The EU market has recognized Vietnam's seafood food safety control system; in which the National Agency for Quality, Processing and Market Development (NAFIQPM) is the competent authority of Vietnam controlling exported seafood. Facilities in the seafood product chain must be inspected and recognized to ensure food safety, meet EU regulations and each shipment exported to the EU must also be assessed, sampled for testing, and granted a food safety certificate with many steps. NAFIQPM provides information on the necessary regulations for businesses to meet when exporting to the EU.

General regulations to ensure food safety

Regulation (EC) No 178/2002 sets out the general principles and basic requirements of food law and the obligations of food businesses in the EU. It covers food safety, precautionary measures, emergency measures, labelling requirements, traceability, recalls and operator liability. The emphasis here is on transparency, with public consultation, for example the traceability regulation requires that each product be traced back one step up and one step down the supply chain. If a problem is detected, the product is recalled immediately.

Regulation (EC) No 852/2004 on food hygiene with requirements ranging from equipment, staff training, record keeping, pest control, use of chemicals to waste disposal. It applies to all stages of the product chain, and food hygiene obligations must be complied with. Food businesses must be registered and approved.

Regulation (EC) 853/2004 establishes specific hygiene rules for food of animal origin, including fishery products. It defines “raw” and “processed” products, and only approved establishments are allowed to place them on the market. The products must have an identification code, meeting high food safety standards.

Regulation (EC) 2073/2004 on microbiological criteria for foodstuffs and Regulation EC 1441/2007 amending Regulation EC 2073/2004. Sets out specific microbiological standards that foodstuffs must comply with to ensure consumer safety.

Regulation (EC) 1881/2006 sets limits for contaminants such as heavy metals, dioxins, and others. Regulation EC 2021/1323 amends EC 1881/2006 concerning maximum levels of Cadmium in foodstuffs and EC 2022/617 amends EC 1881/2006 concerning maximum levels of mercury in fish. The mercury content in fish is 0.3 - 1.0 mg/kg depending on the type of fish, and in salt is 0.10 mg/kg.

Regulation (EC) 333/2007 sets out methods for sampling and analysis of processing contaminants in food, in particular lead, cadmium, mercury, inorganic tin, 3-MCPD and benzo(a)pyrene. Regulation (EU) 2017/644 sets out methods for sampling and analysis of dioxins and PCBs.

Regulation (EC) 1333/2008 sets out the management and use of food additives and processing aids; it sets out specific standards for additives such as colourings, thickeners and flavourings.

Regulation (EC) 470/2009 establishes maximum residue limits (MRLs) for veterinary medicinal products in food of animal origin. Regulation EC 396/2005 establishes MRLs for pesticides. Regulation 37/2010 establishes a list of substances prohibited and permitted for use in food of animal origin.

Regulation EC 1169/2011 sets out information on food labelling. Mandatory on the label: product name (including trade name and scientific name), list of ingredients, information on allergies, genetically modified foods, country of origin.

New regulations on seafood imports

The EU has innovated its regulatory system with the “Smarter rules for safer food and plant health” initiative to improve efficiency and safety in food and plant health control. Three foundational regulations have been issued, including the Animal Health Regulation AHR: (EU) 2016/429; the Plant Health Regulation PHR: (EU) 2016/2031; and the Regulatory Regulation OCR: (EU) 2017/625.

Our country's seafood exports to the EU are quite diverse.

The AHR officially entered into force on 21 April 2021. Most of the provisions of the PHR and OCR entered into force on 14 December 2019.

Regulation (EU) 2017/625 ensures the implementation of food and animal law, expands the scope and harmonises the rules for animal products, live animals, plants and high-risk food of non-animal origin. Article 127(3) of this regulation requires establishments wishing to export to the EU to be listed.

Regulation (EU) 2019/625, as amended by Regulation 2022/2292, sets out the import conditions for consignments of products of animal origin such as fishery products, NT2MV and composite products, effective from 21 April 2021.

Regulation (EU) 2019/627, amended by Regulation 2022/2503, sets out the requirements for implementing controls on NT2MV (Articles 51-65) and fishery controls (Articles 67-71).

Special requirements for aquatic products

Aquaculture: Must develop, implement and be recognized by the EU for a national monitoring program on antibiotic residues in aquaculture. The bivalve mollusc monitoring program (NT2MV) entering the EU must develop, implement and be recognized by the EU for food safety in the harvesting area.

Annually, the competent authority of the exporting country must report to the EU on the results of the implementation of the monitoring program; periodically, the EU competent authority will conduct on-site inspections of the development and implementation of the program.

The EU competent authority requires a separate list for establishments producing frog legs, snails, gelatine/collagen from aquatic raw materials.

Requires a list for all establishments participating in the chain: purchasing establishments, preliminary processing establishments, cold storage, processing establishments, freezing vessels, processing vessels.

In particular, there are regulations on combating IUU fishing.

Source: Tep Bac