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CHALLENGES TO VIETNAM FISHERY INDUSTRYTO MEET FOOD SAFETY REQUIREMENTS OF

IMPORTING COUNTRIES

MINISTRY OF AGRICULTURE AND RURAL DEVELOPMENT OF VIETNAMNATIONAL AGRO-FORESTRY-FISHERIES QUALITY ASURANCE

DEPRTMENT (NAFIQAD)

Canada , 29 September 2013

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CONTENT

I. Seafood export situation

II. Export orientation

III. Challenges

IV. Activities

V. Proposal

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I. Seafood export situation

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I. Seafood export situationMain importing countries 2012

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I. Seafood export situationMain products 2012

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II. Fisheries export target to 2020

Total production: 6,5 - 7 million tons

Aquaculture: 4,3 – 4,6 million tons

Capture: 2,2 – 2,4 million tons

Growth rate of industrial production value: 8 -10%/year

Export turn-over: 8 - 9 billion USD

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III. Challenges

Food hygiene and safety measures and technicalbarriers to trade of import countries; need to upgradethe existing food safety and quality assurance system. 1996: EU equivalence requirements;

1997 : USA HACCP regulation;

2001- 2002: EU zero tolerance for residues;

2004-2005: USA, Canada antibiotics strengthened controls

2002 Catfish labelling, 2008 Farm Bill – catfish inspectionproposal .

2010-2013: Russia, Ucraina restricted import control

2012- 2013: Japan implement stringent uniform limit (0,01 ppmEthoxyquin, 0,001ppm for Trifluralin in shrimp)

2013: Mexico shrimp import ban based on media information onshrimp disease; Brasin requires biosecurity in aquaculture;

… … …

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III. CHALLENGES

Lack of transparency in import permit rules and procedures (insufficientnotice period before import ban or strengthened import control);

Complicated system audit and import approval procedures - notharmonised with Codex (inspection and license for every foreignestablishment, restrict number of approved establishments and importquota for Pangasius);

Strigent standards and more criteria enforced by importing countries -microbial, contaminants, residues - but not harmonized withinternational Codex standards;

Focus on chemical residues - Limits more stringent than needed, basedon LOD rather than risk-based (Japan uniform limit for Ethoxyquin inshrimp 0,01 ppm, MRL Trifluralin 0,001ppm, Enrofloxacin 0,01ppm);

Inaderquate cooperation, information exchange between CA ofimporting and exporting countries (alert notification, regulations andstandards, food safety criteria and MRLs, inspections report for countryaudit…);

Voluntary private standards and certification (ISO 9000/14000/22000,GlobalGAP, ASC, BRC … restricts market access, require more cost forimplementation and certification…

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IV. Activities taken4.1 Improve legislation system in harmonization

with Codex and international practices

Law on Food Safety (inforced since July 2012);

National strategy for Food Safety to 2020.

Overall target:

2015: Overall programs on food safety from production toconsumption will be implemented on basis of so strong,effective management system that food safety status shouldbe improved significantly and comprehensively.

2020: Food safety control in whole food supply chain will bebasically set up and bring into play its effects so as to protectpublic health and consumers’ interests, meet requirementsof development and international economic integration.

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IV. Activities taken

Specific targets:

-Replenished food safety knowledge and practices for allstakeholders;

-Enhanced capacity building of food safety managementsystem;

-Significantly improved food safety status in foodproducers and processors;

-Significantly improved food safety status in food traders;

-Prevented acute food poisoning cases;

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IV. Activities taken Review and revise Circulars, Technical regulations on:- Inspection and certification of fishery business operators and

fishery products (Circular 55/2011);

- National technical regulations on food safety and hygieneconditions of fishery business operators (Circular 47, Circular 02);

- Residue monitoring program for certain harmful substances inaquaculture fish and products thereof (Decision 130/2008);

- Sanitation monitoring program for bivalve mollusc productionareas (Decision 131/2008);

- Traceability, recall and handling of unsafe seafood (Circular02/2011);

- Risk analysis and food safety control throughout the value chain(Circular 03/2012);

- Food safety control for imported foodstuff of animal origin (Circular25/2011);

- …

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IV. Activities taken4.2 STATE ASSIGNMENT OF FOOD SAFETY CONTROL

1. The Ministry of Agricluture and Rural Development (MARD)

Responsible for food safety control during primary productions(aquaculture/capture cultivation, production,, etc…) and whole chainof production, exportation, importation of following food groups:

Fish and fishery products; cereals; meat and meat products;horticulture and horticultural products; egg and egg products;raw fresh milk; ree honey and bee honey products; GMOs, salt.

2. The Ministry of Health (MOH)

Additives; processing aids; bottled water, natural mineral water;functional foods.

