Fish maw is the edible swim bladder of fish, but it cannot be cleared correctly from the trade name alone. HS classification, quarantine, import VAT and CITES documentation may change with the product state, degree of processing and species.

This guide focuses on dried/salted/in-brine or smoked fish maw that is not seasoned or further prepared, and separately maps fresh/chilled, frozen and further-prepared variants. Operational update: 10 September 2026.

CORE HS0305.72.11 (cod) / 0305.72.19 (other species) for dried, salted, in-brine or smoked maw.

REFERENCE MFN5% for 0305.72.11/19, subject to re-check on declaration date.

QUARANTINEDried maw is not automatically on the current list; fresh/chilled/frozen product requires quarantine screening.

IMPORT VATMay be non-taxable if only ordinarily preliminarily processed and not made into another product.

FOOD SAFETY 2026Decree 15/2018/ND-CP continues during the suspension of Decree 46/2026.

CITESLock the scientific species name before shipment.

1. OVERVIEW – SCOPE

In trade, fish maw normally means an edible fish swim bladder separated from the fish. The same commercial name can lead to different HS and specialised-control outcomes.

1.1. Main scope

Genuine fish-derived maw intended for food.
Main state: dried, salted, in brine or smoked, without seasoning, frying, cooking or deep processing.
Bulk or retail-packed product; self-declaration must be assessed against the legal concept of processed, prepacked food and the actual use.

1.2. Do not automatically apply this guide to

Fresh/chilled or frozen maw.
Fried, cooked, seasoned or further-prepared maw.
“Vegetarian fish maw”, which is not fish.
Non-food, technical, collagen/gelatin extraction material, or material already transformed into another product.

DATA TO LOCK BEFORE QUOTING/BOOKING: trade name + scientific species name + state + processing flow + ingredients/seasoning + packing + intended use + origin. Without species, no final CITES conclusion is defensible.

2. KEY TERMS & CONTROL POINTS

Term	Operational meaning	Shipment impact
Fish maw	Edible swim bladder of fish.	Must be distinguished from fish meat and other offal.
Edible fish offal	Edible parts/offal separated from fish.	Supports Chapter 03 classification logic.
Ordinary preliminary processing	Cleaning, sun/heat drying, splitting, deboning, skinning, salting, chilling/freezing and similar basic preservation under VAT rules.	Can determine non-taxable import VAT.
State food-safety inspection	Official inspection of imported food.	Applied under Decree 15/2018 unless a valid exemption/other mechanism applies.
Self-declaration	Business self-declaration regime under Article 4 of Decree 15/2018.	Do not assume every bulk dried maw requires it; first determine whether it is processed prepacked food.
CITES	Convention regulating international trade in endangered species specimens.	Species identification is a pre-shipment stop point.

QUARANTINE – CURRENT RULE: Circular 06/2022/TT-BNNPTNT, effective 11 September 2022, amended Appendix I of Circular 26/2016. The current list describes aquatic animal products subject to quarantine in live/fresh, chilled or frozen form. Therefore, an old HS-based checklist should not be used to automatically impose quarantine on dried maw. Official legal database

3. DETAILED PRODUCT CLASSIFICATION

Product/situation	What to check	Example	Evidence	Potential policy	Documents	Application note
Dried/salted/in-brine/smoked cod maw	True maw, cod species, no further preparation.	Dried cod fish maw	Spec, label, flow chart, scientific name, photos.	Food safety; CITES screening; labels; C/O.	Commercial + technical + food-safety docs.	Core reference HS 0305.72.11.
Dried/salted/in-brine/smoked maw – other species	Scientific species and preservation method.	Dried croaker/seabass maw	Spec/COA, process, species, source.	Food safety; CITES; labels; C/O.	Add species/source evidence.	Core reference HS 0305.72.19.
Fresh/chilled maw	No drying/salting; fresh/chilled chain.	Fresh fish maw	Temperature/species docs.	Aquatic quarantine; food safety; CITES.	Quarantine + trade + food safety.	Reference branch 0302.99.00.
Frozen maw	Frozen, not further prepared.	Frozen fish maw	Temperature/spec/process.	Aquatic quarantine; food safety; CITES.	Quarantine + trade + food safety.	Reference 0303.99.00.
Fried/cooked/seasoned/further prepared	Cooking, oil, seasoning, sauces, recipe.	Prepared fish maw	Recipe, composition %, flow chart, label.	Food safety/self-declaration; Chapter 16/other HS.	Composition/process evidence.	Do not force HS 0305.72.
CITES-listed species	Scientific name against Appendices I/II/III.	High-risk example: Totoaba macdonaldi.	Species, source code, CITES permits.	CITES documentation/permit; trade restrictions.	Documents under Circular 85/2025.	Do not ship until legal-source and permit route are locked.

