FROZEN HOTPOT MEAT–SEAFOOD BALLS IMPORT PROCEDURE IN VIETNAM
“Frozen hotpot balls” is a trade description, not one HS code. Fish balls have a dedicated 1604.20.30 branch; shrimp balls 1605.29.20; squid balls follow prepared-squid branches; chicken, pork and beef balls branch under heading 16.02 by species and formula. For mixed meat–seafood balls, animal-ingredient ratios can change the heading, duty and veterinary treatment.
The main control points are BOM %, species, processing and frozen state. Lock them before shipment so C/O, Veterinary/Health Certificate, food-safety dossier and customs declaration follow one consistent product logic.
Operational reference for import-export businesses · Updated through 10 Sep 2026.
1. QUICK SUMMARY & SCOPE
Fish, shrimp, squid, chicken/pork/beef or mixed balls, normally formed/prepared and frozen.
No universal code; branch by predominant animal ingredient, species and preparation.
Meat branches follow terrestrial-animal quarantine; frozen fish/seafood branches follow aquatic quarantine. Food-safety control also applies.
Ordinary processed prepacked food requires Decree 15 self-declaration review, Vietnamese supplementary labeling and consistent storage temperature.
Fish ball 1604.20.30 reference MFN 30%; shrimp ball 1605.29.20 30%; prepared squid 1605.54 25%; meat balls branch by species.
Lock BOM %, species, process, frozen state, exporting country and establishment. For frozen animal products subject to quarantine, plan for border-area holding while awaiting a compliant quarantine result.
2. KEY TERMS & WHY THE PROCEDURE MATTERS
Quantified meat/fish/shrimp/squid/starch/oil/water/seasoning/additive composition; critical for Chapter 16 Note 2.
For qualifying mixed Chapter 16 preparations, the heading follows the animal component(s) predominating by weight.
Circular 01/2026 applies to terrestrial meat/animal products; commercial cooked meat balls are not automatically exempt.
Circular 03/2026 Appendix I includes aquatic animal products in fresh, chilled or frozen form.
Official veterinary/health certificate from the exporting competent authority where required by the applicable quarantine pathway.
Temperature conditions from origin warehouse through transport, border and destination storage; they must match the product specification and label.
3. PRODUCT CLASSIFICATION & DETAILED IDENTIFICATION
DETAILED PRODUCT CLASSIFICATION
| Product/scenario | What to check | Example | Evidence | Potential policy | Dossier | Application note |
|---|---|---|---|---|---|---|
| Frozen fish ball | Fish is the main animal component; formed prepared/preserved product | Fish ball | BOM %, species, process, photos, package | Review 1604.20.30; the 2026 tariff further expands to 1604.20.30.10 (airtight containers) / 1604.20.30.90 (other); aquatic AQ due frozen state; FS | Formula, process, VHC/AQ, FS, label | 1604.20.30 is the Fish ball branch; crosswalk to .10/.90 by packaging where the detailed tariff/FTA schedule uses those lines. |
| Frozen shrimp ball | Shrimp/prawn predominates among animal ingredients | Shrimp ball | BOM %, species, package, process | Review 1605.29.20 – Shrimp ball; aquatic AQ + FS | Formula, VHC/AQ, FS, label | Distinguish from shrimp paste or a non-ball product. |
| Frozen squid/mollusc ball | Squid/cuttlefish or another mollusc predominates | Squid ball | BOM %, species, process, retail package | Review 1605.54.10/.90 for squid by packaging; other molluscs use the relevant subheading | VHC/AQ, formula, package, FS | Do not use the shrimp-ball code where squid predominates. |
| Chicken/poultry ball | Prepared chicken/poultry predominates | Chicken ball | BOM %, species, heat process, frozen spec | Review 1602.32.90 where appropriate; terrestrial AQ + FS | VHC, establishment, formula, process, FS | Do not default to 1602.10 because the meat is finely minced. |
| Pork / beef ball | Pork or bovine meat predominates | Pork ball, beef ball | BOM %, species, package, process | Pork: review 1602.49.91/.99; bovine: 1602.50.10/.90; terrestrial AQ + FS | VHC, establishment, formula, package | Airtight packaging is a later branch, not the primary species decision. |
| Mixed meat–fish–seafood ball | At least two animal groups; total listed animal ingredients >20% | Pork + fish; fish + shrimp | Full BOM %, process, intended use | Apply Chapter 16 Note 2: heading follows predominant animal component(s); veterinary pathway requires separate review | Full formula + veterinary/health documents | HS predominance does not itself erase specialized-control relevance of another animal ingredient. |
| Animal ingredients ≤20% / different essential nature | Listed animal ingredients do not exceed 20%, or product is mainly starch/cheese/vegetable | Imitation/starch/cheese-filled ball | BOM %, cross-section, process | Do not automatically use Chapter 16; review Chapters 19/21/04 or another heading | Formula, catalogue, label | Exclude Note 2 exceptions for 19.02 and 21.03/21.04. |
4. HS CODE – TAX – C/O
The classification anchor is Chapter 16 Notes 1–2 and the 1602.10 Subheading Note. Preparations with more than 20% by weight of listed animal ingredients may fall in Chapter 16; mixed preparations are classified according to the animal component(s) predominating by weight. “Frozen hotpot ball” itself is not an HS conclusion.
