On the issue of the Draft Circular amending the Circular No. 23/2013 / TT-BKHCN regulating the introduction of equipment parts in the test line into Group 2 measuring devices managed by the Ministry of Science and Technology, According to the registry units, if any problems arise, difficulties can lead to unenforceability by the following reasons:

- These are the components of a synchronous inspection line when the operation of motor vehicle registration units is currently assigned by the Government to the Vietnam Register. The annual inspection equipment are prescribed in the Government's Decree No. 63/2016 / ND-CP of July 1, Therefore, the introduction of the above-mentioned specialized equipment into the list of measuring equipment under Group 2 under the Ministry of Science and Technology will result in overlapping management between state management agencies and cause difficulties for enterprise.

- Currently, according to Announcement No. 43790 / BKHCN-TDC of the Directorate for Standards, Metrology and Quality, all organizations check measuring equipment Group 2  in localities can not verify the equipment in the test line. Therefore, in order to test these devices, the registration units must bring the equipment to a single place, Vietnam Metrology Institute in No 8, Hoang Quoc Viet Street, Cau Giay District, Hanoi to implement.

- The registration of units in all localities must remove each piece of equipment in the line of verification of their synchronous transfer to the Vietnam Metrology Institute for testing is not possible because:

+ Equipment components in the synchronous line can not be separated when operating;

+ The disassembly of equipment components on the line for inspection, when being put into operation, must be examined and re-evaluated by specialized management agencies according to regulations;

+ The characteristics of the inspection equipment’s parts are very cumbersome, so transporting equipment is more likely to cause damage that does not guarantee test conditions;

+ The removal of equipment and calibration ensure operating conditions taking a lot of time, leading to the whole suspension of the inspection of motor vehicles of the registered unit and affect the transport activities of the businesses  and people in localities.

- The price of measuring equipment of group 2 according to the NM.193.17 / BG-DLVN of the Vietnam Metrology Institute is VND 55 million / test line is too high compared with the current test cost is VND 3.1 million / chain. Therefore, for each unit, the cost can be raised up to VND 220 million / year. The current inspection fees of motor vehicle registrars will not be able to meet the cost of testing of measurment equipment for Measurement Equipment Group 2 of the new regulation.

- In addition, from 1995 up to now, the function of planning and managing the system of motor vehicle registration units has been assigned to the Ministry of Transport and the implementation of such regulations in order to be stable for orderly routine. The new regulation added that the Ministry of Science and Technology is involved in the management of specialized equipment lines is not necessary and cause overlapping in state management between agencies, creating more difficulties for enterprises and expensive, waste money of social.

The registration units propose to the Prime Minister to consider and direct the ministries, branches and related agencies to study:

1 - Remove the equipment mentioned in Sections 7, 8, 9, 21, 22, 49, 86, 90, 92 of Clause 1, Article 4 from the list of measuring equipment of Group 2 in the drafted Circular amending Circular No. 23/2013 / TT-BKHCN.

 2 - To amend relevant provisions of law to specify the assignment of responsibilities to specialized agencies for management and inspection of specialized equipment chains, avoiding the overlapping in management work of the State.

3 - To propose the Ministry of Communications and Transport to increase the prices of motorized vehicle inspection for motorized vehicle registration that ensure revenues are enough offset for incurred costs, maintaining and development of Verification activities.