Aquafeed value chain analysis and a review of regulatory ... · technology and high-quality production inputs. In 2014, annual production of pangasius was 1 143 797 tonnes. The key

ISSN 2070-7010

Aquafeed value chain analysisand a review of regulatoryframework of striped catfishfarming in Viet Nam

FAOFISHERIES ANDAQUACULTURE

TECHNICALPAPER

648

Cover photographs:Top to bottom: Feeding striped catfish with commercial pelleted feed from a floating raft in an integrated enterprise farm in Mekong Delta, Viet Nam (©FAO/Mohammad R. Hasan). Hand feeding of commercial pelleted feed in a small striped catfish farm in Mekong Delta, Viet Nam (©FAO/Mohammad R. Hasan).

Cover design:Mohammad R. Hasan and Koen H. Ivens

FOOD AND AGRICULTURE ORGANIZATION OF THE UNITED NATIONS Rome, 2019

FAOFISHERIES ANDAQUACULTURE

TECHNICALPAPER

648

Aquafeed value chain analysisand a review of regulatoryframework of striped catfishfarming in Viet Nam

Mohammad R. HasanFormer Aquaculture OfficerAquaculture Branch FAO Fisheries and Aquaculture Department Rome, Italy

Thomas A. Shipton FAO ConsultantGrahamstown, South Africa

and

Pedro B. Bueno FAO Consultant Bangkok, Thailand

The designations employed and the presentation of material in this information product do not imply the expression of any opinion whatsoever on the part of the Food and Agriculture Organization of the United Nations (FAO) concerning the legal or development status of any country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or boundaries. The mention of specific companies or products of manufacturers, whether or not these have been patented, does not imply that these have been endorsed or recommended by FAO in preference to others of a similar nature that are not mentioned.

The views expressed in this information product are those of the author(s) and do not necessarily reflect the views or policies of FAO.

ISSN 2070-7010 [Print]ISSN 2664-5408 [Online]

ISBN 978-92-5-132004-4© FAO, 2019

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Hasan, M.R., Shipton, T.A. and Bueno, P.B. 2019. Aquafeed value chain analysis and a review of regulatory framework of striped catfish farming in Viet Nam. FAO Fisheries and Aquaculture Technical Paper No. 648. Rome, FAO.

iii

Preparation of this document

Preparation of this technical paper was coordinated by Dr Mohammad R. Hasan, former Aquaculture Officer of the Aquaculture Branch, FAO Fisheries and Aquaculture Department as a part of FAO’s Strategic Objective (SO1): Eradicate hunger, food insecurity and malnutrition. This publication will contribute to organizational outcome 10101: improving capacities of governments and stakeholders for developing sectoral and cross-sectoral policy frameworks and investment plans and programmes for food security and nutrition. The publication provides a description and analysis of the aquafeed value chain and a review of the regulatory framework of striped catfish farming in Viet Nam. It recommends a series of interventions/recommendations with a view to optimizing value chain performance, and ensuring that catfish farmers have access to high quality and cost-effective aquafeed.

This study, and the publication of this document, was funded under the auspices of the project “FMM/BGI/ARI under Blue Growth Initiative (BGI) in Support of Food Nutrition Security, Poverty Alleviation and Healthy Oceans [FMM/GLO/112/MUL Baby 4 (Blue Growth)].

The authors would like to express their sincere thanks to the numerous feed mill owners, catfish farmers and all other stakeholders involved in the broader aquaculture sector who were interviewed, consulted or otherwise took part in the study, for their contribution to the qualitative and quantitative data and information. Dr Nhu Van Can, Ms Nguyen Thi Thuy and Ms Nguyen Thi Bang Tam of the Directorate of Fisheries (D-Fish) under the Ministry Agriculture and Rural Development (MARD), Viet Nam are gratefully acknowledged for conducting the survey and preparing the first draft report on “Aquafeed value chain analysis and on-farm feeding & feed management practices of pangasius farming in Viet Nam” for FAO through a letter of agreement between FAO Viet Nam and D-Fish.

Dr Richard Anthony Corner edited this technical paper for its linguistic quality. For consistency and conformity, the use of scientific and English common names of fish species in this technical paper were used according to FishBase (www.fishbase.org/search.php).