Separate meat, fish, shrimp and squid/mollusc balls by BOM and species.
The >20% threshold and predominance rule are central for mixed products.
Reference: fish/shrimp balls 30%; squid preparations 25%; chicken/pork 22%; bovine 35%.
Processed meat/seafood balls should be reviewed under Decree 174/2025 for 8% where an otherwise-10% product is eligible.
ACFTA/ATIGA/RCEP/VKFTA/AJCEP/VJEPA/CPTPP/EVFTA etc. differ by heading and PSR.
Do not use a 0% FTA line or special-preferential statistical code as a substitute for base HS classification.
PROPOSED HS – TAX – C/O
| Reference HS | Description/group | Classification basis | Conditions | Ordinary duty | MFN duty | VAT | C/O/FTA review | Evidence |
|---|---|---|---|---|---|---|---|---|
| 1604.20.30 2026 tariff: 1604.20.30.10/.90 |
Fish ball; .10 = in airtight containers, .90 = other in the 2026 tariff schedule | Dedicated Vietnam tariff description | Fish predominates; prepared/preserved fish ball; lock packaging before detailed FTA/tariff comparison | 45% if ordinary-duty mechanism applies | 30% | 10% base; review 8% in 2026 if eligible | FTA by origin | BOM %, species, process, package |
| 1605.29.20 | Shrimp ball | Dedicated prepared/preserved shrimp branch | Shrimp predominates; correct ball form | 45% if ordinary-duty mechanism applies | 30% | 10% base; review 8% if eligible | FTA by origin + 1605.29 PSR | BOM, species, package, process |
| 1605.54.10/.90 | Prepared cuttlefish/squid – airtight retail / other | 1605 + species + package | Squid predominates and product is prepared/preserved | 37.5% if ordinary-duty mechanism applies | 25% | 10% base; review 8% if eligible | FTA by origin | BOM, species, package proof |
| 1602.32.90 | Prepared Gallus domesticus – other | 1602 by species | Chicken predominates; not curry .10 or 1602.10 homogenised preparation | 33% if ordinary-duty mechanism applies | 22% | 10% base; review 8% if eligible | FTA by origin | BOM, species, process, VHC |
| 1602.49.91/.99 | Other prepared pork | 1602.49 + package | Pork predominates; not another ham/shoulder/cold-cut branch | 33% if ordinary-duty mechanism applies | 22% | 10% base; review 8% if eligible | FTA by origin | BOM, process, package, VHC |
| 1602.50.10/.90 | Prepared bovine meat | 1602.50 + package | Bovine meat predominates | 52.5% if ordinary-duty mechanism applies | 35% | 10% base; review 8% if eligible | FTA by origin | BOM, species, process, VHC |
| Other HS – mixed/≤20% | Mixed preparation or starch/cheese/vegetable-heavy product | Chapter 16 Note 2 + actual nature | Insufficient facts to lock a heading | By final HS | By final HS | By final HS | FTA by final HS | Full BOM %, process, photos, use |
C/O / FTA REVIEW BY IMPORT ROUTE
| Route/origin | FTA | Origin proof | Special preferential rate if supported | Conditions | Dossier | Application note |
|---|---|---|---|---|---|---|
| China | ACFTA / RCEP | Form E / RCEP proof | Check the 2026 schedule at final HS | Meet PSR/document/transport rules | C/O, Invoice, B/L, BOM, HS crosswalk | 1602, 1604 and 1605 may have different PSRs/schedules. |
| ASEAN | ATIGA | Form D / ATIGA proof | Check 2026 schedule | Meet origin rules | C/O + commercial docs | Shipping country does not replace origin proof. |
| Korea / Japan | AKFTA/VKFTA/RCEP; AJCEP/VJEPA/CPTPP/RCEP | Relevant origin proof | Check 2026 schedule | Meet selected FTA PSR | Origin dossier + BOM | Mixed balls require careful CC/CTH/RVC and animal-material review. |
| Australia / New Zealand | AANZFTA / CPTPP / RCEP | Relevant proof | Check 2026 schedule | Meet PSR/transport rules | Origin + shipping docs | Lock final HS, then choose the eligible agreement. |
