Animal feed producers find fault in ruling

Animal feed producers have been troubled by “unnecessary and costly” conformity regulations

From July 1, enterprises must complete procedures for conformity declaration for entire types of animal feed and supplements on an annual basis.

In a meeting organised by the Ministry of Agriculture and Rural Development’s (MARD) Livestock Production Department (LPD) on July 12, with the participation of Deputy Minister of Agriculture and Rural Development Nguyen Hoang Hiep, representatives of many producers and associations raised their voices to propose abolishing the regulation.

Nguyen Van Tue, deputy general director of Dabaco Group, told VIR that the requirement on conformity declaration is unnecessary because animal feed producers already comply with the regulations in terms of facilities, workforce, and research and development during the operation process.

“Besides that, producers register quality standards for every product and they have to be in charge of the products.”

In addition, Tue said, domestic products have to compete with each other and imported ones. “Thus, if their products do not good enough, they will be out of the market whether they have conformity certificates or not.”

A representative of a foreign-invested livestock company explained that the expenditures for completing the new annual procedures are unnecessary.

“The company wastes a large amount of money on these procedures,” he said. “There are two kinds of certificates – one is an annual certificate which costs VND1 million ($44) for a product sample; and the other is a three-year certificate which costs VND2 million ($88). In total, in our facilities in the north in particular, it takes over VND1 billion ($43,500) for this unnecessary procedure.”

Along with the money, it takes time to complete the dossiers to get the conformity certificate. “This regulation is not only unnecessary but also unreasonable, causing overlaps. There is no precedent in the world in terms of this. Even in Vietnam, the Ministry of Health removed similar regulations on food safety. It is one of the factors pushing up the selling prices of products, impairing the competitiveness of animal feed producers in the domestic market compared to imported products,” he said.

The implementation of conformity declaration for compound and concentrated feed was introduced a decade ago, after the Law on Product and Goods Quality, the Law on Standards and Technical Regulations, and other legal guidelines came into effect. The LPD built up the roadmap to develop standards for each type and group of feed, in which the standards for supplementary feed products were completed last year. After 10 years, producers pointed out numerous shortcomings of the regulation and submitted the proposal to the LPD.

“Dabaco and other companies submitted the recommendations to the authorities and we are still waiting for feedback. Removing this regulation would not only help producers lighten the financial burden but also match with the government’s assignment in reforming and simplifying administrative procedures” Tue said.

According to regulations, animal feed is included in the group of products and goods which have a particular safety risk, as regulated in Circular No.14/2018/TT-BNNPTNT dated October 2018 of the MARD.

Clause 2, Article 34 of the Law on Product and Goods Quality stipulates that imported goods belonging the group must be declared and certified in conformity with relevant technical regulations related to the production process.

Meanwhile Clause 1 of Article 12 of the Ministry of Science and Technology’s Circular No.28/2012/TT-BKHCN provides for the announcement of standard conformity and declaration methods to assess them.

Accordingly, “objects of declaration of technical-regulation conformity include products, goods, services, and processes specified in the national technical regulations promulgated by ministries, managing sectors, and fields; or specified in the local technical regulations promulgated by people’s committees of provinces and central-affiliated cities in Vietnam. Moreover, the declaration of technical regulation conformity is a compulsory operation.”

The LPD’s acting director Duong Tat Thang explained, “We are collecting recommendations and proposals from producers and associations and we will report and propose amendments to relevant legal documents and regulations. At the same time, we are also supporting organisations and individuals to implement conformity regulations.”

Thang added, “The government is building a decree on state inspection on food safety of imported and exported foods, thus the department will contribute its opinion to completing the decree with the direction of simplifying conformity declarations.”