Proposal to remove the 'iron ring' of iodized salt requirements for seafood enterprises

Difficulties in finding non-iodized salt for export processing

According to Mr. Truong Dinh Hoe, the Secretary General of the Vietnam Association of Seafood Exporters and Producers (VASEP), Vietnam's seafood exports generate between 10 to 11 billion USD annually. Over 90% of these exports reach more than 160 markets around the world in various forms, including frozen (packaged) products, canned goods, dried items, ready-to-eat products, and traditional fish sauce.

Many processed seafood products from Vietnam's key species, such as shrimp, tuna, catfish, clams, squid, and octopus, rely on salt as a crucial ingredient in the production process. However, the salt used must meet specific requirements, including being pure and safe for consumption, in line with HACCP (Hazard Analysis Critical Control Points) standards for food safety.

At present, seafood importing countries do not have any specific requirement for the use of iodized salt in imported seafood products. As a result, importers often request a certificate confirming that no iodized salt was used by exporters during processing. In some instances, importers may even refuse to accept orders if the exporter has used iodized salt during the production process.

Under Decree 09/2016, which mandates the addition of iodine to salt used in food processing to enhance micronutrient intake, food businesses, including those in the seafood industry, are facing significant difficulties. Specifically, seafood processors are struggling to find pure, non-iodized salt that meets their needs for production. While artisanal salt producers, who are not subject to the requirements of Decree 09/2016, could provide non-iodized salt, they are unable to meet the necessary quantity and quality standards. These small-scale salt producers often lack the capacity to produce salt with the required purity levels and consistent quality that the food processing sector demands.

Mr. Hoe pointed out that if this issue persists, it will create major challenges for the entire seafood processing industry in Vietnam.

Disadvantages in competing with imported seafood

Mr. Hoe pointed out that Decree 09/2016 only applies to food products for domestic consumption and does not extend to exports. However, most seafood processing businesses in Vietnam produce goods for both export and domestic consumption based on market demands.

As a result, in order to comply with the regulations in Decree 09/2016 for seafood products intended for the domestic market, businesses are forced to produce separate batches specifically for domestic consumption. They cannot transfer products from export batches to the domestic market, or vice versa. This requirement restricts the business flexibility of companies and creates inefficiencies in production and distribution. For example, when export opportunities are limited or when there is a downturn in the international market, businesses are unable to shift unsold export stock to the domestic market to mitigate losses, and vice versa.

Moreover, the obligation to use iodized salt for domestic market products puts local seafood businesses at a disadvantage in competing with imported seafood. Imported seafood is not subject to the same iodine fortification requirements. This creates an unfair competitive environment, where Vietnamese seafood, especially products destined for the domestic market, faces higher production costs compared to imported goods, potentially leading to a price disadvantage.

On the other hand, while Decree 09/2016 does exempt "export food establishments" from its provisions, as mentioned earlier, very few businesses or facilities focus exclusively on production for export. Most companies also produce for the domestic market. Therefore, this exemption provision becomes highly impractical in real-world implementation. It could lead to arbitrary enforcement by the relevant authorities in determining whether a business qualifies as an "export food establishment" or not.

In addition, there is a concern that individuals who already have sufficient or excessive levels of iodine do not need further supplementation. If they are forced to consume food sources that contain iodized salt without any safe alternatives, there could be negative health impacts. These could include conditions such as hyperthyroidism, thyroid cancer, and other related health issues. This highlights the potential risks of mandatory iodine fortification for those who do not require it, raising concerns about public health.

Proposal to "Untie the constraints" for businesses

Mr. Hoe pointed out that several countries, when introducing regulations for iodine fortification in salt, have made efforts to ease the process for businesses. For instance, while Canada mandates the addition of iodine to household salt, it does not impose this requirement on salt used in food processing.

Mr. Hoe further emphasized that VASEP (the Vietnam Association of Seafood Exporters and Producers) strongly supports the government's initiatives aimed at improving the nutrition and health of the population, including the policy of fortifying food with micronutrients.

However, given the practical challenges arising from the regulation requiring the addition of iodine to salt used in food processing, VASEP has formally proposed that the Government and the Ministry of Health consider revising and amending Decree 09/2016. Specifically, VASEP recommends excluding seafood and export food products from the scope of this decree. At the same time, VASEP advocates for the continued use of iodized salt in the production of food intended for domestic consumption. The mandatory fortification of salt with iodine should remain applicable to household salt, as well as to salt used in the foodservice industry (such as in restaurants and catering services), in accordance with the National Nutrition Strategy for the 2021-2030 period. Additionally, this regulation should also apply to solid salt-based seasonings commonly used in cooking.

VASEP further suggests allowing salt production and importation facilities to offer non-iodized salt for specific purposes, including for individuals who have an excessive intake of iodine or for businesses that manufacture food products for export. Moreover, VASEP proposes that salt be clearly labeled to distinguish iodized salt from non-iodized salt. The labeling should also include information about the benefits of iodized salt in preventing goiter and iodine deficiency, which would help consumers make more informed decisions based on their specific health needs.

According to VASEP, Vietnam's seafood exports in the first nine months of 2024 have reached a total value of 7.2 billion USD, reflecting a 9% increase compared to the same period last year. In September alone, seafood exports amounted to 922 million USD, representing a 13% growth compared to September 2023.

After being severely impacted over the past four years by disruptions such as the COVID-19 pandemic, global conflicts, and inflation, the global market is beginning to stabilize. As a result, Vietnam's seafood export sector has gradually returned to its usual pattern of growth, with exports picking up speed in the second half of 2024, as is typically the case, with the third quarter being the peak period for the industry.

In particular, the third quarter of 2024 saw seafood exports reach 2.8 billion USD, which is a 15% increase compared to the same period last year. Among the key products, there were notable breakthroughs: pangasius (catfish) exports grew by 14%, shrimp exports increased by 20%, crab and soft-shell crab exports surged by 59%, and shelled molluscs saw a twofold increase in exports compared to the same quarter in 2023. However, tuna exports showed signs of stagnation, while exports of squid and octopus continued to experience a downward trend.