| EU / UK | EVFTA / UKVFTA | EUR.1 / permitted origin statement | Check 2026 schedule | Meet PSR/certification | Origin + Invoice/B/L + BOM | Do not infer 0% from a Made in EU/UK label alone. |
5. DOSSIER & PREPARATION
Manage frozen hotpot balls under a “one source of truth – multiple procedures” model. Animal ingredient %, species, heat/process, frozen state, manufacturer/establishment, exporting country and package must align across HS, terrestrial/aquatic quarantine, food safety, VHC, C/O, label and customs.
Invoice, Packing List, B/L/AWB, Contract/PO, C/O, reefer instructions and temperature records where relevant.
BOM %, species, process, heat parameters, frozen storage, package, shelf life, photos, establishment, VHC/Health Certificate, food-safety test.
Quarantine dossier under Circular 01/2026 or 03/2026 as applicable; FS inspection; self-declaration/test; labels; customs dossier.
OPERATIONAL DOSSIER CHECKLIST
| Dossier group | Documents | Used for | Owner | Common errors | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice; PL; B/L/AWB; Contract/PO | Customs/value/shipment match | Importer + supplier + forwarder | Generic hotpot-ball description; weight/package/origin mismatch | Lock SKU, lot, net/gross, reefer temperature and animal-source description before SI. |
| Technical/HS | Full BOM %; species; process; photos; package | HS classification/explanation | Manufacturer | No quantitative formula | Obtain percentages or equivalent evidence of predominance. |
| Terrestrial AQ – meat | VHC; establishment/country data; Circular 01/2026 file | Chicken/pork/beef balls | Supplier + competent authority + importer | Wrong plant/certificate/SKU; cooked=exempt assumption | Review approval/certificate/process/risk group pre-shipment. |
| Aquatic AQ – fish/seafood | Export-country certificate; registration/declaration; transport docs | Frozen fish/shrimp/squid balls | Supplier + competent authority + importer | AQ omitted because cooked; species/VHC mismatch | Circular 03/2026 App.I includes frozen aquatic products. |
| Food safety/circulation | Import FS; self-declaration/test; label | Food safety + Vietnam market | Importer + lab + manufacturer | Test not matching SKU/formula; missing allergen/storage | Cross-check formula, manufacturer, origin, allergen and temperature. |
| C/O/FTA | Origin proof + supporting BOM | Preferential duty | Exporter + importer | C/O HS follows fish while BOM predominance is pork/shrimp | Crosswalk HS + PSR + BOM + invoice + route. |
6. LEGAL BASIS – SPECIALIZED POLICY MATRIX
LEGAL BASIS TO REVIEW
| Instrument group | Instrument | Issuer | Effective time | Role | Key article/appendix | Review note |
|---|---|---|---|---|---|---|
| HS – current nomenclature | Circular 31/2022/TT-BTC – Chapter 16 | Ministry of Finance | Effective 1 Dec 2022 | Vietnam import-export nomenclature/classification notes | Chapter 16 Notes 1–2; 1602.10 Subheading Note | >20% animal-content/predominance rule; 1602.10 is not the ordinary meat-ball code. |
| Specialized HS list | Circular 01/2024/TT-BNNPTNT – Appendix II | Former MARD | Effective 20 Mar 2024; currently partially expired | HS mapping for AQ/FS controls | Row 235: 1602.32.90; rows 243–246 pork/bovine; row 738: 1604.20.30; row 750: 1605.29.20; rows 758–759: 1605.54 | Relevant animal-food rows show quarantine and food-safety control; read with current Circular 01/2026 or 03/2026. |
