 30%.
Check eligibility for the temporary 8% rate through 31 Dec 2026 where the product is not excluded.
Review Decree 37/2026 and Circular 30/2026/TT-BYT for imported food labeling and nutrition information where applicable.
2. KEY TERMS & WHY THE PROCEDURE MATTERS
Commodity classification used for duty and regulatory treatment. It must follow the product’s objective characteristics, not only its commercial name.
Regulatory controls ensuring imported food meets applicable safety requirements before clearance/circulation.
Mechanism for ordinary prepacked processed foods under Decree 15/2018, except products subject to registration or exemption.
Inspection under reduced, normal or tightened methods; the outcome directly affects customs clearance.
May support special preferential duty when the relevant FTA, origin criteria and documentary conditions are met.
Operational deadline for locking HS, label, self-declaration, C/O and specialist documents before storage costs arise.
3. DETAILED PRODUCT IDENTIFICATION
Request the supplier’s formula/BOM, specification, process flow, cross-section photos, original label and taste description. For filled/coated crackers, separate the biscuit base from the filling/coating.
| Product/situation | Key features to check | Example | Evidence | Possible policy | Documents | Application note |
|---|---|---|---|---|---|---|
| Plain unsweetened cracker | Low/non-sweet sugar profile; baked biscuit | Saltine/plain cracker | Formula, spec, sensory description | HS 1905.90.20; food safety; label | Formula, label, self-declaration | Do not classify only from the word “salted”. |
| Seasoned crisp cracker | Crisp texture; cheese/herb/onion/seaweed seasoning | Seasoned savoury cracker | Formula, seasoning spec, process | Potential 1905.90.80 | Spec, process, label | Distinguish from other crisp snacks. |
| Cracker with meaningful sweetness | Sweet taste or sweet-biscuit formulation | Sweet-savoury cracker | Formula, sugar %, standard | Potential 1905.31.10/.20 | Formula, cocoa data, label | “Savory” does not exclude sweet-biscuit classification. |
| Filled/coated cracker | Cheese cream, chocolate, vegetable filling | Sandwich/filled cracker | Cross-section, filling %, formula | HS depends on final characteristics | BOM, image, spec | Do not default to plain-cracker HS. |
| Infant cracker | Designed/claimed for teething or infant feeding | Teething biscuit | Label, age claim, use | Potential 1905.90.10 or other policy | Label, target consumer | Different use can change classification/policy. |
| Sample/non-sale import | Trial, R&D, display | Sample pack | Purpose letter, quantity | Possible different/exempt treatment depending facts | Purpose, invoice, docs | Do not assume all samples are exempt. |
4. HS CODE – TAX – C/O
Savory crackers generally fall under heading 19.05, but the 8-digit subheading depends on sweetness, “crisp savoury” characteristics, structure and ingredients. Rates below are 2026 reference rates; final HS must be supported by the actual dossier.
PROPOSED HS – TAX – C/O TABLE
| Reference HS | Product description | Classification basis | When applicable | Ordinary duty | MFN | VAT | C/O/FTA review | Evidence |
|---|---|---|---|---|---|---|---|---|
| 1905.90.20 | Other unsweetened biscuits | Specific VN/AHTN description | Unsweetened cracker not covered more specifically | 30% | 20% | 10% standard; review 8% reduction | ACFTA/RCEP, ATIGA, AKFTA/VKFTA, AJCEP/VJEPA/CPTPP, EVFTA… | Formula, spec, label, C/O |
| 1905.90.80 | Other crisp savoury food products | “Other crisp savoury food products” wording | Seasoned savory/crisp product matching the description | 30% | 20% | 10%/8% if eligible | FTA according to actual origin | Formula, seasoning spec, process |
| 1905.90.90 | Other | Residual 1905.90 branch | Only if no more specific branch fits | 30% | 20% | 10%/8% if eligible | FTA according to origin | Full technical dossier |
| 1905.31.10 / 1905.31.20 | Sweet biscuits without/with cocoa | Sweet-biscuit subheading | Only if the actual product is a sweet biscuit | 22.5% | 15% | 10%/8% if eligible | FTA according to origin | Formula, cocoa content, label |
Cross-check the tariff schedule in force against the final HS code and shipment dossier.
