Brandy / Cognac carries several compliance layers at once. A vague goods description, weak evidence of distillation from grape wine/grape marc, incorrect ABV, origin mismatch or an unsuitable alcohol-distribution licence can lead to the wrong HS code, wrong tax, import-condition issues, or delays in stamps and food-safety clearance.

This guide provides an end-to-end framework for commercially imported finished brandy/cognac, covering HS classification, alcohol distribution licensing, self-declaration/import food-safety controls, alcoholic-beverage QCVN, electronic stamps, labels, excise tax, VAT and origin before ETA.

Operational reference for import-export businesses · Updated 11 September 2026.

1. QUICK SUMMARY & SCOPE

PRODUCT

Spirits / alcoholic beverage

Brandy is a spirit obtained by distilling grape wine or grape marc. Cognac is a protected origin/type designation; the word itself does not replace classification evidence.

Branches to review

Primary branch 2208.20.50 for brandy. Exclude 2208.20.90, 2208.70, 2208.90 and heading 2204 when the actual product differs from brandy.

LICENCE

Specialized control

For commercial finished alcohol at 5.5% ABV or above, review a valid Alcohol Distribution Licence and the current import conditions, plus food safety, labels and stamps.

MARKET

Food safety · labels · stamps

Review self-declaration under Decree 15/2018 in the current transition, state food-safety inspection, QCVN 6-3:2010/BYT, Vietnamese supplementary labels and imported-liquor e-stamps. Alcoholic beverages are outside the mandatory nutrition-labelling scope of Circular 29/2023/TT-BYT; voluntary nutrition labelling must follow that Circular.

TAX

2026 landed cost

For 2208.20.50: MFN 45%; VAT 10%. If ABV is at least 20%, 2026 excise tax is 65%. EVFTA may be 6% if origin conditions are met.

BLOCKERS

Data to lock

Spirit type, distillation basis, grape/grape-marc origin, ABV, bottle size, origin, proof of origin, licence, product test/self-declaration, label and stamp plan must align before ETA.

Scope: Focused on finished bottled brandy/cognac imported commercially for distribution in Vietnam. Do not automatically apply to fortified wine, liqueur, other compounded spirits, semi-finished alcohol, duty-free goods, gifts or samples.

Warning: The word “Cognac” on the label is not, by itself, sufficient to conclude HS 2208.20.50 or EVFTA eligibility. Verify technical nature, producer, origin and valid origin/GI documentation where relevant.

2. KEY TERMS & WHY THE PROCEDURE MATTERS

ABV

Alcohol by Volume

The alcohol strength by volume. It drives excise-tax grouping and the RT30/RD30 stamp threshold, and must match the label, COA/specification and customs data.

SCT

Special Consumption Tax

Excise tax applicable to alcohol. From 1 Jan 2026: alcohol at 20% ABV or above is 65%; below 20% is 35% under Law 66/2025/QH15.

LICENCE

Alcohol Distribution Licence

An enterprise holding an Alcohol Distribution Licence may import alcohol under Article 30 of Decree 105/2017; validity and enterprise details should be checked before shipment.

FSA

Food-safety compliance

Covers product dossier, self-declaration where applicable, imported-food state inspection, QCVN testing and post-clearance audit exposure.

STAMP

Imported-liquor e-stamp

Imported alcohol for circulation must be reviewed for stamp obligations. In 2026, RT30 applies to alcohol at/above 30 degrees and RD30 below 30 degrees.

C/O

Proof of origin

Supports FTA preference. For Cognac from France/EU, EVFTA is particularly material; an invalid origin proof can return the shipment to MFN 45%.

Why this matters: Brandy/Cognac sits at the intersection of alcohol trading rules, food safety, import duty, excise tax, VAT, stamps and labelling. One ABV or origin mismatch can affect several compliance layers simultaneously.

Remember: Do not treat “foreign liquor”, “Cognac” or ageing grades such as XO/VSOP as legal classification conclusions. The file should state the spirit type, distillation material, ABV, package size, producer and origin.

