VIETNAM IMPORT PROCEDURE FOR DRIED LOTUS SEEDS
Food-grade dried lotus seeds are typically seeds of Nelumbo nucifera that have been cleaned, peeled and sun-dried/dehydrated without being further prepared into another product. For this configuration, the main reference HS code is 1212.99.90. However, if the goods are imported as the medicinal material “Liên nhục – Semen Nelumbinis”, classification and the regulatory route may move to 1211.90.17 / 1211.90.18 / 1211.90.19 under Circular 09/2024/TT-BYT.
If the importer does not lock intended use – HS – plant quarantine – food safety at the outset, the shipment may be classified under the wrong code, routed through the wrong food/medicinal dossier, require document amendments after arrival, and incur storage costs. The workflow below provides an end-to-end review map from pre-ETA through post-clearance to control those blockers.
Operational reference for import-export enterprises. Main scope: dried lotus seeds used as food/food-manufacturing inputs; not automatically applicable to seed-for-sowing goods, medicinal materials, blended powders, roasted/seasoned products or deeply processed snacks.
1. OVERVIEW & SCOPE
Before ETA, lock botanical identity, food/medicinal/seed purpose, peeling – plumule removal – drying process, whole/powder form, ingredients and packing. These facts drive HS, plant quarantine, food safety, VAT and C/O.
Plain dried lotus seeds used as food are mainly reviewed under heading 12.12 – seeds, kernels and other vegetable products primarily used for human consumption and not elsewhere specified.
Circular 01/2024 places 1212.99.90 in the plant-quarantine control layer. Do not assume that “dried” goods are automatically exempt from quarantine.
Circular 01/2024 also places 1212.99.90 in the plant-origin food layer requiring review of imported-food safety inspection where the shipment falls within scope.
Reference MFN import duty is 10%; ordinary duty is 15%. Several FTAs may reduce duty to 0% if origin requirements are satisfied.
Cleaning, drying, shelling/peeling, seed separation and similar operations are listed as ordinary pre-processing; at import, review whether non-taxable VAT treatment applies.
Circular 09/2024/TT-BYT identifies “Liên nhục – Semen Nelumbinis” under 1211.90.17/18/19 depending on form when imported as medicinal material.
2. KEY TERMS & WHY THE PROCEDURE MATTERS
Common botanical name used to identify lotus. It should appear on the specification/COA where the trade name “lotus seed” may be ambiguous.
Reference code for other seeds/vegetable products primarily used for human consumption and not elsewhere specified.
Specialist inspection of quarantinable objects to control plant-health risks and the phytosanitary conditions applicable to the shipment.
Certificate issued by the competent exporting-country authority, used where the shipment remains subject to plant quarantine.
State inspection of imported food using reduced, normal or tightened methods where the goods fall within scope.
Medicinal name for lotus seed. If the declared/intended use is medicinal, review Circular 09/2024/TT-BYT and pharmaceutical rules instead of using the food route as a substitute.
3. DETAILED PRODUCT IDENTIFICATION & CLASSIFICATION
Review botanical name, whole/peeled condition, whether the lotus plumule is removed, process flow, moisture, ingredients, packing, intended use, original label and actual product photos.
