VIETNAM IMPORT PROCEDURES FOR BOTTLED TEA
“Bottled tea” can follow different regulatory routes depending on whether it is ready-to-drink or concentrate, carbonated or non-carbonated, and its total-sugar content. These data points affect HS, import duty, food-safety inspection, nutrition labeling, VAT and—since 2026—the excise-tax scope for sugary beverages.
This guide applies to non-alcoholic bottled/canned tea imported for circulation in Vietnam and maps product identification, HS, food safety, product declaration, labeling and tax before ETA.
Operational reference for import-export businesses · Updated through 11 Sep 2026.
1. QUICK SUMMARY & SCOPE
Finished non-alcoholic tea infusion/extract beverage in bottle/can, ready for immediate consumption without dilution.
Main review branch for other non-aerated ready-to-drink beverages; exclude carbonated/flavoured-water, tea concentrate and milk-based branches first.
From 17 Jul 2026, Circular 28/2026/TT-BCT lists 2202.99.50 among imports subject to state food-safety inspection under MOIT management.
Conventional processed prepackaged bottled tea generally follows Decree 15/2018 self-declaration and Decree 37/2026 labeling; nutrition labeling is reviewed under Circular 29/2023/TT-BYT.
Reference MFN for 2202.99.50 is 30%; ordinary duty should be checked under Decision 15/2023, with 45% as the current reference. For 2026 VAT, first determine whether the SKU is a beverage under TCVN 12828:2019 with total sugars >5g/100ml.
Lock formula, sugar g/100ml, carbonation, tea %, use instruction, claims, label and C/O before customs filing.
2. KEY TERMS & WHY THEY MATTER
Finished beverage consumed directly without dilution—the key feature of 2202.99.50.
Import control under Decree 15/2018 can be reduced, normal or strict depending on the applicable case.
Mechanism for processed prepackaged foods under Article 4 Decree 15/2018, except products requiring registration or qualifying for an exemption.
Decree 360/2025 defines the relevant national-standard beverage by TCVN 12828:2019. Sugar content is total sugars stated on the product label under Ministry of Health rules; if an imported product does not yet carry the compliant label, the importer must determine, declare and take responsibility for the figure.
Supports special preferential duty where the FTA and origin rules are satisfied.
Circular 29/2023 requires energy, protein, carbohydrate, fat and sodium; beverages with added sugar also declare total sugars.
3. DETAILED PRODUCT IDENTIFICATION & CLASSIFICATION
Before HS analysis, lock: ingredient percentages, tea infusion/extract, CO₂, ready-to-drink versus dilution, total sugars g/100ml, milk %, caffeine/claims, pack size and circulation purpose.
| Product group/situation | Data to verify | Example | Evidence | Potential policy | Files to reconcile | Application note |
|---|---|---|---|---|---|---|
| Non-carbonated RTD tea | No CO₂; direct consumption; tea/water base | Green tea RTD, oolong tea RTD | Formula, spec, usage, label | 2202.99.50; food safety; self-declaration; label | Invoice, PL, formula, spec, test | Primary branch. |
| Carbonated/sparkling tea | CO₂ or flavoured/aerated-water character | Sparkling tea | CO₂ spec, process, label | Review 2202.10.* or proper line; food safety | COA, formula, carbonation statement | Do not use non-aerated 2202.99.50. |
| Tea concentrate requiring dilution | Not ready to drink | Tea concentrate/base | Dilution instructions, Brix/solids | Review 2101.20.* or other branch | TDS, use instruction, composition | Outside RTD logic. |
| Bottled milk tea | Material milk content; possible UHT process | UHT bottled milk tea | Milk %, UHT statement, formula | Review 2202.99.10 or proper 2202 line | Formula, process, label | Do not automatically group with water-based tea. |
| Strong functional claims | Dose/health claims/additional actives | Functional herbal drink | Claims, active dose, dossier | May require special-food/product-registration review | Label, formulation, product dossier | Do not assume conventional beverage status. |
| Tea beverage within TCVN 12828:2019 with total sugars >5g/100ml | Confirm both TCVN beverage scope and total sugars >5g/100ml | Sweetened bottled tea | Nutrition data, lab, formula | Decree 174/2025: no 2% VAT reduction in 2026; Law 66/2025 + Decree 360/2025: excise 8% from 2027 and 10% from 2028 | Label, lab result, formula | Do not infer from “sweet tea” alone; both TCVN 12828:2019 scope and total sugars must be evidenced. |
4. HS CODE – DUTY – C/O
The codes below are reference branches. Final classification must be based on beverage character, formula, carbonation, use instructions and concentration.