3. DETAILED PRODUCT CLASSIFICATION & IDENTIFICATION

Before selecting an HS code, review at least the original label, specification/COA, composition, distillation-process description, ABV, bottle size, country of production and origin proof. For Cognac, also control the basis for using the origin/GI name in commercial and labelling documents.

DETAILED PRODUCT CLASSIFICATION TABLE

Product/situation	Identification signs to check	Examples/type/function	Evidence	Possible policy	Documents to cross-check	Application note
Standard Brandy/Cognac	Spirit distilled from grape wine or grape marc; finished beverage	Brandy, Cognac VS/VSOP/XO	Label, spec, COA, process/origin statement	2208.20.50; alcohol licence; food safety; stamp; SCT	Invoice, PL, B/L, C/O, test, self-declaration, licence	Main scope
Other grape spirit, not brandy	Same grape-wine/grape-marc distillation family but not evidenced as brandy	Other grape spirit	Spec, process, manufacturer declaration	Potential 2208.20.90	Technical and commercial dossier	Do not force 2208.20.50 merely because grape-based
Liqueur / sweetened-flavoured spirit	Sugar/flavour/ingredients give the finished product liqueur character	Brandy-based liqueur	Formula, sugar, flavour, label	Potential 2208.70.10/90	Formula, COA, label, classification evidence	Brandy as a base does not make the finished product brandy
Wine / fortified wine	Product remains wine rather than distilled spirit	Fortified wine	Winemaking process, ABV, label	Potential heading 2204	Spec, process, label	Exclude heading 2204 before heading 2208
Other alcoholic drink / gift set	Mixed formula, RTD or accessories/gift components	Mixed spirit, gift set	BOM, packing, photos	Potential 2208.90 or separate lines	BOM, invoice, packing, valuation	Review description, value and labelling separately

Classification lock: 2208.20.50 is appropriate only where the actual goods are brandy. Trade name, XO/VSOP age grade or the word “Cognac” cannot replace technical/origin evidence.

4. HS CODE – TAX – C/O

Primary branch

2208.20.50 – Brandy, under spirits obtained by distilling grape wine or grape marc.

BASIS

Classify by nature

Review raw material, distillation process, post-distillation formulation, ABV, label, intended use and producer documentation.

MFN

2026 reference

2208.20.50: MFN 45%; ordinary duty reference 67.5% where the ordinary regime applies.

VAT

No 2% reduction

Alcohol is subject to SCT and excluded from Decree 174/2025 VAT reduction; the standard VAT is 10%.

FTA

EVFTA focus

For 2208.20.50, EVFTA schedule: 6% in 2026 and 0% in 2027 if origin requirements are met.

LOCK

Before landed-cost calculation

Finalise HS, ABV, customs value, origin proof, SCT and VAT; never carry an FTA rate from one origin route to another.

PROPOSED HS CODE – TAX – C/O TABLE

Reference HS	Suitable goods	Classification basis	Condition	Ordinary import duty	MFN import duty	VAT	C/O/FTA to review	Evidence
2208.20.50	Brandy	Spirit distilled from grape wine/grape marc and having brandy character	Actual file matches	67.5% reference	45%	10%	EVFTA/UKVFTA/ATIGA/VJEPA etc. by origin	Spec, process, label, COA, C/O
2208.20.90	Other grape-wine/grape-marc spirit	Same distillation family but not brandy	Actual file does not establish brandy	Check current tariff	45% reference	10%	Review by final code	Manufacturer statement, spec, label
2208.70.10/90	Liqueur	Liqueur character from sugar/flavour/formulation	Actual formula matches	Check final code	Check final code	10%	Review by final code	Formula, sugar, flavour, label
2204.xx	Wine/fortified wine	Product remains wine, not distilled spirit	Actual process/product matches heading 2204	Check final code	Check final code	10%	Review by final code	Process, label, ABV, composition
2208.90.xx	Other spirituous beverage	No more specific branch applies	Only after excluding specific subheadings	Check final code	Check final code	10%	Review by final code	Formula, spec, label