| Terrestrial AQ – CURRENT | Circular 01/2026/TT-BNNMT, amended by Circular 22/2026/TT-BNNMT; consolidated text 67/VBHN-BNNMT | Ministry of Agriculture and Environment | Circular 01 effective 1 Jan 2026; Circular 22 effective 19 May 2026; consolidated text issued 12 Jun 2026 | Current terrestrial animal/product quarantine list and procedure | Arts.2, 3, 10, 12; Apps.I, II, IV, XII | Art.2(5) classifies animal products in frozen form as high-risk. Appendix XII lists frozen/chilled/preliminarily processed meat and meat products in the high-risk group; processed meat products outside that frozen/chilled/preliminary form are listed low-risk. For this article’s frozen meat balls, do not classify them low-risk merely because cooked. |
| Terrestrial AQ – OLD | Circulars 25/2016, 35/2018, 09/2022, 04/2024, 28/2025 | Former authorities | Replaced from 1 Jan 2026 | Historical/transition only | Arts.29–30 Circular 01/2026 | Do not operate 2026 shipments under the old regime. |
| Aquatic AQ – NEW | Circular 03/2026/TT-BNNMT | Ministry of Agriculture and Environment | Effective 13 Jan 2026 | Current aquatic animal/product quarantine | Art.2(7–8); Arts.3, 11–12; Apps.I–II | Appendix I II.1 includes aquatic animal products in fresh, chilled or frozen form. |
| Aquatic AQ – OLD | Circular 26/2016/TT-BNNPTNT and amendments | Former MARD | Replaced from 13 Jan 2026 | Historical/transition only | Arts.23–24 Circular 03/2026 | Do not use the old regime as the primary 2026 basis. |
| Food safety – CURRENT | Decree 15/2018/NĐ-CP + Resolution 15/2026/NQ-CP | Government | Resolution effective 6 Apr 2026 | Suspends Decree 46/2026 and Resolution 66.13/2026; Decree 15 framework continues | Arts.4–5; 13–19 | Processed-prepacked food generally requires self-declaration review. A FS exception does not itself remove veterinary quarantine. |
| Food-safety procedure 2026 | Circular 22/2026/TT-BNNMT + Decision 1908/QĐ-BNNMT | Ministry of Agriculture and Environment | Procedures apply from 1 Sep 2026 | Current authority/time for import FS inspection | Normal 3 working days; tightened 7 working days | Used for timeline. |
| MFN duty | Decree 26/2023/NĐ-CP | Government | Effective 15 Jul 2023; read with current amendments | Preferential import tariff | 1604.20.30 30%; 1605.29.20 30%; 1605.54 25%; 1602.32.90/1602.49 22%; 1602.50 35% | Apply only the final branch rate. |
| Ordinary duty | Decision 15/2023/QĐ-TTg | Prime Minister | Effective 15 Jul 2023 | Ordinary import-duty mechanism | Check statutory conditions | 45%, 37.5%, 33%, 52.5% are references under 150%-of-MFN mechanism where applicable. |
| VAT – 2026 | VAT Law 48/2024/QH15 amended by 149/2025/QH15; Decree 174/2025/NĐ-CP | National Assembly / Government | Amendment from 1 Jan 2026; 2-point reduction through 31 Dec 2026 | VAT for processed food | Review Decree 174 Art.1 and exclusions | Do not apply the unprocessed-animal non-taxable rule; review 8% where otherwise 10% and eligible. |
| Labeling | Decree 43/2017/NĐ-CP amended by 111/2021/NĐ-CP | Government | Decree 111 effective 15 Feb 2022 | Imported-goods/Vietnamese supplementary label | Mandatory content + food rules | Check name, ingredients, allergens, origin, storage and dates. |
POLICY MATRIX BY GOODS SCENARIO
| Goods scenario | Legal basis | Potential policy | Authority | Trigger |
|---|---|---|---|---|
| Frozen fish ball – fish predominates | 1604.20.30 + Circular 03/2026 + Circular 01/2024 | Aquatic AQ + FS; self-declaration/label for circulation | Customs + aquatic AQ + FS | BOM/process supports fish ball; frozen state. |
| Frozen shrimp ball – shrimp predominates | 1605.29.20 + Circular 03/2026 | Aquatic AQ + FS | Customs + aquatic AQ + FS | Shrimp predominates; ball form; frozen. |
| Frozen squid/mollusc ball | 1605.54 or relevant mollusc subheading + Circular 03/2026 | Aquatic AQ + FS | Customs + aquatic AQ + FS | Lock species + package + frozen state. |
