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Processing seafood for export. Photo: T.H

Many inadequacies

According to the Vietnam Association of Seafood Exporters and Producers (VASEP), problems in implementing regulations on quarantine of aquatic animals and aquatic animal products according to Circular 26/2016/TT-BNNPTNT and Circular 36/2018/TT-BNNPTNT raise many costs of seafood enterprisesdue to inadequacies in these circulars.

According to the enterprises, the Circulars have not specified the application of risk management principles, priority allocation in management and specialized inspections of imported seafood and imported seafood products. Currently, 100% of shipments (including raw aquatic materials and seafood products) must be checked for sensory criteria, storage conditions, packaging and labeling specifications.

Meanwhile, the Government's Resolution No. 19 and Resolution No. 02 require specialized inspections to follow the principles of risk management.

The Government's Decree No. 15/2018/ND-CP of February 2, 2018, guiding a number of articles of the Law on Food Safetyin Article 13 clearly defines the case of "Products and raw materials for productionimportfor use in the production or processing of exports or for the internal production of organizations or individuals not consumed in the domestic market"are exempt from state inspection on imported food safety (except for cases with warnings about food safety).

However, the provisions of the two abovecirculars do not allow for cases of aquatic animals and aquatic products imported under the forms of E31 (raw materials for export production), E21 (raw materials imported for processing to export), and A12 (imported by type of business as raw materials for further production) on the list of exempted aquatic animal and animal products.

Another problem is that the principle of mutual recognition was not applied among nations. Specifically, imported consignments withfood safety and hygiene certificates issued by the competent authorities of the exporting countriesare not recognized and still subject toinspectionbyveterinary agencies in theimporting country.

There are no instructions on methods of sensory inspection; no regulations on methods of checking the storage conditions, packaging, labeling, appearance, sensory perceptions of each type of product (frozen, chilled, dried), only general regulations such as "suspicion" or found "unsecured" goods under veterinary hygiene requirements to conduct sampling to check sanitary criteria.There are no specific criteria as a basis to conclude "Passed" and "Not passed" duringsensory examination.This easily leads to inaccurate inspector conclusions, causing negativeissues and costs for enterprises.

Some cases, such as importing goods from fishing vessels must be sized and separated types with the witness of the seller, so immediately after bringing the goods from the port,they must immediately divided bysize and put into production, cannot be taken backtowait for the results of the inspection, otherwise it will easily lead to goods damage.Or the goods imported by container but when unloading from the container, although the seller wants to witness the trial production to check the quality of the goods, they must wait for the inspection results of the veterinary agency, which makes it difficult for theenterprises.

Incurring many costs

According to VASEP, problems related to specialized inspections not only affect the production and export time of enterprises but also incur costs. Under the provisions, 100% of seafood shipments, aquatic products imported by any type (E31, E21, A12, A11) must pay the sensory inspection costs as prescribed.

According to the definition of "shipment" added in Circular 36/2018 in Article 2 of Circular 26/2016, "the shipment is the entire seafood productof an import transportation consignmentwith the same bill of lading."

Based on the charge calculation unit mentioned in Section 3.1 above, "Container/Shipment,"but if a consignment of 10 containerson the same bill of lading, the Animal Health Department willcharge the sensory inspection fee.

For fish shipments, the ship has only one bill of lading, but the Animal Health Departmentcharges the sensory inspection fee not for each shipment, they divide total weight of the shipment into each container with 25 tons to charge the sensory inspection fee.

In addition to the sensory inspection fee, if the shipment is subject to sampling inspection (applies for A11, A12, or E31 or E21) but is considered to "not passed" sensory inspection, the enterprise must pay an additional fee for testing, detailed cost depends on the test criteria specified for each item. In addition, enterprises also have to waitfor testing results, making further costs for electricityand storage.

Expenses for traveling, inspectors, other expensesare also very high, which enterprises have to pay and add to the cost of the product.

For seafood and aquatic products imported into bonded warehouses: procedures go through many stages (importing from ports to bonded warehouses, from bonded warehouses exported to enterprises), each stage must carry out the same proceduresfor the same shipment which takes longer and costs more.Thesame type of export but if the shipment exports many times,the cost will be more.

From the above inadequacies, VASEP proposed MARD to consider revising Circular 26 and Circular 36, developingsolutions to apply the principle of mutual recognition among countries, recognizing the inspection results of the authority of the exporting countryasa way that the EU and other importing countries are recognizing Vietnam, they only check 2-5% of the number of imported consignments under normal conditions.

Applying risk management principles, priority allocation in specialized management andinspection of imported seafood and fishery products. Applying the reduction and exemption regime for the sensory examination criteria instead of checking 100% of the shipmentto avoid overloading for enterprises and veterinary staff.

For aquatic products imported for trading but used as raw materials for further processing (type A12), it is allowed to apply the exemption of specialized inspection or frequency inspection.

By Le Thu/ Binh Minh

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