Official clarifying regulation on conformity announcement for animal feed and supplemental feed products

Associations and businesses have proposed abolishing conformity regulation for animal feed and supplemental feed products. Have you been informed about the proposal?

The Vietnam Association of Veterinary Medicine Production and Trade (VAVMPT) contacted us, asking for a discussion over the issue. We including representatives from the agriculture ministry’s Department of Sciences, Technology and Environment and Department of Standardization of Contracts and Conforms under the General Department of Standards, Metrology and Quality, Ministry of Science and Technology met with the VAVMPT’s representatives and clarified what they are concerned about.

On May 17, 2021, we received another petition from VAVMPT about the shortcomings of the procedures of conformity announcement for animal feed and supplemental feed products. We are preparing answers for the association.

Regarding the shortcomings that the VAVMPT pointed out, we would submit them to the Ministry of Agriculture and Rural Development for consideration so that the ministry could then send them to involved agencies.

It’s worth noting that animal feed is included in the List of group 2 – the group of products and goods with the potential to cause unsafety. They are under the management of the Ministry of Agriculture and Rural Development, which was promulgated in the Minister's Circular No. 14/2018/TT-BNNPTNT dated October 29, 2018, Ministry of Agriculture and Rural Development.

Point b, Clause 1, Article 5 of the Law on Product and Goods Quality stipulates: “Group 2 products and goods are managed based on relevant technical regulations promulgated by competent state management agencies and the products/goods meet standards that their manufacturers declare to apply.”

Point d, Clause 1, Article 28 of the Law on Product and Goods Quality stipulates that, before being put on the market, domestically-produced products must “comply with technical regulations related to the production, conformity certification and conformity announcement in line with relevant technical regulations imposed for products in group 2”.

Clause 2, Article 34 of the Law on Product and Goods Quality stipulates that: Imported goods belonging to group 2 must be declared and certified in conformity with relevant technical standards relating to the production process of the finished product by a certification body designated or recognized per the provisions of Article 26 of this Law.

Clause 1, Article 12 of Circular No. 28/2012/TT-BKHCN dated December 12, 2012, of the Minister of Science and Technology, provides for the announcement of standard conformity, conformity announcement and methods to assess the conformity. Accordingly, “objects of regulation conformity announcement are products, goods, services, processes and environment specified in national technical regulations promulgated by relevant ministries or specified in local technical regulations promulgated by the People's Committees of provinces and centrally-run cities. Announcement of conformity is a mandatory activity.” 

What do you do to respond to recommendations by businesses?

The conformity announcement for animal feed regulated in Law on Livestock Production is also subject to regulations on standards, technical regulations as well law on product quality.

Shortcomings have been revealed during the implementation of conformity announcement for animal feed.

In the coming time, the Department of Livestock Production would collect opinions and recommendations from businesses, associations and farmers about animal feed management in general and conformity announcement for animal feed in particular. Then, we would report and proposed amendments to relevant legal documents and regulations. We would also promote communication, instructing organisations and individuals to implement conformity regulations.

The Government of Vietnam has been making efforts in administrative reforms, simplifying administrative procedures why the conformity regulation for animal feed is said to be unnecessary but also wasteful. What do you think about it?

The implementation of conformity announcement for feed is not new, particularly the conformity announcement for compound feeds and concentrated feed has been implemented since 2011, right after the Law on Product and Goods Quality, the Law on Standards and Technical Regulations and legal guidelines took effects.

After 10 years of implementation, the animal feed conformity regulations have been well exercised. The Department of Livestock Production has the roadmap to develop standards for each type/group of feed, in which the standards for supplementary feed products were completed in 2020.

However, the Department of Livestock Production also noticed some shortcomings, especially the inadequacy in the regulation that requires imported feed batches that are exempt from inspection still have to announce conformity as regulated in Decree 74/2018/ND-CP dated May 15, 2018, of the Government on amending and supplementing some articles of the Government’s Decree No. 132/2008/ND-CP of December 31, 2008, detailing the implementation of several articles of the Law on Product and Goods Quality.

Currently, the Government is developing a decree on the State’s inspection of imported products and goods. The Department of Livestock Production will contribute comments/opinions to compile the decree, particularly to contents relating to conformity announcement for animal feed.

From July 1, 2021, enterprises must complete procedures of conformity announcement for animal feed and supplemental feed products. Is it necessary to postpone implementing the regulation until shortcomings are solved?

As discussed above, the implementation of conformity announcement for animal feed is not new. Particularly, QCVN 01:190 for complementary foods has been in effect since July 1, 2020. 

After 9 months of implementing QCVN, up to now, 131 supplemental feed manufacturers in Vietnam have completed the procedures for conformity announcement. Some other companies are set to complete the procedures so that they could announce the conformity before July 1, 2021.

Thus, only a few businesses have not yet implemented. 

Moreover, in the past time, the Department has not received any feedback from enterprises about the inadequacy when making a declaration of conformity according to QCVN 01-190. Recently, the Association of Veterinary Medicine Manufacturers and Traders has just voiced their opinions about it.

We found that the regulation on the announcement of conformity of animal feed has been implemented per the provisions of the Law on Product and Goods Quality and the Law on Standards and Technical Regulations. 

If delaying the announcement of conformity until 2024 as suggested by the Association of Veterinary Medicines and Traders, it means that we do not support the serious efforts of more than 130 companies that completed the procedures as required.

"Regarding the shortcomings that the VAVMPT pointed out, we would submit them to the Ministry of Agriculture and Rural Development for consideration so that the ministry could then send them to involved agencies," said Duong Tat Thang, Acting director of Livestock Production Department under the Ministry of Agriculture and Rural Development.