Other non-aerated beverages ready for immediate consumption without dilution—the main branch for most non-carbonated RTD teas.
Exclude UHT milk drinks, coffee drinks, coconut-water drinks, carbonated/flavoured-water and tea concentrates.
MFN for 2202.99.50 is 30%; ordinary rate may be 45% under the current 150%-of-MFN mechanism where applicable.
Goods otherwise subject to 10% VAT and outside Decree 174/2025 exclusions may be reduced to 8% through 31 Dec 2026. A TCVN 12828:2019 beverage with total sugars >5g/100ml is expressly listed in Appendix II and therefore not reduced, remaining at 10%.
Law 66/2025 adds the sugary-beverage category; Decree 360/2025 ties the scope to TCVN 12828:2019 and explains total-sugar determination. The rate is 8% from 1 Jan 2027 and 10% from 1 Jan 2028; do not apply 8% to 2026.
For 2202.99.50, ATIGA and ACFTA show 0% in 2026 where origin and documentary conditions are met.
| Reference HS | Suitable goods | Classification basis | Application condition | Ordinary duty | MFN | VAT | C/O/FTA to review | Evidence |
|---|---|---|---|---|---|---|---|---|
| 2202.99.50 | Other non-aerated RTD beverages without dilution | Chapter 22 | RTD; non-aerated; no more specific line | ~45% reference where 150%-MFN mechanism applies | 30% | 8% if the goods are normally 10%-VAT and qualify for the reduction; 10% if the SKU is a TCVN 12828:2019 beverage with total sugars >5g/100ml or otherwise excluded by Decree 174/2025 | ATIGA/ACFTA/VKFTA/RCEP/CPTPP… | Formula, usage, CO₂, sugar, C/O |
| 2202.10.90 | Water with added sugar/sweetener/flavouring, other | Competing 2202.10 branch | Actual beverage fits 2202.10 description | Check Decision 15/2023/final HS | 35% | Review sugar/excise and VAT reduction | FTA by origin | CO₂, formula, label, spec |
| 2202.99.10 | Flavoured UHT milk-based drink | Specific 2202.99 line | Milk/UHT character matches legal description | Review final HS | 30% | Review sugar/excise and VAT reduction | FTA by origin | Milk %, UHT process |
| 2101.20.* | Tea extracts/concentrates and tea-based preparations | Chapter 21 | Concentrate/preparation requiring dilution or further use | Recalculate; do not transfer 2202 duty | Check current 8-digit line | Review product nature | FTA by final line | Brix/solids, dilution instruction, TDS |
| Origin route | FTA | C/O/origin proof | Special rate where verified | Conditions | Evidence | Note |
|---|---|---|---|---|---|---|
| ASEAN | ATIGA – Decree 126/2022/ND-CP | Form D/eligible origin proof | 0% for 2202.99.50 in 2026 | Meet PSR and document requirements | C/O, invoice, B/L, origin data | Lock HS before FTA mapping. |
| China | ACFTA – Decree 118/2022/ND-CP | Form E | 0% for 2202.99.50 in 2022–2027 schedule | Valid origin, PSR and transport/documents | Form E, invoice, B/L | Chinese shipment alone does not prove ACFTA origin. |
| Korea | VKFTA – Decree 125/2022/ND-CP / AKFTA / RCEP | Form KV or applicable proof | VKFTA may be 0% for 2202.99.50; other agreements separately checked | Correct agreement and PSR | C/O, invoice, origin/process data | Do not transfer VKFTA rate to RCEP/AKFTA. |
| Other routes | CPTPP / EVFTA / RCEP / AJCEP… | Agreement-specific proof | Check country/year schedule | Meet PSR and transport/document rules | C/O/origin declaration, invoice, B/L/AWB | Each FTA has its own schedule and HS edition. |
C/O CHECKLIST BEFORE CLAIMING PREFERENCE
- Correct form/origin proof for the agreement and origin country.
- Applicable WO/RVC/CTH/CTSH or PSR.
- Third-party invoicing and transit/direct-transport evidence where relevant.
- HS, description, quantity/weight and origin reconcile with Invoice, Packing List and customs declaration.
- Issue date, validity, signature/e-authentication and authenticity verified.
5. DOCUMENT SET & PREPARATION
Use a one-data-source – multiple-procedures approach: formula, sugar g/100ml, carbonation, net content, manufacturer, origin and product name must remain consistent across self-declaration, food safety, label, C/O and customs filing.
Contract, Commercial Invoice, Packing List, B/L/AWB, Arrival Notice/DO and customs value data.
