IMPORT PROCEDURE GUIDE FOR WHISKY
Whisky is a high-compliance import product. Errors in HS classification, ABV, alcohol distribution eligibility, food-safety records, electronic alcohol stamps, labeling or C/O can delay clearance and add logistics cost. This guide provides an E2E pre-ETA control map.
Operational reference for import-export businesses · Updated 11 Sep 2026.
1. QUICK SUMMARY & SCOPE
Distilled spirit, usually ≥20% ABV. This guide does not automatically cover vodka, brandy, liqueur, RTD or wine.
2208.30.10 for containers over 5 litres; 2208.30.90 for other whisky.
For commercial whisky imports, review the alcohol distribution licence, imported food-safety inspection under Circular 28/2026/TT-BCT, and conformity declaration under QCVN 6-3:2010/BYT and Circular 14/2026/TT-BKHCN.
Review Vietnamese labeling/supplementary labeling, imported alcohol e-stamps under Circular 93/2026/TT-BTC, and the conformity mark before market circulation.
2026 SCT is 65% for alcohol ≥20% ABV; FTA treatment may change import duty only.
Inconsistent ABV, container size, licence, C/O or food-safety documentation can stop the shipment.
2. KEY TERMS & WHY THEY MATTER
Whisky is not just a product name. A change in ABV, direct-container size, origin or gift-set configuration can change HS, tax and compliance treatment.
HS drives import duty and policy review; whisky splits between 2208.30.10 and 2208.30.90 by direct container size.
ABV directly affects special consumption tax; commercial whisky is generally at or above 20% vol.
Whisky must be reviewed under the self-declaration/imported food-safety regime of Decree 15/2018/ND-CP, which continues during the suspension of Decree 46/2026, and separately for conformity declaration under QCVN 6-3:2010/BYT.
A valid origin document can support special preferential import duty under an FTA but does not replace SCT, VAT or food-safety obligations.
3. DETAILED PRODUCT IDENTIFICATION
| Product/scenario | Key identification point | Example | Evidence | Possible policy | Documents to cross-check | Application note |
|---|---|---|---|---|---|---|
| Retail whisky ≤5L direct container | Whisky name, ABV, bottle size | Scotch/Bourbon/Irish/Japanese whisky | Label, COA/spec, product sheet | HS 2208.30.90; alcohol licence; food safety; stamp; label; conformity declaration/conformity mark | Invoice, PL, B/L, C/O, food-safety dossier | Do not use 2208.30.10 merely because a carton totals >5L. |
| Whisky in direct container >5L | Size of the immediate container | Keg/can/bulk container >5L | Packing spec, photos, invoice | HS 2208.30.10 plus applicable alcohol controls; conformity declaration/conformity mark | Packing spec, contract, transport docs | The direct container is the key, not total shipment volume. |
| Whisky gift set | Accessories included | Bottle + glass + gift box | BOM/set list, photos | Set classification or split declaration may need review | Detailed invoice, PL, images | Do not assume the whole set is always classified solely as whisky. |
| Samples/non-commercial | Purpose, quantity, volume | Tasting/R&D sample | Purpose letter, proforma invoice | Separate treatment may apply but exemptions are not automatic | Purpose file, value, quantity | Do not equate ‘sample’ with blanket exemption. |
4. HS CODE – DUTY – C/O
2208.30.10 for containers over 5 litres; 2208.30.90 for other whisky.
Do not classify from trade name alone.
Reference MFN for HS 2208.30.
Alcohol subject to SCT is not assumed eligible for general VAT reduction.
Check the applicable preferential tariff on declaration date.
Key data before tax calculation.
