IMPORT PROCEDURES FOR FRUIT JUICE INTO VIETNAM
“Fruit juice” may mean 100% juice, concentrate, mixed juice, nectar or a diluted fruit drink. Classifying only from the commercial name can lead to the wrong HS code, duty and food-safety treatment.
This guide follows the E2E path: product identification → 20.09/22.02 branching → duty/C/O → self-declaration & import food-safety inspection → labeling → customs → post-clearance.
Operational reference for import-export businesses · Updated through 11 Sep 2026.
1. QUICK SUMMARY & SCOPE
Lock fruit type, juice %, Brix, concentrate/NFC status, added water, sugar/sweetener and ready-to-drink/dilution status.
Juice retaining fruit/vegetable-juice character may remain in 20.09; diluted nectar/fruit drinks may move to 22.02.
Circular 28/2026/TT-BCT, effective 17 Jul 2026, lists heading 20.09 and related beverage HS lines for state food-safety inspection.
Ordinary prepacked juice must be screened for self-declaration under Decree 15/2018 and comply with goods/nutrition labeling rules where applicable.
Example: 2009.12.00 MFN 30%; many 2009.89/2009.90 lines 25%; 2202.99.50 30%, 2202.99.90 20%.
These data often decide 2009 vs 2202 and affect declaration, testing and C/O.
2. KEY TERMS & WHY THE PROCEDURE MATTERS
Heading 20.09 separates orange, grapefruit, other citrus, pineapple, tomato, grape, apple, other fruit/nut/vegetable juice and mixtures.
Several 20.09 subheadings use Brix directly; without it the HS position may not be defensible.
NFC is direct juice; FC is reconstituted from concentrate. Either may remain in 20.09 if juice character is retained.
Usually includes added water and may include sugar/sweetener; depending on final character it may compete with 22.02.
The normal food self-declaration mechanism under Decree 15/2018, supported by an appropriate test report and retained records.
Decree 15 provides reduced, ordinary and strict methods; Circular 28/2026 locks the MOIT beverage HS list.
3. DETAILED PRODUCT CLASSIFICATION & IDENTIFICATION
Determine the true nature of the goods before calculating duty or filing food-safety documents.
| Product group / scenario | Technical signs to check | Example type / function | Supporting documents | Possible policy impact | Documents to cross-check | Application note |
|---|---|---|---|---|---|---|
| 100% single-fruit juice | Identify fruit, Brix and reconstitution | Orange/apple/pineapple juice | Spec, Brix, ingredients, flow chart, label | 20.09, food safety, self-declaration, label | Spec + test + commercial docs | Use the specific fruit/Brix branch where available. |
| Concentrated juice | High Brix; raw-material or RTD use | Concentrated mango juice | COA, Brix, concentration ratio, use | 20.09 or another branch by nature | COA + process + intended use | Separate ingredient concentrate from RTD beverage. |
| Mixed juice | Two or more juices but still juice | Apple-grape blend | Recipe %, Brix, process | 2009.90, food safety, self-declaration | Recipe + label + test | Review 2009.90.91 if ready-to-drink. |
| Nectar / diluted fruit drink | Significant added water; lower juice % | Mango nectar 25%, peach drink | Recipe %, Brix, water %, label | May move to 22.02 | Recipe + spec + process | Do not assume 2009 because fruit juice is an ingredient. |
| Coconut water | Distinguish 100% coconut water from coconut beverage | 100% coconut water vs coconut drink | Brix, recipe, process | 2009.89 or 2202.99.30 | Spec + recipe + label | Common 2009 ↔ 2202 competition. |
| Fruit syrup/base | Not RTD; high Brix; dilution instruction | Fruit syrup/base | Dilution ratio, Brix, recipe | May be outside 2009/2202 | Spec + usage | Reclassify from actual nature. |
4. HS CODE – DUTY – C/O
There is no single fruit-juice code. Heading 20.09 varies by fruit, Brix and form; products with the character of another prepared beverage must be screened against 22.02.