Ms Marianne Guyonnet and Ms Lisa Falcone are acknowledged for their assistance in quality control and FAO house style. Mr Koen H. Ivens prepared the layout design for printing. The publishing and distribution of the document were undertaken by FAO, Rome. Mr SongHa Nguyen, Assistant FAO Representative in Viet Nam is acknowledged for providing the support and advice necessary to undertake this study.

iv

Abstract

The study sought to characterize Viet Nam’s pangasius aquafeed value chain and identify constraints to feed supply and use. Its key objectives were to identify and map the pangasius aquafeed value chain and characterize the roles of different actors and linkages along the value chain; assess the performance of the value chain; and evaluate the on-farm feeding and feed management practices. The results including the methodologies are presented in two sections, namely, the analysis of the aquafeed value chain and the review of the aquafeed regulatory framework. The third section comprises the technical, strategic and policy recommendations distilled from the results.

v

Contents

Preparation of this document iiiAbstract ivAbbreviations and acronyms vii Executive summary ix

Background 1

SECTION 1: AQUAFEED VALUE CHAIN ANALYSIS 5

1. Introduction 5

2. Methodology 5

3. Results 6 3.1 Spatial distribution and characterization of the sector 6 3.2 Value chain map 10 3.3 Feed ingredient suppliers 11 3.4 Feed manufacturing 12 3.4.1 Feed manufacturing costs 12 3.4.2 Feed ingredient availability 12 3.4.3 Commercially manufactured aquafeeds 16 3.4.4 Product quality monitoring 19 3.4.5 Feed packaging, transportation and storage 19 3.4.6 Certification 20 3.5 Feed wholesalers and traders 21 3.6 Farmers 23 3.6.1 Production characteristics 24 3.6.1.1 Grow-out production 24 3.6.1.2 Fry and fingerling production 24 3.6.2 On-farm production costs 26 3.6.3 On-fam feed management practices 27 3.6.4 Feed affordability 28 3.7 Services 30 3.7.1 Inspection systems 30 3.7.2 Financial services 31 3.7.3 Tax regimes 32

SECTION 2: AQUAFEED REGULATORY REVIEW 33 1. Introduction 33

2. Methods 35

3. Review of Decree No. 39/2017/ND-CP 35

SECTION 3: RECOMMENDATIONS TO IMPROVE VALUE CHAIN EFFICIENCY AND REGULATORY FRAMEWORKS 47

1. Technical recommendations 47

2. Strategic recommendations 51

References 53

APPENDIX ACompound feed for sutchi catfish and tilapia: TCVN 10300:2014Banned substances (chemicals, antibiotics) in compound feedsfor Sutchi catfish and tilapia 55

APPENDIX BCompound feed for sutchi catfish and tilapia: TCVN 10300:2014Items to be presented on a label 57

vi

vii

Abbreviations and acronyms

AAFCO Association of American Feed Control OfficialsASEAN Association of Southeast Asian Nations BAP best aquaculture practiceCoD cash on deliveryDARD Department of Agriculture and Rural DevelopmentD-Fish Directorate of FisherieseFCR conomic food conversion ratioEIA environmental impact assessmentEMP environment protection planEUAEU Eurasian Economic UnionFCR feed conversion ratioGSTP Global System of Trade Preferences Among Developing CountriesHACCP hazard analysis and critical control point g grammeGAA Global Aquaculture AllianceGlobalGap The Global Partnership for Good Aquaculture PracticeGSTP Global System of Trade Preferences Among Developing Countriesha hectareISO International Organization for Standardization kg kilogram MARD Ministry of Agriculture and Rural Development NGO non-government organizationNIRS near infrared spectroscopyPPP public-private partnershipSE standard errorWTO World Trade OrganizationUSA United State of AmericaUSD US dollarVAT value added taxVietGap Vietnamese Good Agricultural PracticesVNA Vietnamese National Assembly VND Viet Nam Dong1 USD 22 470 VND (Vietcombank, November, 2015)

A grow-out pond in a small catfish farmin Mekong Delta, Viet Nam.(©FAO/Mohammad R. Hasan)

ix

Executive summary

This report presents the findings of a value chain analysis of the aquafeed (aquatic animal feed) sub-sector for the striped catfish (Pangasianodon hypophthalmus) farming in Viet Nam, including a review of aquafeed regulatory framework in the country. The striped catfish (pangasius) production sub-sector is characterized by intensive pond production technology and high-quality production inputs. In 2014, annual production of pangasius was1 143 797 tonnes. The key actors in the value chain comprise input suppliers, including feed ingredients suppliers, feed manufacturers, and hatchery operators (seed producers), along with fingerling and grow-out farmers, fish processors, exporters, consumers and service providers. In recent years, large-scale vertically integrated enterprises have started to emerge that operate along the entire value chain, and these now dominate many areas of production.

The pangasius production sector is centered on the ten provinces of the Mekong Delta. The value chain analysis revealed that in 2014, there were 109 hatcheries in operation producing 23.6 billion larvae per annum. The hatchery-reared larvae were distributed across 2 683 nurseries with a combined annual production of2.58 billion fingerlings per annum. The grow-out production sector comprised5 089 ponds operated as 143 enterprise farms (3 389 ha ponds), 1 490 family-run farms(1 572 ha ponds), and 11 cooperatives (209 ha ponds). In the grow-out production sector, highest production costs were for feed and fingerling, which accounted for81.25 percent and 7.4 percent of the total production costs respectively.

