“Fish snack / fish strips” is only a trade description. Depending on actual processing, the goods may be simply dried fish under Chapter 03, prepared fish in pieces under 1604.1x, or shredded/minced/otherwise prepared fish under 1604.20. From 13 Jan 2026, Circular 03/2026/TT-BNNMT is the current aquatic-quarantine rule and its basic product list focuses on fresh, chilled and frozen aquatic products.

Lock species, formula, process flow, piece/shredded structure, finished state, packaging and storage before finalizing HS, tax, quarantine, food safety and customs documentation.

Operational reference for import-export businesses · Updated through 10 Sep 2026.

1. QUICK SUMMARY & SCOPE

PRODUCT GROUP

Processed fish food

Fish snack, fish strips, shredded fish or fish floss for direct consumption; separate from simply dried fish and chilled/frozen semi-processed products.

REFERENCE HS

03.05 / 1604.19 / 1604.20

Do not lock one code from “fish strips”; determine processing degree, species and whole/pieces versus shredded/other preparation.

SPECIALIZED CONTROL

Food safety; AQ by product state

Deep-processed fish snack no longer fresh/chilled/frozen generally falls outside Appendix I-II.1 of Circular 03/2026; actual chilled/frozen goods require AQ review.

MARKET CIRCULATION

Self-declaration + label

Ordinary processed prepacked food must review self-declaration under Decree 15/2018 and Vietnamese supplementary labeling.

TAX

1604.19/.20: MFN 30%

Reference branches 1604.19.30/.90 and 1604.20.91/.99 carry 30% MFN. A Chapter 03 branch requires tax review by the final species code; VAT also depends on the actual degree of processing.

KEY BLOCKER

Process + structure + storage

Misclassifying dried fish as prepared fish snack, or calling frozen/chilled goods “snack”, can change both HS and AQ treatment.

Scope: fish snack/fish strips typically seasoned, dried, baked, smoked, shredded or heat-treated and packed for food use. Simply dried fish, fresh/chilled/frozen fish, fish balls, fish sausage, fish paste/surimi and flour-heavy composite snacks require separate branching.

WARNING: “fish strips” does not automatically mean 1604.20. Strips cut from fillet may remain fish pieces under 1604.1x; shredded/minced/formed fish may point to 1604.20. If processing remains within dried/salted/smoked fish of Chapter 03, review 03.05.

2. KEY TERMS & WHY THE PROCEDURE MATTERS

Aquatic animal quarantine

Veterinary quarantine for aquatic animals/products. Circular 03/2026 took effect 13 Jan 2026 and replaced the Circular 26/2016 regime.

HIGH/LOW RISK

High-risk / low-risk aquatic product

Circular 03/2026 defines high-risk products as preliminary-processed, fresh, chilled or frozen; low-risk means outside that group.

PROCESS FLOW

Manufacturing process

Shows thawing, cutting, shredding/mincing, seasoning, drying/baking/smoking and packing; central evidence for HS and AQ scope.

PIECES / SHREDDED

Pieces versus shredded

A fish strip can remain a piece; fish floss/shredded fish normally loses piece structure. They should not share one automatic HS conclusion.

Food safety

Includes state import inspection under the applicable method, self-declaration and circulation obligations.

C/O

Proof of origin

Supports FTA preference after HS is finalized; it does not replace food safety or AQ when AQ is actually triggered.

Why this matters: marketing names do not prove legal product nature. Authorities look at formula, species, finished structure, process, packaging and storage.

Key reminder: “processed” does not automatically mean “quarantine exempt”. The conclusion must follow Appendix I of Circular 03/2026, actual product state and technical evidence.

3. PRODUCT CLASSIFICATION & DETAILED IDENTIFICATION

Before legal analysis, lock: species; fish % and flour/seasoning %; whole/piece/strip/shredded/minced form; process; heat/drying/smoking; final state; storage; package; import purpose.

