Recommendation on constraints in the importing fertilizers process
Wed, 27 Nov 2019 09:48:00 | Print | Email Share:
Name of recommendations: Recommendation on constraints in the importing fertilizers process
Recommended by units: The Vietnam Fertilizer Association
Official letter: No 2099/ PTM - KHTH, dated: 2019-09-16
Vietnam Fertilizer Association received recommendations from its members regarding problems in the fertilizer import process, specifically as follows:
1. Name of fertilizer:
Recently in the process of importing fertilizers, inspection organizations such as Vinancontrol, FCC, Vinacert, ... are organizations authorized by the State Department of Plant Protection to check the state notice "all Import dossers as well as packaging of the manufacturers must show the names of fertilizers that the importing enterprises have been granted in the decisions on recognition of fertilizers circulated in Vietnam. "
Currently, the fertilizer in the marketing decision is self-named and used exclusively for the enterprise ... For the fertilizer name in the import decision of the importing enterprise is only required to use when the enterprise makes clearance and conformity procedures for imported fertilizer products to be traded in Vietnam.
Vietnamese importers cannot require foreign manufacturers / suppliers to use names registered for circulation in Vietnam for inscribing in import contracts and documents because the same manufacturer may have more than one manufacturer. Vietnamese enterprises import and use different trade names. Therefore, the import dossier set such as: contract, invoice, bill of lading, type of goods ... cannot name the fertilizer but only the factors such as type of fertilizer, composition, content, limiting factor , volume, origin ... to meet the standards that businesses have registered for circulation and in accordance with Vietnam standards. The Decree 108/2017 / ND-CP on fertilizer management only stipulates the content target, the content of the lower bound fertilizer, does not stipulate the upper limit.
- A number of other difficulties and obstacles that arise when importing:
- SA goods registered for nitrogen (N) content on the circulation decision is 20%; The sulfur content (S) is 23%, when importing products that achieve a higher N content, for example: 20.5% or 21% are in trouble, no application for clearance because it is considered as other fertilizer when it hasn’t circulated.
- - When applying for a license to import fertilizer as a raw material with a humic acid content of 30%, but if the imported product has a higher humic acid content, it is also problematic.
- - Moisture content: According to the Decree 108, some fertilizers in salt form have moisture content of 1%. However, if you use the water-soaked salt when drying out the water from the molecule, the humidity is very high, even higher than 10%. Some consignments (eg SA), after being analyzed with a moisture content higher than the prescribed 1.1%, are used as raw materials, not sold directly to the market, but are still required to be re-exported or destroyed, This provision is unreasonable, causing loss to businesses.
The above regulations are not reasonable, making it difficult for businesses because there are many costs for the shipment being imported (costs due to ship penalties, container storage at the port due to slow clearance ...). The fact that the imported ship arrived at the port without clearance for the above reasons would cause great damage to Vietnamese importers.
3. Recommendations: To resolve the above issues, the Vietnam Fertilizer Association recommends:
- For consignments that have arrived at the port and have problems about the names of fertilizers on import dossiers or packing: The Plant Protection Department shall consider and approve the existing dossiers if the imported fertilizers suit the type. fertilizers in the decision to recognize fertilizers circulated in Vietnam by the Plant Protection Department to enterprises, expediting the customs clearance procedures for the fastest shipment.
- For shipments with high humidity, other criteria are in compliance, businesses committed to putting the goods into production, allow clearance as soon as possible.
- To solve problems for the next batch of goods, the Plant Protection Department is requested to consider and issue specific guidelines for enterprises as well as inspection units and customs offices to clear customs procedures and regulation conformity according to current regulations of the state.
Responded by units: The Ministry of Agriculture and Rural Development
Official letter: No 2440/ BVTV - TTPC, dated: 2019-09-09
The Plant Protection Department received a Document No. 238 / CV-HHPBVN dated August 23, 2019 of the Vietnam Fertilizer Association, on resolving problems in the fertilizer import process. In this regard, the Department of Plant Protection has the following ideas:
1. Clause 1, Article 6 and Clause 1, Article 27 of Decree No. 108/2017 / ND-CP of September 20, 2017 of the Government on fertilizer management stipulate:
“Fertilizers are products and commodities group 2; which are conditional business recognized by the Plant Protection Department in Vietnam "
"Organizations and individuals that have fertilizers already recognized and circulated in Vietnam may import or authorize other organizations or individuals to import them, no import permits are required, except for the case specified in Clause 2 of Article this "
According to these regulations, organizations and individuals are only allowed to import fertilizers that have been recognized for sale in Vietnam; In case of importing fertilizers not yet recognized for circulation in Vietnam, import licenses are required in one of the cases specified in Clause 2, Article 27 of Decree No. 108/2017 / ND-CP.
For cases of importing fertilizers already recognized for circulation in Vietnam, the import dossiers and product information (name of fertilizer; quality criteria; ingredients, nutritional content; methods use, instructions for use; expiry date ...,) must be consistent with the corresponding contents of the Decision recognizing circulating fertilizers (Article 34 of the Decree No. 108/2017 / ND-CP).
2. Regarding quality criteria (including humidity, density, pH ...), ingredients and nutritional content:
The quality criteria, ingredients and nutritional content of fertilizer products registered and announced by organizations and individuals meet the provisions of Sections 1, 2, 3, 4 and 5, Appendix V issued attached to the Decree No. 108/2017 / ND-CP and these indicators are reflected in the content of the Decision recognizing fertilizers circulating in Vietnam; For some types of fertilizer, it is required to check the limiting factors specified in Section 6, Appendix V issued with Decree No. 108/2017 / ND-CP.
Therefore, the state management agency shall base on the criteria of quality, composition and nutritional content in the Decision on recognition of fertilizers circulated in Vietnam; The limiting factors specified in Section 6, Appendix V issued together with Decree No. 108/2017 / ND-CP compare with the acceptable content between the test results and the registered contents specified in Section 8, Appendix V issued together with Decree No. 108/2017 / ND-CP to conclude on the quality of imported fertilizer products.
3. In cases where organizations or individuals importing fertilizers violate law provisions, competent state management establishments shall base on law provisions to handle them.
Therefore, the Plant Protection Department replies to the Vietnam Fertilizer Association for information and dissemination to enterprises engaged in fertilizer production, import and trading activities in strict compliance with law./.
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