Fishery industry is one of the key economic sectors in Vietnam. Therefore, the State always focuses on developing the scale of aquaculture, in order to bring Vietnam’s seafood brand to not only affirm its position in the country but also reach out to many markets around the world.
It is forecasted that in the future, the seafood industry will continue to grow positively. Therefore, in order to have more access to international partners, it is very necessary to map out an import-export strategic orientation, helping many shippers and businesses to better understand customs procedures. export specific aquatic products such as pangasius; Basa fish, contributing to speeding up the trade process. Fish for export must be raised and processed at establishments that fully meet export conditions.
In order to properly determine export policies and procedures, it is first necessary to determine the HS code of the item.
HS Code for exported fish
Basa and pangasius with HS code of Chapter 03 and heading 0302
Fish export tax
VAT: VAT for exported fish is 0%.
Export tax: fish is not on the list of items subject to export tax. Therefore, when exporting fish, the exporter does not have to pay export tax.
Check export standards of basa and pangasius according to the regulations of the importing country
In the EU market, seafood products of developing countries must comply with hygiene regulations; food quality and safety and regulatory oversight. Accordingly, countries that want to bring seafood products to the EU must be on the list of countries that can be exported to the EU. Each consignment must be accompanied by a certificate of compliance with EU requirements issued by the authorities of the exporting country. In addition, producers whose seafood products are exported to the EU must organize monitoring of their production and processing activities in accordance with HACCP.
China: If Vietnam wants to export seafood to China, the supplier must have a certificate of quality; products meet the quality requirements of the Vietnamese and Chinese governments: GlobalGap Standard, SQF Standard, HACCP Standard, ..
For the US market: there is a legal system of quality control, food safety, competent authorities; have the capacity to enforce the law; in the entire production chain from breeding stock, raising ponds, to transportation, preliminary processing, processing and export, must ensure food hygiene and safety conditions required by the US Department of Agriculture.
Business, production and processing establishments must satisfy the following conditions:
Fish for export must be raised and processed at establishments that fully meet export conditions.
Meeting the regulations on business investment conditions in Article 21 of the Government’s Decree 66/2016/ND-CP dated July 1, 2016 stipulating conditions for business investment in plant protection and quarantine ; type of tree; raising common forest animals; breed; Seafood; food.
There is a traceability system that meets the provisions of the law and ensures traceability to the farming establishment.
In case an organization or individual exporting pangasius products does not have a processing facility that meets the conditions for pangasius processing, it must satisfy one of the following two conditions:
Having a contract to purchase pangasius products processed at a pangasius processing establishment that meets the above conditions for pangasius processing.
Having a processing and processing contract with the owner of the processing establishment that meets the conditions for processing pangasius.
Meet regulations and technical regulations on conditions to ensure food safety in seafood processing.
Having a certificate of food safety eligibility, issued by a competent state management agency.
A quality management program must be developed according to the requirements of the importing country
HACCP food safety and quality management
28TCN129:1998 Seafood processing establishments – The HACCP food safety and quality management program compiled by the Department of Science and Technology and proposed by the Ministry of Fisheries to promulgate according to Decision No. 732/1998/QD-BTS December 16, 1998.
This standard stipulates the requirements, content and order of application of the quality management system from the point of view of HACCP to ensure the safety of aquatic products.
This standard applies to establishments processing aquatic products for human consumption (hereinafter referred to as establishments) nationwide.
Applying HACCP to seafood, enterprises, along with their initiative, have a strong voice in quality management work at the enterprise, industry and national level. The Vietnam Association of Seafood Exporters and Producers (VASEP) has the role of cooperating, criticizing and supervising the State management work from developing and implementing regulations on management and quality control, on improving the reliability of the programs to ensure the hygiene and safety of seafood quality…
The process of exporting fish
Step 1: Prepare and check the source of exported seafood products
Checking exported fish products
Before exporting, enterprises need to check whether their aquatic products are on the list of goods permitted for export based on Clause 2, Article 31 of Circular 04/2015/TT-BTC dated 12/02/ 2015 by the Ministry of Agriculture and Rural Development.
CITES-listed aquatic species exported for commercial purposes must obtain a CITES permit as prescribed in Decree No. 06/2019/ND-CP and Decree No. 84/2021/ND-CP.