A total of 78 registered feed ingredient-trading companies supply an estimated1.6 million tonnes of feed ingredients to feed manufacturers. 50.87 percent of feed ingredients used in animal feeds (terrestrial and aquatic animal feeds) in Viet Nam are imported. The majority of imports comprise high quality protein sources such as fishmeal, poultry meal, meat & bone meal, blood meal, and soybean and canola oil seed products. In addition, many of the feed additives used in the formulated feeds are also imported.

There are 48 commercial aquafeed manufacturers supplying the pangasius sector with high quality floating extruded feeds. These facilities have an installed production capacity of 5 232 500 tonnes/annum, with an average production capacity of10 900 tonnes/annum/manufacture. The feed manufacturing sector is centered in Dong Thap province where 26 of the sectors’ 48 feed manufacturing facilities are located. Overall the feed manufacturing facilities operate below the installed capacity. In 2014, commercial feed production was estimated at 1 830 075 tonnes (34 percent capacity), with a mean production cost of USD0.511 ± 0.03/kg based on the grower feed formulation. Profit margins accruing to the feed manufacturing sector were estimated at 4.7 percent. The study found that farm-made feed production was negligible at (<10 000 tonnes/annum). Distribution of feed occurs through 882 feed wholesalers and retailers, registered as suppliers of pangasius feeds. On average, wholesalers traded 643 tonnes of feed per annum, with 94 percent supplying between 10–1 000 tonnes per annum. Profit margins for suppliers was estimated at 4.07 percent.

Regulation in feed is defined through Decree 39/2017/ND-CP “Providing the regulatory framework for terrestrial and aquatic animal feeds”, which was reviewed by this project. Several recommendations were made for substantive revisions of some provisions in the decree, to improve enforcement and/or facilitate compliance, to simplify procedures to reduce the costs of regulation and facilitate the production of new feed, and for improvement in the ability of the regulated organization to be

able to comply with the decree. Important measures for development of implementing regulations and technical guidelines and the formulation of a national aquafeed standard are urgently recommended. There are management, technical and funding issues, however, that need to be resolved to initiate and successfully implement these measures. Recommendations on overall governance mechanism other than regulatory requirements are made, including on market-based requirements, voluntary management and stakeholder participation. There is a need for a policy that provides incentives on the development and commercialization of new aquafeed, and the search for, development of and commercial production of local ingredients for aquafeed and for new and more efficient feed formulations. Better compliance by farmers is envisaged by the development and promotion of a better feed management practice guide. Measures to strengthen the capacity of regulators and the regulated, and the science and technology support services are recommended.

x

1

Background

Striped catfish (Pangasianodon hypophthalmus, commonly known as pangasius) farming in Viet Nam has a long history (Table 1) and dates back to the 1940’s when the species was first cultured in small ponds, using wild caught seed and natural feed. Intensification of pond production system was initiated in the 1980s when simple farm-made feed was introduced, and further production advances were made in the mid-1990s with the with introduction of artificially propagated seed and small-scale cage culture facilities. Since the late 1990’s production in the sector has increased rapidly, most associated with the introduction of commercially manufactured pellet feed in 2001, followed by the introduction of extruded floating feed in 2005. There was a concomitant move from cage culture production to the widespread use of intensive pond culture systems that continue to be in use today. The rapid adoption of intensive pond production systems combined with the introduction of hatchery-reared seed and commercially available feed resulted in a significant growth in the sector. Production was less than 100 000 tonnes per annum in 1999, and that expanded to 400 000 tonnes in 2005, reaching a peak in 2008 with production of1.4 million tonnes (Figure 1). In recent years, production has stabilized at approximately 1.2 million tonnes, and that equates to approximately 30 percent of the country’s total aquaculture production (D-Fish, 2015). Pangasius products are now exported to140 countries. As a consequence, production is expected to grow approximately by5.0 percent per annum until the end of the decade and by 2020, the value of the sector is anticipated to reach USD2.0 billion per annum (Kim Quyen et al., 2017).

TABLE 1

History of pangasius farming

Period Culture method Feed Seed

1940–1950 Small ponds (An Giang, Dong Thap)

Natural feed Wild caught

1981–1982 Intensive production in small ponds

Natural & moist farm-made feed Wild caught

1996–1999 Intensive production in ponds and cages

Moist farm-made feed/ introduction of compressed pellet

Wild caught + Artificial

2001 –2004 Expand production in ponds and cages.

Moist farm-made & dried compressed pellet feed

Artificial seed

2005 – present Change from cages and net pen to super-intensive production in ponds

Dried extruded pellet feed Artificial seed

Source: Modified from De Silva and Nguyen (2011).