DETAILED PRODUCT CLASSIFICATION TABLE
| Product/situation | Technical signs to check | Example/function | Supporting evidence | Possible policy | Documents to cross-check | Application note |
|---|---|---|---|---|---|---|
| Whole/peeled dried lotus seeds – food grade | Nelumbo nucifera; cleaning/peeling/sun-drying or dehydration only | Dried lotus seeds, peeled/unpeeled | Spec, botanical name, process, COA, photos | HS 1212.99.90; plant quarantine; food-safety inspection as applicable | Phyto if applicable, Invoice, PL, C/O, food-safety dossier | Primary scope of this article. |
| Dried lotus seeds with plumule removed | Plumule removed only; no additives | Dried lotus kernels without lotus plumule | Process, ingredients, photos | Usually still review 1212.99.90 where this is only food pre-processing | Spec, Phyto, label | Document that the operation is only pre-processing. |
| Freeze-dried lotus seeds without additives | Freeze-drying only; no sugar/seasoning | Freeze-dried lotus seeds | Process, ingredients, COA | May still be reviewed under 1212.99.90 where the goods have not become another preparation; VAT/quarantine/food safety depend on actual status | Process, packing, label | Do not equate with a seasoned snack. |
| Plain dried retail pack | Sealed retail pack and label; formula contains only lotus seeds | Retail dried lotus seeds | Label, ingredients, process, packing | Review plant quarantine separately; review self-declaration/imported-food inspection according to actual processed-prepacked status | Label, test report, self-declaration if applicable | Packaging alone does not automatically remove quarantine obligations. |
| Roasted/seasoned/candied lotus seeds | Seasoning, sugar, oil or processing that creates a snack | Seasoned/roasted lotus seed snack | BOM, formula, process, label | Reclassify according to the processed product; self-declaration/label/VAT for processed food | BOM, label, test | Do not default to 1212.99.90. |
| Lotus-seed powder / blended powder | Ground material, potentially blended with other ingredients | Lotus seed powder / mixed powder | Formula, process, protein/starch composition | Recheck HS according to composition/function; food-safety rules by final preparation | BOM, spec, label | 100% powder and blended powder must be distinguished. |
| Semen Nelumbinis imported as medicinal material | Semen Nelumbinis; intended for medicinal/pharmaceutical use | Medicinal lotus seed raw material | Purpose statement, pharmacopoeial/specification, medicinal COA | Circular 09/2024/TT-BYT: 1211.90.17/18/19 depending on form + pharmaceutical rules | Medicinal dossier + commercial documents | Do not mechanically use food-grade HS 1212.99.90. |
4. HS CODE – TAX – C/O
Heading 12.12 covers seeds, kernels and other vegetable products primarily used for human consumption and not elsewhere specified. For plain food-grade dried lotus seeds, 1212.99.90 is the main reference code.
PROPOSED HS – TAX – C/O TABLE
| Reference HS | Suitable description/product group | Classification basis | Conditions for application | Ordinary import duty | MFN | VAT | C/O/FTA to review | Evidence to cross-check |
|---|---|---|---|---|---|---|---|---|
| 1212.99.90 | Other – food-grade dried lotus seeds | Nelumbo nucifera; seeds used as food and not elsewhere specified | Plain dried/peeled/dehulled; not transformed into another product | 15% | 10% | Non-taxable VAT at import where only ordinary pre-processing is performed and statutory conditions are met | ATIGA, ACFTA, AIFTA, AKFTA/VKFTA, AJCEP/VJEPA, AANZFTA, EVFTA, UKVFTA, CPTPP, RCEP… | Botanical name, process, ingredients, C/O |
| 1211.90.17 | Liên nhục – medicinal form listed as fresh/dried, cut/crushed/powder as applicable | Circular 09/2024/TT-BYT – Semen Nelumbinis | Intended use is medicinal and form matches the listed line | Check current tariff | Check current tariff | Review under medicinal/VAT rules as applicable | FTA according to medicinal HS | Medicinal purpose, pharmacopoeia/specification |
| 1211.90.18/19 | Other Semen Nelumbinis forms under the medicinal list | Circular 09/2024/TT-BYT | Imported for medicinal use | Check current tariff | Check current tariff | Review by actual status | FTA according to final HS | Purpose + medicinal dossier |
| Reclassify | Roasted/seasoned/blended lotus-seed powder/snack | Further processed or blended beyond plain seed | Contains seasoning/sugar/oil/additives or a blend | Check new HS | Check new HS | Review VAT for processed product | FTA by new HS | BOM, formula, process, label |
MFN 10% / ordinary 15% are current reference rates for 1212.99.90. Medicinal-material and deeply processed goods must have HS locked again before tax calculation.
