Re: Response to Official Letter No. 4304/UBKHCNMT15 dated October 13, 2025, from the National Assembly Committee for Science, Technology and Environment requesting comments on the Draft Law Amending and Supplementing a Number of Articles of 15 Laws in the Field of Agriculture and Environment (hereinafter referred to as the Draft), the Vietnam Chamber of Commerce and Industry (VCCI) summarizes enterprise feedback as follows:

1. Responsibility of Commercial Animal Feed Production Facilities

Article 3.14 of the Draft has repealed Article 32.1 of the Livestock Law, thereby eliminating the requirement for commercial animal feed to announce applicable standards and announce conformity. Thus, it can be understood that enterprises will be exempt from this procedure and only need to meet other management requirements. However, Article 48.2.đ of the Livestock Law stipulates that enterprises are responsible for announcing applicable standards and announcing conformity. The current Draft makes no change to Article 48.2.đ. This creates inconsistency among legal regulations and makes it difficult for enterprises to understand and implement the rules. Therefore, recommendation: Consider amending the provision in Article 48.2.đ of the Livestock Law to ensure consistency among the provisions in the law.

2. Shelf Life of Raw Materials

Article 48.2.c of the Livestock Law stipulates that raw materials used in the finished product must have a shelf life at least equal to the shelf life of the finished product. According to enterprise feedback, this regulation is not entirely reasonable. Specifically, in the animal feed industry, complete mixed feeds have a shelf life of 60 days, and concentrated feeds have a shelf life of 90 days, while some specific raw materials have a short shelf life (due to the nature of the material, they degrade on their own if not processed), such as fresh rice bran products, which have a shelf life of about 7-10 days. Furthermore, the production unit must be responsible for controlling the production cycle and product quality, and the management agency will also inspect based on the quality of the final product.

In addition, this regulation is unfair to domestically produced goods. Imported animal feed is only inspected for quality based on the analysis of the finished imported product, with no control over input raw materials. Moreover, other fields such as food and agricultural supplies do not have such a regulation.

Therefore, recommendation: Consider amending the regulation towards requiring enterprises to be responsible for using raw materials that are within their expiry date.

3. Use of Raw Materials Containing Drug Precursors in Animal Feed Production

Currently, the animal feed production industry uses some types of organic acids containing drug precursors, such as formic acid. This organic acid is used in animal feed to support antibiotic alternatives. However, according to enterprise feedback, the use of substances containing drug precursors in animal feed is currently not clearly regulated, neither in the law on chemicals nor in the law on drug prevention and control. Therefore, recommendation: Consider researching and supplementing regulations on the method of use, management, and supervision of animal feed containing drug precursors.

4. Fertilizer Testing (Khảo nghiệm phân bón)

Article 39 of the Cultivation Law regulates fertilizer testing and cases of exemption from testing. Enterprise feedback requests consideration for amending the testing regulations towards reducing the regulations, procedures, and conditions for testing to reduce the time and resources required for implementation and quickly bring products to market. For instance, consider narrowing the number of plant groups that require testing; shortening the time for small-scale and large-scale testing. For fertilizers such as NPK, organic-mineral, mineral-organic, and microbial-organic fertilizers, consider allowing only large-scale testing to serve as a basis for drafting usage instructions.

These are some comments received by the Vietnam Chamber of Commerce and Industry regarding the Draft Law Amending and Supplementing a Number of Articles of 15 Laws in the Field of Agriculture and Environment. We sincerely hope that the distinguished Agency will consider them for amendment and completion of this Draft.

Thank you for your cooperation./.