Pangasius farming in Viet Nam is now based on super-intensive production technologies, the use of high-quality production inputs, and is characterized as a well-developed production sector. While the rapid growth of the sector has been characterized by increasing production intensities and improved production efficiencies, there has been a decline in profit margins and frequent restructuring in the sector (Nguyen, et al.,2007; De Silva and Nguyen, 2011). In recent years, large-scale vertically integrated

enterprise companies have started to emerge, that operate along the entire value chain and now dominate many areas of production. The economies of scale and concomitant production efficiencies available to these large vertically integrated enterprises has resulted in consolidation of much of the production capacity. This has inevitably come at the expense of some of the smaller family scale and cooperative producers, which in recent years have shown a decline in numbers and production capacity (Box 1).

BOX 1

Pangasius farming models in Viet Nam

Three distinct farming models have evolved in the Vietnamese pangasius production sector:

the enterprise farm, the family farm and the cooperative farm. While all three are based on

similar intensive production technologies (hatchery, nursery and grow-out pond culture),

their scales of operations and levels of vertical integration differ markedly.

The enterprise farms represent the largest group, comprising 143 farms operating

3 389 ha of production ponds, producing 780 004 tonnes per year (mean farm size: 23 ha; mean

production: 5 454 tonnes per year). Enterprise farms are best characterized as large-scale

industrial production units that operate at varying degrees of vertical integration. There are a

number of production scales within the enterprise farm sector. The smaller farms usually limit

their production activities to grow-out production and procure their inputs (feed and seed)

from larger vertically integrated enterprise farms or independent feed mills and hatcheries.

They either process their harvest or pass it on to the larger enterprise farms that have excess

processing capacity or to independent fish processing companies. Typically, the large-scale

vertically integrated enterprise farms will have invested in all aspects of the production chain

from input supplies (feed manufacturing and hatchery production), grow-out farming, to fish

processing. Clearly, these large vertically integrated operations have more control over their

productions costs and can benefit from economies of scale that smaller enterprises, family

farms and cooperatives have difficulty attaining.

The family farms comprise the second largest production sub-sector. There are 1 490

family farms operating 1 572 ha of production ponds, producing 309 937 tonnes per year

(mean farm size: 1.05 ha; mean production: 208 tonnes per year). Ownership is at the family

level, with family members being employed and, if needed, additional labour is hired. While

mostly concentrating on grow-out production, some specialist farms produce fingerlings. In

many cases, the high production cost (principally feed and seed) makes it difficult for these

small businesses to independently fund their farming operations. In such cases, they enter

into some form of contract farming with the larger vertically integrated enterprise farms or

independent feed manufacturers/fish processors, which guarantees them access to feed and

processing capacity, as well as market (section 3.6.4).

The cooperative farms represent the smallest sub-sector; there are only 11 of these,

operating 209 ha of production ponds, producing 53 856 tonnes per year (mean farm size:

19 ha; mean production: 4 896 tonnes per annum). The member farmers are better placed

to negotiate lower input prices (feed and seed) and joint fish processing contracts. In recent

years, the number of cooperatives has been falling as profitability across the value chain has

favoured the large-scale family and enterprise farms with their concomitant economies of

scale, and lower production costs.

2 Aquafeed value chain analysis and a review of regulatory framework of striped catfish farming in Viet Nam

3

Prior to 1995, the feeds used in pangasius culture was primarily a combination of moist farm-made feed and low-value fish. The introduction of commercially manufactured feed coincided with a general move from cage to pond production systems. While the adoption of commercially manufactured feed over farm-made feed was initially slow, concerns over the increasing demand and dwindling supplies of feed ingredients to support farm-made feed production, limitations in the supply of low-value fish, and environmental concerns regarding the use of farm-made feed in intensive pond production systems, have led to the gradual acceptance of commercially manufactured feed (Nguyen, 2013). A reduction in the availability of farm-made feed increased demand for commercial feed, enabling the feed manufacturing sector to expand rapidly, and develop over the past 20 years. The first commercial feed manufacturer started operating in 1995, and by 2004 the number had increased to 18 manufacturers producing approximately 300 000 tonnes of commercial feed per annum (Tran, 2005). By 2015, the number had increased to 48 feed manufacturers with an installed production capacity of 5.2 million tonnes of feed per annum (current study). Capacity is not a current constraint to the pangasius sector, but future development will be constrained by rising input costs, most notably feed cost (Rola and Hasan, 2007; Piesse and Thirtle, 2009). Lam et al. (2009) reported that aquafeed accounted for approximately 75 percent of the operating cost of pangasius farming. With feed cost continuing to rise, ensuring the quality, cost effectiveness, availability, and the optimization of their use, should all be considered as important factors to the promotion of continued growth in the sector.