Formula/ingredients, specification, process, self-declaration, test report, label, nutrition data and shipment food-safety dossier if required.
C/O/origin proof, sugar evidence for VAT/excise analysis, HS-classification record and customs documentation.
| Group | Required files | Used for | Typical owner | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Contract, Invoice, PL, B/L/AWB | Booking, value, customs | Importer + supplier + forwarder | Product/volume/package mismatch | Match label/spec. |
| HS | Formula, RTD statement, CO₂, use instruction, spec | 2202.99.50 vs alternatives | Supplier + importer | Only says “bottled tea” | Lock gas, dilution, milk %, claims. |
| Self-declaration | Form 01 + test ≤12 months + product records | Market/cargo file | Importer | Test and formula versions differ | Freeze formula/test/label versions. |
| Import food safety | Registration + self-declaration + method-specific files | Specialized clearance | Importer | Wrong authority/product group | Check Circular 28/2026 + Decree 15/2018. |
| Label | Original + Vietnamese supplementary/mandatory content + nutrition panel | Clearance/circulation | Manufacturer + importer | Missing sugars/sodium/ingredients/origin | Check Decree 37/2026 + Circular 29/2023. |
| Sugar/tax | Nutrition facts, lab, formula | VAT/excise classification | Supplier + importer | No total-sugar evidence | Cross-check label – lab – formula. |
| Origin | C/O + support data | FTA preference | Exporter + importer | Wrong HS/PSR/description | Pre-check draft C/O. |
6. LEGAL BASIS – SPECIALIZED POLICY MATRIX
| Legal group | Instrument | Issuer | Status/time | Role | Key article/appendix | Review note |
|---|---|---|---|---|---|---|
| Customs | Customs Law 54/2014/QH13 and current implementing/amending rules | National Assembly/Government | Current version at declaration date | Filing, inspection, clearance | Current customs provisions | Do not rely on superseded forms. |
| Import duty | Decree 26/2023/ND-CP as amended | Government | Current MFN schedule, with amendments | MFN: 2202.99.50 30%; 2202.10.90 35% | Appendix II, Chapter 22 | Recheck on filing date. |
| Ordinary duty | Decision 15/2023/QD-TTg | Prime Minister | Effective 15 Jul 2023 | Ordinary-rate schedule/mechanism; 150% of MFN where statutory conditions apply | Article 3 | 2202.99.50 is about 45% where this mechanism applies. |
| MOIT food-safety list | Circular 28/2026/TT-BCT | Ministry of Industry and Trade | Issued 1 Jun 2026; effective 17 Jul 2026 | HS list for state food-safety inspection under MOIT | Appendix includes 2202.99.50, 2202.99.90, 2202.10.90… | Clause 1 Article 2 and Appendix 2 of Decision 1182/QD-BCT ceased to apply from 17 Jul 2026. Do not state that Circular 11/2022 was replaced unless separately supported. |
| Food safety/declaration | Decree 15/2018/ND-CP as amended/supplemented by Decree 155/2018/ND-CP | Government | Continues during Resolution 15/2026 suspension of Decree 46/2026 | Self-declaration; exemptions; reduced/normal/strict inspection | Articles 4–5, 13 and 16–19 of Decree 15/2018 plus relevant amendments | Conventional processed prepackaged RTD tea generally uses self-declaration. |
| 2026 transition | Resolution 15/2026/NQ-CP | Government | 6 Apr 2026 | Suspends Decree 46/2026 and Resolution 66.13/2026; Decree 15/2018 continues during suspension | Arts. 1–2 | Recheck if new food-safety law/decree becomes effective later. |
| Non-alcoholic beverage technical regulation | QCVN 6-2:2010/BYT under Circular 35/2010/TT-BYT | Ministry of Health | Still effective in standards database | Technical requirements for non-alcoholic beverages | Applicable parameters | Useful for testing specification where relevant. |
| Goods labeling | Decree 37/2026/ND-CP | Government | 23 Jan 2026 | Original import label, Vietnamese supplementary/e-label, mandatory food contents | Arts. 40, 42; Appendix I; Arts. 97–98 | Apply to new imports; check transition cases. |
| Nutrition labeling | Circular 29/2023/TT-BYT | Ministry of Health | Effective 15 Feb 2024; from 1 Jan 2026 non-compliant labels may not be newly imported, subject to transition | Energy, protein, carbohydrate, fat, sodium; added-sugar beverages also total sugars | Arts. 1, 5–9 | Review Article 1.2 exemptions where potentially applicable. |
