Tiếng Việt
中文 (中国)
EXPORT GUIDE FOR FILLING MACHINES
“Filling machine” may refer to a semi-automatic piston/servo filler, liquid or paste dosing filler, bottle/tube/jar filler, aseptic filler, or an integrated filler–capper–labeller. If the exporter does not freeze the principal function, container type, filled product, automation level, product-contact parts and line boundary, the shipment may be classified under the wrong HS code, supported by the wrong origin file, or packed and certified for the wrong scope.
This guide follows the shipment from market scan to post-shipment, with deeper review of Japan, China and the United States. Burkina Faso is noted as a high-value 2024 destination in importer-side data, but it is treated as a possible project-driven signal rather than the default target market.
1. QUICK OVERVIEW
WITS/UN Comtrade 2024 importer-side data for HS6 842230 shows notable imports from Vietnam by Burkina Faso, Japan, China, the United States and Pakistan. JP/CN/US are analyzed in depth because both trade evidence and compliance sources are clearer.
Ordinary industrial fillers require model-based screening; the product name alone does not create an export permit. Used status, dual-use features, batteries, residual liquids or explosion-protected components must be screened separately.
8422.30.00 is the main working direction where the principal function is filling/closing/sealing/labelling containers. Wrapping-only machines, parts and standalone dosing/weighing/pumping equipment need separate classification.
China: ACFTA/RCEP. Japan: VJEPA/AJCEP/CPTPP/RCEP, although 8422.30 is currently Free in Japan’s 2026 tariff. The United States has no preferential FTA with Vietnam.
There is no single certificate for every filler. Electrical safety, food-contact/GMP, hazardous location, pressure/pneumatic systems, wireless and exact end-use are the main triggers.
Control Production Freeze → Cargo Ready → SI/VGM/CY/CFS Cut-off → ETD. Rotary and aseptic lines need packed dimensions, GW/NW, CoG, lifting points, module mapping and residual-fluid/DG screening.
2. PRODUCT SCOPE & TECHNICAL VARIANTS
This guide covers machines or integrated units whose principal function is placing product into bottles, cans, jars, tubes, bags or similar containers. It does not automatically cover every dosing device, pump, wrapper or scale marketed as a “filling system”.
| VARIANT | TECHNICAL SIGNS | EVIDENCE | HS / POLICY DIRECTION | SEPARATE WHEN |
|---|---|---|---|---|
| Semi-auto liquid/paste filler | Piston/gear/peristaltic, 1–4 nozzles | Catalogue, cycle video, pump/nozzle specs | Review 8422.30.00 where container filling is principal | Do not treat a standalone dosing pump as the same product |
| Automatic linear/rotary filler | Conveyor, starwheel, servo/PLC, multi-head | Layout, I/O, throughput, electrical drawing | 8422.30.00 is commonly the working direction | Freeze machine boundary and accessories |
| Filler–capper–labeller monoblock | Multiple packaging operations in one line | Process flow, line layout, module list | Classify by function/principal function and unit rules | Do not split modules mechanically without a basis |
| Aseptic / sterile filler | CIP/SIP, sterile barrier, HEPA/isolator, 316L contact parts | P&ID, validation and material documents | HS may remain 8422.30 but market compliance becomes much deeper | Food/pharma GMP and sterile boundary |
| Form-fill-seal | Forms the container, then fills and seals | Process diagram, forming module description | Review 8422.30 by exact function | Do not confuse with wrapping-only 8422.40 |
| Parts / nozzle / pump / control cabinet | Shipped separately and incomplete | Part no., BOM, exploded view | Review parts heading or the component’s own heading | Do not use complete-machine code for every spare part |
| Used/refurbished | Year, serial, operating history | Condition report and photos | HS does not change merely because goods are used | Destination-market used machinery rules |
3. EXPORT MARKETS & MARKET ACCESS
WITS/UN Comtrade 2024 importer-side data for HS6 842230 reports imports from Vietnam of approximately USD 2.754 million by Burkina Faso, USD 1.739 million by Japan, USD 765 thousand by China, USD 471 thousand by the United States and USD 399 thousand by Pakistan. The HS6 bucket also includes closing, sealing, labelling and beverage-aerating machinery, so the figures are market signals rather than filler-only sales.
