In response to Official Letter No. 3710/BNNMT-CCPT dated April 16, 2026, from the Ministry of Agriculture and Environment requesting comments on the Draft Circular promulgating the list of products and goods with medium and high risk levels under the Ministry's management, VCCI stated that the development of this list is of significant importance in perfecting the mechanism for managing product and goods quality in the direction of risk-based management.
According to VCCI, the list will serve as a basis for determining appropriate management measures for each group of products and goods, thereby contributing to improving the effectiveness of state management, ensuring safety for humans, livestock and the environment, and facilitating the production and business activities of enterprises.
One of the key bases for developing the list in the draft is the regulation in Decree No. 37/2026/ND-CP. Accordingly, the determination of the risk level of products and goods must be based on scientific evidence, practical data, the management capacity of state agencies, ensuring transparency, objectivity, and the principle of management commensurate with the level of risk.
However, based on a comparison with the draft documents and explanatory notes, VCCI believes that there are still some issues that need further improvement.
Regarding methods for determining the risk level of products and goods, VCCI notes that current risk assessment forms mainly present qualitative descriptions and do not clearly demonstrate the quantitative basis and calculation methods for determining the corresponding risk level.
When evaluating factors C, k, and P to determine the risk level of products and goods, the input data is often unclear and lacks concrete evidence. For example, for rice and corn seeds, the risk assessment for "air, water, and soil pollution" and "impact on ecosystems and biodiversity" is determined to be "possible" based on data on environmental violations by rice and corn seed production and trading establishments. However, the explanatory document does not specify the number of violations, their frequency, or the extent of the impact in practice.
Therefore, VCCI proposes that the drafting agency add a scoring table for criteria k, C, and P, and provide a detailed explanation of how to determine the score for each product or group of products. At the same time, the data sources used should be specific, quantitative, and reflect current production and business practices as well as existing control mechanisms.
Regarding transitional regulations and the roadmap for amending national technical standards (QCVN), the Vietnam Chamber of Commerce and Industry (VCCI) stated that many businesses have reported the risk of overlapping regulations arising from the shift to a risk-based management mechanism under Decree No. 37/2026/ND-CP, while the QCVN system and related management regulations have not yet been reviewed and adjusted accordingly.
According to VCCI, this could make it difficult for businesses to declare conformity, conduct testing, assess conformity, and apply management measures to products circulating in the market.
Therefore, VCCI proposes that the drafting agency add regulations on management measures to be applied during the transitional period for products in the medium-risk and high-risk groups while the national technical standards system has not yet been adjusted accordingly. At the same time, it suggests studying a roadmap for reviewing, amending, or supplementing the national technical standards and related regulations to ensure consistency and uniformity in the application of the new management mechanism.
Furthermore, regarding some content in the Appendix of product and goods catalogs, VCCI stated that businesses and associations have reported that the draft does not fully reflect the actual scope of products in the animal feed sector.
The Vietnam Animal Feed Association proposes adding the product "mixed concentrate feed for calves and beef cattle" to Section A.3 of the Appendix. At the same time, the name in Section A.3.3 should be amended to "supplementary feed" or "supplementary feed in single and mixed ingredient forms" to fully reflect the products currently available on the market.
The Vietnam Chamber of Commerce and Industry (VCCI) stated that these are the initial opinions of the business community regarding the draft circular and requested the drafting agency to study and consider them in order to further revise and improve the draft in the future.
Source: https://doanhnghiepvn.vn/doanh-nghiep/can-lam-ro-can-cu-danh-gia-rui-ro-san-pham-hang-hoa/20260516101518401
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