Decree 108/2017 / ND-CP regulating strict fertilizer management from input to output is consistent with practical requirements. Fertilizer must be recognized for circulation and declared conformity before putting fertilizers on the market according to the current regulations are 2 activities that do not overlap, do not lead to overlapping in management.

Thuy Kim Sinh Company Limited (HCMC) is an enterprise operating in the field of manufacturing and trading in fertilizers used in agriculture.

According to Decree 108/2017 / ND-CP on fertilizer management, a fertilizer producer needs: A certificate of eligibility for fertilizer production is valid for 5 years. To be granted the Certificate, the manufacturer must meet the technical requirements and be directly verified by the competent authority at the production establishment. After one year of operation, the production establishment must have a quality management system that meets ISO 9001. Every year, the local specialized management agency will inspect the production facility.

A fertilizer product permitted to be circulated in the market should: Must have quality standards in accordance with the provisions of Decree 108/2017 / ND-CP; the application must be appraised by the Plant Protection Department for the application meeting the requirements for issuing a sale decision; Fertilizer lots, before being released, must have standard test results. Every year, the local specialized management agencies conduct random sampling on the market, and test products according to the announced criteria.

Như vậy, theo Công ty TNHH Thủy Kim Sinh, các quy định, yêu cầu về quản lý phân bón sản xuất trong nước được quy định trong Nghị định 108/2017/NĐ-CP đã đầy đủ, nên việc yêu cầu sản phẩm phân bón sản xuất trong nước cần thực hiện chứng nhận và công bố hợp quy là trùng lặp, dẫn tới việc sản phẩm phân bón sản xuất trong nước khi lưu hành trên thị trường cần tới 3 “giấy phép”: Quyết định công nhận lưu hành do Cục Bảo vệ thực vật cấp, Chứng nhận hợp quy do tổ chức được Bộ Nông nghiệp và Phát triển nông thôn chỉ định cấp và thông báo tiếp nhận hợp quy do Sở Nông nghiệp và Phát triển nông thôn cấp.

Trong khi nội dung trong Giấy Chứng nhận hợp quy chỉ là: “Chứng nhận sản phẩm phân bón phù hợp với yêu cầu trong Nghị định 108/2017/NĐ-CP” – yêu cầu bắt buộc để được cấp quyết định công nhận lưu hành.

I (Chinhphu.vn) - Decree 108/2017 / ND-CP regulating strict fertilizer management from input to output is consistent with practical requirements. Fertilizer must be recognized for circulation and declared conformity before putting fertilizers on the market according to the current regulations are 2 activities that do not overlap, do not lead to overlapping in management.

Thuy Kim Sinh Company Limited (HCMC) is an enterprise operating in the field of manufacturing and trading in fertilizers used in agriculture.

According to Decree 108/2017 / ND-CP on fertilizer management, a fertilizer producer needs: A certificate of eligibility for fertilizer production is valid for 5 years. To be granted the Certificate, the manufacturer must meet the technical requirements and requirements and be directly verified by the competent authority at the production establishment. After one year of operation, the production establishment must have a quality management system that meets ISO 9001. Every year, the local specialized management agency will inspect the production facility.

A fertilizer product permitted to be circulated in the market should: Must have quality standards in accordance with the provisions of Decree 108/2017 / ND-CP; the application must be appraised by the Plant Protection Department for the application meeting the requirements for issuing a sale decision; Fertilizer lots, before being released, must have standard test results. Every year, the local specialized management agencies conduct random sampling on the market, and test products according to the announced criteria.

Currently the Department of Agriculture and Rural Development City. Ho Chi Minh City is temporarily suspending receiving dossiers of announcement of fertilizer conformity. Thus, even in the case that Thuy Kim Sinh Co., Ltd. has a decision to recognize the circulation of fertilizers, has carried out certification of conformity at an organization designated by the Ministry of Agriculture and Rural Development, it still cannot sell. products to the market.

While waiting for regulation conformity certification and announcement, circulation of products will decrease gradually, businesses waste costs, time and business opportunities. Farmers miss the opportunity to use good products to meet urgent needs.

Through the receiving system, responding to the enterprise's recommendations, Thuy Kim Sinh Co., Ltd. proposed to remove the requirement for certification and regulation conformity announcement for domestically produced fertilizer products to decide to recognize circulation as the license means substantially - the product is allowed to circulate in the country.

Regarding this issue, the Plant Protection Department - Ministry of Agriculture and Rural Development has the following opinions:

Decree 108/2017 / ND-CP stipulates strict fertilizer management from input (recognition of fertilizer circulation) to output (when put into circulation, used in the market) is suitable for practice in the present period. Fertilizer must be recognized for circulation and announced conformity before putting fertilizers on the market according to current regulations are two activities that do not overlap, do not lead to overlapping in management.

The marketing authorization decision is an important basis for maintaining quality control, inspection, examination, and traceability. In the decision on recognition of a circulating fertilizer, in addition to information on quality norms, there are also mandatory information on the label (type of fertilizer, name of fertilizer, method of use, instructions for use, expiry date. fertilizer codes) so that users can know the origin, properties, uses and use properly and effectively.

Announcement of regulation conformity for a specific fertilizer product after being manufactured, imported for circulation and use comply with the law on product and goods quality and according to standards and regulations, technical standards.

Accordingly, the announcement of conformity is based on results of self-assessment of the conformity of organizations and individuals having fertilizers or certification results of certification organizations registered or recognized in accordance with the law. or the certification results of the designated certification body.

Fertilizers that have been issued with decisions recognizing circulation but have not yet produced or imported for circulation in the market, have not yet been subject to regulation conformity announcement.

Organizations and individuals that have fertilizers can apply the method of regulation conformity declaration based on self-assessment results without going through the regulation conformity certification body.

Fertilizers that have been issued with a decision on circulation but have a number of quality indicators without a laboratory designated for testing are fertilizers recognized for transition circulation under Article 47 of Decree No. 108 / 2017 / ND-CP (not a new fertilizer).

Therefore, no new fertilizers that have been proven through testing under the provisions of Decree No. 108/2017 / ND-CP and recognized for circulation are not allowed to circulate.

Previously, at the time when the organizations and individuals that had fertilizer, when producing and putting fertilizer into circulation, there was no national standard (TCVN) on testing methods and neither did organizations and individuals have fertilizers. publish the establishment standard (TCCS) on the method of testing that indicator. Fertilizers subject to the above-mentioned cases may be declared for regulation conformity to put into circulation based on the results of conformity assessment by a foreign conformity assessment organization recognized under the provisions of law (for with imported fertilizers) or the organizations having fertilizers announce the TCCS on the testing method being applied and send it to the Plant Protection Department for consideration and designation of qualified certifying organizations.

Currently, the Department of Agriculture and Rural Development. Ho Chi Minh City is receiving announcement of fertilizer conformity according to Notice No. 621 / TB-SNN dated November 20, 2018.