Major global markets are simultaneously raising import standards, creating mounting pressure for Vietnamese agricultural exporters to restructure their production and export models.

Exports to China enter the era of data-driven compliance

China is rapidly transitioning toward a fully digitalized agricultural and food import management model centered on risk-based supervision and end-to-end traceability throughout the supply chain.

Notably, Decree No. 280 issued by the General Administration of Customs of China (GACC) on the registration management of overseas food manufacturing enterprises exporting to China will officially take effect on June 1, 2026, replacing the previous Decree No. 248.

Under the new regulation, the entire process of enterprise registration, GACC code management, customs declaration, and import supervision will become more stringent, with oversight increasingly based on the risk profile of each product category.

One of the key changes is that many product groups, including seafood, dairy products, bird’s nest, and honey, will be required to obtain official recommendation letters from competent Vietnamese authorities when registering for export to China.

Enterprises must also re-register their GACC codes if there are changes to production locations, legal representatives, or official registration codes issued by competent authorities.

At the same time, China is strengthening electronic customs declaration requirements. According to Notice No. 219/2025, importing enterprises must fully and accurately declare the registration code of foreign exporters in customs documentation.

For shipments containing multiple product categories, each corresponding registration code must be declared separately.

According to Dr. Dao Van Cuong of the Vietnam SPS Office, these new regulations demonstrate that China is rapidly moving toward a digitalized SPS management system increasingly aligned with international standards.

“In the near future, the absence of data will effectively mean the inability to export,” Dr. Dao Van Cuong stated.

Beyond reviewing enterprise documentation, China is now conducting deeper risk analysis for each product category, covering raw material origins, production processes, processing and storage practices, historical compliance records, and food safety performance.

Many of Vietnam’s major export sectors are currently subject to heightened scrutiny.

Rice has been classified as an independent management category with specific warnings concerning pests, cadmium residues, and genetically modified rice risks.

Dried vegetables and root crops are facing tighter controls related to sulfur dioxide and heavy metal residues.

Seafood remains under strict surveillance due to concerns related to disease risks, veterinary drug residues, microorganisms, and parasites.

According to experts, the most significant impact lies not in administrative procedures but in China’s establishment of real-time enterprise monitoring systems that evaluate compliance performance and automatically classify risk levels.

Enterprises lacking digital data systems, effective raw material area management, and supply chain control capabilities will face an increased risk of being excluded from the market.

In contrast, businesses with stable growing areas, robust traceability systems, and professional data governance structures will hold a clear competitive advantage.

EUDR, carbon, and MRL create a new screening framework

China is not alone in tightening standards.

Major markets such as the EU, Japan, and the United States are also raising import requirements in line with green transition and sustainable development objectives.

According to Dr. Dao Van Cuong, the European Union Deforestation Regulation (EUDR) will have profound implications for many of Vietnam’s key export sectors, including coffee, timber, and rubber.

Under EUDR, all products exported to the EU must demonstrate that they are not linked to deforestation occurring after December 31, 2020, and do not contribute to forest degradation.

The most significant challenge lies in the requirement for traceability down to exact geolocation coordinates.

Enterprises must maintain GPS data, digitized maps, growing area records, and verification capabilities supported by satellite imagery.

In addition, exporters must fulfill mandatory due diligence obligations, including deforestation risk assessments, mitigation planning, and submission of due diligence statements through the EU’s compliance system.

Failure to comply may result in shipment rejection or substantial financial penalties.

According to experts, EUDR will place considerable pressure on small and medium-sized enterprises, cooperatives, and smallholder farmers due to rising compliance costs and limited digitalization capacity.

However, it also presents an opportunity to restructure Vietnam’s agricultural sector toward greater transparency and sustainability.

Standardizing raw material areas, strengthening traceability systems, and digitizing supply chains will improve product quality, reduce fragmented production, and enhance the international reputation of Vietnamese agricultural exports.

Alongside EUDR, carbon-related regulations are emerging as a new technical barrier in global trade.

As the EU implements its Carbon Border Adjustment Mechanism (CBAM), exporters are facing increasing pressure to disclose emissions data and ensure ESG transparency throughout their supply chains.

This trend is no longer limited to steel, cement, or fertilizers but is rapidly extending to agricultural products, food processing, logistics, and related sectors.

According to Dr. Dao Van Cuong, industries such as seafood, rice, coffee, and livestock production will face substantial pressure due to their direct connection to methane emissions, energy consumption, and logistics-related carbon footprints.

Enterprises will be required to invest in greenhouse gas inventories, emissions measurement systems, carbon traceability tools, and ESG audits to maintain access to premium markets.

Meanwhile, maximum residue limit (MRL) regulations remain among the strictest screening mechanisms for agricultural exports.

Experts emphasize that no unified global MRL standard currently exists.

The EU, Japan, and the United States each apply their own thresholds for active substances based on distinct regulatory approaches.

The EU currently applies an extremely precautionary principle, with a default MRL threshold of only 0.01 mg/kg for substances without specific regulatory limits.

Many active substances such as Chlorpyrifos, Carbendazim, and Tricyclazole have been subject to tighter restrictions, placing considerable pressure on Vietnam’s rice, fruit, vegetable, and seafood sectors.

Japan, meanwhile, applies its Positive List System, under which only explicitly permitted substances may be present in food products.

According to forecasts from the Vietnam SPS Office, MRL tightening will continue to intensify in the coming years through lower residue thresholds, additional substance bans, and higher inspection frequencies.

This will require exporters to establish multi-standard compliance systems tailored to each destination market, significantly increasing compliance costs.

Pressure creates opportunities for restructuring

According to experts, the common denominator across GACC regulations, EUDR, carbon disclosure requirements, and MRL controls is their emphasis on data transparency, traceability, and supply chain governance.

This reflects a broader transformation in global trade from price-based competition toward competition driven by quality, low emissions, and sustainable development.

In this context, fragmented production models, small-scale purchasing systems, and poor data management will become increasingly unsustainable.

By contrast, enterprises with stable raw material areas, comprehensive traceability systems, strong ESG governance, and effective supply chain control capabilities will gain substantial advantages.

According to Dr. Dao Van Cuong, the challenge is no longer about complying with individual regulations but about building the capacity to simultaneously meet multiple standards.

This shift is also creating momentum for Vietnam’s agricultural sector to transition more rapidly toward professional, transparent, and sustainable production models.

Enterprises that invest early in digital data systems, raw material area management, traceability infrastructure, and ESG governance will be better positioned to expand markets, enhance product value, and participate more deeply in global supply chains.

In the future, MRL requirements will no longer operate independently but will increasingly be integrated with traceability, carbon, and EUDR requirements to form a comprehensive import control framework.

This means that products entering major global markets must not only satisfy food safety standards but also demonstrate transparent origins, low-carbon production practices, and no association with deforestation.

Source: Bao Cong Thuong