DETAILED PRODUCT CLASSIFICATION TABLE

Product/scenario	What to check	Example	Evidence	Potential policy	Dossier to cross-check	Application note
Simply dried fish	Mainly dried/salted/smoked without processing beyond Chapter 03 scope	Dried/salted/smoked fish	Species, process, ingredients, photos	Review 03.05; FS; AQ by actual state	Spec, process, label	Do not move to 16.04 merely because ready-to-eat.
Prepared fish strips that remain pieces	Fillet/cut strips still identifiable as pieces	Seasoned fish strips	Photos, cut size, species, process	Review species-specific 1604.1x; other fish may use 1604.19.30/.90	Formula, process, package	Exclude more specific species codes first.
Shredded/minced/floss fish	Piece structure destroyed; shredded/minced/formed	Fish floss, shredded fish snack	Process, photos, formula	Review 1604.20.91/.99 where appropriate	Formula, process, package	Split airtight retail versus other.
Composite snack with substantial flour/cereal	Fish is one ingredient in dough/cracker/extruded base	Fish cracker/extruded snack	Formula %, process	May require Chapter 19/21 or another heading	Formula, photos	Do not force Chapter 16 if fish does not give essential character.
Marketed as snack but actually chilled/frozen	Chilled/frozen storage; high-risk state	Frozen seasoned fish strips	Storage, process, transport	May trigger AQ + FS	AQ dossier/certificate, cold-chain docs	The word “snack” does not remove AQ.
Deep-processed shelf-stable snack	Completed heat/drying; ready-to-eat; ambient per spec	Dried seasoned fish floss	Process/spec, moisture/storage	Focus on HS + FS + self-declaration; AQ under Circular 03/2026	Test, declaration, label	Avoid absolute AQ-exempt wording without evidence.

4. HS CODE – TAX – C/O

Exclude competing branches before tax: 03.05 if still dried/salted/smoked fish within Chapter 03 → 1604.1x if whole/pieces, not minced → 1604.20 if other prepared/preserved fish. Composite snacks may require Chapter 19/21 depending on formula/process.

HS BRANCH

03.05 / 1604.19 / 1604.20

At least three directions require review.

CLASSIFICATION BASIS

Species + process + structure

Fish %, species, finished structure, process, packaging and storage are core facts.

MFN / ORDINARY

1604.19/.20: 30% / 45%

Reference 1604.19.30/.90 and 1604.20.91/.99 have 30% MFN; 45% is only an ordinary-rate reference where Decision 15/2023 actually applies.

VAT

VAT: branch by processing level

Chapter 03 aquatic products that are unprocessed into another product or only ordinarily preliminarily processed may be non-taxable at import. Processed fish snack otherwise at 10% VAT should be reviewed for the temporary 8% reduction if eligible.

C/O / FTA

By origin

Use the correct 2026 schedule and PSR for each agreement.

LOCK BEFORE DECLARATION

8-digit HS → FTA detail

Crosswalk 10-digit FTA tariff lines from the national base HS; do not use FTA detail as the classification conclusion.

PROPOSED HS – TAX – C/O TABLE

Reference HS	Description/group	Classification basis	Conditions	Ordinary duty	MFN duty	VAT	C/O/FTA review	Evidence
03.05 – by species/state	Dried, salted, in brine or smoked fish remaining in Chapter 03	Processing degree + species	Not transformed into Chapter 16 preparation	Check final code	Check final code	May be non-taxable for VAT at import where the aquatic product has not been processed into another product or has only undergone ordinary preliminary processing under the current VAT law and Decree 181/2025 as amended; verify the actual process.	FTA by final HS	Species, process, formula
1604.19.30	Other fish, airtight retail – whole/pieces branch	16.04 + structure + package	No more specific species code; still pieces	45% if ordinary mechanism applies	30%	8% if eligible; otherwise 10%	Review FTA	Species, photos, process, package
1604.19.90	Other fish – other, whole/pieces branch	16.04 + structure	Not .30/more specific code	45% if applicable	30%	8% if eligible; otherwise 10%	Review FTA	Species, process, package
1604.20.91	Other prepared fish, airtight retail	Outside whole/pieces branch	Shredded/floss/other preparation	45% if applicable	30%	8% if eligible; otherwise 10%	Review FTA	Formula, process, structure
1604.20.99	Other prepared fish – other	16.04 other prepared fish	Not fish sausage/ball/paste and not .91	45% if applicable	30%	8% if eligible; otherwise 10%	Review FTA	Formula, process, package
19.xx / 21.xx – competing	Composite snack where flour/cereal/other base may dominate	Formula + essential character	Only after excluding Ch.03/16	Do not use Ch.16 rate	Do not use Ch.16 rate	By final HS	By final HS	Formula %, process

