Seafood enterprises propose to remove obstacles from exporting to the EU

	Seafood enterprises have more opportunities to expand market share in China
	Decrease in exports affects the profits of seafood enterprises
	Green seafood enterprises are the best choice for sustainable exports

The enterprise bought yellowfin tuna but could not obtain an S/C certificate. Photo: TH.

Difficulties in getting S/C

According to Truong Dinh Hoe, General Secretary of VASEP, on February 13, 2023, the Prime Minister issued Decision No. 81/QD-TTg promulgating the "Action plan to combat illegal fishing, not reported and not obeyed the law, preparing to work with the Inspection Delegation of 4th European Commission". Therefore, VASEP Association and member seafood businesses have updated and understood the contents of Decision 81 to implement the Prime Minister's direction well.

However, in the implementation process, enterprises have encountered inadequacies in the issue of certification of raw materials (S/C) and certificates of food safety (H/C) for the production and export of seafood to the EU.

Specifically, there are shortcomings in the procedure for applying for an S/C certificate, which prevents businesses from obtaining this certificate according to regulations. For example, the enterprise bought yellowfin tuna but could not obtain an S/C certificate. According to the explanation of the fishing port management board, if the small-size tuna is really yellowfin, then the port management board will issue the S/C certificate. However, large fish are not yellowfin tuna, so the fishing port does not issue S/C certificates.

However, VASEP and businesses did not find any specific regulations regulating the distinction or classification of yellowfin tuna by size, as explained by the fishing port management.

The enterprise buys fish according to the actual quantity at the port and applies for the S/C according to the quantity purchased, but the fishing port management board does not issue the S/C according to the actual quantity and only issues it according to the less quantity because the fishing port explains the big amount of fishing is not reasonable.

The main fishing profession for enterprises that purchase swordfish from ships with fishing licenses is tuna fishing. However, during the fishing process, in addition to tuna as the main fishing material, the ship can still exploit other types of fish, such as swordfish, filet, and mackerel.

However, the fishing port did not issue an S/C certificate for the swordfish shipment. In addition, some fishing ports stopped issuing S/C certificates for raw material batches of long-term fishing vessels (over 1 month) – parameters through the records.

Enterprises said that, from February 16, 2023, the Regional Center for Agro-Forestry and Fisheries Quality 4 (NAFIQAD 4) issued an official letter No. 67/TTCL4-CL to the Directorate of Fisheries to verify the suitability of the contents of the Fishing certificate and fishing log. However, in the meantime, the Directorate of Fisheries has not had a reply to NAFIQAD 4 or a general guideline to send to the units, so the fishing port management board has stopped issuing the S/C.

Removing obstacles to seafood exports to the EU

In addition to difficulties in applying for S/C papers, seafood enterprises also face inadequacies in the procedures for applying for food safety certificates (H/C) for some shipments of exploited seafood for export to the EU.

For example, some businesses face problems when they cannot obtain H/C papers for shipments with raw materials from long-term fishing vessels. According to Document No. 67/TTCL4-CL of NAFIQAD 4 to the Directorate of Fisheries, NAFIQAD 4 has doubts: the time from the start of fishing to the loading and unloading of raw materials when the fishing vessel docks is long (from 3 to 5 months) ), no conveying operation will not guarantee food safety; The time on the S/C paper and the mining log is different.

According to the explanation of some businesses around the above issue, the time on the S/C paper is determined from when the ship starts leaving the port to when the ship returns. The time on the log is when the ship begins to cast the first fishing net to collect the last net.

As such, the time on the S/C paper and the mining log will often not match (and the time on the S/C will be longer than on the mining log). Besides, according to the fishing industry's characteristics, mining is trawling with large ships, and the time to go to sea to exploit is more than 1 month (sometimes from 2-5 months).

Besides, due to some peculiarities, such as, ships operating in remote areas, so the travel time is long. When the boat reaches the fishing area, but there is no fishing channel, the ship will spend time exploring without casting the net. In some localities, the ships often exploit in groups or teams. At that time, 1 ship will be assigned to go to sea first to explore the fishing area with fishing channels to notify other ships to come out later. With the above characteristics of the profession, there are cases where the time on the S/C and the mining log has a long-time difference. And despite the long seagoing time, the ship declared differently at a later time, so the time for storing raw materials on the ship was not long.

In addition, when Vietnam has no legal regulations on how long to exploit the sea to be exported, the assessment of the responsiveness of the shipment (if necessary), the authorities consider the use of specific measures to evaluate (food safety indicators).

According to Mr Truong Dinh Hoe, the above-arising inadequacies are affecting the export situation of enterprises, and in the context of the goal of good implementation of current regulations on anti-IUU fishing, removing the yellow card of the Government. Currently, VASEP has reported to the relevant authorities and proposed to consider and remove the shortcomings as mentioned above to well implement current regulations and open up the chain of marine exploitation, processing and export to the EU.