SPECIAL PREFERENTIAL C/O/FTA ROUTES TO REVIEW
| Origin/route | FTA | Origin document | Preferential rate | Conditions | Documents | Note |
|---|---|---|---|---|---|---|
| China | ACFTA / RCEP | Form E / appropriate RCEP proof | Check 2026 schedule by final HS | Meet PSR, transport and documentary conditions | C/O, invoice, B/L, HS | Do not assume 0% before checking PSR. |
| ASEAN | ATIGA | Form D / e-Form D | Check 2026 schedule | Meet ASEAN origin rules | C/O, invoice, transport docs | Check exclusions where applicable. |
| Korea | AKFTA / VKFTA / RCEP | Form AK/VK or RCEP proof | Check 2026 schedule | Meet origin criteria | C/O + commercial docs | Choose the best eligible FTA. |
| Japan | VJEPA / AJCEP / CPTPP / RCEP | Applicable proof | Check 2026 schedule | Meet PSR and documentation | C/O, invoice, B/L | Do not mix requirements across FTAs. |
| EU/UK | EVFTA / UKVFTA | Proof under the agreement | Check 2026 schedule | Meet certification mechanism | Origin statement/C/O, invoice | Review shipment-value rules where relevant. |
| Australia/New Zealand | AANZFTA / CPTPP / RCEP | Applicable proof | Check 2026 schedule | Meet PSR | Origin docs | Select the optimal eligible arrangement. |
5. DOCUMENT SET & SUBMISSION PRINCIPLES
Manage the dossier in three layers so that commercial documents, food-safety documents and label data remain consistent.
Commercial Invoice, Packing List, B/L or AWB, Contract/PO if any, and C/O when claiming preference.
Formula/BOM, specification, process flow, original label, product images, self-declaration, food-safety test report and documents for the applicable inspection method.
Inspection registration where applicable, packing list, self-declaration and evidence supporting reduced/change-of-inspection status where relevant.
OPERATIONAL DOCUMENT CHECKLIST
| Document group | Required document | Used at | Usually prepared by | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, PL, B/L/AWB, Contract/PO | Customs/shipment matching | Shipper/Buyer/Docs | Generic name; qty/weight mismatch | Match SKU, carton, NW/GW, origin |
| HS classification | Formula, spec, process, photos, label | HS/tax determination | Supplier + Importer | Only marketing catalogue available | Obtain sugar %, seasoning, filling/coating, process |
| Self-declaration | Form 01 + food-safety test report ≤12 months | Before commercial circulation | Importer/Compliance | Expired test; inconsistent product name | Check name, sample, parameters and submitting entity |
| Imported-food inspection | Applicable registration + self-declaration + PL + evidence | Customs clearance | Importer/Forwarder | Wrong inspection method; missing evidence | Review Articles 16–19 of Decree 15 |
| C/O | FTA-compliant proof of origin | Preferential duty | Supplier/Exporter | Wrong HS/description/issue date | Cross-check invoice/B/L/origin criterion |
| Label | Original label + proposed supplementary label | Market circulation | Supplier + Importer | Missing ingredients/warning/nutrition | Lock artwork before ETA |
6. LEGAL BASIS – SPECIALIST POLICY MATRIX
6.1. LEGAL REFERENCES TO REVIEW
| Area | Instrument | Issuer | Effective/application | Role | Key provision | Review note |
|---|---|---|---|---|---|---|
| Food safety | Decree 15/2018/ND-CP | Government | Currently applied during suspension of Decree 46/2026 | Self-declaration and imported-food inspection | Arts. 4–5; 16–19 | Ordinary crackers generally fit prepacked processed foods unless an exception applies. |
| 2026 status | Resolution 15/2026/NQ-CP | Government | 6 Apr 2026 | Suspends Decree 46/2026 and Resolution 66.13/2026 | Suspension provisions | Monitor replacement legislation. |
| Food-safety HS list | Circular 28/2026/TT-BCT | MOIT | 17 Jul 2026 | HS list subject to state food-safety inspection | Heading 19.05 annex | Includes 1905.90.20/.80/.90. |
| HS | Circular 31/2022/TT-BTC | MOF | Current nomenclature basis | Vietnam HS/AHTN 2022 | Heading 19.05 | Classify on objective characteristics. |
| Import duty | Decree 26/2023/ND-CP + current schedules | Government | Check on declaration date | MFN duty | Final HS | Special FTA schedules are separate. |