CLASSIFICATION WARNING: dry → frozen or plain → prepared can change HS, quarantine, VAT and food-safety requirements. A change in species can trigger CITES even when the physical product looks similar.

4. HS CODE – DUTIES – C/O

4.1. PROPOSED HS – TAX – C/O TABLE

Within heading 0305, subheading 0305.72 covers fish heads, tails and maws, with fish maws split between 0305.72.11 (cod) and 0305.72.19 (other). This branch fits only goods within heading 03.05: dried, salted/in brine or smoked. Decree 26/2023/ND-CP tariff reference

Reference HS	Description	Classification basis	Conditions	Ordinary duty	MFN	VAT	FTA/C/O	Evidence
0305.72.11	Fish maws – of cod	Edible maw under 03.05	Dried/salted/brined/smoked; cod; not further prepared	7.5%	5%	Non-taxable at import if only ordinarily preliminarily processed and not made into another product; otherwise reassess	ATIGA/ACFTA/RCEP/VJEPA/AKFTA/VKFTA etc.	Species + process + C/O
0305.72.19	Fish maws – other	Same, non-cod species	Dried/salted/brined/smoked, no deep processing	7.5%	5%	Same principle	By origin	Lock scientific name/CITES
0302.99.00	Other edible fish offal, fresh/chilled, potentially including maw	Heading 03.02	Fresh/chilled	15%	10%	Generally non-taxable at import if unprocessed into another product	By origin	Spec + temperature + quarantine + species
0303.99.00	Other edible fish offal, frozen, potentially including maw	Heading 03.03	Frozen, not further prepared	15%	10%	Generally non-taxable at import if only frozen preservation	By origin	Spec + temperature + quarantine + species
To be classified	Further-prepared/seasoned/cooked maw	Ingredients + processing	No longer necessarily Chapter 03	Determine final HS		If base 10% and eligible for temporary reduction, 8% through 31 Dec 2026; check exclusions	By final HS	Recipe + process + label

Reference duty data must be rechecked on the customs declaration date. Decree 26/2023/ND-CP – Government Portal

VAT – PRODUCT-SPECIFIC POINT: Article 4(1) of Decree 181/2025/ND-CP treats imported aquatic products that are not processed into another product, or only ordinarily preliminarily processed, as non-taxable. The listed preliminary processes include cleaning, drying, splitting, salting and chilling/freezing. Plain maw that is only cleaned/separated/dried or salted should therefore be assessed under this rule. Frying, cooking, seasoning or mixing requires a fresh analysis. Ministry of Finance guidance

4.2. FTA / C/O MATRIX BY ORIGIN

Origin	FTA	C/O / proof	Potential preference	Conditions	Evidence	Note
ASEAN	ATIGA	Form D/e-Form D	Check the current ATIGA schedule for the final HS; do not state a preferential rate without the year-specific tariff check	Meet PSR + valid origin proof	C/O, invoice, B/L, HS	Use 2026 schedule
China	ACFTA or RCEP	Form E or RCEP proof	Check the current ACFTA/RCEP schedule for the final HS; confirm the rate only after HS and origin-rule verification	Correct HS/origin/transport documents	C/O + trade docs	“Made in China” alone is insufficient
Korea	AKFTA/VKFTA/RCEP	AK/KV/RCEP proof	Check schedule	Meet PSR	Origin + commercial docs	Choose best valid route
Japan	VJEPA/AJCEP/CPTPP/RCEP	Agreement-specific proof	Check 2026 schedule	Meet PSR	Species/source + origin docs	Do not assume WO with third-country raw material
EU/UK	EVFTA/UKVFTA	EUR.1/origin statement as applicable	Check final HS	Origin rules satisfied	Origin + trade docs	Keep product/species description consistent
India	AIFTA	Form AI	Check 2026 schedule	Meet PSR	C/O + invoice + transport docs	Check criterion/date

Verify the correct form/proof and issuer.
Match HS, fish-maw description, species, quantity, weight and origin across C/O, Invoice, Packing List and B/L.
Check WO/RVC/CTH/CTSH/CC against the actual PSR.
Check third-party invoicing, transit/direct transport, issue date and validity where relevant.

5. DOSSIER & FILING METHOD

5.1. Commercial documents

Commercial Invoice.
Packing List.
Bill of Lading/Air Waybill.
Sales Contract/Purchase Order where used.
C/O when claiming special preferential duty.