SPECIAL-PREFERENTIAL C/O/FTA TABLE BY IMPORT ROUTE

Route/origin	FTA	C/O/proof of origin	Special preferential rate where supported	Conditions	Documents	Application note
France/EU	EVFTA	EUR.1 or EVFTA-permitted proof	2208.20.50: 6% in 2026; 0% in 2027	Origin rule, valid proof and transport conditions	Origin proof, invoice, B/L, producer/origin data	Key route for Cognac
United Kingdom	UKVFTA	UKVFTA proof	Check 2026 schedule for final code	Meet UKVFTA origin rules	Proof, invoice, B/L	Do not apply EVFTA to UK-origin goods
ASEAN	ATIGA	Form D/e-Form D as applicable	Check current ATIGA schedule	Genuine ASEAN origin	C/O, invoice, transport	Compare with MFN
Japan	VJEPA/CPTPP	Relevant proof	Check 2026 schedule; some routes may be highly preferential	Meet chosen agreement rules	Origin proof, invoice, B/L	Do not mix rules across FTAs
Other origin	Relevant FTA or MFN	Agreement-specific	Finalise only after HS/origin verification	Meet applicable FTA conditions	Origin dossier	Without valid proof, use the applicable non-preferential/MFN treatment

C/O checklist: Correct form/proof; WO/RVC/CTH/CTSH criterion as applicable; HS and goods description; exporter/producer; third-party invoice if any; transport route; quantity/weight; country of origin; issue date/validity; authenticity; and consistency with Invoice – Packing List – B/L – label.

5. DOSSIER & PREPARATION METHOD

Commercial dossier

Contract/PO, Commercial Invoice, Packing List, B/L or AWB, Arrival Notice where available, and valuation/payment records where required.

Technical/specialized dossier

Original label, specification/COA, ABV, package size, composition, distillation/origin statement, test report, QCVN/food-safety and stamp records.

Registration & cross-check

Alcohol Distribution Licence, self-declaration where applicable, import food-safety inspection file, C/O/proof, supplementary label and e-stamp data.

Dossier rule: Use one Product Master for product name, brand, spirit type, ABV, volume, manufacturer, origin, lot, ingredient statement and artwork. Commercial, origin, licence, label and food-safety documents must not conflict.

OPERATIONAL DOSSIER CHECKLIST

Dossier group	Documents	Used for	Typical owner	Common error	Pre-ETA check
Trading condition	Valid Alcohol Distribution Licence	Import/circulation condition	Importer	Expired or mismatched licence	Check number, validity and entity details
Technical	Label, COA/spec, ABV, process/origin statement	HS, SCT, food safety, stamp	Manufacturer/importer	Only marketing catalogue available	Obtain official SKU technical file
Food safety	Self-declaration, test, inspection registration where applicable	Import/circulation food safety	Importer/lab	Test mismatches SKU	Align QCVN 6-3 and product file
Stamp & label	Original/supplementary labels, stamp plan/purchase/receipt	Clearance/circulation	Importer/customs ops	Bottle count/ABV/stamp-type mismatch	Reconcile bottle count and 30-degree threshold
Origin	C/O/proof	FTA duty	Exporter/importer	HS/description/origin mismatch	Pre-check before issuance
Customs	Declaration + commercial + specialized docs	Clearance	Broker/importer	HS/value/ABV mismatch	Final cross-check before submission