| Reference HS | Suitable description | Classification basis | Condition | Ordinary duty | MFN | VAT | FTA/C/O review | Evidence |
|---|---|---|---|---|---|---|---|---|
| 2208.30.10 | Whisky in containers over 5 litres | Heading 22.08, whisky subheading | Immediate container >5L | Ref. 67.5% | 45% | 10% | EVFTA/UKVFTA/CPTPP/RCEP/ATIGA etc. | Label, packing spec, C/O, invoice |
| 2208.30.90 | Other whisky | Heading 22.08, whisky subheading | Typical retail bottle ≤5L | Ref. 67.5% | 45% | 10% | By origin route and applicable ROO | Label, COA/spec, C/O, invoice |
| Origin route | FTA | Origin document | Special preferential duty | Conditions | Evidence | Note |
|---|---|---|---|---|---|---|
| EU | EVFTA | EUR.1 / applicable origin proof | Check effective EVFTA schedule on declaration date | Correct HS, origin, transport, document | Origin proof, invoice, transport docs | Do not infer rate from brand name. |
| UK | UKVFTA | Valid origin proof | Check current UKVFTA schedule | Meet rule of origin | Origin proof, invoice, B/L | Relevant for Scotch whisky. |
| Japan | CPTPP/RCEP/VJEPA | As selected agreement requires | Check current schedule | Meet selected agreement ROO | Origin proof, invoice | Compare agreements for the lawful best rate. |
| ASEAN | ATIGA/RCEP | Form D or RCEP proof | Check current schedule | Origin and direct-consignment rules | C/O, transport docs | Transit through ASEAN does not create ASEAN origin. |
5. DOSSIER & PREPARATION
Contract/PO, Commercial Invoice, Packing List, B/L or AWB, Arrival Notice, C/O if claiming preference.
Original label, Vietnamese label artwork, COA/spec, ingredients, ABV, size; self-declaration and food-safety inspection documents where applicable. The technical file should also support conformity declaration under QCVN 6-3:2010/BYT and use of the conformity mark before circulation.
Alcohol distribution licence/eligibility, imported alcohol electronic-stamp records, one-source data cross-check.
| File group | Required documents | Used for | Typical owner | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, PL, Contract/PO | Value, quantity, terms | Importer + supplier | Mismatch in item name/ABV/pack | Cross-check each SKU against label/spec. |
| Transport | B/L/AWB, Arrival Notice | Customs and cargo release | Forwarder/carrier | Wrong consignee/package count | Check booking, manifest, invoice. |
| Food safety | Self-declaration, inspection file, COA/test | Specialized inspection | Importer + lab/specialist | Sample/label/ABV mismatch | Use one SKU/manufacturer/ABV dataset. |
| Alcohol | Distribution licence; e-stamp file | Import/circulation condition | Importer | Expired or unsuitable scope | Verify validity before booking. |
| Origin | C/O/origin proof | Preferential duty | Exporter/importer | Wrong HS/invoice/criterion | Review form, date, description, HS, transport. |
| Label | Original + Vietnamese supplementary label | Circulation/post-clearance | Importer | Missing mandatory data | Approve artwork before mass printing. |
| Conformity | Conformity declaration; conformity assessment/certification evidence where the applicable method requires it; conformity-mark records | Before circulation and for post-market review | Importer + conformity-assessment body where required | Completing food self-declaration but omitting conformity | Cross-check QCVN 6-3:2010/BYT, Circular 14/2026/TT-BKHCN and product evidence. |
6. LEGAL BASIS – SPECIALIZED POLICY MATRIX
| Area | Instrument | Issuer | Status | Role | Key point | Review note |
|---|---|---|---|---|---|---|
| Import tariff | Decree 26/2023/ND-CP as currently amended; Decision 15/2023/QD-TTg | Government/Prime Minister | Applicable | MFN and ordinary import duty | HS 2208.30.10/2208.30.90 have MFN 45%; ordinary rate follows the 150%-of-MFN rule where applicable | Lock HS before calculating tax. |
| Alcohol trade | Decree 105/2017/ND-CP amended by Decree 17/2020/ND-CP | Government | Applicable | Alcohol import and trading conditions | Alcohol at or above 5.5% is under the licensing regime; a licensed alcohol distributor may import within the permitted scope | Whisky normally exceeds the 5.5% threshold. |
| Licence delegation | Decree 146/2025/ND-CP | Government | From 1 Jul 2025 | Delegation for alcohol distribution licences | Authority for alcohol distribution licences is delegated to the provincial People’s Committee; published processing time for a new licence is 15 working days after a valid complete file | Do not state MOIT as the current licensing authority. |