5.2. Technical data to obtain from supplier

Product Specification/COA.
Common and scientific species names.
Process flow: cleaning/separating/drying/salting/smoking or actual process.
Ingredient list/recipe for any seasoning, additive, oil, sauce or cooking/frying.
Original label, package photos, retail/bulk format.
Capture/aquaculture source and CITES documents if applicable.

5.3. Food-safety/self-declaration – by case

Self-declaration: Article 4 of Decree 15/2018 applies to processed, prepacked food and other stated categories. Retail-packed finished dried maw should be screened under this branch; bulk/raw-material or exempt cases require separate analysis.

ARTICLE 14 BRANCH – DECREE 15/2018/ND-CP: for imported aquatic-animal food products, except processed and prepacked foods, returned Vietnamese exports and Article 13 cases, screen the exporting country/territory approval, the approved establishment list for aquatic products, and the competent exporting-authority food-safety certificate for each shipment, subject to the statutory exception. Accordingly, bulk dried fish maw that does not satisfy the combined “processed and prepacked” exception must not be treated like a retail pack.

Import food-safety inspection – Article 18 of Decree 15/2018/ND-CP:

Reduced inspection: self-declaration plus three consecutive satisfactory notices under normal inspection, or a valid qualifying GMP/HACCP/ISO 22000/IFS/BRC/FSSC 22000 or equivalent certificate; Article 14 aquatic products also require the exporting-authority food-safety certificate unless the processed/prepacked exception applies.
Normal/tightened inspection: Form 04 + self-declaration + Packing List; three consecutive satisfactory notices under tightened inspection are relevant only for conversion from tightened to normal inspection; Article 14 products also require the exporting-country food-safety certificate as prescribed.

5.4. Quarantine dossier – only when triggered

Fresh/chilled/frozen maw: screen quarantine under Circular 26/2016 as amended by Circular 06/2022.
Dried maw: do not impose quarantine merely because the product originates from fish; use the current list and actual case.

5.5. CITES dossier – if triggered by species

Scientific name, CITES Appendix and specimen source.
Foreign CITES export/re-export permit when required.
Application under Form 36 when a Vietnamese import permit is required.
CITES permit Form 35 when issued; import permits are valid up to 12 months and for one use under Article 28 of Circular 85/2025.

5.6. OPERATIONAL DOSSIER CHECKLIST

Group	Document	Step	Typical owner	Common error	Pre-ETA check
Commercial	Invoice, PL, B/L/AWB, Contract/PO	Customs	Supplier + importer + forwarder	Only “fish maw”, no state/species	Lock detailed description before B/L
Technical	Spec, process, species, label	HS/VAT/policy	Supplier	No scientific name; vague process	Supplier-confirmed technical pack
Food safety	Self-declaration; Article 18 dossier; approved country/establishment + exporting-country food-safety certificate if Article 14 applies	Clearance/market	Importer	Mismatch with label/spec	100% consistency check
Quarantine	Registration/certificate as applicable	Pre-clearance	Importer + supplier	Applying dry logic to frozen or vice versa	Lock product state/temperature
CITES	Species proof, permit/certificate	Pre-shipment/clearance	Exporter + importer	Species/source mismatch	Screen before deposit/booking
C/O	Origin proof	Preferential duty	Exporter	HS/description/species mismatch	Draft check before issuance

100% CONSISTENCY RULE: Invoice, Packing List, B/L/AWB, C/O, specification, label, species evidence and food-safety/CITES files must not conflict on product name, state, species, quantity, weight, origin or use.

