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Exporting live fish & seafood products from Canada to Vietnam

This guide is provided in the context of recent regulatory developments in Vietnam related to the import of fish & seafood for human consumption.

Step-by-step guide on registration of Canadian fish & seafood establishments

Background

Effective from February 02, 2018, Canadian establishments wishing to export fish and seafood products for human consumption to Vietnam must be approved by the Ministry of Agriculture and Rural Development (MARD) under the requirements of Government Decree 15/2018/ND-CP dated February 02, 2018. Decree 15 provides detailed implementation of some articles of Vietnam Law on Food Safety 2010. Chapter VI of Decree 15 regulates the state control of food hygiene and safety of imported foodstuff, including products of terrestrial and aquatic animals for human consumption. Previously, approval requirements for foreign establishments were implemented under Circular 25, which has now been withdrawn with Decree 15 taking effect. A particular note is that Decree 15 exempts processed and pre-packed products from the listing requirements.

On February 12, 2015, MARD issued Circular 04 /2015/TT-BNNPTNT providing general regulations on trade of agricultural and agri-food products including live aquatic animals for human consumption. Except for Pacific Oyster (Crassostrea gigas), which can be imported into Vietnam without the need for a risk assessment or import permit, all other live aquatic animal species from Canada or elsewhere are required under Circular 04 to undergo a risk assessment approval process though MARD’s General Department of Fisheries (D-Fish) before an import permit can be issued.  To date, live lobster (Homarus americanus) and live Dungeness crab (Cancer magister) are the only two species from Canada for which an import risk assessment has been successfully completed.

On October 2, 2017, the Department of Animal Health (DAH) of MARD advised the Embassy of Canada in Hanoi that foreign establishments wishing to export only LIVE aquatic animals for human consumption were no longer required to be approved. Subsequently, all Canadian establishments which were previously listed to export only LIVE aquatic animal for consumption to Vietnam had been removed from the list of Vietnam’s approved establishments. MARD has confirmed that this removal does not affect the ability of Canadian establishments to export live products (namely lobster, Dungeness crab and Pacific oyster – the only three live species from Canada currently having access) to Vietnam. 

In light of the implementation of Decree 15 and DAH’s advice to the Embassy dated October 2, 2017, the Embassy has confirmed with MARD that the listing requirements now apply to Canadian establishments wishing to export non-viable fish and seafood products which are not processed and pre-packed.

Guide for Canadian establishments to register

Step 1

An individual establishment prepares information package in accordance with Form 9 of the Decree’s Annexes and forward it to CFIA for verification. Required information includes:

  1. Name of establishment
  2. Address
  3. Registered products
  4. Description of production processes
  5. Quality management system(s) applied

Note: The information needs to be establishment-specific. DAH (the Vietnamese Competent Authority to approve foreign establishments) might request additional information specific to the establishment as they process the application dossier.

Step 2

According to Decree 15, the Vietnamese Competent Authority has 30 working days from the date of their receipt of original dossiers to process and approve a new Canadian establishment. Once approved, the details of the Canadian establishment (including name, address, approval number and approved products) will be updated in the list of approved Canadian fish and seafood establishments, available at the DAH’s web site (link provided below). The Canadian industry is advised to visit DAH’s link regularly after application was formally submitted with DAH to check on progress.

Guide for an existing (approved) establishment seeking to export additional products to Vietnam

All steps outlined above must also be followed when an existing Canadian establishment wants to add a new product (other than live aquatic animal species for consumption or processed/pre-packed products) in their export portfolio to Vietnam. The individual establishment needs to supply information related to food safety control for the additional product. A turnaround time (up to 30 working days) for DAH to review and approve a new product of an existing registered establishment may apply.   

For example, Canadian establishment X is already listed by DAH for export of frozen lobster products to Vietnam. Establishment X now wishes to export frozen snow crab products. Company X prepares information package in accordance with Form 9 of the Decree’s Annexes specifically on their food safety control practices for frozen snow crab products and submits to CFIA for verification and official submission.

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