| MARKET | 2024 SIGNAL | FIT | ACCESS POINTS | DATA TO FREEZE |
|---|---|---|---|---|
| Japan | ~USD 1.739m from Vietnam | High | 8422.30 tariff Free; PSE only where in scope; food-contact apparatus may trigger Food Sanitation Act | End-use, contact materials, importer handling, electrical scope |
| China | ~USD 765k | High | CCC scope screening; whole filler should not be presumed CCC; ACFTA/RCEP origin can matter | Model, electrical/Ex BOM, end-use, PSR |
| United States | ~USD 471k | Medium-high | No single federal machine-import certificate; NRTL/workplace electrical and sanitary design may drive acceptance | Electrical package, NRTL/field evaluation path, application, buyer spec |
| Burkina Faso | ~USD 2.754m | Project-driven | High annual value but insufficient quantity/time-series evidence for a default target market | Buyer/project, local approvals, service capability |
Source: WITS/UN Comtrade 2024, importer-side, HS 842230 (HS 1988/92 H0). Do not combine with exporter-side figures to infer market share.
4. VIETNAM EXPORT POLICY
For a new standard packaging filler, there is no basis to impose an export permit solely from the commercial name. The shipment must still be screened against Decree 292/2026/ND-CP, exact model, end-use/end-user and accompanying components before being treated as ordinary export cargo.
Hazardous-area/ex-proof equipment, battery/UPS, wireless, pressure vessel assemblies, used status and residual cleaning chemicals or oils may create separate market or transport requirements. They do not automatically mean a Vietnam export licence is required.
Prepare a Policy Screening Sheet covering HS working code, model, filling principle, filled product, contact parts, voltage/power, pressure/pneumatic system, wireless/battery, hazardous-zone rating, new/used status, end-use/end-user, destination and accessories. Note the transition clause of Decree 292/2026/ND-CP: ministerial regulations currently in force that guide Decree 69/2018/ND-CP continue to apply through 31 December 2026 within their transitional scope.
5. HS CODE – EXPORT DUTY – EXPORT VAT
5.1. HS working matrix
From 15 September 2026, customs classification and analysis for classification are governed by Circular 85/2026/TT-BTC, replacing Circulars 14/2015/TT-BTC and 17/2021/TT-BTC. Therefore, 8422.30.00 remains a working code until the actual technical file is locked.
| SCOPE | HS WORKING CODE | WHY | EVIDENCE | MISCLASSIFICATION RISK |
|---|---|---|---|---|
| Complete filling/closing/sealing/labelling machine | 8422.30.00 | Heading text expressly covers the relevant packaging functions | Catalogue, process video, container/product description | Pump/doser/wrapper confusion |
| Other packing/wrapping machine | 8422.40.00 | Where principal function is other packing/wrapping | Functional description | Using 8422.30 just because equipment is in the same line |
| Packaging machinery parts | Review 8422.90 or component heading | Separate part may not retain complete-machine identity | Part no., BOM, exploded view | Complete-machine code for spares |
| Standalone dosing/weighing/pumping | Review function-specific heading | Principal function may fall outside 84.22 | Principle and load-cell/pump data | Marketing term “filling” used as classification |
Do not infer export duty from Vietnam MFN import duty. After final HS is confirmed, check Appendix I of Decree 26/2023/ND-CP at the declaration date. Decree 201/2026/ND-CP amends export duty rates for certain specific products such as fluorite and bismuth and should not be used to infer a rate for heading 8422. If the final HS is not listed in the Export Tariff, apply Article 4 of Decree 26/2023/ND-CP.
Law 48/2024/QH15, as amended by Laws 90/2025/QH15 and 149/2025/QH15 (effective 1 January 2026), provides a 0% VAT mechanism for qualifying exported goods. This is conditional; verify the actual transaction and evidence under Decrees 181/2025/ND-CP, 359/2025/ND-CP and 144/2026/ND-CP.