6. LEGAL BASIS & SPECIALISED-POLICY MATRIX

6.1. LEGAL BASIS TO REVIEW

Area	Instrument	Issuer	Effective/status	Role	Key provision	Source/note
Food safety	Decree 15/2018/ND-CP	Government	2 Feb 2018; continues under Resolution 15/2026	Self-declaration/import inspection/exemptions	Art. 4, 13; Chapter VI	Official database
2026 transition	Resolution 15/2026/NQ-CP	Government	6 Apr 2026	Suspends Decree 46/2026 and Resolution 66.13/2026; continues Decree 15/2018	Arts. 1, 2, 5	Government Gazette
Aquatic quarantine	Circular 26/2016 amended by Circular 06/2022/TT-BNNPTNT	MARD	Amendment effective 11 Sep 2022, in force	Defines aquatic products subject to quarantine	Art. 2(1), Appendix I amendment	Official database
CITES	Circular 85/2025/TT-BNNMT	Ministry of Agriculture & Environment	1 Jan 2026, in force	Endangered-species/CITES management	Arts. 27, 28, 30; Forms 35/36	Official database
CITES transition	Decree 42/2026/ND-CP	Government	26 Jan 2026, in force	Current framework change; old Decrees 06/2019 and 84/2021 expired	Effect diagram	Official database
Import duty	Decree 26/2023/ND-CP + effective amendments	Government	From 15 Jul 2023	MFN tariff	Chapter 03	Recheck on filing date
Ordinary duty	Decision 15/2023/QD-TTg	Prime Minister	15 Jul 2023; in force	Ordinary import rates	By HS	Official database
VAT	VAT Law 48/2024/QH15; Decree 181/2025/ND-CP, as amended/supplemented by Decree 359/2025/ND-CP and Decree 144/2026/ND-CP	National Assembly/Government	Decree 359 effective 1 Jan 2026; Decree 144 effective 20 Jun 2026	Non-taxable/5%/10%	Art. 4(1) of Decree 181	Decree 359/2025 · Decree 144/2026
VAT reduction	Decree 174/2025/ND-CP	Government	1 Jul 2025 – 31 Dec 2026	10% → 8% where eligible	Arts. 1–2 and exclusions	Government guidance
Labels	Decree 43/2017 amended by Decree 111/2021/ND-CP	Government	Amendment in force from 15 Feb 2022	Original/Vietnamese supplementary label	Product-specific annexes	Official database
Customs	Customs Law 54/2014; Decree 08/2015/ND-CP as currently amended by Decree 167/2025/ND-CP (Decree 59/2018/ND-CP fully expired on 15 Aug 2025); Circular 38/2015/TT-BTC as amended/supplemented by Circular 39/2018/TT-BTC and Circular 121/2025/TT-BTC	NA/Government/MOF	Decree 167 effective 15 Aug 2025; Circular 121 effective 1 Feb 2026; recheck provisions in force on filing date	Declaration, inspection, clearance	By transaction type	Customs Law · Decree 167/2025 · Circular 121/2025

2026 OLD/NEW CONTROL: do not apply Decree 46/2026/ND-CP as the active food-safety rule in September 2026. Resolution 15/2026/NQ-CP suspends it and Resolution 66.13/2026 until the amended Food Safety Law and its new implementing decree take effect; Decree 15/2018/ND-CP continues during the suspension.

6.2. POLICY MATRIX BY SITUATION

Situation	Legal basis	Potential policy	Authority/channel	Trigger
Plain dried maw, non-CITES species	Decree 15; Circular 06; VAT; label rules	Food safety by status/use; no automatic quarantine; self-declaration if processed prepacked	Assigned local food-safety authority + Customs	Food use, retail/bulk, dossier
Fresh/chilled maw	Circular 26 + 06	Quarantine + food safety + customs	Competent quarantine authority	Fresh/chilled state
Frozen maw	Same	Quarantine + food safety + customs	Competent quarantine authority	Frozen state
Further-prepared retail product	Decree 15; label rules; final HS	Self-declaration where Art. 4 applies; food inspection; label; VAT reassessment	Assigned food authority + Customs	Cooking/seasoning/recipe/retail pack
CITES species	Circular 85/2025 + CITES Appendices	CITES permit/document route	Vietnam CITES Management Authority + Customs	Scientific name in Appendix I/II/III
Species unknown	Insufficient evidence	Stop final CITES conclusion	Supplier/importer must supplement	Generic “fish maw” only

CITES WARNING EXAMPLE: Totoaba macdonaldi is controlled in CITES Appendix I, and illegal totoaba-maw trade is a major international enforcement issue. This is why fish maw should be screened by species before purchase/shipment. CITES source

7. TIMELINE, FEES & RISK COSTS

Step	When	Time	Cost	Delay risk
Lock species/state/process	Before PO/booking	Internal/supplier	Testing/verification if needed	Wrong HS/CITES/quarantine
CITES review	Before shipment	Where a VN permit is required, ordinary case: 5 working days from a valid dossier; consultation cases take longer	Do not invent a fee without a current basis	Hold/refusal/legal exposure
Self-declaration if applicable	Before market circulation/planned import	Business self-responsibility; filing follows current local assignment	Testing if needed	Post-market non-compliance
Food inspection/quarantine	Start before ETA as applicable	Depends on method, sampling and authority	Actual testing/inspection charges	Storage, DEM/DET, delivery delay
Customs	Once dossier is ready	Depends on Green/Yellow/Red channel and specialised clearance	Import duty + logistics charges	HS/value consultation, physical inspection