6. LEGAL BASIS – SPECIALIZED POLICY MATRIX

Table 1 – Legal instruments to review

Area	Instrument	Authority	Effective/application status	Role	Key provision/annex	Review note
Alcohol business	Decree 105/2017/ND-CP; amended by Decree 17/2020/ND-CP	Government	Current with amendments	Import conditions, licence, label, stamp, border gate	Article 30; point b clause 3 amended	Do not reuse the old pre-import conformity-publication wording
Administrative decentralisation	Decree 146/2025/ND-CP	Government	From 1 Jul 2025	Authority/procedure for Alcohol Distribution Licence	Appendix VI	Check current competent authority for licence changes
Food safety	Decree 15/2018/ND-CP; Resolution 15/2026/NQ-CP	Government	Decree 46/2026 suspended; Decree 15 framework continues pending new rules	Self-declaration and imported-food inspection	Articles 4–5 and import inspection chapter	Check transition on declaration date
Imported food inspection list	Circular 28/2026/TT-BCT	MOIT	Effective 17 Jul 2026	MOIT imported-food list	Beverages, alcohol, beer, food-grade alcohol	Replaces Circular 11/2022
Alcoholic beverage QCVN	Circular 45/2010/TT-BYT; QCVN 6-3:2010/BYT	MOH	Current reference	Safety criteria for alcoholic beverages	Relevant chemical/safety annexes	Testing plan must match product type
Electronic stamps	Circular 23/2021/TT-BTC; amended by Circular 31/2025/TT-BTC	MOF	Current 2026 stamp mechanism	Issuance/management/use of imported-liquor e-stamps	RT30/RD30 forms and records	2026 notice: RT30 ≥30°, RD30 <30°
Excise tax	Law 66/2025/QH15	National Assembly	Effective 1 Jan 2026	Alcohol SCT	Article 8/schedule	2026: ≥20° 65%; <20° 35%
VAT	VAT Law 48/2024/QH15; Resolution 204/2025/QH15; Decree 174/2025/ND-CP	National Assembly/Government	2% reduction through 31 Dec 2026 for eligible goods	VAT determination	Appendix II excludes SCT goods	Alcohol remains standard 10%
Labelling	Decree 43/2017/ND-CP; Decree 111/2021/ND-CP	Government	Current	Original/supplementary Vietnamese labels	Mandatory label contents	Keep ABV, quantity, origin and responsible entity consistent
Nutrition labelling	Circular 29/2023/TT-BYT	MOH	Effective 15 Feb 2024	Determines mandatory scope for nutrition information	Clause 2 Article 1	Alcoholic beverages are excluded from the mandatory scope; voluntary nutrition labelling must comply with the Circular
Import duty/EVFTA	Decree 26/2023/ND-CP; Decree 116/2022/ND-CP	Government	Per current tariff/2026 stage	MFN and EVFTA preference	HS 2208.20.50	EVFTA 2026: 6% if qualified

Table 2 – Policy matrix by goods scenario

Goods scenario	Legal basis to review	Possible policy	Authority at high level	Trigger
Finished Brandy/Cognac ≥5.5% for commercial import	D105 + D17 + D146	Alcohol Distribution Licence; international border gate; labels/stamps	Industry & trade authority + Customs	Commercial import of finished alcohol
Shipment subject to state food-safety inspection	D15 + C28/2026	Registration/inspection under current method/exemptions	State food-safety inspection body	HS/product in list and no exemption
ABV ≥30°	C23/2021 + C31/2025	RT30 e-stamp	Customs	Actual ABV ≥30 degrees
ABV ≥20° in 2026	Law 66/2025	65% SCT; no 2% VAT reduction	Tax/Customs	Alcohol subject to SCT
EU-origin Cognac with valid proof	D116/2022 and EVFTA	Special preferential import duty	Customs	Correct HS, origin rule and proof

Legal status as of 11 Sep 2026: Decree 46/2026/ND-CP and Resolution 66.13/2026/NQ-CP are suspended by Resolution 15/2026/NQ-CP. Food-safety processing should follow the current operative framework and be rechecked if new rules take effect before declaration.