C/O / FTA REVIEW BY IMPORT ROUTE

Route/origin	FTA	Origin proof	Special preferential rate	Conditions	Dossier	Application note
China	ACFTA / RCEP	Form E / RCEP proof	Check 2026 schedule at final HS	Meet PSR/document rules	C/O, Invoice, B/L, HS crosswalk	Do not transfer a 1604.20 rate to 1604.19/03.05.
ASEAN	ATIGA	Form D	Check 2026 schedule	Meet origin rule	C/O, Invoice, transport docs	Lock final HS first.
Korea / Japan	VKFTA/AKFTA/RCEP; VJEPA/AJCEP/CPTPP/RCEP	Relevant proof	Check 2026 schedule	Meet the selected agreement’s PSR	Origin dossier	PSR may vary by subheading/species.
EU / UK	EVFTA / UKVFTA	EUR.1 / permitted proof	Check 2026 schedule	Meet PSR	Origin docs + Invoice/B/L	Do not borrow PSR from another FTA.
India	AIFTA	Form AI	Check 2026 schedule	Meet PSR/document rules	C/O + transport docs	Quote rate only after final HS.

C/O CHECKLIST: proof; WO/RVC/CC/CTH/CTSH under the correct FTA; HS; description; quantity/weight; origin; issue date; third-party invoice; transport; authentication. A 10-digit FTA line needs a crosswalk to the national 8-digit base HS.

5. DOSSIER & PREPARATION

Use a “one source of truth – multiple procedures” approach: species, fish %, piece/shredded form, process, storage, packaging and SKU must remain consistent across HS, food safety, AQ if any, labels, C/O and customs.

Commercial dossier

Invoice, Packing List, B/L/AWB, Contract/PO, C/O; temperature instruction for controlled cargo.

Technical / specialized dossier

Ingredient %, species, process flow, finished photos, strip/shred size, treatment, storage, shelf life, package spec, COA/test; AQ certificate only if triggered.

Registration & cross-check dossier

Food-safety inspection file; self-declaration + test where applicable; label; AQ registration/declaration only where actual state is in scope.

Dossier principle: do not describe goods only as “fish snack”. Use species + processed state + product form + package consistently across Invoice, PL, B/L/AWB, C/O, spec, labels, FS and customs.

OPERATIONAL DOSSIER CHECKLIST

Dossier group	Documents	Used for	Typical owner	Common errors	Pre-ETA check
Commercial	Invoice; PL; B/L/AWB; Contract/PO	Customs/shipment match	Importer + supplier + forwarder	Generic name; weight/lot/package mismatch	Lock SKU, lot, net/gross, origin before SI.
Technical	Formula %, species, process, photos, strip/shred, storage, package	HS/AQ/FS/label	Manufacturer	Cannot prove pieces vs shredded; missing process	Use revision-controlled spec + actual photos.
Food safety	Inspection dossier; self-declaration/test if applicable	Import FS + circulation	Importer + lab	Test/label does not match SKU	Cross-check name, formula, origin, manufacturer.
AQ – if triggered	Registration/declaration; exporting-country certificate; transport docs	Only for in-scope AQ branch	Importer + competent authority	Mechanical AQ by HS or omitted AQ for actual frozen goods	Lock state under Circular 03/2026 before shipment.
Label/circulation	Self-declaration/test; original + VN supplementary label	Vietnam market	Importer/brand owner	Wrong ingredient/allergen/storage/origin	Compare artwork with formula/spec.
C/O/FTA	Origin proof + support docs	Preferential duty	Exporter + importer	Wrong HS branch/criterion	Crosswalk base HS/FTA before declaration.