| VAT | Decree 174/2025/ND-CP | Government | Reduction policy through 31 Dec 2026 | VAT reduction for eligible goods | Exclusion annexes | Do not automatically assume every cracker is 8%. |
| Label | Decree 37/2026/ND-CP | Government | 23 Jan 2026 | Goods labeling | Imported goods label provisions | Lock label before circulation. |
| Nutrition | Circular 30/2026/TT-BYT | MOH | 10 Jul 2026 | Nutrition ingredient/value labeling guidance | Scope/application | Review artwork by product type. |
| Customs | Decree 08/2015 as amended by 167/2025/ND-CP | Government | Amendment effective 15 Aug 2025 | Customs procedures | Shipment-specific dossier | Read with Customs Law and current guidance. |
| Ordinary import duty | Decision 15/2023/QD-TTg | Prime Minister | Effective 15 Jul 2023 | Legal basis for ordinary import duty rates | Tariff appendix by HS line | Review together with the final HS when MFN/FTA treatment is not available. |
| Food safety – new/old | Circular 28/2026/TT-BCT / Decision 1182/QD-BCT | MOIT | Circular 28 effective 17 Jul 2026 | Circular 28 replaces the former imported-food list layer in Clause 1 Article 2 and Appendix 2 of Decision 1182 | Article 4 of Circular 28/2026 | Clause 1 Article 2 and Appendix 2 of Decision 1182 cease to apply from 17 Jul 2026; review Circular 28 transition rules for earlier-filed dossiers. |
| Labeling – new/old | Decree 37/2026/ND-CP / Decree 43/2017 + Decree 111/2021 | Government | Decree 37 effective 23 Jan 2026 | New labeling regime replacing Decree 43/2017 and Decree 111/2021 | Articles 97–98 of Decree 37/2026 | Transitional rules apply to certain goods/labels/commercial packaging produced or imported under the former regime. |
6.2. POLICY MATRIX BY SHIPMENT SCENARIO
| Scenario | Reference | Possible policy | Authority level | Trigger |
|---|---|---|---|---|
| Ordinary prepacked savory cracker | Decree 15 + Circular 28/2026 | Self-declaration + state food-safety inspection | MOIT-designated inspection + Customs | Imported for domestic business/circulation and not exempt |
| Eligible for reduced inspection | Arts. 16–17 Decree 15 | Reduced inspection; Customs random check up to 5% | Customs/relevant authority | Meets a statutory reduced-inspection condition |
| Normal inspection shipment | Arts. 17–19 Decree 15 | Document inspection | State food-safety inspector + Customs | Not reduced or tightened |
| Warning/previous failure | Arts. 17–19 Decree 15 | Tightened inspection with sampling/testing | State food-safety inspector | Tightened-inspection trigger exists |
| Special claim/product | Art. 6 Decree 15 and relevant rules | May require registered declaration instead of self-declaration | Relevant authority | Actual product falls under Article 6 |
| Imported only for internal export production | Art. 4 Decree 15 | Potential self-declaration exemption | Authority/Customs | Not sold domestically and exemption conditions met |
7. TIMELINE, FEES & RISK COSTS
| Stage | Operational point | Timing/basis | Cost layer | Main risk |
|---|---|---|---|---|
| HS/dossier review | Before booking/ETA | Depends on completeness of formula/spec | Internal/advisory cost if any | Late HS causes wrong landed-cost estimate |
| Self-declaration | Before commercial circulation | Business-led under Decree 15; test report ≤12 months | Testing if needed | Product/test-report name mismatch |
| Normal food-safety inspection | Before/at arrival | 3 working days from dossier receipt under Art. 19 | Official/testing cost if applicable | Supplement request increases storage |
| Tightened inspection | When triggered | 7 working days for dossier review, sampling/testing and notice under Art. 19 | Testing + logistics | DEM/DET/storage exposure |
| Customs | After specialist conditions | Depends on Green/Yellow/Red channel and dossier | Import duty, VAT, logistics | Valuation, C/O, label or description issue |
| Post-clearance | Before circulation/audit | According to labeling/record duties | Supplementary label, warehouse, record control | Formula/label changes not reflected |
8. PRACTICAL E2E WORKFLOW
Collect formula, spec, process, photos and label; decide whether it is unsweetened or a crisp savoury/flavoured product.