| Frozen chicken/pork/beef ball | 1602 species branch + Circular 01/2026 | Terrestrial AQ + FS; risk/sampling by process/App.XII | Customs + terrestrial AQ + FS | Terrestrial meat; commercial import; no applicable exemption. |
| Mixed meat + fish/seafood | Chapter 16 Note 2 + Circulars 01/2026 and 03/2026 | HS by predominance; veterinary pathway reviewed separately due mixed animal origins | Customs + veterinary/FS authority | Full BOM %, species, process, frozen state; lock treatment pre-shipment. |
| Animal ingredients ≤20% / exception | Chapter 16 Note 2 + competing heading | May fall outside Chapter 16; specialized control follows final nature | Customs + relevant authority | Does not meet Chapter 16 threshold or falls under Note 2 exceptions. |
7. PROCESSING TIME, FEES & RISK COSTS
OPERATIONAL TIMELINE
| Step/operation | Sourced time | Conditions | Fees | Logistics risk |
|---|---|---|---|---|
| Lock BOM/HS/control before shipment | Variable; no fixed statutory period | Full formula %, species, process, frozen temp, country, establishment | Supplier-document/test cost if any | Wrong meat/fish/shrimp/squid branch may force VHC/C/O rework. |
| Terrestrial AQ – pre-import registration | 4 working days from complete valid dossier | Terrestrial product subject to AQ | Current veterinary/testing fees | Country/plant/VHC may block shipment. |
| Terrestrial AQ – border declaration | 1 working day to confirm complete valid declaration | Guidance/dossier available | Current veterinary fees | Late declaration affects inspection/free time. |
| Terrestrial AQ – quarantine/certificate | Certificate within 5 working days from quarantine where dossier, actual condition and required test results comply | Frozen meat product: Art.2(5) + Appendix XII high-risk route; sampling under Appendix XII | Quarantine/testing fees may apply | Key blocker: high-risk frozen animal products must be held in the border area until a compliant quarantine result; allow plug-in/cold-storage/free-time buffer. |
| Aquatic AQ – pre-import registration | 4 working days from complete valid dossier | Frozen aquatic product subject to AQ | AQ/testing fee by case | VHC/species/country mismatch delays approval. |
| Aquatic AQ – declaration/certificate | Declaration 1 working day; no-sample certificate 1 day; sampled lot within 5 days if compliant | Arts.11–12 Circular 03/2026 | Testing may apply | Key blocker: Circular 03/2026 specifically requires frozen aquatic animal products to remain at the import border until the quarantine result is satisfactory; allow reefer/plug-in/storage buffer. |
| Food safety – normal | 3 working days | Normal inspection method | Inspection/testing fee by case | Late FS dossier creates storage cost. |
| Food safety – tightened | 7 working days | Tightened inspection | Testing may apply | Higher reefer/storage/DEM-DET risk. |
| Customs → delivery → circulation | Depends on channel and AQ/FS results | HS/tax/C/O/AQ/FS complete | Duty, VAT, local charges | Clearance does not replace labels, self-declaration and cold-chain obligations. |
8. PRACTICAL E2E WORKFLOW
Obtain full BOM %, species, process, cooked/raw status, frozen temperature, package, country and establishment.
Apply Chapter 16 Note 2: fish→1604, shrimp/mollusc→1605, terrestrial meat→1602; mixed by predominance; exclude ≤20%/exceptions.
Meat branch: Circular 01/2026; frozen fish/seafood: Circular 03/2026; all food SKUs: FS/Decree 15.
Lock VHC/Health Certificate, country/establishment, applicable AQ file, FS, self-declaration/test and labels.