SPECIAL PREFERENTIAL C/O/FTA ROUTES TO REVIEW
| Origin/route | FTA/agreement | C/O/origin proof | Special preferential rate | Conditions | Documents to cross-check | Application note |
|---|---|---|---|---|---|---|
| China | ACFTA | Form E | 0% for 1212.99.90 where eligible | Meet PSR/origin and documentary rules | Form E, Invoice, B/L, HS, botanical identity | Compared with MFN 10%, C/O directly affects landed cost. |
| ASEAN | ATIGA | Form D / e-Form D | 0% in 2026 where eligible | Meet ASEAN origin and PSR | C/O, Invoice, B/L | Do not use Form D merely because the seller is located in ASEAN. |
| India | AIFTA | Form AI | 0% in 2026 where eligible | Meet rules of origin | C/O, Invoice, B/L | Relevant route for plant-seed ingredients. |
| Korea / Japan | AKFTA/VKFTA; AJCEP/VJEPA | Applicable origin proof | Several current schedules may be 0% where eligible | Meet PSR and origin | C/O + commercial documents | Choose the agreement that is both more favorable and best supported by the dossier. |
| Australia/New Zealand | AANZFTA / CPTPP | Applicable origin proof | May be 0% under the current schedule where eligible | Meet origin/PSR | Origin proof + commercial documents | Review by actual country of origin. |
| EU/UK | EVFTA / UKVFTA | EUR.1/REX or applicable proof | May be 0% under the current schedule where eligible | Meet the agreement’s origin-certification mechanism | Origin proof, Invoice, transport documents | No preference merely because goods are transshipped through EU/UK. |
| RCEP | RCEP | RCEP origin proof | Review the 2026 partner-specific schedule | Correct country of origin + PSR | Origin proof, Invoice, B/L | Do not assume RCEP is more favorable than ACFTA/ATIGA/AJCEP, etc. |
5. DOCUMENT SET & SUBMISSION METHOD
For dried lotus seeds, the dossier should prove three layers: correct species – correct level of pre-processing – correct intended use. If the purpose is medicinal, the medicinal-material file must be separated from the outset.
Invoice, Packing List, B/L/AWB, Contract/PO if any, C/O; the description should state dried lotus seeds / Nelumbo nucifera / peeled or lotus kernels where appropriate.
Specification, COA, botanical identity, process flow, ingredients, original label/packing, Phyto where plant quarantine applies, and test report where required.
Plant-quarantine registration; Form 04 food-safety registration where applicable; Packing List; self-declaration + test report where Articles 4–5 of Decree 15 apply; medicinal dossier where the shipment is declared as Semen Nelumbinis.
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 | Supplier/Buyer/Docs | Only says lotus seed; no botanical name/intended use | Where needed, lock “dried lotus seeds – Nelumbo nucifera – food use”. |
| HS classification | Spec, botanical name, process, ingredients, photos | Lock 1212.99.90 or another branch | Supplier + Importer | Food-grade product not separated from medicinal Semen Nelumbinis | Review intended use + process before PO. |
| Plant quarantine | Quarantine registration, Phyto, permit only if legally triggered | Import quarantine | Exporter + Importer/Forwarder | Assuming dried seeds are automatically exempt; wrong botanical name/weight/origin on Phyto | Pre-check draft Phyto + species + quantity. |
| Food-safety inspection | Form 04, Packing List, evidence for reduced/normal/tightened method | Specialist condition where in scope | Importer/Compliance | No country-eligibility review or wrong inspection method | Review Decision 1908/2026 + Decree 15 by shipment. |
| Self-declaration – if applicable | Form 01 + food-safety test report issued within 12 months under Decree 15 | Processed prepacked food under Article 4 | Importer/Compliance | Mechanically applied to every bulk dried-lotus-seed shipment or invalid test report | Determine processed/prepacked status before filing. |
| Medicinal material – if applicable | Dossier under pharmaceutical law + Circular 09/2024/TT-BYT | Semen Nelumbinis imported for medicinal use | Licensed medicinal importer/Compliance | Using food dossier for a medicinal-use shipment | Lock intended use at PO/Contract stage. |