| Excise tax | Law 66/2025/QH15; Decree 360/2025/ND-CP | National Assembly/Government | Law effective 1 Jan 2026 | Defines the sugary-beverage scope and excise-rate schedule | Article 2.1(l) and Article 8 of Law 66/2025; Article 3.4 Decree 360/2025: TCVN 12828:2019, total sugars from the label; importer determines/declares if compliant import label is not yet available | Law/Decree are effective from 1 Jan 2026, but the beverage excise rate starts at 8% from 1 Jan 2027 and 10% from 1 Jan 2028. |
| VAT 2026 | VAT Law 48/2024 as amended by Law 149/2025; Decree 174/2025 | National Assembly/Government | Decree 174 through 31 Dec 2026 | 10%-to-8% reduction mechanism and the express 2026 exclusion | Point b Clause 1 Article 1 and Part II Appendix II of Decree 174/2025 | From 1 Jan–31 Dec 2026, TCVN beverages with total sugars >5g/100ml are not eligible for the 2% VAT reduction; other 10%-VAT goods only get 8% if no exclusion applies. |
| Situation | Legal basis | Potential policy | Authority – high level | Trigger |
|---|---|---|---|---|
| Non-aerated RTD tea 2202.99.50 | Circular 28/2026 + Decree 15/2018 | State food-safety inspection; self-declaration; label | MOIT/assigned body; Customs | In-scope imported food and no exemption. |
| RTD tea within TCVN 12828:2019, total sugars >5g/100ml | Law 66/2025 + Decree 360/2025 + Decree 174/2025 | Decree 174/2025 excludes it from the 2% VAT reduction in 2026 → VAT 10%; excise schedule: 8% from 2027, 10% from 2028 | Tax/Customs | Both TCVN 12828:2019 beverage scope and total sugars >5g/100ml must be met; do not infer from the trade name alone. |
| RTD tea ≤5g sugars/100ml or outside excise category | VAT law + Decree 174/2025 | Potential 8% VAT through end-2026 if no other exclusion | Tax/Customs | Goods otherwise subject to 10% and reduction conditions met. |
| Tea with added sugar | Circular 29/2023/TT-BYT | Nutrition panel including total sugars | Food-safety/market authority | Within Circular 29 scope and not exempt. |
| Tea concentrate requiring dilution | Chapter 21 tariff + applicable food rules | Reclassify 2101.20.*; recalculate tax/policy | Customs + food authority | Not RTD. |
| UHT milk tea | 2202.99.10 + Circular 28/2026 + Decree 15/2018 | Different HS/food-safety/label route | MOIT/food authority; Customs | Milk/UHT character matches the line. |
7. PROCESSING TIME, FEES & DELAY COSTS
Only state time limits that are legally grounded. Under the current Decree 15/2018 import-food-safety procedure, normal inspection: 3 working days; strict inspection: 7 working days from receipt of the prescribed dossier. Actual elapsed time may increase if documents or sampling require supplementation.
| Stage | Action | Timing/condition | Potential cost | Delay risk | Control |
|---|---|---|---|---|---|
| 1. Preparation | Lock formula, RTD, CO₂, sugar, HS, label, self-declaration | Before booking/ETA | Testing/translation/label work | Wrong HS/VAT/excise | Product master. |
| 2. Registration/intake | Prepare/submit food-safety inspection file where required | Before or upon arrival under Decree 15 | Official fees if prescribed | Late specialized file | Circular 28 pre-check. |
| 3. Review | Dossier review under applicable method | Normal: 3 working days | Service/testing cost if any | Storage/DEM/DET | Freeze file version. |
| 4. Supplement/sampling | When requested/strict method | Strict: 7 working days under Decree 15 | Sampling/test/storage | Longer dwell time | Pre-check test/spec. |
| 5. Result | Obtain pass/fail specialized result | After review/testing | Keep specialized fee separate from logistics | Clearance blocked | Track status. |
| 6. Customs | HS, value, VAT, C/O, channel handling | Depends on channel/file | Import duty, VAT, handling | Reassessment/inspection | HS–C/O–sugar–food-safety match. |
| 7. Post-clearance | Label, circulation, retention, change control | Product lifecycle | Label/record cost | Post-audit/recall | Version control. |
8. PRACTICAL E2E WORKFLOW
Lock formula, RTD/dilution, CO₂, tea %, milk %, total sugars, caffeine/claims, packing and origin.
Compare 2202.99.50 with 2202.10.*, 2202.99.10 and 2101.20.*; only then calculate MFN/FTA.
