The Vietnam Association of Seafood Exporters and Producers (VASEP) has voiced concerns about the draft decree amending Decree No. 15 on food safety management, citing potential financial losses of more than $300 million annually due to increased administrative burdens.

VASEP recently submitted its feedback to Deputy Prime Minister Le Thanh Long and four related ministries, urging reconsideration of the draft's proposed changes to avoid costly complications for businesses.

Financial burden for businesses

Since its enactment seven years ago, Decree 15 has been hailed as a successful reform in food safety management, following global risk management principles. It has helped businesses save millions of workdays and billions of Vietnamese dong annually.

However, the new draft decree introduces numerous additional requirements, creating new bottlenecks and administrative challenges that could hinder business operations. According to VASEP, the proposed changes lack more effective solutions than Decree 15 to ensure food safety for consumers.

The draft decree increases and adds numerous requirements to three groups of administrative procedures related to self-declaration, registration for declaration, and re-registration.

Many of these regulations are deemed unreasonable and inconsistent with international practices, potentially creating new bottlenecks that make compliance difficult or even impossible, particularly for seafood products.

Increased costs and administrative challenges

According to VASEP's estimates, the self-declaration process alone, with increased documentation and processing time, could delay business operations by at least three months, causing annual financial losses worth billions of Vietnamese dong.

One problematic aspect is the Product Information File (PIF) requirement, which adopts standards designed for pharmaceuticals and cosmetics (both chemical-based) and applies them to food products (mostly natural). This contradicts the guidelines of the Codex Alimentarius Commission, which advocates using the HACCP system (Hazard Analysis and Critical Control Points) without PIF.

The PIF also mandates testing every batch for all criteria, which goes against the HACCP’s focus on checking only key indicators at specified frequencies. These requirements could result in additional annual costs of over $300 million for businesses.

Furthermore, the registration for declaration process requires increased documentation, potentially costing businesses hundreds of billions of VND annually and significantly increasing labor requirements.

The seafood industry is particularly alarmed by these changes. VASEP strongly recommends maintaining the current self-declaration requirements as stipulated in Decree 15, which have proven efficient and practical.

Strict domestic regulations hinder market access

Another major concern raised by VASEP is the draft decree's narrow focus on tightly regulating packaged processed foods, while neglecting high-risk items like street food, fresh produce, and collective kitchens, which are primary sources of food poisoning.

In addition, many seafood products that meet stringent safety standards in the EU and US markets still face difficulties entering Vietnamese supermarkets. This is due to residual antibiotic and chemical levels that, while minimal and acceptable in foreign markets, exceed domestic thresholds.

The issue stems from the repeal of Circular 28/2020, which previously regulated the testing of banned chemicals and antibiotics in seafood products. Since its revocation in February 2024, no legal document has been issued to fill the regulatory gap, complicating the distribution of Vietnamese seafood domestically.

To address these legal voids and promote the “Vietnamese people prioritize Vietnamese products” policy, VASEP urges the government to assign new responsibilities to the Ministry of Agriculture and Environment in the draft decree. This would facilitate smoother circulation and consumption of seafood in the domestic market.

VASEP also suggests shifting from pre-inspection to post-inspection methods on the market, in line with risk management principles. All registration and declaration procedures should be conducted digitally to streamline the process and minimize unnecessary obstacles.

Tam An