FIGURE 1Striped catfish production in Viet Nam between 1999 – 2014

Source: D-Fish (2015).

Background

Feed storage in an industrial feed mill, Mekong Delta, Viet Nam.(©FAO/Mohammad R. Hasan)

5

SECTION 1:AQUAFEED VALUE CHAIN ANALYSIS

1. Introduction

To date there has been no study to characterize the pangasius aquafeed value chain, and to identify the constraints to its supply and use. In this context, the study was designed to address to the following key objectives:

•Identify and map the pangasius aquafeed value chain in Viet Nam and characterize the roles of different actors and linkages along the value chain.

•Determine and assess the performance of the aquafeed value chain. •Evaluate on-farm feeding and feed management practices.

2. Methodology

Two survey questionnaires were developed to characterize and collect data on the principal actors along the aquafeed value chain, one completed by regulatory authorities, and one by feed ingredient suppliers, feed manufacturers, wholesalers, retailers and farmers. In addition, the current status of on-farm feeding and feed management practices used by both enterprise and family farmers was determined using a third questionnaire. Prior to the deployment, the questionnaires were tested, and where appropriate they were revised. Enumerators were trained to support the data collection process, which included interviews, data collection and compilation.

A total of 88 questionnaires were completed, as follows:

•10 by the provincial aquaculture authorities where pangasius production is undertaken in the country, all of which are under the administrative umbrella of D-Fish. The general aquaculture information was collected by the provincial aquaculture authorities.

•12 by feed manufacturers – representing 25 percent of 48 manufacturers in the sector.

•16 by feed ingredient suppliers – representing 20 percent of the 78 suppliers in the sector.

•18 by feed wholesalers/retailers – representing 2 percent of the 747 retailers/wholesalers in the sector.


•32 by farms – consisting of 20 enterprise farms (14 percent of 143 enterprise farms), 15 family farms representing 1 percent of the 1 490 family farms,

1 cooperative farm representing 9 percent of the 11 cooperatives farms.

While the survey was conducted across the ten provinces of Mekong delta, the primary focus was centered around the five provinces - Dong Thap, An Giang, Can Tho, Ben Tre and Vinh Long - where the majority of aquafeed manufacturing capacity is placed and where farming activities are also located.

3. Results

3.1 Spatial distribution and characterization of the sectorThe pangasius (striped) catfish production sector is centered on the Mekong Delta (Figure 2), and distributed throughout the ten provinces (Tables 2 and 3). The survey revealed that in 2014, there were 109 hatcheries in operation producing 23.6 billion larvae per annum. The majority of the hatchery production (89 percent) was located in Dong Thap and An Giang provinces with 77 and 16 hatcheries producing 19.0 and 2.2 billion larvae per annum respectively. The remaining production was distributed across the other six provinces (viz., Can Tho, Vinh Long, Ben Tre, Hau Giang, Tien Giang and Soc Trang) with no hatchery production capacity recorded in Tra Vinh and Tay Ninh provinces.

The hatchery-reared larvae were subsequently distributed to 2 683 nursery farms with a combined annual production of 2.58 billion fingerlings per annum. Concomitant with hatchery production, the nursery farms were centered in Dong Thap(1 676 nurseries; 46.5 percent production capacity) and An Giang (302 nurseries; 26.5 percent production capacity), and to a lesser extent in Can Tho (105 nurseries; 14.7 percent of production capacity) and Tien Gang (500 nurseries; 7.9 percent of production capacity). With the exception of Soc Trang province, all the provinces maintained some nursery production capacity.

In 2014, the grow-out sector comprised 5 170 ha ponds with 143 enterprise farms,1 490 family farms and 11 cooperatives with a combined annual production of1 143 797 tonnes (Tables 2 and 3). The grow-out sector comprised 5 089 ha ponds, of which the enterprise farms accounted for 3 389 ha ponds (65.5 percent of total), the family farms accounted for 1 572 ha ponds (30.4 percent) and the cooperative farms accounted for 209 ha ponds (4.0 percent). The majority of the production was undertaken by the enterprise farms (780 004 tonnes, 68.2 percent of total production), followed by the family farms (309 937 tonnes, 27.1 percent), with cooperatives contributing just 53 567 tonnes (4.7 percent of total production). The major grow-out areas were Dong Thap province (contributing 372 146 tonnes, 32.5 percent), An Giang (243 581 tonnes, 21.2 percent), Ben Tre (160 000 tonnes, 13.9 percent) and Vinh Long (96 180 tonnes, 8.4 percent).