Cross-check Invoice – PL – B/L/AWB – C/O – BOM – spec – VHC – FS – label – declaration description.
Declare SKU-level HS; support the branch with BOM %, Chapter 16 Note, species, process, package and regulatory documents.
Coordinate terrestrial/aquatic AQ, FS, sampling if any, tax and reefer/cold-store schedule.
Maintain cold chain; apply supplementary label; retain BOM revision, VHC, AQ, FS, C/O and customs records; reassess changes.
9. FAQ – FREQUENTLY ASKED QUESTIONS
1. Is there one HS code for “hotpot balls”?
No. Separate fish, shrimp, squid/mollusc, chicken/pork/beef or mixed balls using BOM %, species and process.
2. Reference HS for frozen fish balls?
Where genuinely a prepared fish ball and fish predominates, review 1604.20.30 – Fish ball; reference MFN 30%.
3. Can shrimp balls use the fish-ball code?
No. Vietnam has a dedicated 1605.29.20 – Shrimp ball branch; reference MFN 30%.
4. Is there a dedicated “squid ball” code?
Not by that wording. If squid predominates and the product is prepared/preserved, review 1605.54.10/.90 by packaging.
5. Does finely minced meat ball use 1602.10?
Usually no. 1602.10 is narrowly defined for homogenised infant/young-child or dietetic food in retail containers ≤250 g.
6. How is a mixed meat–fish ball classified?
For a qualifying Chapter 16 preparation with two or more animal groups, Note 2 points to the heading of the animal component(s) predominating by weight. Full BOM % is required.
7. Do cooked frozen fish/shrimp/squid balls require aquatic quarantine?
Yes. Circular 03/2026 Appendix I II.1 includes aquatic animal products in frozen form. Article 12 also specifically requires frozen aquatic products to remain at the import border until the quarantine result is satisfactory.
8. Are cooked but still frozen chicken/pork/beef balls high-risk for quarantine?
Under consolidated text 67/VBHN-BNNMT, Art.2(5) treats animal products in frozen form as high-risk; Appendix XII also lists frozen meat products in that group. For frozen meat balls, do not use the low-risk processed-product line merely because they are cooked. Non-frozen/chilled shelf-stable processed products require a separate review.
9. Mixed meat + seafood: terrestrial or aquatic quarantine?
Do not decide solely from HS. HS may follow predominance, while mixed animal origins can create separate veterinary considerations. Lock BOM, VHC and treatment before shipment.
10. VAT rate?
These are prepared foods, so do not use the unprocessed-animal non-taxable logic. Review final HS; in 2026 eligible otherwise-10% goods may receive the 8% reduction under Decree 174/2025.
11. Does China Form E guarantee 0%?
No. Fish, shrimp, squid and meat balls have different headings/PSRs. Final HS, origin criterion and 2026 ACFTA line must be checked.
12. Minimum pre-ETA data?
Full BOM %, species, cooked/raw/heat process, frozen temperature, manufacturer/establishment, country, VHC format, package, HS branch, FS/test, C/O and consistent Invoice–PL–B/L descriptions.
10. OUTPUTS & POST-CLEARANCE OBLIGATIONS
Full BOM %, Note 2 analysis, species, process, photos, package, frozen state and HS rationale.
Invoice, PL, B/L/AWB, Contract/PO, lot, weight, origin, reefer temperature and manufacturer aligned.
Terrestrial or aquatic AQ by branch; VHC/Health Certificate; FS; self-declaration/test; country/establishment evidence where applicable.
Declaration, HS rationale, MFN/ordinary duty, VAT, C/O/FTA and tax evidence.
Original/Vietnamese label, ingredients, allergens, origin, manufacturer, storage temperature, use and dates.
Manage recipe/BOM revisions, supplier, establishment, country, species, package and cold-chain changes.
11. TGIMEX SOLUTIONS
For frozen hotpot balls, the hardest task is locking BOM predominance + the correct veterinary pathway before the supplier issues certificates and C/O.
Lock BOM %, HS branch, duty/VAT/FTA, terrestrial/aquatic AQ, VHC and FS before shipment.
Cross-check formula, species, establishment, country, process, package, C/O, VHC, FS, tests and labels.
Plan quarantine/sampling, FS, reefer/cold storage, customs, tax, D/O and delivery.
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