| Food safety – current regime | Decree 15/2018/ND-CP; Resolution 15/2026/NQ-CP | Government | Currently applicable while Decree 46/2026 and Resolution 66.13/2026 are suspended | Self-declaration and imported-food controls | Resolution 15/2026 keeps Decree 15/2018 in force during the suspension | Recheck when the amended Food Safety Law and new guiding decree take effect. |
| Imported food list | Circular 28/2026/TT-BCT | MOIT | From 17 Jul 2026 | State food-safety inspection list | Both 2208.30.10 and 2208.30.90 are listed | Still check any lawful exemption/reduced-inspection pathway. |
| Alcoholic-beverage conformity | QCVN 6-3:2010/BYT; Circular 14/2026/TT-BKHCN | MOH/MST | Circular 14 effective 25 May 2026 | Conformity declaration and conformity mark | MST official guidance dated 11 Aug 2026 confirms food self-declaration does not replace conformity declaration for alcoholic beverages within QCVN scope | Lock the applicable conformity-assessment/certification method for the actual product. |
| Goods labeling | Decree 43/2017/ND-CP amended by Decree 111/2021/ND-CP | Government | Applicable | Original/Vietnamese supplementary label | Align product name, net quantity, ABV, ingredients and responsible entity with the actual dossier | Approve artwork before circulation. |
| Alcohol e-stamp | Circular 93/2026/TT-BTC | MOF | From 1 Jul 2026 | Printing, issuance, management and use of alcohol e-stamps | Circular 93/2026 replaces Circulars 23/2021 and 31/2025; previously issued old-form stamps may continue until exhausted | Use Circular 93/2026 as the current operating basis. |
| SCT | Special Consumption Tax Law 66/2025/QH15 | National Assembly | From 1 Jan 2026 | Special consumption tax | Alcohol ≥20%: 65% in 2026; alcohol below 20% follows its separate rate branch | Lock actual ABV and tax point. |
| VAT | Decree 174/2025/ND-CP; current VAT Law | Government/National Assembly | VAT-reduction policy through 31 Dec 2026 | VAT on import | Alcohol is SCT-liable and excluded from the 2% VAT reduction; operational reference is 10% | Recheck after the 2026 policy period. |
| Customs location | Decision 31/2026/QD-TTg | Prime Minister | From 14 Aug 2026 | Goods subject to import-border-gate customs formalities | The appendix lists the whole 2208 heading, so whisky is within scope, subject to the Decision’s statutory exceptions | Do not state the rule as absolute where an exception applies. |
| Scenario | Legal basis | Potential policy | Authority level | Trigger |
|---|---|---|---|---|
| Commercial whisky ≥5.5% ABV | Decree 105/2017 + Decree 17/2020 + Decree 146/2025 | Alcohol distribution licence/import eligibility | Provincial People’s Committee/assigned authority | Import for commercial distribution. |
| Whisky HS 2208.30 | Circular 28/2026 + Decree 15/2018 + Resolution 15/2026 | State food-safety inspection | Assigned/designated inspection body | No applicable exemption. |
| Whisky within QCVN 6-3:2010/BYT | QCVN 6-3:2010/BYT + Circular 14/2026/TT-BKHCN | Conformity declaration and conformity mark before circulation | Receiving authority/conformity-assessment body as applicable | Alcoholic beverage within QCVN scope. |
| Whisky circulated in Vietnam | Labeling decrees + Circular 93/2026/TT-BTC | Vietnamese label/supplementary label + alcohol e-stamp | Relevant market/customs/tax authority | Market release. |
| FTA-origin whisky | Special preferential tariff + ROO | Preferential import duty | Customs | Valid origin proof and ROO. |
| Whisky under heading 2208 | Decision 31/2026/QD-TTg | Review import-border-gate customs location | Customs | Listed import and no statutory exception. |
7. TIMELINE, FEES & RISK COSTS
| Step | Recommended timing | Fees/costs | Delay risk | Note |
|---|---|---|---|---|
| Lock SKU/HS/ABV | Before PO/booking | Internal | Wrong tax/classification baseline | Confirm label, size, ABV. |
| Licence + food-safety review | Before ETA | Depends on dossier/test | Cannot complete compliance | If the importer must obtain a new alcohol distribution licence, the currently published administrative processing time is 15 working days from receipt of a complete valid dossier; food-safety and conformity timelines vary with the actual file and assessment method. |
| C/O + documents | Before ETA | Supplier-dependent | Loss of preference | Review draft before issue. |
| Customs/food-safety inspection | When file is ready | Taxes + inspection/test if any | Storage/DEM/DET | Depends on customs channel and inspection. |
| Post-clearance | Before circulation | Stamp/label/warehouse | Post-market enforcement risk | Retain lot file and change-control records. |
8. PRACTICAL E2E PROCESS
Lock whisky type, ABV, direct-container size, manufacturer, origin, SKU and import purpose.
