Part 1: Slow implementation: Businesses say specialised inspections: many procedures and costs

	Many customs procedures for specialised inspection
	Da Nang Customs: Handling procedures complying with regulations, do not ask for more documents
	Continue listening to ministries suggesting to the project of checking product qualities
	Enterprise takes responsibility with the use purpose of imported goods

Many fields and items face problems in specialised inspection for import-export goods.

With the guidance of the Government in recent years, specialised inspections for import-export goods have achieved positive results, the rate of imported shipment subject to specialised inspections before customs clearance has fallen from 26% in 2015 to 19.1%; the procedure time in many specialised inspections has significantly reduced.

However, this figure has not met the requirements of the Government of the 10% reduction for import goods in 2018-2019. There are shortcomings and overlaps that have not yet been handled.

Shortcomings in specialised inspections have affected the imports of businesses. For example, Network Infrastructure Services Joint Stock Company (Hanoi) has carried out procedures and found the competent authority for handling for many months, and finally its imported goods must be re-exported and the company cannot complete specialised inspection procedures for customs clearance.

Network Infrastructure Services Joint Stock Company carried out customs procedures to import salt flush containing 10% pure salt with sodium chloride content :> 99%, calculated on a dry basis (NaCl-2.25g/pack, 30 packs/box). HS Code: 25010092.

The company registered for quality inspection at the Ha Noi Agro-Forestry-Fisheries Quality Assurance Sub-Department under the Hanoi Department of Agriculture and Rural Development on October 3, 2018 and sent a sample for quality inspection at the Quality Assurance and Testing centre 1 and quality indicators shown in the test results.

However, on October 16, 2018, the Ha Noi Agro-Forestry-Fisheries Quality Assurance Sub-Department issued a written instruction stating the item imported by the company was not subject to imported salt managed by the Ministry of Agriculture and Rural Development and the HS code of this item was 3004.90.99 (under the specialised management of the Ministry of Health), and returned the company’s dossier and instructed the firm to contact the Ministry of Health for guidance on import procedures.

The company did not have the right address and then it went to the Department of Medical Equipment and Facilities (Ministry of Health). On October 18, 2018, the company sent a dispatch to the department for guidance. However, months later due to the the failure of specialised inspection procedures for customs clearance, on June 2019, the company had to re-export the shipment.

Many other businesses have also found shortcomings in the specialised inspection process. Director of TRA-SAS Company (based in Ho Chi Minh City) Nguyen Viet Huy said although ministries and sectors have made great efforts in reforming procedures, there still have been shortcomings, even costing businesses time and money.

For specific examples of importing non-commercial publications, Huy said as per Article 25 of the Publishing Law 19/2012/QH13 and Notice 513/STTTT-XBPH of the Department of Information and Communications, the time limit for handling dossier is seven working days from the date of receiving sufficient dossiers (for publications not subject to appraisal); 15 working days from the receiving sufficient dossiers (for publications subject to appraisal).

In fact, imports of items such as catalogues and kids comics take seven working days for registration forms, taking sample, sealing samples to submit to the Department of Information and Communications. The company must wait 15 working days for verification and be issued import permit for customs clearance. Thus, for each shipped catalogue and kids comic, the company must wait for nearly a month at ports for customs clearance, incurring costs for container storage fees, Huy said.

Huy said there are still many shortcomings for the import of textile products and clothes, even more than prior to the issuance of revised documents. For example, Circular 21/2017/TT-BCT of the Ministry of Industry and Trade on National Technical Regulation on the content of formaldehyde and certain aromatic amines derived from Azo colourants in textile products taking effect from 1 January 2019 stipulates “Textile and garment products before being sold must be inspected and businesses declare their conformity with the Department of Industry and Trade. This costs money and is time consuming for businesses.

Previously, Circular 32/TT-BCT provides that businesses only registered for State quality inspection and then their goods would be cleared. This took about two working days and costed 3-5 million VND. Now, according to the new Circular, for products to be sold on the market, businesses must spend more than one month to get the certificate of conformity approved on the system, 3-4 working days for testing for conformity certification, 3-5 working days for issuing certificate of conformity and 5-20 working days for stamping for each product code and pay from VND 10-20 million -Huy said. He also said effects of formaldehyde and certain aromatic amines derived from Azo colourants do not specify. Thus, the Ministry of Industry and Trade should remove and not apply this control or apply the exemption from inspection but approve the dossier of announcing the conformity for test samples of 3 to 5 consecutive shipments that meet the requirements, and should not require the test of each shipment to save test costs, because the business must spend from VND 7 to 17 million for each test.

There are problems in specialised inspection for import-export goods in many fields and items, even overlapping management between ministries or units in each ministry. How many difficulties are the business suffering?.