For aquatic products that are not on the list of aquatic products banned from export in Appendix 1 of this Circular, when exporting, enterprises carry out customs procedures (for aquatic products managed by CITES, they will comply with CITES regulations. Vietnam).
The type of seafood listed in the list of aquatic products for export with conditions in Appendix 2 of this Circular, if the conditions are met, the exporting enterprises will go through customs procedures (for aquatic products managed by CITES). shall comply with the provisions of CITES Vietnam).
The cases on the list mentioned above that are exported for the purpose of scientific research or international cooperation must have a permit issued by the Ministry of Agriculture and Rural Development as prescribed.
Step 2: Check the set of export documents
The unit needs to prepare all documents to export seafood shipments. Mandatory export documents include:
Sales contract
Commercial Invoice (Invoice)
Packing List (Packing List)
Bill of lading
Customs declaration (received after the declaration has been successfully transmitted)
Document of notification of exemption from specialized inspection or documents prescribed by law on specialized management and examination
Papers proving that the enterprise is eligible to export fish
Certificate of Origin (requires importing country)
Particularly for aquatic products, in addition to the usual documents, goods owners need to register for animal quarantine before exporting.
Testing and announcing fish for export
Table 1: Sensory Indicators
| Tên chỉ tiêu | Yêu cầu |
| 1. Màu sắc | – Trắng tự nhiên đặc trưng của sản phẩm, không có màu lạ. |
| 2. Mùi | – Thơm đặc trưng của sản phẩm, không có mùi lạ. |
| 3. Vị | – Đặc trưng của sản phẩm, không có vị lạ. |
| 4. Trạng thái | – Cơ thịt mịn, săn chắc, có tính đàn hồi, vết cắt nhẵn, không sót xương, da, mỡ, cơ thịt đỏ,phần thịt bụng được xử lý sạch, cho phép tối đa 2 điểm máu hoặc đường gân máu trên thịt.
– Băng được mạ đều trên bề mặt sản phẩm. |
| 5. Tạp chất | – Không cho phép. |
| 6. Khối lượng | – Khối lượng tịnh của mỗi đơn vị sản phẩm trên mẫu kiểm sau khi rã đông nhanh để ráo nước, cho phép sai khác 2,5%; song giá trị trung bình của tổng số mẫu kiểm, phải đạt giá trị ghi trên bao bì. |
Table 2: Chemical Indicators
| Tên chỉ tiêu | Mức |
| 1. Hàm lượng tổng số Nitơ bazơ bay hơi, tính bằng số mg trong một 100g sản phẩm, không lớn hơn. | 25 |
| 2. Hàm lượng Borat, tính bằng số mg trong 1kg sản phẩm. | Không cho phép |
| 3. Dư lượng kháng sinh, tính bằng số mg trong 1kg sản phẩm. | Không cho phép |
| 4. Dư lượng thuốc bảo vệ thực vật, tính bằng số mg trong 1kg sản phẩm. | Không cho phép |
Microbiological criteria of the product must comply with the level specified in Table 3:
Table 3: Microbiological Indicators
| Tên chỉ tiêu | Mức |
| 1. Tổng số VSV hiếu khí, tính bằng số khuẩn lạc trong 1 g sản phẩm, không lớn hơn. | 106 |
| 2. Tổng số Coliforms, tính bằng số khuẩn lạc trong 1 g sản phẩm, không lớn hơn. | 200 |
| 3. Staphylococus Aureus, tính bằng số khuẩn lạc trong 1 g sản phẩm, không lớn hơn. | 100 |
| 4. E. Coli, tính bằng số khuẩn lạc trong 1 g sản phẩm. | Không cho phép |
| 5. Salmonella, tính bằng số khuẩn lạc trong 25 g sản phẩm. | Không cho phép |
| 6. Vibrio cholera, tính bằng số khuẩn lạc trong 25 g sản phẩm. | Không cho phép |
Fish testing process and fish quality announcement
Fish testing and fish quality announcements are based on the Government’s Decree No. 15/2018/ND-CP, detailing a number of articles of the Law on Food Safety issued on February 2, 2018.
Fish testing will be carried out according to the following procedures:
Step 1: Test fish products
Enterprises prepare product samples for testing.
Set up testing criteria based on fish standards according to Vietnamese regulations.