General food safety management coodination

3. The Ministry of Industry and Trade (MOIT)

Beverages, processed milk; vegetable oil; flour and starch products

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MARD ASSIGNMENT OF FOOD SAFETY CONTROL OF AGRO-FORESTRY AND FISHERY PRODUCTS

The National Agro-Forestry and FisheriesQuality Assurance Department (NAFIQAD):

• MARD’s focal point for quality and food safety control of agro-forestry and fishery products;

• Presidely control food safety of fishery products for exportNAFIQAD.

Mandate:- Inspection and approval for fish proccesing

establishments for export;- Inspection and certification for fishery products for

export;- Implementation of national monitoring programs;- Approval of foreign establishments eligible for export to

Vietnam;- On-site inspections to access food safety control system

of exporting countries.- … … …

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IV. Activities taken4.3. Trainings for central and

local competentauthorities:

Law, legislation on food safety ofVietnam and importing countries;

- Quality , food safetymanagement programs,laboratory quality asurance(HACCP, GMP, SSOP, GAP,ISO17025 ... );

- Sampling, testing and inspectiontechniques and skills;

- Implementation of nationalmonitoring programs;

- Traceability and risk analysis;

- Building up Practices Manual forthe monitoring programs(residues, bivalve molluscs);

…

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IV. Activities taken

4.4 Capacity building for national laboratories:NAFIQAD 06 laboratories:

Accredited with ISO/IEC 17025 since 2002,

Criteria accredited with ISO 17025: including chemcials(residue of chemicals, antibiotics, biotoxins, etc…) andmicrobiologicals in foodstuff, Gamma-ray radioactivity.

Validation and accreditation, setting up SOPs, improvement ofdetection capacity at lower LOD;

Satisfactory results in international proficency tests on foodsafety criteria (FEPAS, FAPAS, Agri-quality…)

Morden equipments: HPLC (PDA, Fluorescent, UV), LC/MS-MS,GC-MS, GC ( ECD detector), AAS, ELISA, Real – time PCR,Isotope-radiation analysis system,ICP-MS…

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IV. Activities taken

4.5 Extension trainings and support for FBOs on:- Legislation, national technical regulations of Vietnam and

importing countries; especially harmful effects ofchemicals and antibiotics abused in aquaculture ;

- Trainings for small-scale and primaryproducers(aquaculture farms, fishing vessels, …),

- Supports to aquaculture farms in GAP implementation, tomiddlemen and processing establishments in GMP,SSOP, HACCP application;

- Re-organization of production (aquaculture planning,models for safe fisheries food supply chain based onintegration and contract bases )

- … … …

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IV. Activities taken

4.6 Implementation of monitoringprograms for fisheryproducts

i) Monitoring Program for certainsubstances and residues inaquaculture fish and products thereof:

Implemented since 2000.

Scope: 157 production areas(shrimp, catfish, tilapia, etc..)

Criteria: heavy metal, Organo-chlorinated pesticides, chemicals,banned/restricted antibiotics, anti-parasites drug, mycotoxin inaquaculture fish.

Total samples taken in 2012: 4,167samples

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Food safety control of fishery products

ii) Sanitation Monitoring Program for bivalve molluscproduction areas

Implemented since1999;

Scope: 20 production areas (Baby clam; Yellow clam,Blood clam, Antique ark, Antique ark, Scallop).

Criteria: Microbiological, algae toxins, marine biotoxins,heavy metals, organo-chlorinated pesticides.

Total samples taken in 2012: 2,150 samples

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Food safety control of fishery products

iii) Post-harvest fisherymonitoring program

Implemented since 2009

Objects: Captured fish(tuna, cuttle fish, octopus,etc…); aquacultured fish.

Criteria: focus oncontamimated food safety& hygiene criteria, abusedchemicals duringpreservation

2012: 48 provinces/cities/963 samples

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IV. Activities taken

4.7 Inspection to access food safety conditions ofprimary producers (aquaculture sites, fishingvessels, middlemen…) – GAP, GMP, SSOP;

- Inspection for approval of fishery processingestablishments (compulsory application ofHACCP, GMP, SSOP);

- Listing fishery business operators approved for

export as required by importing countries (EU, Korea,China, Russia,…)

Inspection frequency: Grade A: once/year;

Grade B: twice/year;More often for violated FBOs

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IV. Activities takenNumber of establishments eligible for export tospecific countries

No. Country 2000 2003 2005 2006 2007 2010 2011 2012

1Vietnam(HACCP)