6. LEGAL BASIS – SPECIALIST POLICY MATRIX
6.1. LEGAL REFERENCES TO REVIEW
| Legal area | Instrument | Issuing authority | Effective/application date | Role in the procedure | Key article/clause/appendix | Review note |
|---|---|---|---|---|---|---|
| HS | Circular 31/2022/TT-BTC | Ministry of Finance | 01 Dec 2022 | Vietnam export-import nomenclature | Heading 12.12; 1212.99.90 | Plain food-grade lotus seeds must be supported as “other” products primarily used for human consumption. |
| Specialist HS list | Circular 01/2024/TT-BNNPTNT | Ministry of Agriculture and Rural Development | 20 Mar 2024 | Identifies 1212.99.90 in the plant-quarantine and food-safety inspection layers | Appendix II, item 1236 | 1212.99.90 is marked for both plant quarantine and food-safety inspection; do not infer exemption merely because the goods are dried. |
| Plant-quarantine list – NEW/OLD | Circular 14/2024/TT-BNNPTNT / Circular 30/2014 | Ministry of Agriculture and Rural Development | Circular 14 effective 15 Dec 2024 | List of quarantinable objects and PRA-trigger objects | Articles 1–2 | Circular 14 replaces the previous list layer; permit/PRA is reviewed only where the actual origin/product triggers it. |
| Plant-quarantine procedure | Circular 33/2014/TT-BNNPTNT and effective amendments | Former MARD / Ministry of Agriculture & Environment | Effective portions | Registration, inspection and plant-quarantine certification | Articles 6–7 and forms | Apply together with current administrative procedures. |
| Plant-quarantine TTHC 2026 | Decision 3445/QD-BNNMT | Ministry of Agriculture & Environment | Applicable from 01 Sep 2026 | Administrative procedure for import plant-quarantine certificate | Compliant shipment: normally 24 hours from start of quarantine | May take longer for technical reasons. |
| Food safety 2026 | Decree 15/2018/ND-CP + Resolution 15/2026/NQ-CP | Government | Resolution 15 effective 06 Apr 2026 | Decree 15 continues to apply while Decree 46/2026 is suspended | Articles 4–5, 13, 16–19 | Separate self-declaration, inspection exemptions and imported-shipment inspection. |
| Food-safety decentralization 2026 | Circular 22/2026/TT-BNNMT + Decision 1908/QD-BNNMT | Ministry of Agriculture & Environment | Circular 22 effective 01 Aug 2026; actual receiving authority should be checked against the locally published administrative-procedure/decentralization arrangement at the applicable time | Updates authority/TTHC for imported-food inspection | Procedures 1.003814 and 2.001604 | Normal/tightened inspection is handled by the agency assigned or designated by the provincial People’s Committee Chair. |
| Import duty | Decree 26/2023/ND-CP + Decision 15/2023/QD-TTg | Government / Prime Minister | 15 Jul 2023 | MFN and ordinary import duty | 1212.99.90: MFN 10%; ordinary 15% | Special preferential rates are reviewed under each FTA. |
| VAT | VAT Law 48/2024/QH15; Decree 181/2025/ND-CP and 2025–2026 amendments | National Assembly / Government | Current in 2026 | Ordinary pre-processing includes cleaning, drying, peeling/shelling, seed separation and similar operations | Article 4(1) of Decree 181 and amendments | Plain dried lotus seeds have a basis to review non-taxable VAT treatment at import. |
| Medicinal material | Circular 09/2024/TT-BYT | Ministry of Health | 26 Jul 2024 | Identifies HS codes for “Liên nhục – Semen Nelumbinis” | List 11, item 197 | 1211.90.17/18/19 depending on form; triggered only by medicinal use. |
| Labeling | Decree 43/2017/ND-CP amended by Decree 111/2021/ND-CP | Government | Decree 111 effective 15 Feb 2022 | Imported-goods labeling / supplementary labels | Mandatory content and supplementary-label rules | Retail packs require additional review of food-label requirements. |
| Customs | Customs Law 2014; Decree 08/2015 amended by Decree 167/2025/ND-CP | National Assembly / Government | Decree 167 effective 15 Aug 2025 | Customs procedure, inspection and supervision | Shipment-specific | Specialist results must align with the customs declaration. |
