VASEP is concerned about the contents of the draft circular replacing Circular No. 15/2018/TT-BNNPTNT promulgating the HS Code Table for the List of Goods under the management of the Ministry of Agriculture and Rural Development. It will cause many difficulties for businesses in the quarantine stage, the representative of the Department of Animal Health confirmed.

Illustration. Source: Internet

Quarantine products increase

According to Nguyen Hoai Nam, Deputy General Secretary of the Vietnam Association of Seafood Exporters and Producers (VASEP), in the past 10 years (2010-2020), the Ministry of Agriculture and Rural Development has issued four circulars guiding and regulating quarantine of aquatic products, including: Circular 06/2010/TT-BNNPTNT (TT06) dated February 2, 2010, then replaced by Circular 26/2016/TTBNNPTNT (TT26) dated June 30, 2016.

TT26 was amended and supplemented with a number of articles by Circular 36/2018/TT-BNNPTNT (TT36) dated December 25, 2018 and Circular 11/2019/TT-BNNPTNT (TT11) dated October 22, 2019.

The Law on Veterinary Medicine does not stipulate that products processed from “animal products” or products containing “animal products” are subject to animal quarantine. However, the documents under this Law detail the direction of diversifying the products that need to be quarantined.

"In parallel with the existing regulations, the process of replacing, amending and supplementing circulars, the list of imported aquatic products subject to quarantine will be expanded without any change in legal basis or risk reporting, international practices or disease information," said Nam.

While these technical documents are controversial because of the tendency to expand the subjects that need to be quarantined, at present, the Ministry of Agriculture and Rural Development is collecting opinions to finalize the draft circular to replace Circular No. 15/2018/TT-BNNPTNT of the Minister of Agriculture and Rural Development promulgates the HS Codes for the List of Goods under the management of the Ministry of Agriculture and Rural Development (TT15).

This is a circular on HS codes for the list of goods under the management of the Ministry of Agriculture and Rural Development, which clearly stipulates which lines must be imported under quarantine and food safety inspection or the quality of the goods checked.

Nam said that the quarantine work of the veterinary industry with processed seafood products is actually food safety inspection. TT15 is a list for Customs authorities to compare and consider specialized inspection certificates to clear shipments.

“If promulgated with the list following the direction of this draft amendment, it will make more than 80% of the products imported for production and export processing and export processing on the list of goods exempted from food safety import inspection (according to Decree 15/2018/ND-CP detailing the implementation of a number of articles of the Law on Food Safety) will be subject to 100% quarantine upon import," said Nguyen Hoai Nam.

What does the Department of Animal Health say?

Regarding amending TT15, before the concerns of VASEP, the Department of Animal Health has given a detailed response.

According to the Department of Animal Health, the criteria that VASEP considers to be food safety criteria are those of organisms such as E. Coli, Salmonella and Vibrio cholera. Are all microorganisms that cause diseases in animals and are transmitted to humans and are to be quarantined by the Department of Animal Health.

Imported aquatic products need to be checked for criteria firstly for unprocessed products to prove that they do not carry pathogens.

For processed products, the World Organization for Animal Health (OIE) stipulates that each disease has a different level of heat treatment, and the exporting country needs to demonstrate that the treatment process is in accordance with OIE regulation and recognized by Vietnam.

"However, one aquatic species can be infected with many diseases in the list. Therefore, the assessment of processed seafood products that meet the treatment requirements of each disease is very complicated," said Nguyen Van. Long, Deputy Director of the Department of Animal Health, said.

The leader of the Department of Animal Health further said that many countries importing Vietnamese seafood require testing of disease criteria for aquatic products, such as Australia, Korea, China, Brazil, Saudi Arabia, and Eurasian Union countries, etc. In addition, some other countries require Vietnam to demonstrate a disease control system (including quarantine upon importation) to consider opening the market for Vietnamese seafood.

The Department of Animal Health is assigned by the Ministry of Agriculture and Rural Development the task of quarantining animal products in accordance with the Law on Veterinary Medicine in 2015 and the documents under the Law, and at the same time inspecting the food safety of some items according to the Law on Food Safety 2010 and the guiding Decree to implement a number of articles of the Law on Food Safety.

Nguyen Van Long emphasized that these activities are currently unified in a specialized inspection focal point. An imported product is inspected by a specialized inspection agency, both for quarantine and for food safety inspection, in accordance with the spirit of the Government's Decrees and Resolutions on reform in specialized inspection.

"The overlapping inspection criteria between quarantine and food safety inspections only have to be done once, which is convenient and does not incur costs for testing and inspection for enterprises' shipments," Long said.

The Ministry of Agriculture and Rural Development regularly reviews items subject to specialized inspection (quarantine, quality inspection, food safety inspection) within the scope of state management of the Ministry, reducing and changing inspection methods towards the direction of the Ministry of Agriculture and Rural Development to create maximum advantages for businesses under the direction of the Government.

"Currently TT15 is still in the process of developing, collecting opinions from organizations and businesses to be amended. We are very respectful to listen to comments and will have appropriate solutions to coordinate with the Legal Department (Ministry of Agriculture and Rural Development) in the direction of ensuring health and safety for people, domestic animals and the environment, but also creating maximum advantages for businesses," said Nguyen Van Long.