6. ORIGIN / FTA / C/O
Filling machines often contain imported PLC/HMI, servo motors, pumps, valves, load cells, sensors, stainless fabrication, conveyors and control panels. Origin therefore must be BOM-first, not a certificate exercise after packing.
| ROUTE | FTA / PROOF | RULE TO CHECK | PRACTICAL VALUE | BASE FILE |
|---|---|---|---|---|
| Vietnam → China | ACFTA Form E / appropriate RCEP proof | ACFTA HS 8422.30: RVC40 or CTSH. Under RCEP, HS 8422.30 also follows CTSH or RVC40; verify the applicable HS version and agreement file. | May provide preference only when all importer and origin conditions are met | BOM, component HS/origin/value, supplier and production records |
| Vietnam → Japan | VJEPA/AJCEP/CPTPP/RCEP where relevant | Compare PSR and buyer needs | Japan 2026 tariff shows 8422.30 as Free; preferential proof may add no tariff benefit when final HS matches | Only produce preferential proof with a clear objective |
| Vietnam → United States | No preferential US-Vietnam FTA | Non-preferential origin/marking and buyer documents | Do not promise a preferential C/O to reduce duty | BOM/origin and commercial records |
7. PRODUCT-SPECIFIC & MARKET COMPLIANCE
Compliance depends strongly on the filled product and end-use: food/beverage, pharmaceutical, cosmetics, chemicals or flammable liquids. Separate destination law from buyer specification and from transport triggers.
JAPAN
Do not assume every electrically powered filler requires PSE. PSE applies only where the machine or supplied electrical item falls within DENAN scope.
- MHLW can treat machines that directly contact food/additives as “apparatus”.
- Food Sanitation Act Article 27 can require importer notification for apparatus imported for sale or business use.
- Contact-material/test evidence may be requested during quarantine review.
- Food vs non-food end-use
- 316L/gasket/hose contact-material list
- Importer confirmation on Article 27
- PSE scope of separately supplied items
CHINA
Do not assume that an entire filling machine requires CCC merely because it contains a motor or PLC. Check the current CCC catalogue and implementation rules against the exact machine/components; explosion-proof electrical equipment is a separate trigger for hazardous-area applications.
- Screen electrical/components that are independently in CCC scope.
- Explosion-proof electrical equipment is a separate CCC category and matters for hazardous-area fillers.
- Confirm national/local standards, manuals and site acceptance with the importer.
- Electrical BOM + Ex rating
- Whole machine vs separately supplied component
- Chinese manual/label inputs
- Form E/RCEP route and origin evidence
UNITED STATES
OSHA does not certify machinery generally. Nevertheless, certain workplace electrical equipment must be approved/accepted under the NRTL framework, and buyers/AHJs may require listing or field evaluation.
- Screen industrial control panels/electrical systems against relevant NRTL standards.
- For food use, 21 CFR 117.40 addresses cleanability, maintenance and contamination prevention.
- Pharma/supplement buyer GMP qualification can be materially deeper.
