Dried / processed sea cucumber has three compliance layers that should be locked together: classification between 0308.19 and 1605.61, food-safety/quarantine treatment based on actual condition, and a scientific-name – source – CITES check before purchase.

Simply dried, salted or brined sea cucumber may remain in Chapter 03; only preparation or preservation beyond heading 03.08 should move the review to Chapter 16. For CITES-listed taxa, species or source-document errors can stop a shipment even when HS and food-safety work are otherwise correct.

Operational reference for importers and exporters · Updated through 10 Sep 2026.

1. QUICK SUMMARY & SCOPE

PRODUCT

Dried / processed sea cucumber for food

Covers simply dried, salted/brined, smoked and more deeply cooked/seasoned/prepared or preserved sea cucumber.

HS TO REVIEW

0308.19.20 / .30 ↔ 1605.61.00

0308.19.20: dried/salted/brined; 0308.19.30: smoked; 1605.61.00: prepared/preserved beyond Chapter 03 scope.

SPECIALIZED

Food safety · AQ by condition · CITES by species

Ambient dried/treated products are not automatically in ordinary aquatic quarantine under Circular 03/2026; food safety and CITES screening remain separate.

MARKET

Self-declaration + label + nutrition

Processed prepacked food normally follows Decree 15/2018 self-declaration; label under Decree 37/2026 and nutrition under Circular 29/2023 where applicable.

DUTY

0308.19.20 MFN 10% · 1605.61 MFN 25%

Reference ordinary duties are 15% and 37.5% respectively. VAT depends on ordinary preliminary processing versus a different processed product.

STOP POINT

Scientific name · wild/farmed · process · CITES

Do not lock purchase/shipment without species name, source, process flow, ingredients/packing and CITES/source evidence where relevant.

Scope: For dried or processed sea cucumber imported for human consumption. Live/fresh/chilled/frozen specimens, broodstock, research samples or non-food use may follow different rules.

Warning: “Dried sea cucumber” does not automatically mean Chapter 16 prepared/preserved goods. Heading 03.08 expressly includes dried, salted/brined and smoked sea cucumber. CITES follows the taxon/specimen/source, not the trade name.

2. KEY TERMS & WHY THEY MATTER

Tariff classification

Separate states expressly covered by 03.08 from preparation/preservation under 16.05. Drying alone does not force a chapter shift.

SCIENTIFIC NAME

Taxonomic identity

Essential for CITES screening, conservation-list checks and source traceability.

CITES

Convention on wildlife trade

Several sea-cucumber taxa are currently in CITES Appendices II/III. Permits/documents depend on species, specimen source and transaction route.

Aquatic quarantine

Circular 03/2026 defines ordinary quarantinable aquatic products as live/fresh/chilled/frozen; ambient dried product is not automatically covered.

FSI

Imported food-safety inspection

A separate compliance layer requiring inspection-method/exemption review under Decree 15/2018 and the 2026 authority framework.

C/O

Origin evidence

May significantly reduce duty, but only after final HS is locked and the agreement-specific origin rule is met.

Why this matters: A shipment may have the correct tariff code but fail because the scientific name is CITES-listed; or it may have valid CITES papers but use 1605.61 for goods that are only dried under 03.08.

Key point: Common names such as sea cucumber, beche-de-mer or teatfish are not enough for CITES. Obtain the scientific name and lawful-source evidence early.

3. DETAILED PRODUCT IDENTIFICATION & CLASSIFICATION

Before calculating duty or preparing food-safety work, obtain scientific name, wild/farmed source, harvest/farm country, raw-material condition, process flow, ingredients, final condition, packing and import purpose.

Lock this table before HS, CITES and specialized-policy conclusions.

