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Export production of Seafood. Picture: Thu Hoa

According to the Vietnam Association of Seafood Exporters and Producers (VASEP), from the inadequacies of reality, after four years of implementation of Decree No. 38, seafood enterprises have proposed many contents related to export and import activities.

Regarding the scope of standard conformity announcement and food safety compliance declaration, enterprises proposed: To strictly comply with the provisions of Article 12 of the Law on Food Safety and related Resolutions of the Government.

Accordingly, the draft decree must ensure that: only register with competent state agencies the standard conformity announcement for packed processed food before being circulated on the market; remove the regulation of the certificate issuance of food safety regulations conformity announcement, which is not regulated by the Law on Food Safety and over 4 years of implementation this has shown the inadequacies and obstacles which are the nature of a "sub-license"; exempt the implementation of the standard conformity announcement and declaration of food safety, exempt the Vietnamese labeling for food, food ingredients, food additives, material for food processing, packaging materials and containers for food imported into Vietnam which used for export production and processing of export goods and import goods for export and not for consumption on the domestic market.

Regarding the regulations on registration, receipt of registration and result return of food standard conformity announcement, enterprises have recommended that Decree 38 should be amended to simplify components of registration dossiers for standard conformity; procedures of standard conformity registration, registration acceptance and announcement of acceptance of standard conformity announcement which are based on the following principles: The submission of standard conformity announcement dossiers is implement by organizations and individuals who are responsible for the product; the state agencies shall only undertake the task of acceptance the registration and issue a "notice of acceptance the dossiers of announcement of standard conformity"; amending the regulations of requiring state agencies to receive dossiers: "To check if the dossiers are complete enough by the time the enterprises submit the dossiers", and the time limit for the issuance of "notices on the announcement of standard conformity dossiers" which reduce to a maximum of 3 working days.

The explanation for that, as the current practice, Decree 38/2012 / ND-CP is stipulating procedures for registration of standard conformity announcement between individuals, organizations and competent state agencies which have the permission of issuance, re-issuance, and replacement of the "standard conformity announcement acceptance certificate" as a form of "sub-license". This is not in line with the spirit of the Law on Product Quality; Law on Standards and Technical Regulations and Food Safety Law, as well as the spirit of Resolution 19-2017 / NQ-CP.

In addition, the nature of the registration of standard conformity announcement is the organizations or individuals announce that their own products are in accordance with relevant technical standards which were promulgated by competent state agencies and enterprises take responsibility for the publication. Organizations and individuals who responsible for products shall submit dossiers of standard conformity announcement and competent agencies shall receive and return results in the form of "Notification of dossiers of standard conformity announcement acceptance".

Regarding the time to make a standard conformity announcement dossiers, according to enterprises, to complete the procedure for many kinds of products, including products for domestic consumption, enterprises also take a long time (under Clause 4 Article 4 of Decree 38 is 15 working days, equivalent to about 3 weeks) and high cost.

But in fact, the time for enterprises to get the certification is not just 3 weeks as prescribed above, it usually takes longer than that, even doubles the time required. The reason is that many cases after waiting for 3 full weeks, the company received new notices that the records failed, requesting the company to receive the records for correction. Enterprises have to continue to apply and recalculate from the beginning of 15 working days. Therefore, the time to process is often long, lead to the situation of partners who can not wait so they switch to other suppliers, the enterprise lost their customers and opportunities, adversely affect business activities of enterprises.

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The Association recommends all levels to review, adjust and revise the Draft in order to comply with legal regulations and promptly solve problems and difficulties for the business community, comply with the spirit of Resolution 19/2016 / NQCP and Resolution 35 / NQ-CP of the Government, facilitate the enhancement of competitiveness of Vietnamese seafood exporters.