Conformity procedure for animal feed products causes wasting?

Mr. Hoang Trieu, Chairman of the Vietnam Association of Veterinary Medicine Production and Trade, (VAVMPT) said that there are currently many regulations for ensuring the quality of animal feed. When registering for circulation, animal feed products have been tested at a laboratory designated by the Ministry of Agriculture and Rural Development. In addition, domestic products are all coming from factories that are qualified to produce animal feed, granted, periodically assessed, and monitored by the Department of Livestock Production.

For imported products, they are required to possess GMP, HACCP, FAMI-QS, or ISO certifications. When being imported, they should be checked through quality customs clearance. In addition, products that are preserved in warehouses as well as circulated on the market should also pass through regularly quality supervising by specialized agencies such as local sub-departments of livestock and veterinary medicine, departments of agriculture and rural development, sub-department of market management, and inter-sectoral inspectors...

Therefore, it is unnecessary and wasteful if animal feed business enterprises have to pass through more declaring conformity procedures after completing a series of above procedures as it will cause wasting and increasing product expenditure, and no one else but farmers themselves have to this unreasonable cost.

According to the VAVMPT, there is no animal feed conformity regulation in the world. In Vetnam, the Ministry of Health has also abolished the conformity policy for food safety. Thus, it is necessary to consider abolishing such rules for animal feed and other supplementary animal foods so that to minimize administrative procedures following the Government's reform direction, because this procedure is causing waste for both business enterprises and consumers, causing complications for the State’s management process.

Mr. Nguyen Thanh Son, Chairman of the Vietnam Poultry Breeding Association said according to the provisions of Circular No. 28/2012/TT-BKHCN of the Ministry of Science and Technology and Circular No. 04/2020/TT-BNNPTNT of the MARD, before being circulated on the market, organizations, and individuals trading in aquafeeds and raw materials for aquafeed production in the Vietnamese territory must announce the conformity applicable to commercial animal feed and raw materials for aquatic feed production.

As the chairman of an industry association, Mr. Son agrees with the views and proposals of business enterprises that it is not necessary to follow regulations on the announcement of conformity for animal feed because there are other regulations to control the quality of animal feed. He took ab example saying that when registering for circulation, animal feed products have been tested at a designated laboratory of the MARD.

Moreover, according to Mr. Son, the implementation of the regulation on conformity announcement wastes time and human resources for enterprises because they have to perform many duplicate and complicated administrative procedures which can increase production costs such as those for testing, repackaging, labels re-printing, and changing batches... This will result in an increase of the products’ price and many obstacles for the livestock sector in the context of the spreading pandemic.

From 2018 up to now, the Ministry of Health has not regulated that regulation conformity announcement is required for even products that directly affect human health such as functional foods, medical nutrition, processed prepackaged products like candies and instant noodles… There are also no conformity regulations for animal feed in the world.

“In accordance with Resolution 84/NQ-CP of the Government on tasks and measures to continue solving hardship for production and trade is that urgently complete the review, amendment and supplement of documents immediately for overcoming overlaps, removing bottlenecks, and promoting reform,...; Research to amend and supplement current policies should be carried out create a source of support for businesses and people while still ensuring the macro-economy… Therefore, we recommend ministries and agencies to study and consider abolishing the procedures of conformity announcement for animal feed and supplemental feed products to minimize administrative procedures in accordance with the Government's guiding lines of administrative reform", Mr. Son suggested.

Mr. Nguyen Nhu So, Chairman of the Board of Directors of Dabaco Vietnam Group, one of the largest animal feed manufacturers in the country, said that most business enterprises seriously follow the regulations of the Department of Livestock Production, the Department of Veterinary Medicine, Directorate of Fisheries to ensure product quality as they know quality creates a brand. If the company's product does not ensure quality, it cannot survive.

Therefore, according to Mr. So, adding more conformity procedures only wastes the time, efforts, and costs of enterprises without increasing product quality. Product quality does not depend on that conformity label, so he proposed the MARD to cancel the conformity procedure as soon as possible to reduce the cost burden for businesses. This is at the same time also suitable with the State's policy on reducing administrative procedures and costs, creating a healthy environment for businesses to develop.

A representative of an enterprise specializing in importing animal feed and supplementary feed products shared his view that when he worked a lot with the customs offiers, he always heard them saying that they did not understand how the agricultural policy makers have done with regulations as  it took much time for them in handling documents for imported animal feed products. It is very opposite with products of food and drug which administration procedure does not include such strict regulations despite they are for human health. Partner manufacturers do not understand why Vietnam regulates the conformity, while they have all certification documents and international standards such as GMP, HACCP, FAMI-QS or ISO and CFS. Since then, this enterprise representative suggests that when the production has met international standard conditions, the State should go into post-inspection process.