Bring the fish sample to the testing center.
Fish testing time is from 05 to 07 working days.
Step 2: Announce fish product standards
Announcement of fish quality standards in accordance with regulations No. 15/2018/ND-CP at the Food Safety Management Board; If your establishment is in a province, you should register at the Food Safety Department.
Components of the dossier for announcing the quality of fish products according to regulations No. 15/2018/ND-CP include:
Business registration license or Household business license.
Product testing.
Certificate of eligibility for food hygiene and safety at the place where fish is produced.
The time to register for publication of fish quality standards under Decree No. 15/2018/ND-CP is from 05 to 07 working days, the food safety management board will upload your profile on the website of the management system of the company. that agency.
Step 3: Register for animal quarantine for the shipment
The quarantine for aquatic products and aquatic animal products is implemented in accordance with Circular No. 26/2016/TT-BNNPTNT.
Submit application for quarantine registration
The exporting side goes to the Department of Animal Health to submit the registration dossier for quarantine of aquatic products. Dossier for quarantine registration for a shipment includes:
Quarantine declaration form (according to the form)
For aquatic animals and animal products under the management of other relevant competent state agencies, documents or permits must be submitted as prescribed.
Quarantine requirements of the importing country (if any)
Certificate of disease safety of the aquaculture establishment where the seafood originated for the production of the consignment (if any)
Other relevant documents depending on the actual exported seafood products
Officials in the Department of Animal Health will check the quantity, type, take samples of products for testing, etc. of the submitted aquatic product samples.
Time to issue quarantine certificate
The time for issuance of the quarantine certificate is regulated as follows:
Inspection within 05 working days from the beginning of the quarantine, the animal quarantine body at the border gate shall issue the Certificate of quarantine of imported aquatic animals and animal products for the qualified aquatic products. request for goods owners to complete customs procedures. In case it takes more than 5 working days, the animal quarantine agency at border gate shall notify the goods owner in writing and clearly state the reason;
For batches of aquatic animal products that do not have to be sampled for inspection: within 01 working day, the animal quarantine body at border gate shall issue the following Certificate of quarantine of aquatic animals and animal products. when checking the satisfactory documents so that the goods owner can complete the customs procedures;
The exporting side will base on the time stated on the appointment card to go to the Department of Animal Health to receive the Certificate of Quarantine.
Step 3: Get the license
Apply for a medical certificate (HC)
Apply for a health certificate – HC for seafood based on Circular 52/2015/TT-BYT stipulating the state inspection of food safety for imported food and documents and procedures for granting the certificate receipt for exported food under the management of the Ministry of Health
Step 1: Prepare documents
Application for a medical certificate
Business license
Product self-declaration
Product test card
List of production facilities (if any) of the trader
Certificate of food safety eligibility of the manufacturer or processing contract;
Label
Step 2: Submit your application
Enterprises submit dossiers at the Food Safety Department – Ministry of Health.
Step 3: Get the license
Above is the process of applying for a license to export seafood. Enterprises exporting the above items should pay attention to ensure efficient operation and avoid business mistakes.
Commercial inspection
In commercial activities, pangasius/pangasius from the time it is produced to the time it is delivered to the buyer/consumer, has to go through many stages (transportation, delivery, preservation, etc.), which cannot be avoided. from risks, errors, losses… leading to disputes between the parties involved in the purchase/sale contract.
Some common disputes are:
Errors in quantity, volume, quality, packaging, value of goods, origin, type of goods, condition, safety, hygiene standards, and other content as required of cutomer. (inspection under commercial contract)
Loss and causes leading to loss, division of responsibility, compensation level of related parties when goods are lost; (insurance loss assessment)
Time, place of delivery, transfer of ownership, risks to the goods … To directly prevent and have a legal basis to resolve disputes that occur quickly when goods are damaged or missing. , loss, damage, etc., the contracting parties often include in the commercial contract a clause to designate an independent, neutral, competent/reputable inspection organization to conduct the inspection and issue the results of the inspection. conformity of goods quality, quantity and volume with the signed contract.
Packaging, labeling, transportation, storage
Label products printed on coupons, label on packages with the following contents:
Product’s name.
Name and address of the manufacturing facility.
Product volume.
Material.
User manual.
Production date, expiry date, etc.