The feed manufacturing industry is centered in Dong Thap province, which contains 26 of the sector’s 48 feed manufacturing facilities. In Dong Thap province, the combined installed feed production capacity was 3 310 000 tonnes/annum out of a total

7Aquafeed value chain analysis

capacity of 5 232 500 tonnes/annum (63.2 percent of feed manufacturing capacity). Can Tho, Vinh Long and Tien Gang were smaller centers for feed production with seven (total capacity: 600 000 tonnes/annum), five (170 000 tonnes/annum) and four(700 000 tonnes/annum) feed manufacturing plants respectively. These three provinces had a combined production capacity of 1.47 million tonnes/annum equating to28 percent of the total.

As expected, the feed ingredient suppliers that supply the raw materials to the feed manufacturers were also concentrated in Dong Thap, with 75 of the 78 registered suppliers located in this province. In contrast, the 882 registered feed wholesalers and retailers were distributed more evenly throughout the 10 provinces, and were generally distributed according to the size of the grow-out sectors in the respective provinces.

There are 112 fish processing facilities with a combined annual production capacity of 1 519 974 tonnes per annum. The majority (102 processors: 95.5 percent of capacity) were concentrated in four provinces, namely Can Tho (40 processors: 35.7 percent), Dong Thap (20 processors: 28.2 percent of capacity), An Giang (23 processors:21.0 percent) and Tien Giang (19 processors: 10.5 percent).

FIGURE 2Map of Mekong Delta showing different districts with the areas of pangasius ponds

and the number of commercial feed mills

Source: modified from Lovell (2017).


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3.2 Value chain mapA schematic view of the value chain, describing the principal actors in the chain is presented in Figure 3.

FIGURE 3Schematic view of the aquafeed value chain in Viet Nam (2015)

Source: modified from Lovell (2017).

Feed ingredient suppliers

• Feedingredientsuppliers:78registeredtradingcompanies.• Supplyanestimated1.60milliontonnesoffeedingredients(89.4%)thatareusedinthe

manufacture of pangasius feeds. Remaining feed ingredients are sourced independently by the feed manufacturers (0.19 million tonnes).

• 50.8percentofterrestrialandaquaticanimalfeedingredientsusedinVietNamareimported.

• Majorityofimportscomprisehighqualityproteinsourcese.g.fishmeal,poultrymeal,meat & bone meal, blood meal, and soybean and canola oil seeds products. In addition, wheat and feed additives are imported.

• TradersarecenteredaroundDongThapandCanThoProvinces.

Feed manufacturers

• Commercialfeedmanufacturers:48manufacturers;installedproductioncapacity: 5 232 500 tonnes/annum; average production capacity: 109 010 tonnes/manufacture/

annum; Feed type: 100 percent extruded pellets.• Commercialfeedproductionestimatedat1830075tonnes(35.0%ofthecapacity).• Averageproductioncostofcommercialfeeds:USD0.511±0.03/kg(growerformulation).• Estimatedprofitmarginoffeedproduction:4.7%.• Provinceswherethefeedmanufacturersarecenteredaround:DongThap,CanTho,

Vinh Long and Tien Giang.• Commercialfeedmanufacturerstypicallyproducefeedsformultiplefishspeciesand

terrestrial animals (primarily poultry and livestock). • Farm-madefeedproductionisnegligible:<10000tonnes/annum.

Feed wholesalers and retailers

• Numberoffeedwholesalersandretailers:882.• Annualaverageamountoffeedtradedbywholesalers:643tonnes;94%supply

between 10 – 1 000 tonnes per annum.• Estimatedprofitmarginoffeedtrader:4.07%.

Farmers

• Totalfarmingareas:5170ha.• Annualtotalfishproduction:1143797tonnes.• Enterprisefarms-143farms;farmingarea:3389hagrow-outponds(65.6%oftotal);

annual production: 780 004 tonnes.• Familyfarms–1490farms;farmingarea:1572hagrow-outponds(30.4%oftotal);

annual production 309 937 tonnes.• Cooperativefarms:11farms;farmingarea:209hagrow-outponds(4.0%oftotal):

annual production: 53 856 tonnes. • Feedrepresents81.3%oftotalproductioncost.• AverageFCR:1.57±0.06(growerfeed).


3.3 Feed ingredient suppliersThere were 78 registered feed ingredient-trading companies that supplied feed ingredients and feed additives to the aquaculture feed manufacturing sector. Of these 75 (96 percent) were located in Dong Thap province with the remaining three located in Can Tho province. In addition, many of the larger feed manufacturers reported sourcing their own feed ingredients from local commodity markets and importing feed products directly from overseas suppliers. While it is difficult to accurately quantify the volumes of feed ingredients supplied by the feed ingredient dealers and those sourced directly by the feed manufacturers, extrapolating sale volumes reported by the surveyed feed dealers to those of the feed dealership sector as a whole would suggest that the feed dealers traded in the region of 1 640 000 tonnes of feed ingredients per annum. Based on a feed manufacturing output of 1 830 000 tonnes of feed per annum, it can be suggested that the feed manufacturers sourced approximately 190 000 tonnes of feed ingredients directly, independent of the feed ingredient dealers. The analysis needs to be treated with caution because of the extrapolation undertaken, but given no dealers reported exporting feed ingredients to other countries. This suggests that the dealers supplied 88 percent of the feed ingredients used in Viet Nam, while about12 percent are sourced directly by manufacturers.