- Site/AHJ and NRTL route
- Control-panel evidence if required
- Product-contact materials and cleanability
- FAT/SAT, manuals, wiring and spares
COMMON LOGISTICS TRIGGERS
| TRIGGER | DATA REQUIRED | OPERATIONAL EFFECT |
|---|---|---|
| Residual oil / cleaning liquid | Substance, SDS, quantity, drain status | Leak prevention, DG screening, carrier acceptance |
| Battery/UPS | Chemistry, Wh, UN38.3/SDS if applicable | Air/sea DG booking |
| Wood packaging | Solid wood vs plywood; treatment mark | ISPM 15 by route/market |
| Heavy/OOG | Packed L×W×H, GW, CoG, floor load, lifting points | Container fit, FR/OT/OOG, crane/forklift |
| Hazardous-area design | Ex component list, certificates, zone rating | Market and site acceptance |
8. EXPORT DOCUMENT SET & SUBMISSION
| GROUP | DOCUMENTS | USED FOR | OWNER | DATA TO MATCH | COMMON FAILURE |
|---|---|---|---|---|---|
| Commercial | Contract/PO, Invoice, Packing List | Customs, booking, buyer/bank | Sales/Docs | Model, qty, price, Incoterm, scope | Generic “machine” description; PO scope mismatch |
| Customs | Declaration + classification evidence | Export clearance | Customs/Docs | HS, description, value, origin | No explanation of 8422.30 vs 8422.40/parts |
| Technical/compliance | Catalogue, layout, electrical, P&ID, manuals, test/certs | Market/buyer acceptance | Engineering/QA | Exact model, serial, voltage, contact material | Certificate scope mismatch |
| Origin | BOM, supplier docs, C/O input, RVC/CTSH evidence | Origin review/C/O | Procurement/Factory/Docs | Finished/input HS, supplier, value, batch | Prototype BOM used instead of shipped BOM |
| Transport/buyer | Booking, SI, VGM, B/L/AWB, FAT/SAT, L/C docs | Shipping/post-shipment | Forwarder/Docs/Finance | Packages, GW/NW, marks, consignee, serial | SI/B/L mismatch; missing crate map |
9. LEGAL MATRIX – THREE LAYERS
| LAYER | LEGAL SOURCE | AUTHORITY | EFFECTIVE / TIMING | SCOPE | CHANGE / NOTE |
|---|---|---|---|---|---|
| Vietnam – Foreign trade | Decree 292/2026/ND-CP | Government | 05 Sep 2026 | Prohibitions/restrictions/licensing framework | Replaced Decree 69/2018; apply only relevant triggers |
| Vietnam – Customs | Decree 08/2015 + 59/2018 + 167/2025; Circular 38/2015 + 39/2018 + 121/2025 | Government / MOF | Decree167: 15 Aug 2025; Circular121: 01 Feb 2026 | Declaration, dossier, inspection | Use current amended text |
| Vietnam – Export tariff | Decree26/2023 + Decree201/2026 | Government | Decree201: 23 Jul 2026 | Export Tariff | Check final HS; do not infer from import MFN |
| Vietnam – VAT | Law48/2024; Decree181/2025; Decree359/2025; Decree144/2026 | National Assembly / Government | Decree144: 20 Jun 2026 | Export VAT / 0% conditions | Check actual transaction and evidence |
| Origin | Circular40/2025 + decentralization changes under Circular26/2026 | MOIT | Circular40: 01 Jul 2025; authority changes from 01 Aug 2026 | C/O issuance/self-certification authority | Check correct issuing body at filing date |
| ACFTA | Circular12/2019/TT-BCT | MOIT | 12 Sep 2019 | Form E / ACFTA PSR | 8422.30 cited PSR: RVC40 or CTSH |
| Japan | 2026 tariff; Food Sanitation Act Art.27; DENAN/PSE guidance | Customs / MHLW / METI | Current 2026 | Tariff, food-contact apparatus, electrical scope | No blanket PSE rule |
| China | CCC catalogue / current implementation rules | SAMR/CNCA | Current 2026 | Compulsory certification by listed scope | Whole filler is not automatically a CCC product |
| United States | OSHA NRTL framework; 21 CFR 117.40 when food-use applies | OSHA / FDA | Current | Workplace electrical acceptance / food equipment sanitation | Not a blanket customs certificate |
10. PRACTICAL E2E EXPORT PROCESS
Freeze product scope and market
Define filled product, container, capacity, filling principle, line scope, sanitary/hazardous-area requirements and buyer acceptance path.
HS, policy and origin route
Separate 8422.30 complete fillers from wrapping-only equipment, parts and standalone dosing/weighing/pumping. Screen Vietnam policy and destination triggers.
Contract and compliance deliverables
Freeze Incoterm, payment, FAT/SAT, warranty, spares, manuals and responsibility for NRTL/PSE/food-contact/CCC screening and commissioning.
Production Freeze and dossier
Freeze BOM, contact parts, electrical options, safety guards and accessories. Complete FAT, manuals, market documents, origin calculation and packaging engineering.
Packing, modules and transport
Freeze packed dimensions, GW/NW, CoG, lifting/forklift points, residual liquids, batteries, wood packaging, container fit and OOG status.
Declaration and cross-check
Cross-check Invoice, PL, catalogue, HS, origin, model/serial and line scope before declaration. Keep crate/module mapping for split-container shipments.