Product/situation	What to verify	Example	Evidence	Potential policy	Documents	Application note
Simply dried sea cucumber	No preparation beyond cleaning/drying and normal preliminary handling	Dried sea cucumber / beche-de-mer	Scientific name, process, moisture/spec	Food safety; CITES if taxon listed	Spec/process/source/label	Review 0308.19.20; do not automatically use 1605.61.
Salted/brined sea cucumber	Preserved by salt/brine without deeper preparation	Salted/brined sea cucumber	Brine formula, process, species	Food safety; CITES if applicable	Process/ingredients/source	03.08 expressly covers salted/brined state.
Smoked sea cucumber	Smoking operation, with or without cooking before/during smoking	Smoked sea cucumber	Smoking process, temperatures, species	Food safety; CITES if applicable	Process/spec/source	Review 0308.19.30 if description remains within 03.08.
More deeply prepared/preserved sea cucumber	Cooked, seasoned, sauced or otherwise prepared beyond 03.08	Seasoned/cooked/RTE sea cucumber	Recipe, process, heat treatment, pack	Food safety, self-declaration/label; CITES if applicable	Recipe/process/test/label/source	Review 1605.61.00 after excluding 03.08.
CITES-listed / sensitive wild source	Scientific name matches a CITES Appendix or related conservation list	Relevant Holothuria/Thelenota taxa	Scientific-name evidence, source/origin, CITES documents	CITES permit/document + source legality	CITES + commercial/technical file	Screen before purchase/booking; do not rely on common name.

4. HS CODE – DUTY – C/O

The branches below are references based on actual processing. Read heading 03.08 correctly before moving to 16.05, and never use HS as a substitute for CITES screening.

DRIED

0308.19.20

Sea cucumber dried, salted or in brine; the first branch for beche-de-mer that remains only preliminarily processed.

SMOKED

0308.19.30

For smoked sea cucumber described by heading 03.08; cooking before/during smoking does not automatically shift it to Chapter 16.

PREPARED

1605.61.00

Prepared or preserved sea cucumber beyond the conditions already covered by 03.08; requires process/recipe support.

MFN / ORD.

10% / 15% ↔ 25% / 37.5%

0308.19.20: MFN 10%, ordinary 15%. 1605.61.00: MFN 25%, ordinary 37.5%.

VAT

Preliminary processing differs from another processed product

Ordinary preliminary processed aquatic products may be non-taxable at import under Decree 181/2025. A different processed product normally uses 10%, reduced to 8% through 31 Dec 2026 if eligible.

FTA

Several routes reach 0%

Verified: ATIGA/ACFTA 0% for relevant branches; EVFTA 0308.19.20 is 0% in 2026 and 1605.61.00 is 3.1%.

Duty/VAT follows the final HS and process; CITES remains an independent control layer.

Reference HS	Suitable description	Basis	Condition	Ordinary duty	MFN	VAT	FTA review	Evidence
0308.19.20	Dried, salted or brined sea cucumber	Heading 03.08	No preparation beyond 03.08 scope	15%	10%	If only ordinary preliminary processing: review non-taxable treatment under Decree 181/2025	ATIGA, ACFTA, EVFTA and origin-specific FTA	Scientific name, process, spec, source
0308.19.30	Smoked sea cucumber	Heading 03.08 – smoked	Correct smoked condition	Verify current final-code schedule	MFN reference 25%	Review by actual process	FTA by origin	Smoking process, species, source/CITES
1605.61.00	Prepared or preserved sea cucumber	Heading 16.05	Preparation/preservation beyond 03.08	37.5%	25%	If another processed product: standard 10%, 8% through 31 Dec 2026 if eligible	ATIGA, ACFTA, EVFTA/UKVFTA and other FTAs	Recipe/process/heat/pack/species/source
Trade name not enough	Instant/premium/dried sea cucumber etc.	GRI + actual description	Only after process + scientific name are known	After HS lock	After HS lock	After final HS/process	FTA after HS lock	Complete technical file

Use the FTA rate only for the final HS and qualifying origin route.

Origin route	FTA	Origin document	Verified preferential treatment	Condition	Evidence	Note
ASEAN	ATIGA	Form D / permitted evidence	0308.19.20 and 1605.61.00: 0% in 2026	Meet PSR	C/O, invoice, transport	CITES/source legality remains separate.
China	ACFTA	Form E	0308.19.20 and 1605.61.00: 0% under 2022–2027 schedule	Meet ACFTA PSR	C/O, invoice, transport	Check country-specific exclusions/notes in the schedule.
EU	EVFTA	EUR.1 / permitted evidence	0308.19.20: 0%; 1605.61.00: 3.1% in 2026	Meet seafood origin rule	Origin dossier	No preference if lawful origin/PSR not met.
UK	UKVFTA	Permitted UKVFTA evidence	1605.61.00: 3.1% in 2026; check the exact 0308 line separately	Meet PSR	Origin dossier	Do not transfer a 1605 rate to 0308.
Japan/CPTPP/RCEP	Applicable agreement	Relevant origin evidence	Verify 2026 schedule for final HS	Meet chosen PSR	Origin file	Choose after HS and origin dossier are locked.