51 189 264 319 386 496 515 561

2 EU 49 100 171 209 269 330 380 392

3 Korea - 189 251 298 379 483 493 539

4 China - - 260 319 381 485 506 542

6 Brazil - - - - - 79 79 103

7 Russia - - - - 25 33 34 34

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IV. Activities taken

4.8 Inspection and certification for export fish andfishery products:

Compulsory certification: as required by importingcountries (EU, Korea, China, Russia, Brazil,Indonesia,…);

Optional certification: according to CooperationArrangement with importing countries (Canada,...);

On request of customers: when importingcountries (Japan, the US, Australia…) do not requirecompulsory pre-export inspection and certification

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IV. Activities taken Actions to non-compliant establishments (when their

products notified non-compliant by importingcountries)

- NAFIQAD require the establishment to conduct traceability,

investigate contamination cause, establish appropriate

corrective actions, self-verify and make report to NAFIQAD;

- NAFIQAD conduct sampling and testing for food safety criteria

until testing results of 5 consecutive export consignments are

satisfactory;

- Suspend export certification on request of Competent authority

of importing country;

- Organize audit and ad hoc inspection to processing

establishment and its suppliers (if needed); provide competent

authority of importing country with verification results.

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4.9 Strengthening food import control:

- Enforcement of Circular 25/2010/TT-BNNPTNT.

- Approval of foreign establishments eligible for export toVietnam.

- Inspections to access food safety control system ofexporting countries in accordance with internationalpractices.

4.10 Active participation in regional (ASEAN - China,Japan) and international forums (Codex, IAFI, ...).

4.11 Cooperation with foreign competent authorities,negotiation on cooperation arrangements or mutualrecognition of seafood inspection and certificationsystem .

IV. Activities taken

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4.13. Arrangements with importing countries

TTCountry/Region

Content

1EU Decision 2004/267/EC of the European Commission recognizing NAFIQAVED (currently

NAFIQAD, Decision No. 1999/813/EC dated November 16, 1999 recognizingNAFIQACEN)

2Korea Arrangement on Fishery Products Quality Control and Food Safety with NFIS, currently

QIA (signed 2004, revised 2007)

3Canada Arrangement concerning the Inspection and Certification of Aquaculture Fish and Fish

Products exported from Vietnam to Canada for Drugs Residues

4China Co-operation Agreement on Import and Export Fishery Products Inspection,

Quarantine and Health Supervision

5Thailand Arrangement on Technical Cooperation on Fishery Diseases and Hygiene Safety

Control

6Cambodia

Arrangement on Technical Cooperation on Amphibian and Aquatic Animal HealthProtection

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Russia Protocols on Quality and Safety Control of Fish and Fish Products exported to theRussian Federation; Memorandum between FSVPS and NAFIQAD concerning the

safety of mutual deliveries of fish and seafood between RF and SRV.

8NewZealand

Pre-clearance arrangement with New Zealand Food Safety Authority

9 Indonesia Arrangement on quality and food safety control of fish and fishery products

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V. Proposals5.1 To importing countries It should set standards, technical requirements and MRLs in

harmonization with Codex and based on risk assessments;

It should harmonize and publish requirements, procedures forassessment and recognition of fishery food quality and safety controlsystem of importing country.

It should respect principle: assessment of food safety control systemof exporting country and audits to some fishery food businessoperators should be the basis to approve all fishery food businessoperators inspected and certified by exporting country.

It should publish import control requirements, food safety criteria andMRLs, principles for actions to non-compliance (strict control, importsuspension, import ban…)

It should actively conclude cooperation arrangements, equivalencerecognition of food safety control system between importing andexporting countries

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5.2 To international organizations anddeveloped countries It should reinforce role of international organizations (FAO, Codex,

IAFI …) in setting up and harmonization of food safety and hygienestandards, technical requirements, as well as procedures forassessment and recognition of fisheries inspection and certificationsystem;

International organizations (FAO, UNIDO ...) and developedcountries (EU, the US, Japan, Australia …) are proposed to providedeveloping countries with technical assistance to capacity building ofrisk assessment, traceability, implementation of national monitoringprograms, HACCP audit, testing …

It should intensify information exchange to share experiences onfood safety control, assist developing countries in building up policy,requirements and standards in international forum.

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Contact point agency on food safety of the VietnamMinistry of Agriculture and Rural Development

The National Agro-Forestry-Fisheries Quality AssuranceDepartment (NAFIQAD)

Under the Ministry of Agriculture and Rural Development (MARD)(renamed from the National Fisheries Quality Assurance and Veterinary

Directorate - NAFIQAVED since February 23, 2008)

Headquarter: 10 Nguyen Cong Hoan Street, Ba Dinhdistrict, Hanoi, Vietnam

Tel: +84-4-37714195 Fax : +84-4-38317221 Email: nafiqad@mard.gov.vn Website: www.nafiqad.gov.vn

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Thank you for your attention