On August 4, 2026, the Ministry of Agriculture and Environment issued Circular No. 33/2026/TT-BNNMT amending and supplementing multiple regulations within the seafood sector. Among these, it comprehensively amends Circular No. 74/2025/TT-BNNMT regarding certification of seafood and seafood products exported to the US market.

According to the content of Circular No. 33/2026/TT-BNNMT, Article 6 of Circular No. 74/2025/TT-BNNMT is amended to specifically stipulate COA (Certificate of Admissibility) application dossiers corresponding to each raw material source.

Specifically, for domestic wild-caught raw materials used for export processing, the dossier comprises a COA application form and one of the origin verification documents—such as a Port Unloading Product Receipt, a Wild-Caught Seafood Material Confirmation, or a Catch Certificate (CC).

For imported wild-caught raw materials, enterprises must submit a COA application form accompanied by one of the origin-verifying documents, such as a Captain’s Statement with the vessel's fishing license, a COA issued by the flag state of the harvesting vessel, a Catch Certificate (CC), or a Reported Catch (RC). Concurrently, the Circular clearly details minimum information that must be reflected on the Captain’s Statement to guarantee traceability capacity.

For raw materials originating from aquaculture, dossiers are distinguished between domestically farmed and imported raw materials. Accepted documents include aquaculture confirmation papers, food safety compliance certificates, Good Aquaculture Practice certificates, Certificates of Origin (C/O), quarantine certificates, or aquaculture facility certificates, depending on specific cases.

Alongside that, a supplementary case is added for utilizing raw materials belonging to the COA-requiring list but outside the US import prohibition list. In such instances, the dossier requires merely an application form alongside raw material purchase contracts, invoices, or goods procurement manifests as prescribed.

Clauses 2 and 3 of Article 7 in Circular No. 74/2025 are amended to perfect regulations on dossier submission forms.

Specifically, for dossiers submitted directly or via postal services, enterprises submit original application forms and copies for remaining documents. Separately, raw material origin verification documents specified in Article 6 must present originals for competent authorities to confirm remaining raw material volumes prior to returning them to enterprises. If documents are created in electronic environments, physical paper presentation is not required; verification is conducted on electronic origin traceability systems. Concurrently, enterprises are permitted to combine multiple types of origin verification documents within a single COA application to reduce administrative procedure frequency.

For dossiers in foreign languages, new regulations require an accompanying Vietnamese translation, except for documents in English or bilingual with English. Organizations and individuals bear responsibility for translation accuracy and must affix overlapping stamps or initials across the entire translation.

Regarding COA dossier appraisal contents, Circular No. 33 amends the entirety of Article 8 in Circular No. 74. Accordingly, under new regulations, competent authorities first cross-check enterprise declaration information against origin verification documents. Inconsistent dossiers will be returned with stated reasons; valid cases will continue to be categorized by raw material sources.

For raw materials outside the US import prohibition list, competent authorities consider issuing a COA. This list is updated on the website of US regulatory agencies.

For raw materials within prohibition lists, appraisal continues based on harvesting origins, harvesting nations, fishing gears, harvesting zones, and related information.

Additionally, Circular No. 33 stipulates 3 dossier handling scenarios: considering COA issuance for raw materials from nations recognized as equivalent by the US or farmed raw materials; considering COA issuance if fishing gear, harvesting zone, or harvesting nation information differs from prohibition lists; and withholding COA issuance if species, fishing gear, nation, and harvesting zone information match US import prohibition lists.

Furthermore, Circular No. 33 supplements responsibilities for management agencies and enterprises in points e and g, Clause 1, and Clause 3 of Article 10 in Circular No. 74.

Specifically, management agencies are assigned to organize inspections of COA issuance operations across localities and enterprises in accordance with Vietnamese law or upon US request. Concurrently, they bear responsibility for constructing and guiding localities and enterprises to update COA databases, while coordinating full-process public service deployment and electronic COA issuance on the National Public Service Portal.

For enterprises, complete dossiers must be prepared, with full legal responsibility borne for declared information accuracy; raw material origin documentation and records must be retained for a minimum of 36 months from the COA issuance date; and origin traceability systems must be established to ensure complete monitoring across receipt, preservation, processing, and export phases when requested by competent authorities.

Regarding transitional provisions, Circular No. 33 amends and supplements Article 11 of Circular No. 74 as follows: In cases where organizations and individuals exporting seafood or seafood products utilize raw materials harvested prior to December 26, 2025 without dossier components required under Article 6 of this Circular, they are permitted to submit a COA application form accompanied by invoices or procurement manifests to prove raw material purchase timing serving processing and export. Cases where dossiers were received prior to the effective date of this Circular continue to be resolved under previous regulations, unless organizations or individuals request application of new regulations.

Concurrently, Form No. 01 in Appendix I and Form No. 02 in Appendix II issued alongside Circular No. 74/2025/TT-BNNMT are replaced with new forms to standardize nationwide implementation.

Source: Tap chi Thuy san Viet Nam