6.2. POLICY MATRIX BY SHIPMENT SCENARIO
| Shipment scenario | Reference to cross-check | Possible policy | Authority/portal | Trigger |
|---|---|---|---|---|
| Plain food-grade dried lotus seeds – bulk | Circular 01/2024 + Circular 14/2024 + Decree 15 | HS 1212.99.90; plant quarantine; food-safety inspection under the applicable method | Plant-quarantine authority + provincially assigned food-safety authority + Customs | Used as food/ingredient and not deeply processed |
| Plain dried retail pack | Circular 01/2024 + Decree 15 Articles 4–5/13 + Decision 1908/2026 | Plant quarantine reviewed separately; self-declaration/imported-food inspection depends on actual processed-prepacked status | Food-safety authority + Customs + plant-quarantine authority where applicable | Packaging/label/process establish actual status |
| Reduced food-safety inspection | Decree 15 Articles 16–17 | Reduced inspection | Customs/current mechanism | Meets reduced-inspection conditions |
| Normal/tightened food-safety inspection | Decree 15 Articles 17–19 + Circular 22/2026 + Decision 1908/2026 | Normal: 3 working days; tightened: 7 working days | Provincially assigned/designated authority | Not eligible for reduced inspection or a tightened-inspection trigger exists |
| Origin/product triggers PRA/permit | Circular 14/2024 + relevant plant-quarantine rules | PRA/import plant-quarantine permit before import where required | Competent plant-protection authority | Only where the actual origin/product is subject to a permit requirement |
| Semen Nelumbinis imported as medicinal material | Circular 09/2024/TT-BYT + pharmaceutical rules | HS 1211.90.17/18/19 depending on form + medicinal-material dossier | Pharmaceutical/traditional-medicine authority + Customs | Intended use and dossier establish medicinal use |
| Roasted/seasoned/blended lotus-seed product | Processed-product HS + Decree 15 | Reclassify HS; self-declaration/label/VAT according to processed food | Food-safety authority + Customs | Ingredients/process exceed plain dried-seed scope |
7. TIMELINE, FEES & RISK COSTS
| Stage | Operational point | Timing/basis | Cost layer | Main risk |
|---|---|---|---|---|
| Intended use / HS identification | Before PO/booking | Depends on spec, botanical name, process and intended use | Internal/advisory if any | Confusing food-grade 1212.99.90 with medicinal 1211.90.xx Semen Nelumbinis |
| Plant-quarantine / Phyto review | Before shipment | According to Circular 01/2024, Circular 14/2024 and origin dossier | Quarantine fee if incurred | Missing Phyto/permit; wrong botanical name, weight or origin |
| Plant quarantine if applicable | At start of quarantine | Decision 3445/2026: compliant shipment commonly 24 hours | Quarantine/sampling/treatment fees under current schedule | Pest finding or document supplementation |
| Normal food-safety inspection | Where in scope | Decision 1908/2026: 3 working days | Inspection/testing cost if incurred | Country eligibility or dossier mismatch |
| Tightened food-safety inspection | When triggered | Decision 1908/2026: 7 working days | Testing + logistics | Storage/DEM/DET while waiting |
| Customs | After specialist conditions | Green/Yellow/Red channel dependent | Import duty, port/warehouse/trucking | Loss of 0% C/O preference; VAT error; medicinal/food dossier does not match intended use |
8. PRACTICAL E2E WORKFLOW
Confirm Nelumbo nucifera, food versus medicinal use, whole/peeled condition, plumule removal, bulk/retail format and ingredients.
Plain food-grade product: review 1212.99.90, MFN 10%, ordinary 15%, VAT and FTA; medicinal product: separate into 1211.90.xx as applicable.
Cross-check Circular 01/2024 + Circular 14/2024; determine Phyto/quarantine registration/permit where triggered.
Determine reduced/normal/tightened inspection or the processed-prepacked/self-declaration branch according to the dossier.