6. LEGAL BASIS – SPECIALIZED POLICY MATRIX

LEGAL BASIS TO REVIEW

Instrument group	Instrument	Issuer	Effective/application time	Role	Key article/appendix	Review note
Aquatic quarantine – NEW	Circular 03/2026/TT-BNNMT	Ministry of Agriculture and Environment	Effective 13 Jan 2026	Current AQ list, PRA and import procedure	Art.2(7–8); Art.3; Arts.11–12; App.I–II	App.I-II.1 lists fresh, chilled, frozen aquatic products for quarantine.
OLD rules replaced	Circular 26/2016/TT-BNNPTNT + 36/2018 + 06/2022	Former MARD	Replaced from 13 Jan 2026	History/transition only	Arts.23–24 Circular 03/2026	Do not use the old procedure as current operating law.
HS list – aquatic quarantine	Circular 01/2024/TT-BNNPTNT – Appendix I, Section 5	Former MARD	Effective 20 Mar 2024; currently partially expired	HS mapping for aquatic-products quarantine scope	At heading 16.04, the list contains a scope note excluding certain heat-treated, dried, smoked, salted/brined, fermented etc. products from the AQ mapping	Read together with Circular 03/2026/TT-BNNMT, which now governs the current AQ list and procedure; do not conclude from Appendix I alone.
Pre-clearance specialized-inspection list	Circular 01/2024/TT-BNNPTNT – Appendix II	Former MARD	Effective 20 Mar 2024; currently partially expired	Maps HS codes to specialized controls before clearance	1604.19/.20 lines show AQ/food-safety control columns in the table; scope must be read with notes and current specialized rules	Circular 27/2026/TT-BNNMT, effective 1 Jul 2026, repealed quality-inspection provisions in Appendices II/III; this does not itself repeal aquatic quarantine or food-safety controls.
Food safety – CURRENT	Decree 15/2018/NĐ-CP + Resolution 15/2026/NQ-CP	Government	Resolution effective 6 Apr 2026	Suspends Decree 46/2026 + Resolution 66.13/2026; Decree 15 framework continues during suspension	Arts.4–5; 13–19	Processed prepacked snack must review self-declaration + import inspection.
Food safety – current procedure	Circular 22/2026/TT-BNNMT + Decision 1908/QĐ-BNNMT	Ministry of Agriculture and Environment	Procedures 1.003814 and 2.001604 under Decision 1908 apply from 1 Sep 2026	Updates implementing authority and processing time for import food-safety inspection under the Ministry’s scope	Normal inspection: 3 working days; tightened inspection: 7 working days from receipt of dossier under the published procedure	Supports Section 7 timeline; no click-by-click filing instructions are exposed.
Import duty	Decree 26/2023/NĐ-CP	Government	Effective 15 Jul 2023	MFN tariff	1604.19.30/.90; 1604.20.91/.99: 30%	Recalculate if final HS is 03.05/other.
Ordinary tariff	Decision 15/2023/QĐ-TTg	Prime Minister	Effective 15 Jul 2023	Ordinary tariff mechanism	Apply only under statutory conditions	With MFN 30%, 45% is a reference only when applicable.
VAT – base law	VAT Law 48/2024/QH15, amended by Law 149/2025/QH15; Decree 181/2025/NĐ-CP, amended by Decree 359/2025/NĐ-CP	National Assembly / Government	Law 149 and Decree 359 effective 1 Jan 2026	Distinguishes unprocessed/ordinarily preliminarily processed aquatic products from processed food	Art.4(1) Decree 181: at import, aquatic products not processed into another product or only ordinarily preliminarily processed are non-taxable; ordinary preliminary processing includes drying, cutting, deboning, mincing, salting, chilling/freezing etc.	Do not infer VAT solely from 03.05; verify actual process. Seasoned/processed products that become another product follow the applicable taxable regime.
VAT – 2-point reduction	Decree 174/2025/NĐ-CP	Government	Reduction policy through 31 Dec 2026	Two-percentage-point reduction for eligible goods otherwise at 10% and not excluded	Check Art.1 and exclusion appendices	Use for processed fish-snack branch only where final HS/product qualifies; it does not apply to goods that are non-taxable.
Customs	Customs Law 54/2014/QH13; Decree 08/2015 amended by Decree 167/2025/NĐ-CP	National Assembly / Government	Decree 167 effective 15 Aug 2025	Customs procedure/inspection	Use current text at declaration date	HS/specialized data must match declaration.
Labels	Decree 43/2017 amended by Decree 111/2021/NĐ-CP	Government	Decree 111 effective 15 Feb 2022	Imported goods/VN supplementary label	Mandatory content + food rules	Review ingredients, allergens, storage, origin, dates.