20.09 covers qualifying fruit/nut/vegetable juices; 22.02 covers other non-alcoholic beverages.
Cross-check subheading wording, ingredients, Brix, reconstitution and added water.
Frozen orange 20%; orange Brix≤20 is 30%; many other juice/mixture lines 25%; 2202.99.50 30%, 2202.99.90 20%.
Do not use one ordinary rate for the whole product family.
Decree 174/2025 provides a 2% reduction through 31 Dec 2026 for eligible non-excluded goods.
Review ATIGA, ACFTA/RCEP, VKFTA/AKFTA, VJEPA/AJCEP/RCEP, EVFTA/UKVFTA by final HS and PSR.
| Reference HS | Suitable description/group | Classification basis | Conditions | Ordinary import duty | MFN duty | VAT | C/O/FTA to review | Documents to cross-check |
|---|---|---|---|---|---|---|---|---|
| 2009.12.00 | Orange juice, not frozen, Brix≤20 | Specific orange subheading | Correct fruit/form/Brix | Review current tariff | 30% | 10%; potentially 8% | FTA by origin | Brix, spec, recipe, process, C/O |
| 2009.41.00 / 2009.49.00 | Pineapple juice, Brix≤20 / other | Pineapple subheadings | Confirm Brix | Review current tariff | Review current line | 10%; potentially 8% | FTA by origin | Brix, COA, spec, C/O |
| 2009.71.00 / 2009.79.00 | Apple juice, Brix≤20 / other | Apple subheadings | Confirm Brix | Review current tariff | Review current line | 10%; potentially 8% | FTA by origin | Brix, spec, C/O |
| 2009.89.99 | Other single fruit/nut/vegetable juice | Other single-juice branch | No more specific branch | Review current tariff | 25% | 10%; potentially 8% | FTA by origin | Recipe, Brix, label, C/O |
| 2009.90.91 | Mixed juices, ready-to-drink | Mixture branch | Still has juice character | Review current tariff | 25% | 10%; potentially 8% | FTA by origin | Recipe %, Brix, label, C/O |
| 2202.99.50 / 2202.99.90 | Other non-alcoholic beverage outside 20.09 | Competing fruit-drink/nectar branch | Dilution/preparation changes character | Review current tariff | 30% / 20% | 10%; potentially 8% | FTA by origin | Recipe %, dilution, label, usage |
| Origin route | FTA/agreement | C/O/origin proof | Special preferential duty where sufficiently verified | Conditions | Documents to cross-check | Application note |
|---|---|---|---|---|---|---|
| ASEAN | ATIGA | Form D/e-C/O | Review 2026 schedule by final HS | Meet PSR | C/O, invoice, B/L, PL | Do not use a 2009 rate for goods finally in 2202. |
| China | ACFTA/RCEP | Form E/RCEP proof | Review 2026 schedule | Meet PSR/transport rules | Origin proof, invoice, transport docs | Cross-check HS and description. |
| Korea | VKFTA/AKFTA/RCEP | Applicable proof | Review 2026 schedule | Meet PSR | Origin proof, BOM/recipe if needed | Do not assume 0%. |
| Japan | VJEPA/AJCEP/RCEP | Applicable proof | Review HS/tariff period | Meet PSR | Origin proof, invoice, transport docs | Check tariff period where relevant. |
| EU/UK | EVFTA/UKVFTA | Statement/C/O | Review final HS | Meet preferential origin rules | Origin proof, invoice | Do not market 0% before HS/PSR are locked. |
5. DOSSIER & PREPARATION METHOD
Use a single source of truth: Brix, juice %, recipe and product name must match across specs, self-declaration, label, food-safety inspection, C/O and customs.
Invoice, Packing List, contract/PO, B/L/AWB and C/O where claimed.
Spec, ingredients/recipe %, Brix/COA, flow chart, label, test report, concentrate/RTD evidence.