8. END-TO-END OPERATIONAL PROCESS

PRE-CHECK BEFORE ETA/BOOKING: obtain species, state, process flow, ingredients, label, origin and real photos.
CITES SCREEN: match scientific name against CITES Appendices and Circular 85/2025; lock permit route before export.
LOCK HS + VAT: dry/salted/brined/smoked plain → 0305.72.11/19; fresh/chilled → 0302.99.00; frozen → 0303.99.00; prepared → reclassify.
LOCK FOOD SAFETY + QUARANTINE: decide self-declaration, inspection method and quarantine trigger.
LOCK DOCUMENTS: review draft Invoice, PL, B/L/AWB, C/O, species documents and permits.
FILE SPECIALISED DOSSIERS: CITES/quarantine/food-safety through the competent channel at the time of filing.
CUSTOMS & CHANNEL: Green is generally more automated; Yellow involves document review; Red may include physical inspection.
RELEASE – LABEL – RETENTION: complete market-label obligations and retain a shipment file for post-clearance audit.

PRE-ETA RULE: screen CITES before shipment; lock HS/species/process before booking; prepare food-safety/quarantine files when draft documents are available. Do not wait until arrival to ask the supplier what species the maw came from.

9. FAQ

1. Must dried fish maw undergo aquatic quarantine?

Not automatically under the current list. Circular 06/2022 narrowed the listed aquatic animal products to live/fresh, chilled and frozen forms, subject to treaty/special cases.

2. What are common HS codes for dried maw?

0305.72.11 for cod maw and 0305.72.19 for other species, where the product is dried/salted/in brine/smoked and not further prepared.

3. What is the reference MFN rate for 0305.72.11/19?

5%; ordinary rate reference 7.5%. FTA C/O can lower the rate if all origin rules are met.

4. Is import VAT payable on plain dried maw?

If it remains an aquatic product not processed into another product and has only ordinary preliminary processing such as cleaning/separating/drying/salting, Article 4(1) of Decree 181/2025 supports non-taxable import VAT. Further processing changes the analysis.

5. Is self-declaration always required?

No. Article 4 of Decree 15/2018 is tied to processed, prepacked foods and listed categories. Retail finished packs require screening; bulk/raw-material/exempt situations must be assessed separately.

6. Why is the scientific species name essential?

CITES is species-based, not trade-name based. Species also supports cod/other HS determination.

7. Can frozen maw use 0305.72.19?

Do not assume so. Frozen edible fish offal, including maw, should be screened under 0303.99.00, with quarantine implications.

8. Does every CITES-listed maw need a Vietnamese import permit?

Not always. Article 27(6) of Circular 85/2025 identifies certain cases where no Vietnamese-issued import permit is needed but foreign CITES documents must be presented to Customs. Other cases must follow Article 30.

9. Can Form E reduce duty?

For qualifying Chinese origin, a valid Form E may provide a rate below MFN. Do not state 0% based only on the commercial name “fish maw”. Confirm the final HS against the 2026 ACFTA tariff schedule, PSR and document consistency.

10. What if the goods arrive and the supplier cannot identify the species?

Do not guess from photos. Obtain species/source evidence; if CITES risk exists, resolve it with the competent authority before proceeding.

10. OUTPUTS & POST-CLEARANCE OBLIGATIONS

Customs declaration and duty evidence.
Invoice, Packing List, B/L/AWB, C/O.
Specification, process, ingredients and scientific species evidence.
Self-declaration/food-inspection records where applicable.
Quarantine file where applicable.
CITES permit/documents and source evidence where applicable.
Original and Vietnamese supplementary labels where required.

For preferential-origin or CITES shipments, keep a dedicated audit trail linking HS, species, origin, permit and shipment records.

Main sources: Resolution 15/2026 · Decree 15/2018 · Circular 06/2022 · Circular 85/2025 · Decree 42/2026 · Decree 111/2021. Recheck HS/tax and shipment-specific policy on the filing date.

11. SOLUTIONS FROM TGIMEX

For fish maw, operational control starts by locking species, state and processing level before ETA, not by fixing documents after arrival.

Review description, scientific species, state and processing to propose HS.
Screen quarantine by state and avoid outdated dry-product logic.
Review food safety, self-declaration, inspection method and labels.
Screen CITES before shipment and coordinate permit/document route where triggered.
Review C/O/FTA consistency across origin and shipment documents.
Coordinate customs, transport, port/warehouse and post-clearance file retention.

This English version is for operational reference only and is not an official legal translation. It does not replace a binding classification or approval by the competent authority for a specific dossier.

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