After reviewing and studying carefully the draft contents of the Circular amending and supplementing the Circular No. 25/2016/TT-BNNPTNT, comparing with the current law provisions, international practice, the Vietnam Dairy Association basically agreed as the content of the draft. For paragraphs 1, 3 and 4, part II of Appendix I, the Association proposed to implement according to Option 2 as the Department of Animal Health - Ministry of Agriculture and Rural Development proposed to create favorable conditions for production and business, ensuring safety for consumers, applying advanced risk management principles of the world. However, the Editorial Committee should pay attention to the following contents:

1. A clear list of high-risk groups should be issued, using nominal names and codes in the international HS system for avoiding confusions. Food preparations containmilk / dairy products or components of processed animal origin with HS codes of chapters 19, 21 and 22 should be classified as low risk.

2. Specifying the inspection sampling processstipulated as the sameby the Government to the food safety inspection process in the Decree No. 15/2018 / ND-CP.

3. For imported food, both food safety inspection and animal quarantine, the Resolution 19 and Clause 1, Article 15of the Decree No. 15/2018 / ND-CP stipulated "In case of an imported goods shipment" If there were many foods under the management of many ministries, the state inspection agency was the agency assigned or assigned by the Ministry of Agriculture and Rural Development, so we would like to recommend the Circular 25 to specify "In case of imported food, both the food safety inspection and the animal quarantine only performed animal quarantine" to meet the Resolution 19 and also in accordance with Veterinary Law and theDecree 15

4. For export goods, quarantine regulations and quarantine certificates shall be issued at the request of the importing country to encourage export.

Comments on the above if both ensure safety for consumers, meet the requirements of state management, and create favorable conditions for production and business and in accordance with international practices, meet the requirements demand of the Resolution No. 19/2018 / ND-CP "Ministry of Agriculture and Rural Development: considering and early solving difficulties for enterprises on: (1) the area of goods subject to quarantine of animals was too large, over necessary (should only be quarantined for fresh or semi-processed products (2) the situation of two units inspecting a shipment or a unit of inspection in accordance with the two laws but with two different procedures, granted two certificates. "