POLICY MATRIX BY GOODS SCENARIO

Goods scenario	Legal basis	Potential policy	Authority (high level)	Trigger
Deep-processed shelf-stable snack	Circular 03/2026 App.I + 16.04 note Circular 01/2024	Generally outside fresh/chilled/frozen AQ list; FS still applies	Veterinary/FS authorities	Process/spec proves processed shelf-stable state.
Marketed snack but actually chilled/frozen	Circular 03/2026 App.I-II.1	AQ + FS	Border AQ + FS authority	Actual state fresh/chilled/frozen or special trigger.
Simply dried fish	Ch.03 + Circular 03 + FS	Review 03.05; AQ by state; FS	Customs + specialized authority	Processing insufficient for Ch.16.
Prepared fish pieces	16.04 + dossier	Review 1604.1x by species/package; FS	Customs + FS	Still whole/pieces.
Shredded/other prepared fish	16.04 + dossier	Review 1604.20.91/.99; FS	Customs + FS	Outside whole/pieces; not fish sausage/ball/paste.
Processed prepacked food	Decree 15 + Resolution 15/2026	Self-declaration; FS inspection by applicable method	Assigned FS authority	Imported for Vietnam market and not exempt.
Export-processing material/sample	Circular 03/2026 App.I-B + Decree 15 Art.13 where relevant	Potential exemption only under exact purpose/conditions	Specialized authority	Prove purpose; do not extend to normal commercial goods.

Circular 03/2026 – aquatic quarantine Appendix I Circular 03/2026 Appendix II Circular 01/2024 Resolution 15/2026 – food safety Decree 174/2025 – VAT

7. PROCESSING TIME, FEES & RISK COSTS

OPERATIONAL TIMELINE

Step/operation	Sourced processing time	Conditions	Fees	Logistics risk
Lock product pre-shipment	Variable; no fixed statutory period	Formula/species/process/photos/package/storage complete	Test/docs cost if any	Wrong HS/AQ branch causes rework.
If AQ applies – pre-import registration	4 working days from complete dossier under Art.11 Circular 03	Goods are in AQ scope	Veterinary fees by operation	Resolve certificate/origin before shipment.
If AQ applies – border declaration	1 working day from valid declaration	AQ branch confirmed	Current veterinary fees	Late filing affects free time.
If AQ applies – no sampling	1 working day depending on case after compliant review	No sampling	By operation	Only for truly in-scope AQ shipment.
If AQ applies – sampling	5 working days if results pass	Sampling required	Testing may cost extra	Failure extends handling.
Food safety – normal	3 working days under current published procedure	Normal method	Inspection/test fee as applicable	May prepare in parallel where lawful.
Food safety – tightened	7 working days	Tightened trigger	Testing may cost extra	Higher storage/DEM/DET risk.
Customs/pickup	By channel + specialized results	HS/tax/FS/AQ if any complete	Duty + local charges	Wrong HS/policy can hold cargo.
Post-clearance	No approval waiting period for self-declaration; complete before circulation	Self-declaration applies	Test/label/record cost	Clearance does not replace circulation duties.

Timeline principle: first decide whether AQ is triggered. Do not add 4 + 1 + 5 days to every 16.04 shipment.

8. PRACTICAL E2E WORKFLOW

STEP 01

Identify product

Lock species, fish/flour %, whole/piece/strip/shredded/minced, process, heat/drying/smoking, storage, package.

STEP 02

Finalize HS/tax/C/O

Exclude 03.05 ↔ 1604.1x ↔ 1604.20 ↔ composite, then calculate tax.

STEP 03

Review AQ & food safety

Use current Circular 03/2026; do not impose AQ mechanically from old HS marks, and do not omit AQ for actual chilled/frozen goods.

STEP 04

Complete dossier

Food safety, self-declaration/test/label; add AQ registration/declaration/certificate only if triggered.

STEP 05

Lock documents pre-ETA

Cross-check Invoice–PL–B/L/AWB–C/O–spec–label–FS–AQ if any.

STEP 06

Declare & handle channel

Declare HS/tax/C/O; for Yellow/Red use formula/process/photos/package evidence.

