DNVN - Commenting on the draft Decree amending and supplementing a number of articles of Decree 15/2028/ND-CP detailing the implementation of a number of articles of the Law on Food Safety, VASEP said that the draft creates new requirements and bottlenecks, causing difficulties for production and business activities of enterprises...
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The Vietnam Association of Seafood Exporters and Producers (VASEP) has just sent a dispatch to relevant parties to provide comments on the draft Decree amending and supplementing a number of articles of Decree 15/2028/ND-CP detailing the implementation of a number of articles of the Law on Food Safety (FSS).
According to VASEP, in the past 7 years since the issuance of Decree 15/2018/ND-CP detailing the implementation of a number of articles of the Food Safety Law, the Government and the business community have assessed this as an effective reform model in food safety management, integrating according to the risk management principles that advanced countries in the world are applying. Thereby helping businesses save millions of working days and thousands of billions of VND/year.
Practices in the years of implementing Decree No. 15 show that the food industry has had high growth even during the pandemic, contributing about 15% to GDP; 0.38 percentage points to GDP growth in 2021; 1 percentage point to GDP growth in 2022.
Regarding the draft Decree amending and supplementing a number of articles of Decree No. 15/2018/ND-CP (Draft) drafted by the Department of Food Safety, Ministry of Health, VASEP and seafood enterprises have many concerns because they realize that the Draft is creating new requirements, new bottlenecks, causing difficulties for production and business activities of enterprises while not providing more effective solutions than Decree 15 to ensure food safety for people.
According to VASEP, the draft adds, increases, and creates many requirements and administrative procedures, most of which are not related to food safety, causing particular difficulties for businesses.
The Draft is adding many requirements and regulations to all three groups of administrative procedures on self-declaration, declaration registration, and re-registration of declaration. Among them, there are many unreasonable regulations, inconsistent with international practices, and the risk of creating many new bottlenecks for production and business, making it difficult or impossible for many food products, especially seafood, to meet or fulfill. Meanwhile, many additional requirements to these procedures of the Draft have nothing to do with food safety.
According to VASEP's estimates, with the self-declaration procedure, the increased number of documents and time will cause business delays of at least 3 months and losses of thousands of billions of VND/year. With the declaration registration procedure, the increased number of documents can cause costs of hundreds of billions of VND/year, and the number of additional working days cannot be determined.
"The seafood business community is particularly concerned about the addition of the above requirements and contents to the above self-declaration procedure/form. It is also completely unclear what the purpose of adding the above information requirements is (to resolve the arising situation causing food safety loss due to some unrelated to food safety, such as drug and pharmaceutical management), VASEP stated.
Therefore, the seafood business community recommends that the information requirements related to self-declaration procedures remain the same as they have been effectively and appropriately designed in Decree 15/2018.
The object of centralized management is not suitable.
VASEP believes that the draft is only focusing on strict administrative management of pre-packaged processed foods, while not providing suitable solutions to prevent food poisoning related to street food, fresh food, collective kitchens... as recently identified as products with high potential risk of causing food safety loss, which are the main cause of food poisoning.
This Association suggested that the Drafting Committee review and adjust the management object to be consistent with the risk management principles.
In addition, according to VASEP, many measures proposed in the Draft are not based on international food safety management principles, and are not in accordance with the direction of General Secretary To Lam to "thoroughly cut administrative procedures", "remove bottlenecks", "abandon the mindset of banning if you can't manage", "fight waste". In particular, the Draft clearly shows that it is not consistent with the Solutions for developing food safety laws stated in the Summary Report on 5 years of implementing Decree 15 No. 1895/BC-BYT dated December 31, 2024, Section II, Point 1 of the Ministry of Health.
Some existing and arising issues in food safety management regulations that Decree 15 has not mentioned have not been included in this Draft.
To facilitate the production and business activities of enterprises, and at the same time improve food safety for people, VASEP requests the Ministry of Health and the Drafting Committee to study the comments, remove unreasonable draft regulations, and supplement appropriate management measures to ensure that the Decree is developed in accordance with the instructions of the General Secretary and the Government, as well as the solutions in Report No. 1895/BC-BYT to avoid creating bottlenecks for production and business, and to ensure food safety for people as well as improve management efficiency.
The Government chaired a dialogue meeting between the Drafting Committee and relevant food industry associations to review the final draft before submitting it to the Government. VASEP also suggested that the Government consider amending the Food Safety Law first, and then amending the Decree guiding the implementation of the Law.
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Source: https://doanhnghiepvn.vn/kinh-te/chinh-sach/vasep-du-thao-quy-dinh-ve-an-toan-thuc-pham-phat-sinh-diem-nghen-gay-kho-cho-doanh-nghiep/20250303043611721
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