One of the most notable requirements was that by December 31, 2015, all commercial catfish farms in the country were to have obtained a Certificate of Good Aquaculture Practice with VietGap or a comparable international certificate.
Now nearly 14 months past the deadline, the Vietnam Association of Seafood Exporters says that only roughly half of the country’s commercial fish farmers have complied with the certification requirements.
In addition, catfish processors were informed under the Decree that they would have to put in place a quality control system to ensure compliance with the Government’s standards for food safety and hygiene during manufacture and sale of products.
Many of the requirements detailed in the Decree were very specific and addressed matters related to industry participants obtaining a certificate of food safety issued by an appropriate authority as approved by the Government.
Other requirements related to inspections to ensure quality and matters related to packaging and labelling. The decree also specifically noted that the amount of water in fish products must not exceed 83% of net weight (weight of catfish fillets after removing the ice glazing).
The measures and requirements outlined in the Decree were aimed at resolving the problems catfish raised and harvested in Vietnam faces gaining market entry into countries around the globe— specifically the strict US and EU markets.
Given the failure of those in the industry to comply with the Decree it appears highly problematic that the industry will be able to meet with the new USDA Food Safety and Inspection Service (FSIS) catfish inspection program by the September 1 deadline.
After that date, the first hurdle the industry faces is that it must show it is complying with the Decree issued by the Government.
Secondly, for exports to continue after September 2, the Vietnam government must have the approval of FSIS.
That approval can only be obtained by the Government submitting a complete dossier showing that Vietnam has a system for monitoring and inspection of catfish that is operational and that it is substantially equivalent to the FSIS system.
So, right now, those in the farm raised catfish industry need to quickly coordinate with the Ministry of Agriculture and Rural Development and the Vietnam Seafood Exporters Association to prepare records for submission to FSIS if they want to continue exporting to the US.
Given that there is currently a lack of compliance with the Decree issued by the Vietnam government in 2014 (Decree No. 36/2014/ND-C) it appears the farm raised catfish industry has its work cut out for it over the next few months.