Confirm MOIT list status and inspection method under Decree 15/2018.
Self-declaration where applicable; test, label, nutrition panel, sugar evidence and product spec.
Reconcile Invoice – PL – B/L/AWB – C/O – declaration – test – label – sugar data.
Declare HS/value/origin; process Green/Yellow/Red and any supplements/physical inspection.
Complete food-safety result, import duty, VAT and related obligations, then cargo release.
Complete Vietnamese labeling under Decree 37/2026 + Circular 29/2023; retain files and manage reformulation.
9. FAQ – FREQUENTLY ASKED QUESTIONS
1. What HS code is commonly reviewed for bottled tea?
2202.99.50 is the main reference for non-aerated RTD beverages without dilution, provided no more specific line applies.
2. Does sparkling tea remain 2202.99.50?
Not automatically. Carbonation/flavoured-water character can trigger review of 2202.10.* or another appropriate line.
3. Can bottled tea concentrate use 2202.99.50?
Usually not under the RTD logic if dilution is required. Review 2101.20.* or other lines based on concentration and intended use.
4. Is bottled milk tea classified the same as green tea RTD?
Not necessarily. A flavoured UHT milk-based beverage may fall under 2202.99.10 if the legal description fits.
5. Does bottled tea require self-declaration?
Conventional processed prepackaged RTD tea generally falls under Article 4 Decree 15/2018 unless it belongs to a registration category or exemption.
6. What does the self-declaration dossier include?
Article 5 requires Form 01 and a food-safety test report within 12 months from a designated or ISO 17025-recognized laboratory, with consistent product records.
7. Is bottled tea subject to state food-safety inspection at import?
If the actual HS is listed in Circular 28/2026 and no Decree 15 exemption applies, the applicable import inspection method must be followed.
8. Is 8% excise tax already payable in 2026 for tea over 5g sugars/100ml?
No. Law 66/2025 and Decree 360/2025 define the sugary-beverage category, but the 8% excise rate starts on 1 Jan 2027; the 2028 rate is 10%. Separately, Decree 174/2025 already excludes TCVN 12828:2019 beverages with total sugars >5g/100ml from the 2% VAT reduction during 2026.
9. Is 2026 VAT 8% or 10% for bottled tea?
If the SKU is a TCVN 12828:2019 beverage with total sugars >5g/100ml, Appendix II to Decree 174/2025 excludes it from the reduction, so 2026 VAT remains 10%. If it is outside that case and all other exclusions, goods otherwise subject to 10% may be reduced to 8% through 31 Dec 2026.
10. Is nutrition labeling mandatory in 2026?
Circular 29/2023 sets the 1 Jan 2026 compliance milestone for in-scope new imports; added-sugar beverages must pay particular attention to total-sugars declaration. Article 1.2 exemptions must be checked where relevant.
11. Can China-origin bottled tea get 0% import duty?
For 2202.99.50, the ACFTA 2022–2027 schedule shows 0%, subject to valid Form E/origin rules and documentation.
12. Does lowering the sugar formula require compliance review?
Yes. Total sugars, ingredients and claims can change label, testing, self-declaration, VAT/excise treatment and potentially HS; use formal change control.
10. REQUIRED OUTPUT & POST-CLEARANCE OBLIGATIONS
HS rationale, formula, RTD/no-dilution, carbonation, spec and sugar evidence.
Invoice, PL, B/L/AWB, lot/batch, Arrival Notice/DO and value support.
Self-declaration, test result, food-safety inspection file/result and exemption/reduced-inspection evidence if used.
Declaration, MFN/FTA, C/O, VAT, total-sugar evidence and excise treatment where relevant.
Original label, Vietnamese supplementary/mandatory content and nutrition facts under Decree 37/2026 + Circular 29/2023.
Track supplier, formula, sugar, CO₂, milk %, claims, origin and packaging; reassess after changes.
11. TGIMEX SOLUTIONS
For bottled tea, the three data points to lock earliest are HS branch – total sugars – food-safety status. If these remain open, both landed-cost quotes and clearance timelines are unstable.
Review formula, RTD/gas, sugar g/100ml, HS, VAT/excise, Circular 28/2026 and origin before shipment.
Reconcile self-declaration, test, nutrition panel and label with Invoice/PL/C/O and actual SKU data.
Track food-safety inspection – declaration – customs channel – tax – cargo release to reduce document-driven storage/DEM/DET.
Useful pre-ETA data: formula/ingredients, product spec, label artwork, total sugars g/100ml, CO₂ status, use instruction, origin and draft Invoice/PL/C/O.
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