7. PROCESSING TIME, FEES & COST RISKS

Actual timing depends on whether the importer already has an Alcohol Distribution Licence, the readiness of test/self-declaration records, food-safety inspection method, origin proof and customs lane. ETA should not be fixed before the critical legal blockers are understood.

REFERENCE OPERATIONAL TIMELINE

Stage	Main work	Timing/variation	Cost to budget	Delay risk	Control point
Preparation	Licence, product master, HS, ABV, origin review	Before shipment planning	Compliance/testing	No import eligibility	Do not book if licence status is unclear
Product file	Testing + self-declaration/food-safety file	Depends on lab/file	Testing fees	Retest/additional data	Align QCVN 6-3 and SKU
Origin	Lock EVFTA/FTA proof	Before final export docs	Origin-document costs if any	Loss of preference	Pre-check C/O
Pre-ETA	Invoice/PL/B/L, label, bottle count, stamp plan	Before arrival	Stamp cost	Count/stamp mismatch	ABV determines RT30/RD30
Specialized inspection	Registration/inspection/sampling where applicable	Varies by method/file	Inspection/lab fees if applicable	Storage while waiting	Prepare dossier early
Customs	Declaration, lane, tax payment	Depends on lane/file	Duty + SCT + VAT + logistics	DEM/DET/storage	Tax calculation and docs align
Post-clearance	Complete/control e-stamps and labels and retain records before market release	According to the circulation plan; e-stamps may be affixed during import procedures or after completion of import procedures, but must be completed before the goods are placed on the market	Warehouse/distribution	Post-audit/recall	Lot traceability

Cost risk: Alcohol taxes form a large share of landed cost. Rejection of EVFTA origin proof can move duty from preferential treatment back toward MFN 45%, while food-safety or stamp delays can add storage, DEM/DET and launch delays.

8. END-TO-END OPERATIONAL PROCESS

STEP 01

Product identification

Collect label/spec/COA, ABV, bottle size, distillation process, producer and origin; confirm true brandy/cognac nature.

STEP 02

HS · tax · C/O

Branch 2208.20.50/90 and exclude liqueur/wine/other spirits; model MFN, EVFTA and SCT/VAT.

STEP 03

Specialized policy review

Check Alcohol Distribution Licence, food safety, border-gate rule, e-stamps, labels and circulation conditions.

STEP 04

Product dossier

Testing, self-declaration where applicable, artwork/label finalisation and shipment food-safety records.

STEP 05

Lock documents before ETA

Cross-check invoice, PL, B/L/AWB, origin proof, bottle count, ABV, volume, origin, licence and stamp data.

STEP 06

Customs declaration & lane

Declare HS/value/taxes; handle green/yellow/red lane and requested documents.

STEP 07

Inspection, tax & release

Complete applicable food-safety controls, taxes and customs procedures; arrange and control e-stamp affixing under the applicable option and ensure it is completed before market release.

STEP 08

Circulation & post-audit

Control label/stamp before sale, retain lot files and manage changes to supplier, formula, ABV, origin or packaging.

Pre-ETA milestone: Licence, product master, HS branch, test/self-declaration, draft origin proof, label artwork and stamp plan should be reviewed before the cargo departs where practicable.

Key blocker: An unsuitable licence, unsupported Cognac origin/nature, invalid C/O, ABV mismatch between label/COA, or incomplete food-safety file can block several workstreams at once.

9. FAQ – FREQUENTLY ASKED QUESTIONS

1) Does each Brandy/Cognac shipment need a separate import licence?

The core requirement is not a shipment-specific import licence but a suitable, valid Alcohol Distribution Licence for commercial finished alcohol and compliance with Article 30 of Decree 105/2017 as amended.

2) Is Brandy/Cognac always HS 2208.20.50?

No. 2208.20.50 is the main branch when the product is genuinely brandy distilled from grape wine/grape marc. Other grape spirit, liqueur or fortified wine may fall elsewhere.

3) What is the 2026 EVFTA rate for EU Cognac under 2208.20.50?