The majority of the feed ingredient dealers (86 percent) operated as privately-owned companies and 14 percent were equally split between joint ventures and public institutions. The size of the trading operations varied considerably, ranging between 1 500 and 120 000 tonnes per annum. There were companies specializing in the supply of feed additives, that would likely be supplying lower volumes compared to those that supplied protein and carbohydrate ingredient sources in large quantities. The sector was dominated by a large number of small ingredient suppliers. The survey revealed that 46 percent of the suppliers traded in volumes up to 5 000 tonnes per annum,31 percent between 5 000 and 10 000 tonnes per annum, and the remaining23 percent of suppliers traded in excess of 50 000 tonnes per annum. Profit margins reported by feed ingredient dealer were on average 3.27 ± 0.42 percent (mean ± S.E). Concomitant with other sub-sectors in the feed value chain, the ingredient-trading sector was a relatively new sector with 66 percent of dealers being in operation for less than ten years (mean 8.5 years; maximum 16 years; minimum 4 years). The majority (86 percent) reported financing their operations using a combination of private capital and bank loans, with the remaining dealers relying on private capital.

Product quality monitoring is necessary to assess proximate composition of ingredients was reported by 78 percent of the feed dealers reported this was undertaken. The level and timing of monitoring undertaken varied considerably. Twenty seven percent of dealers reported monitoring all their products on arrival at their warehouses. A further nine percent reported monitoring just once every two weeks and the majority (63 percent) only randomly tested delivered products once every 30 days. The majority of dealers (82 percent) indicated that they had no diagnostic laboratory equipment to monitor feed ingredient quality and while the remaining 18 percent reported some diagnostic capacity. All dealers indicted they used the services of private laboratories to monitor the quality of their products, which may explain the variation in monitoring carried out.

Dealers require storage, and storage facilities varied with the size of the trading operations. Storage capacity varied between 8 and 60 000 tonnes. One third of the traders maintained a storage capacity of less than 100 tonnes, a further third reported a storage capacity of between 100 and 1 000 tonnes with the remaining third reporting a capacity of over 1 000 tonnes. While the transit or storage period of the feed ingredients varied between five days and six months, the majority (63 percent) of materials were stored by the dealers for less than 30 days. A further 27 percent were stored for 30 to 90 days with just 10 percent of products being stored for over 90 days (up to 6 months).


The dealers reported that they were provided with little government support to assist in the development of their businesses.

3.4 Feed manufacturing In 2014 there were 48 commercial feed manufacturers registered with D-Fish producing aquafeed. Combined production capacity was estimated at 5 232 500 tonnes covering all species produced within Viet Nam. In 2014, total pangasius production was estimated at 1 143 797 tonnes and based on an average feed conversion ratio (FCR) of 1.6 (Table 7), it is reasonable to suggest 1 830 075 tonnes1 of manufactured feeds for pangasius were needed to satisfy demand. This level of feed production accounts for 34.9 percent of the total aquaculture feed manufacturing capacity.

Of those feed manufacturers surveyed, the average installed manufacturing capacity was 98 400 tonnes per annum. The largest feed mill reported a production capacity of 280 000 and the smallest 20 000 tonnes/annum. Specialized feed manufacturing equipment such as milling and mixing equipment, extruders and pellet dryers were reported to be imported from France, Denmark, United States of America, China, Netherlands, Thailand, Germany and Taiwan Province of China.

The average age of feed manufacturing companies was 7.6 years (maximum15 years; minimum 1 year), with 20 percent being established within the past5 years, 70 percent being established between 6 – 10 years, and 10 percent having been established for over 10 years. Seven of the 12 feed mills surveyed were privately operated with the remaining five feed mills being joint ventures. With respect to financing, 50 percent of the feed manufacturers reported financing their operations with private capital, 30 percent had used a combination of private and bank loan capital, and 20 percent had relied exclusively on bank loans to fund their investments.

3.4.1 Feed manufacturing costsThe average feed manufacturing cost reported by the feed manufacturers wasUSD496.5/tonne (Table 5). Feed ingredients accounted for the single highest production cost, being 86.5 percent of total production costs. Labour and management costs were relatively high at 6.3 percent of production costs. At 3.2 percent of production costs, the provision of amenities (power, fuel, water and electricity) comprised the third largest production cost, with storage and transportation accounting for a further2.0 percent of production costs.