5. DOCUMENT SET & PREPARATION

Manage a single product-data source across multiple procedures: scientific name, source, process and packaging must match HS, food safety, CITES, C/O, label and customs declaration.

Commercial documents

Invoice, packing list, B/L-AWB, contract/PO, packing specification, SKU/lot and sufficiently specific product description.

Technical / specialized documents

Scientific name, wild/farmed source, harvest/farm country, process, ingredients, spec/COA, test, label and CITES/source documents where applicable.

Registration & cross-check set

Self-declaration if applicable, imported-food-safety file, Article 14 evidence where relevant, CITES permit/file if listed, C/O and pre-ETA checklist.

Preparation rule: Do not accept a dossier where Invoice says “dried sea cucumber”, the specification uses another scientific name, or the process shows cooking/seasoning inconsistent with the declared HS.

Document group	Documents	Used for	Typical owner	Common error	Pre-ETA check
Commercial	Invoice, PL, B/L-AWB, contract/PO	Customs/value/shipment	Importer/supplier/forwarder	Generic description	Match SKU, common/scientific name, weight and pack.
Species & source	Scientific name, wild/farmed, country/source evidence	CITES/conservation/traceability	Supplier/exporter	Only “sea cucumber” provided	Lock taxon and lawful source before booking.
Technical	Process, ingredients, spec, moisture/heat treatment	HS, VAT, food safety	Factory/QA	No distinction between drying and further preparation	Map each process step to 0308/1605 logic.
Food safety	Self-declaration/test/import-inspection dossier; Article 14 evidence if needed	Import + market	Importer	Treating every dried product as processed prepacked	Verify actual processing/packaging and end use.
CITES	Permit/application file; export/re-export CITES document where applicable	CITES import control	Exporter/importer	Species/Appendix/source mismatch	Cross-check current Appendices and Circular 85/2025.
Origin & label	C/O; original/supplementary label; nutrition when applicable	FTA + market placement	Exporter/importer	C/O origin/HS conflicts with CITES/source file	Cross-check HS, origin, species and labels.

6. LEGAL BASIS & SPECIALIZED-POLICY MATRIX

Area	Instrument	Issuer	Status/time	Role	Key provision/appendix	Review note
HS	Circular 31/2022/TT-BTC	Ministry of Finance	AHTN 2022 basis	Vietnam nomenclature	Headings 03.08 and 16.05	Separate dried/salted/smoked from prepared/preserved.
MFN/ordinary duty	Decree 26/2023 as amended by Decree 199/2025; Decision 15/2023	Government / PM	Review at declaration date	MFN/ordinary tariff	0308.19.20; 1605.61.00	No rate transfer between branches.
VAT	Decree 181/2025 as amended by Decrees 359/2025 and 144/2026; Decree 174/2025	Government	Current 2026 framework	VAT scope/rate/reduction	Ordinary preliminary processing vs another product	Review process, not trade name.
Agriculture HS controls	Circular 01/2024 and 2026 changes including Circular 27/2026	MARD / MAE	Cross-read current substantive rules	HS-control mapping	0308.19.20 food-safety mapping; 1605.61 cross-read AQ/food safety	An HS matrix does not replace substantive trigger rules.
Aquatic quarantine	Circular 03/2026/TT-BNNMT	MAE	From 13 Jan 2026	Current AQ scope	Products: live/fresh/chilled/frozen	Ambient dried product is not automatically AQ.
Food safety	Decree 15/2018 + Resolution 15/2026; Circular 22/2026	Government / MAE	Decree 15 continues; 2026 decentralization	Self-declaration, import inspection, Article 14	Article 14(1) exclusion for processed prepacked food from specific country/establishment/lot-certificate conditions	Not an exemption from all food-safety controls.
CITES / protected species	Circular 85/2025/TT-BNNMT + current CITES Appendices	MAE / CITES	Circular effective 1 Jan 2026; Appendices checked at transaction date	CITES specimens and import permit	Article 30 Circular 85/2025	Scientific name is mandatory for screening; note that H. lessoni does not take effect in Appendix II until 5 Jun 2027, so it is not yet an operative listing on 10 Sep 2026.
Labels & nutrition	Decree 37/2026; Circular 29/2023/TT-BYT	Government / MOH	Decree 37 from 23 Jan 2026	Commodity/nutrition labels	Mandatory content/transition	Apply by packaging/market form.