SI, VGM, CY/CFS and B/L draft
Freeze shipper/consignee, marks, packages, weights, container, SI/VGM and on-board data. Draft B/L must align with Invoice/PL/C/O and bank requirements.
Final documents and commissioning archive
Complete Final B/L/AWB, proof of origin if used, buyer/bank set, payment, FAT/SAT handover, commissioning records and claims if any.
11. TIMELINE BEFORE ETD / CARGO READY / CUT-OFF
| MILESTONE | FREEZE | DATA | OWNER | RISK IF LATE |
|---|---|---|---|---|
| Before Contract | Market access, HS direction, Incoterm, payment, compliance scope | Application, buyer spec | Sales/Engineering/Compliance | Order accepted before configuration can pass market/site |
| Before Production Freeze | BOM, contact parts, electrical/Ex, manual/label inputs, origin version | BOM rev., drawings, supplier evidence | Engineering/Procurement/QA | Component change breaks origin or approval |
| Before Cargo Ready | FAT, docs, packing, booking | FAT, manuals, packed dims, GW/NW, CoG | Factory/QA/Docs | Machine complete but shipment not ready |
| Before CY/CFS cut-off | Customs, trucking, stuffing/gate-in | Declaration, booking, crate map | Ops/Customs/Forwarder | Roll/rebooking/storage |
| Before SI/VGM cut-off | Carrier data, package count/weights, B/L draft | SI, VGM, shipper/consignee/marks | Docs/Forwarder | Amendment/discrepancy |
| After on-board | Origin proof, Final B/L, bank/buyer set, payment | On-board and origin/bank data | Docs/Finance | Late clearance/payment |
12. INCOTERMS – TRANSPORT – PACKING – COST
Small fillers may move by LCL or air; rotary monoblocks and multi-module lines usually favour FCL. Oversized skids/guards/conveyors may require Open Top, Flat Rack or OOG handling. Select the mode based on damage risk, module size, lifting, commissioning sequence and deadline, not freight alone.
- ✓ Packed L×W×H per crate/module
- ✓ GW/NW + CoG
- ✓ Lifting/forklift points
- ✓ Floor load / skid base
- ✓ Nozzle/starwheel/load-cell/HMI protection
- ✓ Clean, dry and capped contact surfaces
- ✓ Residual liquids declared/drained
- ✓ Battery/UPS DG screening
- ✓ ISPM 15 where relevant
- ✓ Crate map by installation sequence
- ✓ Moisture/corrosion protection
- ✓ Stuffing/lashing photos
13. RISKS & CONTROL POINTS
| RISK | ROOT CAUSE | IMPACT | CONTROL | TIMING |
|---|---|---|---|---|
| Wrong 8422.30 vs pump/packing/parts | Classification by trade name | Customs/C/O correction | Technical classification sheet | Pre-contract |
| Japan Food Sanitation trigger missed | No food-contact scope check | Import notification/test delay | Contact-material list + importer confirmation | Pre-contract/Freeze |
| Japan C/O with no tariff benefit | Assuming FTA always saves duty | Unnecessary lead time | Check final Japan tariff | Origin review |
| Blanket CCC assumption in China | “Electrical machine = CCC” | Wrong testing/certification cost | CCC scope screen | Pre-contract |
| Ex component missed in China | No hazardous-area BOM | Component hold/replacement | Ex list + scope | Production Freeze |
| US site rejects electrical package | No NRTL/AHJ route | Field rework/commissioning delay | Buyer/AHJ/NRTL path in Contract | Pre-contract |
| Food/pharma cleanability failure | Wrong MOC/gasket/weld design | FAT/SAT rejection | URS + MOC + weld/passivation records | Design/Freeze |
| Origin fails after BOM change | Calculation uses old BOM | Preference loss/verification | BOM change control | Before proof |
| Residual fluid/DG issue | Oil/chemical not declared or drained | Carrier rejection/claim | SDS + drain checklist | Before booking |
| Crate does not fit | Overall machine size used | Repacking/OOG/rebooking | Container-fit review | Before booking |
| CoG/lifting error | Not recalculated after disassembly | Damage/safety incident | Lift plan + marked CoG | Packing/loading |
| B/L/C/O/serial mismatch | Multiple data sources | Amendment/L/C discrepancy/origin query | One source of truth | Before release |
14. FAQ
1. Can standard filling machines be exported from Vietnam normally?
Usually yes where no specific control trigger applies, but exact model, end-use, components and destination rules must be screened before a final conclusion.
