Amending the Circular 55/2011/TT-BNNPT in compliance with current law aims to facilitate seafood enterprises

(vasep.com.vn) On April 24th 2013, Vietnam Association of Seafood Exporters and Producers (VASEP) issued the official letter 74/2013/CV-VASEP and sent it to the Minister of Agriculture and Rural Development. Accordingly, VASEP asked MARD to amend the Circular 55/2011/TT-BNNPTNT in order to be compliant with current law, facilitating seafood enterprises.

According to the official letter, VASEP urgently asked MARD to implement the following requirements:

1. MARD should direct the National Agro Forestry Fisheries Quality Assurance (NAFIQAD) to amend the Circular 55 in accordance with Food Safety Law, Law 05/2007/QH12 of Nov 21st 2007 on Product and Goods Quality and international regulations. The above regulations establish that seafood exporters can ship their products if their production conditions are ensured by competent authorities, this should not provide an high frequency of samplings for inspecting as a condition for granting Health Certificate (HC). Accordingly, enterprises will avoid complicated procedures, unnecessary loss of time with a consequent lowering of costs.

2. Competent authorities should reduce frequency of samplings on consignments before export so that exporters must not suffer from related difficulties which could reduce  their competitiveness. VASEP suggests competent agencies should adopt Thailand’s sampling frequency. Competent agencies in Thailand take samples to inspect A grade factory every three months and every two months for B grade factory.

3. Building a system to automatically grant HC online through NAFIQAD’s website. Relying on that, exporters which can meet conditions of food safety could submit their documents and receive HC rapidly.

4. Repealing punitive sanctions for violations of food safety and stopping sanctions that are not consistent with the Food Safety Law, the Government’s Decree 91/2012/NĐ-CP of Nov 8th 2012 on the penalties for administrative violations of food safety and Law on Product and Goods Quality. One of these sanctions, which is too strict and creates hardship for exporters, is that they must stop exporting if, during 6 months, they have more than 3 consignments of similar products being alerted by importers on quality and food safety.

5. MARD should direct NAFIQAD to amend and simplify the process and procedures of inspection, lower time and costs for testing food safety and hygiene with an aim to giving the most favourable conditions for seafood exporters.

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