Situation	Rules to check	Potential treatment	Authority (high level)	Trigger
Ambient dried 0308.19.20	HS + current food safety + Circular 03/2026 + CITES screen	Food safety; no ordinary AQ solely due to aquatic origin; CITES if taxon listed	Customs + food-safety + CITES authority where relevant	Dried/salted/brined for food.
Smoked 0308.19.30	HS + food safety + Circular 03/2026 + CITES	Food safety; AQ by actual condition; CITES by taxon	Specialized authorities	Smoked ambient product.
Prepared 1605.61.00	HS + Decree 15 + AQ rule + CITES	Food safety/self-declaration/label; no automatic ordinary AQ if ambient; CITES by species	Customs + food-safety + CITES	Preparation beyond 03.08.
Not within Article 14 processed-prepacked exclusion	Article 14(1) Decree 15	Review approved country/territory, Vietnam-recognized establishment and per-shipment exporting-authority food-safety certificate conditions	Food-safety authority	Product does not qualify as processed, prepackaged food exclusion.
Processed, prepackaged food	Article 14(1) Decree 15	Excluded from that specific country/establishment/per-shipment certificate set; other food-safety obligations remain	Food-safety authority	Must truly be processed + prepackaged.
Scientific name in CITES Appendix	Circular 85/2025 + current Appendices	CITES import permit/documents and exporting/re-exporting country document as applicable	Vietnam CITES Management Authority	Taxon/specimen/transaction falls within CITES.
Non-CITES but sensitive wild species/source	Fisheries/conservation rules + current species lists	Lawful-source and domestic protected-species screening	Relevant specialized authority	Scientific name/source/harvest area triggers control.

7. PROCESSING TIME, FEES & RISK COST

Do not use one lead time for all sea-cucumber shipments: CITES, food-safety and customs are separate workstreams. Only grounded procedural times are stated below.

Stage	Main action	Management milestone	Fee/cost	Delay risk
Pre-PO / pre-shipment	Lock scientific name, source, CITES status, process and HS branch	Before purchase/booking	Verification/advisory where needed	Highest risk: cargo ships before a CITES/source problem is found.
CITES if applicable	Prepare permit file under Circular 85/2025 and exporting-country CITES document	Ordinary case: 05 working days from receipt of a valid dossier under Article 30 of Circular 85/2025; consultation/verification cases follow additional statutory steps	According to applicable rules	Missing permit/export document may stop import.
Normal food-safety inspection	Dossier review and result notice	03 working days from dossier receipt under current procedure	According to applicable fee rules	Supplementation extends actual lead time.
Strict food-safety inspection	Dossier review, sampling/testing	07 working days from dossier receipt under current procedure	Fees/testing cost where incurred	Sampling/non-compliance may extend port time.
Customs	HS/C/O/value/channel processing	When specialized file is ready	Duty + VAT by final branch	Classification query, examination or C/O rejection.
Post-clearance	Label, records, species/source/CITES traceability	Before and during market placement	Relabel/retest/rework if necessary	Inability to trace source or dossier version.

8. PRACTICAL E2E WORKFLOW

STEP 01

Identify product data

Collect scientific name, wild/farmed source, harvest/farm country, process, ingredients, pack and end use.

STEP 02

Lock HS/duty/C/O branch

Split 0308.19.20/.30 ↔ 1605.61.00 before calculating MFN, VAT and FTA.

STEP 03

Review CITES + food safety + AQ

Screen current CITES Appendices/species lists and determine Article 14, food-safety inspection and AQ by actual condition.

STEP 04

Complete product/registration file

Prepare self-declaration/test/food-safety work, CITES permit/file if applicable, labels/nutrition.

STEP 05

Lock documents before ETA

Reconcile commercial docs, C/O, scientific name/source, process, CITES documents, label and food-safety file.

STEP 06

Customs declaration & channel

Declare final HS and handle green/yellow/red channel, including species/source/classification explanation.

STEP 07

Complete checks/tax/clearance

Finish applicable food-safety/CITES/AQ work, duty/C/O and cargo release.

STEP 08

Market placement & post-control

Maintain lot/species/source traceability and re-review changes to taxon, source, supplier, process, pack or origin.

Before ETA: Steps 01–05 should be complete before ETA; scientific name + CITES status should be locked even earlier, before PO/booking.