STEP 07

Complete controls & pickup

Food safety; AQ/sampling if any; tax; customs channel and pickup.

STEP 08

Circulate & retain

VN label; retain self-declaration/test/HS/C/O/FS/AQ/customs; change control.

Before ETA: lock process flow and actual “fish strip” structure photos first; they separate Chapter 03, fish pieces 1604.1x and shredded 1604.20, and support the AQ conclusion.

Main blockers: snack but frozen/chilled; no evidence piece vs shredded; missing species; flour-heavy formula forced into Ch.16; package mismatch; FS/label mismatch; old AQ mark used without Circular 03/2026.

9. FAQ – FREQUENTLY ASKED QUESTIONS

1. Is dried fish snack subject to AQ?

If truly deep-processed, shelf-stable and no longer fresh/chilled/frozen, it generally falls outside App.I-II.1 Circular 03/2026. Prove with process/spec and review special cases.

2. Why do older HS tables show AQ marks?

Circular 01/2024 is an HS mapping and heading 16.04 includes a processing exclusion note. From 13 Jan 2026, current AQ scope/procedure must be read under Circular 03/2026.

3. Is fish strips always 1604.20.91?

No. Cut fillet strips may remain 1604.1x pieces; shredded/minced may point to 1604.20; simply dried fish may be 03.05.

4. Airtight strips: .19.30 or .20.91?

First determine pieces versus other prepared fish; packaging is the second split.

5. MFN for reference 16.04 codes?

1604.19.30/.90 and 1604.20.91/.99 carry 30% MFN; other species/03.05 must be recalculated.

6. Does China Form E guarantee 0%?

No. Lock final HS, PSR and check the 2026 ACFTA line and document validity.

7. Is self-declaration required?

Ordinary processed prepacked food generally follows Arts.4–5 Decree 15, unless registration/exemption applies.

8. Food-safety inspection time?

Normal 3 working days; tightened 7 working days; exemptions/reduced checks have separate conditions.

9. If AQ is triggered, what is the timeline?

Circular 03: pre-import review 4 working days; border declaration 1 day; sampled shipment 5 days if compliant; no-sampling cases use a 1-day mechanism.

10. High flour/starch: still 16.04?

Not necessarily; composite snacks may require Chapter 19/21 depending on formula and essential character.

11. VAT 8% or 10%?

Finalize HS first. Eligible 10% goods not excluded under Decree 174/2025 may be 8% through 31 Dec 2026.

12. What to retain post-clearance?

HS analysis, formula/species/process, photos/package, declaration/tests, label, FS, AQ if any, commercial docs, C/O, customs and tax evidence.

10. OUTPUTS & POST-CLEARANCE OBLIGATIONS

Product/classification file

Species, formula %, process, structure photos, package and 03.05 ↔ 1604.1x ↔ 1604.20 rationale.

Shipment file

Invoice, PL, B/L/AWB, contract/PO, lot/weight/origin/manufacturer aligned.

Specialized file

Food safety; self-declaration/test; AQ file only if Circular 03 branch applies.

Customs & tax file

Declaration, HS rationale, value, MFN/ordinary, VAT, C/O/FTA, payment proof.

Label & circulation

Original/VN supplementary label, ingredients/allergens/storage/origin/dates aligned.

CHECK

Records & change control

Manage species, fish/flour %, process, supplier, origin, package and storage changes.

Target output: correct product nature – correct HS/tax – correct AQ conclusion – correct food safety/self-declaration – correct labeling/circulation.

Change management: cut strip ↔ shredded, fish/flour %, process, frozen ↔ ambient or retail ↔ bulk changes may alter HS, AQ, food safety, label and C/O.

11. TGIMEX SOLUTIONS

The hardest issue is locking the finished-product nature before shipment. One consistent species – formula – process – structure – package – storage dataset reduces HS, AQ and food-safety errors.

Pre-ETA review

Branch 03.05/1604.1x/1604.20, determine AQ under Circular 03/2026, lock tax/C/O and FS.

Compliance dossier control

Cross-check formula, process, species, photos, commercial docs, C/O, FS, self-declaration and label.

Operations/logistics & clearance

Plan FS/AQ if any, customs channel, tax, D/O, temperature/storage and delivery.

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