Self-declaration, import food-safety dossier and master data for customs/origin review.
| Dossier group | Required documents | Used for | Typical preparer | Common error | Pre-ETA check |
|---|---|---|---|---|---|
| Commercial | Invoice, PL, contract/PO, B/L/AWB | Customs/C/O | Importer + supplier + forwarder | Generic “juice” description | Compare with master product sheet. |
| Classification | Spec, recipe %, Brix, COA, flow chart, label | Lock 2009/2202 | Supplier + importer | Missing Brix/added-water data | Obtain formal spec/COA. |
| Self-declaration | Self-declaration + suitable test report | Market/inspection | Importer/brand owner | Expired/inadequate test | Check validity/indicators. |
| Food safety | Reduced/ordinary/strict inspection dossier | Clearance | Importer | Wrong exemption/method | Review Decree 15 Arts. 13–19 + Circular 28/2026. |
| Label | Original + Vietnamese supplementary + nutrition label | Market | Importer/brand owner | Juice %/ingredients mismatch | Freeze artwork after recipe. |
| Origin | C/O/origin proof | FTA | Exporter + importer | HS/description mismatch | Cross-check final HS and PSR. |
6. LEGAL BASIS – SPECIALIZED POLICY MATRIX
| Legal group | Instrument | Issuer | Status/application time | Role | Key article/annex if relevant | Review note |
|---|---|---|---|---|---|---|
| HS & MFN | Decree 26/2023/ND-CP, amended by 108/2025/ND-CP | Government | Current; recheck at declaration | Nomenclature and MFN | Chapters 20, 22 | Lock rate by current HS line. |
| MOIT food-safety list | Circular 28/2026/TT-BCT | MOIT | Effective 17 Jul 2026 | Import food-safety HS list | Heading 20.09 and related beverages | Key current specialized instrument for juice. |
| Food-safety mechanism | Decree 15/2018/ND-CP + Resolution 15/2026/NQ-CP | Government | Decree 15 continues while Decree 46/2026 and Resolution 66.13/2026 are suspended | Self-declaration, exemptions, inspection methods | Articles 4–5, 13–19 | Do not present Decree 46/2026 as current operating basis. |
| Beverage technical regulation | QCVN 6-2:2010/BYT under Circular 35/2010/TT-BYT | MOH | Review scope | Safety indicators for non-alcoholic beverages | Scope/limits | Use for testing where applicable. |
| Goods labeling | Decrees 43/2017 and 111/2021 | Government | Current | Original/supplementary label | Mandatory content | Keep label and declaration aligned. |
| Nutrition labeling | Circular 29/2023/TT-BYT | MOH | Effective 15 Feb 2024; covered new labels must comply from 01 Jan 2026 | Nutrition facts | Scope/roadmap | Added-sugar beverages require sugar review. |
| VAT | Decree 174/2025/ND-CP | Government | 2% reduction through 31 Dec 2026 if eligible | VAT | Scope/exclusions | Do not automatically use 8%. |
| Goods scenario | Legal basis to cross-check | Potential policy | Authority at high level | Trigger |
|---|---|---|---|---|
| Juice HS 20.09 | Circular 28/2026 + Decree 15/2018 | Import food-safety inspection + self-declaration | MOIT-scope food-safety authority | Not exempt under Art. 13; determine method. |
| Fruit drink/nectar HS 22.02 | Circular 28/2026 + Decree 15/2018 | Beverage food-safety inspection + self-declaration | Authority under MOIT scope | Actual product is no longer 20.09. |
| Ordinary prepacked food | Decree 15 Arts. 4–5 | Self-declaration | Authority under delegation | Not a registered-declaration product. |
| Reduced inspection | Decree 15 Arts. 16–17 | Reduced inspection | Customs/relevant authority | Meets history/system/recognition conditions. |
| Recipe/juice %/Brix change | HS + food safety + declaration + label | Re-screen dossiers | Importer + authority where needed | Change alters nature/data. |
7. PROCESSING TIME, FEES & RISK COSTS
Actual lead time depends on inspection method, dossier supplementation and customs channel.