Main blocker: If the supplier cannot provide the scientific name and lawful-source evidence, the purchase/shipment should not be treated as ready. This can be a greater risk than an unresolved reference HS.

9. FAQ – FREQUENTLY ASKED QUESTIONS

1. What HS is commonly reviewed for dried sea cucumber?

If simply dried, salted or brined without preparation beyond heading 03.08, review 0308.19.20.

2. Is dried sea cucumber automatically 1605.61.00?

No. Heading 03.08 expressly covers dried/salted/brined and smoked sea cucumber; 1605.61.00 is for prepared/preserved goods beyond that scope.

3. What about smoked sea cucumber?

If it remains a smoked sea cucumber described by 03.08, review 0308.19.30, subject to the actual process.

4. Is dried sea cucumber subject to aquatic quarantine?

Circular 03/2026 defines ordinary quarantinable aquatic products as live/fresh/chilled/frozen. Ambient dried products are not automatically included; specific cases still need review.

5. Is imported-food-safety inspection relevant?

Yes, when imported for food, subject to the applicable inspection method or exemption for the actual shipment.

6. Does processed prepacked sea cucumber need the Article 14 foreign-establishment conditions?

Article 14(1) excludes processed, prepackaged food from its specific country/recognized-establishment/per-shipment certificate conditions, but other food-safety duties remain.

7. Why is the scientific name necessary?

HS supporting evidence, CITES, conservation screening and source traceability may all depend on taxonomic identity.

8. Which sea-cucumber taxa currently require special CITES screening?

As of 10 Sep 2026, key taxa to screen include Thelenota spp.; Holothuria fuscogilva, H. nobilis and H. whitmaei in Appendix II, and Isostichopus fuscus in Appendix III under Ecuador’s listing. Holothuria lessoni has been adopted for Appendix II but its entry into effect is delayed until 5 Jun 2027; it should not be described as an operative Appendix-II listing in Sep 2026. Always re-check at the transaction date.

9. What changes if the species is in Appendix II?

Article 30 of Circular 85/2025 governs the CITES import permit. In the ordinary case, issuance is within 05 working days from receipt of a valid dossier; Appendix II/III cases involve the exporting/re-exporting country’s CITES export/re-export document as applicable, while consultation/verification cases follow the additional Article 30 steps.

10. Is VAT the same for simply dried and deeply processed sea cucumber?

Do not assume so. Ordinary preliminary processing can receive non-taxable import treatment; a different processed product follows the applicable rate and temporary reduction where eligible.

11. Can ATIGA/ACFTA reduce duty to 0%?

Yes. Verified schedules show 0% for 0308.19.20 and 1605.61.00, provided origin rules and valid evidence are met.

12. Must the file be re-reviewed when species or wild/farmed source changes?

Yes. A taxon/source change triggers a fresh CITES/source-legality review and can also affect classification, origin and traceability.

10. OUTPUTS & POST-CLEARANCE OBLIGATIONS

Classification/product file

Scientific name, source, process, spec/recipe, packing and 0308 ↔ 1605 classification memo.

Shipment file

Invoice, PL, B/L-AWB, contract/PO, lot/SKU and consistent description.

Specialized-control file

Self-declaration/test/food-safety file; AQ if actually triggered; CITES permit/source file if listed.

Customs & tax file

Declaration, valuation, C/O, tax documents and any HS/species/source explanation.

Label & market file

Original/supplementary labels, ingredient statement, nutrition where applicable, storage and shelf life.

CHECK

Retention & change control

Re-review scientific name, wild/farmed source, supplier, process, packing, origin or claim changes.

Required output: The final dossier should answer what species it is, where the lawful source comes from, whether CITES applies, why 0308 or 1605 is used, and which food-safety/tax treatment follows.

Change warning: Species/source is not secondary data for sea cucumber. A taxon or harvest-source change can completely change CITES documentation and importability.

11. TGIMEX SOLUTIONS

TGIMEX can support pre-PO/pre-ETA data control, particularly across HS, food safety, CITES and source traceability.

Pre-ETA review

Cross-check scientific name, source, process, HS, duty, C/O, food safety/AQ and CITES.

Compliance document control

Reconcile commercial documents, technical/process file, CITES/source file, declaration/test, label and C/O by SKU/lot.

Logistics & customs coordination

Coordinate specialized-control work, transport documents, customs channel and cargo-release plan.

Scope should be tailored to species, source, processing form, origin country and the actual dossier.

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