2. Does HS 8422.30.00 cover every “filling” machine?
No. It fits equipment whose principal function falls within filling/closing/sealing/labelling containers. Pumps, dosers, weighing systems and wrappers may classify elsewhere.
3. Must a filler–capper–labeller be split into separate machines?
Not automatically. Where exported as a functional unit, classify the unit according to the applicable functional-unit/principal-function logic and evidence.
4. What is different for food fillers imported into Japan?
Food-contact machine parts can fall under the Food Sanitation Act definition of apparatus, and importers may need Article 27 notification. Freeze contact materials and supporting test evidence.
5. Does every electrically powered filler need PSE in Japan?
No. Screen exact electrical products/components against DENAN scope; the Japanese importer bears obligations only where the goods are in scope.
6. Is preferential C/O always necessary for Japan?
No. Japan’s 2026 tariff shows 8422.30 as Free, so preferential proof may not create extra duty savings when final HS matches.
7. Does a filling machine for China automatically need CCC?
No blanket conclusion. The current CCC catalogue does not list filling machines as a standalone category; screen components and explosion-proof products by exact scope.
8. What ACFTA origin rule applies to 8422.30?
The currently cited ACFTA PSR is RVC40 or CTSH. Verify HS version, PSR and actual BOM before issuing Form E.
9. Does a filler exported to the US always need UL/NRTL certification?
There is no single federal customs certificate for every filler. Workplace electrical equipment may need NRTL approval/acceptance, and the buyer/AHJ may require listing or field evaluation.
10. Does FDA certify food filling machines?
FDA requirements such as 21 CFR 117.40 govern equipment used in food facilities for cleanability and contamination control; this should not be described as FDA certification of every imported machine.
11. When is the machine Cargo Ready?
Only when both physical goods and shipment data/compliance are ready: FAT released, BOM frozen, packed dimensions/GW/NW/CoG known, crate map complete and required market documents available.
12. What must be archived after sailing?
Customs, final transport documents, origin file, shipped BOM, market compliance evidence, technical/manual drawings, packing/lifting proof, bank/payment and commissioning/warranty records.
15. FINAL OUTPUTS & POST-SHIPMENT ARCHIVE
The archive should allow another employee to reconstruct which machine and serial shipped, filling principle, BOM revision, market-compliance route, origin basis, crate/module structure and buyer document set months later.
- ✓ Export customs file
- ✓ Contract/PO + final Invoice/PL
- ✓ Final B/L/AWB/Sea Waybill
- ✓ C/O/proof + Origin Audit Trail
- ✓ Catalogue, layout, electrical/P&ID
- ✓ FAT/SAT/commissioning/warranty
- ✓ Market/importer confirmations
- ✓ Packing/lifting/lashing evidence
- ✓ Buyer/bank docs + payment
- ✓ Claim/survey records if any
RECOMMENDED OPERATING APPROACH
For filling machinery, the key checkpoints are Production Freeze and Cargo Ready. Freeze BOM/contact parts/electrical scope before origin and market-compliance closure; issue booking only after packed dimensions, weights, CoG, residual-fluid/battery screening and crate mapping are confirmed.
Review HS, Vietnam policy, Japan food-contact/PSE, China CCC scope, US NRTL/GMP, ACFTA/RCEP and the exact-model Origin Audit Trail.
Synchronize Invoice–PL–customs–SI–VGM–B/L–origin proof; control packing/lifting/OOG and buyer/bank/commissioning documents through post-shipment.
NEED TO REVIEW IMPORT PROCEDURES OR A SHIPPING PLAN?
Send us the product name, shipping route, current dossier, or implementation request in advance so we can suggest a suitable approach that is practical, focused, and aligned with your shipment.
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