| Stage | Main activity | Reference timing | Fees/costs | Delay risk |
|---|---|---|---|---|
| Preparation | Lock HS, Brix, recipe, declaration, label | Depends on readiness | Testing/advisory if any | Shipment delay. |
| Registration/receipt | Register food-safety inspection if required | Before/when goods arrive | As applicable | Cargo arrives before dossier. |
| Ordinary inspection | Document review | 03 working days from dossier receipt | Applicable fees | Supplement request delays. |
| Strict inspection | Documents + sampling + testing | 07 working days from dossier receipt | Sampling/testing | Storage/DEM/DET. |
| Result | Pass/fail notification | By method | Case-specific | No pass result blocks clearance. |
| Customs | Declaration, channel, duty, clearance | Green/Yellow/Red | Import duty, VAT, logistics | Wrong HS/C/O triggers amendment. |
| Post-clearance | Label, records, post-audit | Ongoing | Internal compliance | Penalty/recall risk. |
8. PRACTICAL E2E WORKFLOW
Lock fruit, juice %, Brix, concentrate/NFC, water, sugar/sweetener and RTD/dilution status.
Compare 20.09 fruit/Brix branches with 22.02 if the product is a prepared beverage, then calculate tax/FTA.
Cross-check Circular 28/2026 and Decree 15; determine exemption and inspection method.
Self-declaration, test report, label/nutrition and technical data.
Cross-check Invoice, PL, B/L/AWB, C/O, spec, recipe, Brix, declaration and artwork.
Green is mainly system-based; Yellow checks documents; Red may include physical inspection. Food-safety controls still apply.
Reconcile food-safety result, tax and customs documents.
Complete supplementary label, retain records and control changes.
9. FAQ – FREQUENTLY ASKED QUESTIONS
1. Is fruit juice always in 2009?
No. 20.09 covers qualifying juice; diluted nectar/fruit drinks may require 22.02.
2. Which code applies to orange juice?
Separate frozen/non-frozen and Brix. 2009.12.00 only covers non-frozen orange juice with Brix≤20.
3. How is mixed juice classified?
If it remains a mixture of juices, review 2009.90; otherwise review 22.02.
4. Is coconut water 2009 or 2202?
100% coconut water has 2009.89 branches; prepared coconut beverages may fall under 2202.99.30.
5. Is nectar automatically 2202?
Not from the word alone; review juice %, water, Brix and product standard.
6. Is imported juice subject to food-safety inspection?
Heading 20.09 is listed in Circular 28/2026; each shipment still needs exemption/method screening under Decree 15.
7. Is self-declaration required?
Ordinary prepacked juice is generally under the self-declaration mechanism unless another regime applies.
8. What matters for the test report?
Check indicators, lab competence, validity and product match.
9. How long does ordinary inspection take?
Decree 15 provides 03 working days; strict inspection is 07 working days from dossier receipt.
10. Are nutrition labels mandatory from 2026?
For products within Circular 29/2023, new labels imported/produced/printed from 01 Jan 2026 must comply.
11. Does a C/O guarantee preferential duty?
No. Final HS, valid proof and PSR must all match.
12. Should recipe or juice-% changes trigger review?
Yes. They may change 2009 vs 2202, declaration, label and C/O treatment.
10. OUTPUTS & POST-CLEARANCE OBLIGATIONS
Spec, recipe %, Brix/COA, process, label and HS memo.
Invoice, PL, B/L/AWB, contract/PO, lot data.
Self-declaration, test report, food-safety dossier/result.
Declaration, valuation, import duty/VAT, C/O and explanations.
Original/supplementary label, nutrition facts, artwork control.
Version-control supplier, origin, recipe, Brix, juice %, packaging and label.
11. SOLUTIONS FROM TGIMEX
TGIMEX can coordinate compliance and operations before cargo moves.
Cross-check recipe, Brix, HS, Circular 28/2026, self-declaration, food-safety inspection and C/O.
Keep technical data, test report, declaration, label, commercial and customs data consistent.
Track ETA, food-safety inspection, customs filing, C/O and shipment blockers.
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