Cross-check Invoice, PL, B/L/AWB, C/O, botanical name, intended use, process, label, Phyto and food-safety/medicinal dossier.
Green is mainly automated; Yellow reviews documents; Red may include physical inspection together with specialist records.
Submit plant-quarantine/food-safety results where applicable, handle C/O/VAT and complete clearance/pickup.
Retain SKU/shipment files; changes in intended use, supplier/origin, process, ingredients or bulk→retail packing require reassessment.
9. FAQ
1. What HS code applies to food-grade dried lotus seeds?
For plain dried Nelumbo nucifera used as food and not further processed into another product, the main reference code is 1212.99.90.
2. Why not classify lotus seeds under heading 12.07?
Heading 12.07 covers oil seeds and oleaginous fruits. Plain food-grade lotus seed does not automatically fall there; heading 12.12 is the stronger starting point where the goods are mainly for human consumption and not elsewhere specified.
3. Does peeling or removing the lotus plumule change the HS code?
Not automatically. If these are only pre-processing operations and the product remains plain food-grade dried lotus seed, 1212.99.90 remains the main code to review.
4. Are dried lotus seeds subject to plant quarantine?
Circular 01/2024 places 1212.99.90 in the plant-quarantine layer. Do not assume exemption merely because the product is dried; review Phyto requirements by actual shipment and origin.
5. Is imported-food safety inspection required?
1212.99.90 is also in the plant-origin food control layer. Determine reduced/normal/tightened inspection or the processed-prepacked branch under Decree 15 and the 2026 procedures.
6. What VAT applies to dried lotus seeds at import?
Cleaning, drying, peeling and separation are listed as ordinary pre-processing. If the goods remain within that scope and are not transformed into another product, review non-taxable VAT treatment at import.
7. What is the MFN duty for 1212.99.90?
The current reference is MFN 10% and ordinary duty 15%. Several FTAs may reduce the rate to 0% if origin documentation qualifies.
8. Can China-origin dried lotus seeds receive 0% duty?
Potentially yes. ACFTA provides a 0% rate for 1212.99.90 where rules of origin are met and a valid Form E is presented.
9. Should medicinal Semen Nelumbinis be declared under 1212.99.90?
Not automatically. Circular 09/2024/TT-BYT identifies Liên nhục – Semen Nelumbinis under 1211.90.17/18/19 depending on form when imported for medicinal use.
10. Can roasted/seasoned lotus seeds use 1212.99.90?
Not automatically. Added sugar/oil/seasoning or snack processing may move the goods to another processed-product HS code; review BOM, process and label before classification.
10. OUTPUTS & POST-CLEARANCE OBLIGATIONS
01. Product file: Nelumbo nucifera, food/medicinal purpose, spec, process, ingredients, whole/peeled condition and packing/label.
02. Shipment file: Invoice, PL, B/L/AWB, C/O, customs declaration, tax/VAT treatment and origin evidence.
03. Specialist file: Phyto/quarantine registration/result where applicable; Form 04/food-safety result or self-declaration + test report; medicinal dossier where intended use is medicinal.
01. Complete original/supplementary labeling, lot/batch, origin, shelf life and SKU/shipment traceability.
02. Retain records for post-clearance review and comparison against later shipments.
03. Reassess when intended use, supplier/origin, process, ingredients, packaging, or plain→seasoned condition changes.
11. TGIMEX SOLUTION
For dried lotus seeds, the key is to lock botanical identity – intended use – HS – plant quarantine – food-safety/medicinal branch – VAT – C/O before ETA so the shipment does not require major corrections after arrival.
Review Nelumbo nucifera, food/medicinal use, HS 1212.99.90 or 1211.90.xx, process, Phyto, food-safety requirements, VAT and FTA/C/O.
Align Invoice, PL, B/L/AWB, C/O, spec, COA, botanical name, intended use, process, label and specialist documents.
Track quarantine/food-safety milestones and coordinate Customs, specialist authorities, port/warehouse, transport and post-clearance records.
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