Distinguish 2208.30.10 vs 2208.30.90 and calculate MFN/FTA, SCT and VAT for the actual declaration date.
Check the alcohol distribution licence, food safety, conformity declaration/mark, labeling, e-stamps under Circular 93/2026 and import-border-gate rules.
Finalize self-declaration/testing, imported food-safety documents and the QCVN 6-3:2010/BYT conformity-declaration file before market circulation.
Cross-check Invoice, PL, B/L/AWB, C/O, label, COA/spec and licence.
Declare HS, value, tax and origin; handle Green/Yellow/Red channel and specialized inspection.
Pay taxes, finish food-safety/physical inspection if triggered, release cargo and control labels/stamps.
Release only when stamp/label and compliance file are ready; retain tax, origin, food-safety and lot records.
9. FAQ
1. Does whisky import require an alcohol licence?
For commercial imports of alcoholic beverages at or above the regulatory threshold, review Decree 105/2017 as amended; licensed alcohol distributors are permitted to import within scope.
2. What HS codes apply to whisky?
Use 2208.30.10 for whisky in containers over 5 litres and 2208.30.90 for other whisky, subject to actual packing and product evidence.
3. Is imported whisky subject to food-safety inspection?
Yes, as a managed food product. From 17 Jul 2026, both whisky codes are on MOIT’s imported food list for state food-safety inspection, unless an exemption applies.
4. Does whisky need product self-declaration?
Review self-declaration under Decree 15/2018 for packaged food/beverage products before circulation, based on the actual product file.
5. What is the 2026 SCT rate?
For whisky at or above 20% ABV, the 2026 special consumption tax rate is 65%. Alcohol below 20% must be reviewed under the 35% branch.
6. Can VAT be reduced to 8%?
Do not assume 8% for whisky. Goods subject to SCT are generally excluded from broad VAT reductions; operational reference remains 10%, subject to law on the declaration date.
7. Can C/O reduce SCT or VAT?
No. C/O may reduce import duty under an FTA; SCT and VAT remain governed separately.
8. A 700ml bottle packed 12 per carton: is it 2208.30.10?
Normally no. The criterion is the direct whisky container, not the aggregate volume of the transport carton.
9. Is an imported alcohol electronic stamp required?
Yes. From 1 Jul 2026 the current operating basis is Circular 93/2026/TT-BTC, which replaces Circulars 23/2021 and 31/2025. Old-form stamps already issued may continue to be used until exhausted.
10. Is a Vietnamese supplementary label required?
If the original label does not contain all mandatory Vietnamese information, a supplementary Vietnamese label is required before circulation, and it must match the compliance dossier.
11. Does whisky require a conformity declaration and conformity mark?
Yes where the product falls within QCVN 6-3:2010/BYT. MST’s official guidance dated 11 Aug 2026 states that food self-declaration under Decree 15/2018 is not a basis for exemption from conformity declaration; the conformity mark must then be used as required.
12. Must customs formalities be done at the import border gate?
From 14 Aug 2026, review Decision 31/2026/QD-TTg for listed goods and statutory exceptions; do not automatically route the declaration to an inland customs office.
10. REQUIRED OUTPUTS & POST-CLEARANCE OBLIGATIONS
Label, COA/spec, ABV, package size, photos, description and HS rationale.
Invoice, PL, B/L/AWB, Contract/PO, Arrival Notice.
Applicable alcohol licence, food self-declaration/imported food-safety file, conformity declaration and conformity-mark records under QCVN where applicable.
Declaration, tax payment evidence, C/O, valuation and HS explanation if needed.
Original label, Vietnamese label, imported alcohol e-stamp and lot traceability file.
Re-review if supplier, plant, ABV, bottle size, label, origin or gift-set structure changes.
11. TGIMEX SOLUTIONS
TGIMEX supports businesses in controlling the import file from pre-ETA review through customs clearance and post-clearance retention.
TGIMEX can review HS, tax, C/O, alcohol eligibility, food safety, label and e-stamp before arrival.
Align commercial documents, product dossier and specialized compliance data from one source.
Coordinate forwarding, customs, specialized inspection and issue handling at the border gate.
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