The EVFTA schedule shows 6% for 2026, subject to origin rules and valid proof of origin.

4) What is the 2026 SCT for 40% ABV brandy?

Alcohol at 20% ABV or above is subject to 65% SCT from 1 Jan 2026 under Law 66/2025/QH15.

5) Is 2026 VAT 8% or 10%?

Alcohol is subject to SCT and excluded from the 2% VAT reduction under Decree 174/2025; the standard rate is 10%.

6) Which stamp applies to 40-degree brandy?

Imported alcohol at or above 30 degrees uses the RT30 electronic stamp; below 30 degrees uses RD30 under the current system.

7) Is product self-declaration required?

For finished prepacked alcoholic beverages, review self-declaration under Decree 15/2018 and the actual product file. Do not reuse the old “pre-import conformity publication” wording from the unamended Decree 105 text.

8) Is imported-food safety inspection required?

Review Circular 28/2026/TT-BCT, Decree 15/2018 and the applicable exemptions/methods. Alcoholic beverages are within MOIT food-safety management.

9) Which QCVN applies?

QCVN 6-3:2010/BYT is the national technical regulation for alcoholic beverages; the test panel should match the actual product and declaration dossier.

10) Are samples treated like commercial lots?

Not automatically. Article 31 of Decree 105/2017 still contains historical wording tied to the former conformity/food-safety declaration procedure, while Article 30 was amended by Decree 17/2020 to require compliance with food-safety law. The old “03-litre” wording should therefore not be treated mechanically as a current exemption route; review the actual sample purpose and current food-safety, customs and alcohol-trading rules separately, and never use samples to bypass commercial-import conditions.

11) Can a gift set with glasses/accessories be declared as one line?

Review set composition, valuation and packing. Accessories may require separate description/lines depending on the actual configuration; do not automatically classify the entire set as 2208.20.50.

12) What records should be retained after clearance?

Keep product dossier, licence, self-declaration/test, food-safety records, declaration, tax records, C/O, stamp data, labels/lots and change-control evidence for traceability and post-audit.

10. OUTPUTS & POST-CLEARANCE OBLIGATIONS

Classification/product dossier

Evidence supports why the goods are Brandy/Cognac and the selected HS branch.

Shipment dossier

Invoice, PL, transport, lot, bottle count, volume, ABV and value are consistent.

Specialized dossier

Distribution licence, self-declaration/test, food-safety and stamp records as applicable.

Customs & tax

Declaration, import duty, SCT, VAT and C/O/FTA treatment follow the correct HS and origin.

Labels & circulation

Vietnamese supplementary label and correct e-stamp type/count before market circulation. Alcoholic beverages are not subject to mandatory nutrition labelling under Circular 29/2023/TT-BYT unless nutrition information is provided voluntarily.

CHECK

Retention & post-audit

Maintain SKU/lot dossier and control supplier, ABV, formulation, origin, bottle size and artwork changes.

Required output: Clearance is not the end state. The company should retain an auditable chain proving product legality, tax treatment, origin, food safety, stamps and labels throughout circulation.

Change control: A producer, origin, formula, ABV, volume, packaging or Cognac/Brandy labelling change may trigger a new HS, C/O, testing, label, stamp or declaration review. Do not mechanically reuse old files.

11. SOLUTIONS FROM TGIMEX

TGIMEX can coordinate Brandy/Cognac compliance from product data through customs clearance rather than fixing documents independently after the cargo arrives.

Pre-ETA review

Review product nature, HS, ABV, landed cost, licence, food safety, stamps, labels and origin before the operational deadline.

Compliance dossier control

Cross-check product dossier against Invoice/PL/B/L/C/O, self-declaration/testing and alcohol licence to reduce supplementation risk.

Operations & customs coordination

Align specialized controls, customs declaration, taxes, stamps and cargo-receipt planning with the actual timeline.

The objective is to lock legal conditions and landed cost early, so the shipment does not become an incident-management exercise after ETA.

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