Implementing diesel engine emission roadmap - Preventing businesses from hoarding

Enterprises must report on the import volume, manufacture and/or assembly of automobile with diesel fuel monthly, register and put to the market before 31st December, 2017. Illustration.

Implementing the Prime Minister's instruction in Official Letter 436/TTg-CN dated 28th March, 2017, the MOT has issued Document 3273/BGTVT-MT sent to the Vietnam Register and vehicles import, manufacturing and/or assembling enterprises for implementation.

Accordingly, the MOT suggested that enterprises importing, manufacturing/assembling automobiles should urgently review and complete plans on importing and manufacturing automobiles using diesel fuel to ensure the fulfillment of Customs procedures, register and put to the market before 31st December, 2017, which stated the number of imported, manufactured and assembled vehicles by type of diesel fuel by 31st March, 2017; scheduling the imported, assembled, and marketed vehicles by type of diesel fuel in each month from April 2017 to December 2017.

At the same time enterprises commit to re-export or export cars using diesel fuel that do not complete the Customs procedures, registration and release to market before 31st December, 2017 and the above plan will send to the Ministry of Transport before 15th April, 2017.

The ministry also asked the Department of Vietnam Register to expeditiously carry out registration procedures for importing, manufacturing and assembling automobiles using diesel fuel in accordance with regulations. To compare the plans of importing and manufacturing automobile using diesel fuel of each enterprise to sum up and report the registration results to the Ministry before the 30th monthly, put into market the automobiles using diesel fuel of each enterprise. According to each type of vehicle and proposals, timely recommend to ensure compliance with the direction of the Prime Minister.

In addition, the Ministry of Transport requests the Department of Environment to synthesize and announce plans to import and produce cars using diesel fuel from enterprises to the Vietnam Register to compare and organize the registration work. To assume the prime responsibility for, and coordinate with the concerned agencies to supervise the implementation of the importing, manufacturing and assembling enterprises with the use of diesel fuel; Monitor, urge and monthly report to the Ministry of implementation results, arising problems then propose solutions to ensure that from 1st January 2018, all types of new manufactured, assembled and imported vehicles must meet EU IV regulation in accordance with Decision 49/2011/QD-TTg.

This solution can be understood as a solution of the management agency to “prevent” the company to take advantages to import the diesel engines cars that do not meet the EU IV regulation level 4 before deadline of 31st December, 2017.

However, the fact that this regulation of the Ministry of Transport also makes difficulties for enterprises to realize since in the first 3 months, the importing and trading activities of enterprises are almost frozen to wait for the Prime Minister's final decision.

In the last days of March, in document 436/TTg-CN signed by Deputy Prime Minister Trinh Dinh Dung, the time of implementation were decided and then a guideline for implementation has been released by the Ministry of Transport.

The time for submitting the planning report to the Ministry (April 15th, 2017) as well as the implementation of the 2017 plan is only a few months to come so enterprises will be difficult in ordering, producing and consuming products, an item that must be planned before 3-4 months.

Not to mention the plan of the enterprise is just expected, putting product to market depends on the needs and developments in the market, it is difficult for any business to correctly calculate. If not consumed before 31st December, 2017 the re-export or export products will not only lead to losses but most likely the enterprises will miss the deadline.

With this fact, it is likely that the implementation will cause problems that need to be resolved similar to the implementation of Circular 20/2011/TT-BCT of the Ministry of Industry and Trade regulations on letter of attorney for the imported vehicles before.

Regarding the implementation of the roadmap under Decision 49/2011/QD/TTg (Decision 49) of the Prime Minister, in November 2016, the meeting was chaired by Deputy PM Trinh Dinh Dung with the ministries, companies relating to petroleum, the Vietnam Automobile Manufacturers Association (VAMA) on the implementation of Decision 49, showed the reality that "Management agencies and enterprises have yet deployed effectively synchronized". Notably, there is no initiative in petroleum production, retail petroleum distribution system is not ready to meet the EU IV regulation 4. At the same time, the system of automobile maintenance and maintenance to meet the EU IV emission regulation 4 has not been implemented synchronously. Therefore, the meeting has reached the unified direction as follows: petroleum engine cars follow the roadmap prescribed in Decision 49; Passenger cars, diesel-powered buses adopt emission standards of level 4 from January 1st, 2018, and diesel-powered trucks that meet EU IV regulation by 2022.

On 5th January, 2017, the Ministry of Transport issued a document requesting comments of the ministries on the amendment of Decision 49, proposed to delay the application of EU IV emission regulation 4 with a number of vehicles. According to the Ministry of Transport, for vehicles meeting the emission level 4 requires complex technology and high cost, only countries with advanced industrial production can meet. Therefore, the Ministry of Transport proposed to delay the application of EU IV emission regulation 4 with a number of vehicles using diesel fuel.

On 23th December, 2016, VAMA also reported to the Prime Minister proposing to delay the application of emission standards for diesel vehicles because of their concerns on fuel not to meet the EU IV emission regulation.

On March 10th, 2017, the Office of the Government issued Official Letter No. 126/TB-VPCP announcing the Prime Minister's opinion on "Keeping the roadmap for application of motor vehicle emission standards" under Decision 49. Particularly diesel-powered cars will be allowed to carry out until 31st December, 2017.

On March 14th, 2017, the Ministry of Transport issued document 2627/BGTVT-MT to the Prime Minister proposed the time of implementing Decision 49 for cars and diesel engines at the end of March 31st, 2017.

On 28th March, 2017, the Prime Minister issued Official Letter 436/TTg-CN set the deadline for importing, manufacturing and assembling automobiles using diesel fuel at 31st December, 2017 as directed by the Prime Minister in Document 126/TB-VPCP dated 10th March, 2017.