A facial mask may be a non-woven sheet impregnated with serum, a hydrogel mask, a cream or rinse-off preparation, or a dry shaped sheet. Its appearance does not determine the HS code. Classification requires the composition, nature of the preparation, quantity of serum, intended use and retail presentation.
Quick conclusion
A facial mask containing or impregnated with a skin-care preparation, presented as a cosmetic and not as a medicament, is generally considered in heading 33.04 and the relevant 3304.99 subheading. A dry sheet without a preparation, or a product with another objective character or therapeutic claim, must be analysed separately. One code should not be applied to every product sold as a “face mask”.
If the product falls within Vietnam’s legal definition of a cosmetic and is imported for sale, the responsible entity must obtain a cosmetic product notification receipt number before placing it on the market and remains responsible for safety, quality, effectiveness and the accuracy of the submitted information.
Four facts that decide classification
1. Does the product contain a skin-care preparation?
The file should include the INCI formula, serum or gel quantity and manufacturing description. For a sheet mask already impregnated with serum, the skin-care preparation will often give the product its essential character.
2. Is it a finished retail cosmetic or only a dry substrate?
A shaped non-woven sheet that has not been impregnated should not be treated as a finished cosmetic unless the objective records support that character. Dry sheets, textile articles and complete cosmetic preparations require different comparisons.
3. Is the intended effect cosmetic or therapeutic?
Claims such as moisturising, softening or supporting a brighter appearance are generally examined as cosmetic claims. Claims to treat disease, change physiological functions or produce a pharmacological effect may move the product outside the cosmetic framework and require separate legal assessment.
4. How is the product packaged and presented?
A single-use sheet packed with serum, carrying skin-care directions and sold at retail as a cosmetic is important evidence. Advertising language does not replace the formula, product information and notification dossier.
HS codes and competing headings
Heading 33.04 — beauty or skin-care preparations
A non-medicinal facial mask whose objective character is a skin-care preparation is generally considered under 3304.99 and the relevant Vietnamese eight-digit provision. The final code must be checked in the nomenclature and tariff effective on the declaration date.
Heading 63.07 or material headings
A dry mask, an unimpregnated substrate or an article whose objective character is a textile product may require comparison with heading 63.07 or the relevant material provision. Heading 63.07 should not be chosen merely because the finished cosmetic contains a fabric layer; the component giving the essential character must be identified.
Products carrying treatment claims
If the label, dossier or advertising presents a treatment effect, the importer should pause the cosmetic conclusion and determine whether another regulated category applies before importation and circulation.
Recommended customs description
Facial sheet mask impregnated with skin-care serum, principal ingredients …, intended use …, retail packing … sheets/sachet, brand …, new 100%.
Avoid declaring only “mask”. The declaration, invoice, cosmetic notification, original label and Vietnamese supplementary label should consistently identify the same product, packing and use. Do not use treatment or whitening wording that exceeds the accepted cosmetic dossier.
Cosmetic product notification in Vietnam
Under Circular 06/2011/TT-BYT as amended, including Circular 34/2025/TT-BYT effective from 18 August 2025, the entity responsible for placing the product on the market must complete notification before circulation. The receipt number records the notification; it is not a government certification that every safety or effectiveness claim has been substantively approved.
Depending on origin and the applicable treaty framework, the dossier may include a power of attorney, Certificate of Free Sale or an accepted substitute or exemption, together with the current notification form. The responsible entity must ensure that the formula, product name, manufacturer and documents are legally accurate and consistent.
Labelling requirements
The original label and Vietnamese supplementary label must meet the general goods-labelling rules and the specific cosmetic requirements. Ingredients, function, directions, warnings, responsible entity and origin must match the notification dossier. Claims should remain within the cosmetic scope.
Import duty and VAT
The importer must first determine the final eight-digit code, origin and C/O. It should then check the MFN tariff, any special preferential tariff and origin rule, and the VAT rules effective on the declaration date. A single rate should not be advertised for every mask because an impregnated cosmetic and a dry substrate may have different codes, while preferential treatment depends on origin evidence.
Import documents to prepare
- Contract, invoice, packing list and bill of lading.
- INCI formula, catalogue, original label and product photographs.
- Retail packing details and serum quantity.
- Cosmetic product notification receipt appropriate to the actual product.
- Power of attorney, CFS or valid alternative documents where applicable.
- C/O when preferential tariff treatment is claimed.
- Draft Vietnamese supplementary label and evidence supporting the stated cosmetic function.
Practical procedure
Step 1 — Distinguish the finished preparation from the substrate. Confirm whether the sheet has already been impregnated.
Step 2 — Reconcile formula and claims. Remove treatment claims and wording inconsistent with the notification dossier.
Step 3 — Compare HS headings. Record why heading 33.04 applies or why textile/material headings are excluded.
Step 4 — Complete notification and labelling. Do not wait until the goods arrive to discover that the label differs from the submitted notification.
Step 5 — Check duty and make the declaration. Use the actual code, origin, C/O and declaration date.
Frequently asked questions
Is every sheet mask classified under 3304.99?
No. The file must establish whether the product is a skin-care preparation or only a dry substrate. The objective character, not the trade name, controls classification.
Does a cosmetic notification number guarantee customs clearance?
No. Classification, customs documents, labels, formula and the imported product must still be consistent, and the competent authorities may inspect them.
May the label claim that the mask “treats melasma”?
This is high-risk wording. A treatment claim may exceed the cosmetic scope and create legal issues for product classification, notification and advertising.
Verified sources and related guidance
- Circular 34/2025/TT-BYT amending the Vietnamese cosmetic-management rules.
- Circular 06/2011/TT-BYT and its legal history.
- How to prepare for a Vietnam post-clearance customs audit.
- Vietnam customs advisory services.
This article provides general legal information. A conclusion for a specific shipment requires the actual technical file, commercial documents and rules effective on the declaration date.