Compare 1905.90.20/.80/.90 and competing branches; estimate MFN/VAT and choose the appropriate FTA.
Complete self-declaration, valid test report, label and shipment food-safety documents.
Check eligibility for reduced, normal or tightened inspection under Decree 15.
Cross-check Invoice, PL, B/L/AWB, C/O, label, HS, product name and food-safety dossier.
Green: primarily automated; Yellow: document review; Red: potential physical examination plus dossier.
Provide the required outcome, resolve C/O/tax and release goods when conditions are met.
Complete supplementary labeling where applicable, retain batch records and manage formula/supplier/origin changes.
9. FAQ
1. Does a savory cracker always use HS 1905.90.20?
No. 1905.90.20 is a key candidate for other unsweetened biscuits. Seasoned crisp savory products may require 1905.90.80/.90 or another branch.
2. Is cheese cracker automatically 1905.90.80?
No. Review formulation, seasoning, biscuit structure, sweetness and any filling/coating before classification.
3. Can a cracker containing some sugar still be unsweetened?
The answer cannot be based only on presence/absence of sugar. The product’s objective formulation and classification characteristics must be reviewed.
4. Must imported crackers be self-declared?
Ordinary prepacked processed crackers generally fall under self-declaration under Articles 4–5 of Decree 15/2018 unless exempt or subject to registered declaration.
5. What is the core self-declaration dossier?
Form 01 and a food-safety test report issued within 12 months under Article 5 of Decree 15/2018, subject to the applicable language/validity requirements.
6. Is every shipment subject to the same food-safety inspection?
No. Decree 15 provides reduced, normal and tightened methods with different triggers.
7. How long does normal inspection take?
Article 19 provides a 3-working-day period from receipt of the dossier for the inspection notice; incomplete files can require supplementation.
8. Can C/O reduce import duty?
Potentially, if the correct FTA, origin criterion and documentary conditions are met. Do not lock a special rate before HS and PSR review.
9. Can the Vietnamese supplementary label be prepared after arrival?
Imported-goods labeling rules must be respected. Operationally, the label should be finalized before ETA to avoid a cleared shipment that is not ready for circulation.
10. Can an original-flavor dossier be reused for cheese/onion flavor?
Do not assume so. Changes to name, origin, ingredients or other dossier-relevant data may trigger updating/re-declaration obligations.
10. OUTPUTS & POST-CLEARANCE OBLIGATIONS
Keep formula/spec/label and classification evidence aligned with the imported SKU version.
Keep Invoice, PL, B/L/AWB, C/O, customs declaration and tax evidence aligned to the actual shipment.
Retain self-declaration, test report and imported-food inspection records/results as applicable.
Control original/supplementary label, ingredients, warnings and nutrition information under current rules.
Organize records by SKU/batch for traceability during post-clearance or food-safety inspection.
When factory, origin, formula, filling/coating, claim or label changes, reassess HS, food safety, C/O and declaration.
11. TGIMEX SOLUTION
For savory crackers, risk usually arises from misalignment across HS – formulation – self-declaration – food safety – C/O – label. Pre-ETA review helps reduce supplementary filings and unplanned storage costs.
Cross-check formula/spec, competing HS branches, MFN/VAT, C/O, self-declaration and label before arrival.
Align Invoice, PL, B/L/AWB, C/O, label, test report, self-declaration and shipment food-safety pack.
Track dossier milestones and coordinate customs, port/warehouse, transport and post-clearance recordkeeping.
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