Feed quality and monitoring accounted for just 0.25 percent of production costs and research and development and capacity building costs accounted for less than0.02 percent of costs. Unfortunately, survey respondents were unable to provide reliable information on fixed costs (e.g. depreciation, taxation) so it was difficult to definitively establish profit margins. However, assuming an average production cost of USD0.50/kg for a grower formulation (Table 4) sold at USD0.52/kg (Table 6), the profit excluding fixed costs, would be in the region of 4.8 percent.

3.4.2 Feed ingredient availability In 2016, the Vietnamese animal feed industry manufactured 34.1 million tonnes of feed (Tran, 2017). The terrestrial animal (primarily poultry and livestock) feed sector accounted for 28.9 million tonnes (74.6 percent), with aquafeed accounting for the remaining 5.2 million tonnes. Of the feed ingredients required to support this level of production, 17.3 million tonnes (50.8 percent) were imported into the country (Tran, 2017). These primarily comprised of high quality protein sources – animal meals including fishmeal, poultry meal, meat & bone meal, blood meal, and oilseeds such as soybean and canola.

1 1 143 797 (fish production) x 1.6 (FCR) = 1 830 075 tonnes


The feed ingredients reported to be used in pangasius feeds are presented in Table 5.The protein sources used in pangasius feeds comprise both animal proteins (fishmeal, poultry meal, meat meal, meat & bone meal and blood meal) and plant protein (soybean meal, peanut meal and brewer’s yeast). The country has limited capacity to produce animal-grade protein sources for inclusion in animal feeds and thus relies heavily on imported feed ingredients (Table 6). In 2016, the country imported approximately 7.5 million tonnes of animal-grade protein sources to support its livestock and aquaculture feed industries. Principal amongst these imports were meat meal and meat & bone meal (0.6 million tonnes, Table 6) imported from Italy, Ukraine and the United States of America; poultry meal imported from Australia; and fishmeal either locally produced or imported from Peru. In 2016, the country used 547 000 tonnes of fishmeal, with80 percent derived from local production and the remainder imported.

The cost of feed ingredients varies according to quality. Fishmeal were differentiated into four quality classes depending on the protein content with prices ranging between USD0.76/kg for fishmeal containing 50 percent crude protein (CP) and USD1.29/kg for fishmeal containing 65 percent CP. With the exception of imported blood meal (containing 92 percent crude protein, supplied at a cost USD1.33/ kg), all other animal protein sources (poultry meal, meat meal and meat & bone meal) were of comparable cost or less expensive than the lowest grade fishmeal (containing 50 percent CP at a cost of USD0.76/kg). As would be anticipated, the plant protein sources available, such as the soybean oil cake, peanut meal and copra, were generally cheaper than the animal protein sources.

The principal oil cakes that are used in pangasius feed formulations are soybean and copra oil cakes, costing USD0.51/kg and USD0.21/kg respectively (Table 5). Peanut oil cake (USD0.33/kg) was reported to be used in some formulations, but this and

TABLE 4

Feed manufacturing costs (USD/tonne)

Production cost elementsCost structure

USD/tonne Percent

Feed inputs (ingredients and additives) 429.59 86.52

Labor and management (technical and administrative) 31.30 6.30

Fuel, electricity and water 16.23 3.27

Others (e.g. therapeutants/chemicals) 3.14 0.63

Storage and transport 9.84 1.98

Sales commission 4.28 0.86

Feed analyses, quality inspection and monitoring 1.26 0.25

Maintenance and spare parts 0.79 0.16

Research and development 0.09 0.02

Training and capacity building 0.05 0.01

Total cost of feed 496.49 100

Total cost of feed per kg (USD) 0.50 -

Source: 2015 Field Survey.

other oilseeds that are commonly used in aquaculture feeds (e.g. canola, cotton seed, sunflower seed, and palm kernel oil cakes) were negligible in Vietnamese domestic production. Of particular note, relatively high quantities of imported canola and palm kernel oil cake, and corn gluten meal that are available for use in terrestrial animal feed, and although suitable for use in aquafeed, these ingredients were not used.

The domestic production of soybean oil cake represents the major oilseed protein source used in aquafeed. The availability of soybean oil cake in Viet Nam is limited, however, by both low domestic soybean production and low processing capacity which primarily relies on importing full fat soybean (2016: domestic production:161 000 tonnes of soybean and 775 000 tonnes of oil cake/meal, Agrolife, 2017). In 2016, soybean oil cake imports were 4.89 million tonnes, accounting for 86.3 percent of the soybean oil cake used by the country (Table 6). The major import counties for soybean oil cake are Argentina, United States of America, India and Brazil. In the absence of significant increases in domestic soybean production and the introduction of additional soybean processing capacity, it is likely that imports will remain high. Copra (coconut meal) was also reported as used in pangasius feed formulations. Similar to soybean oil cake, the majority of the copra used in terrestrial and aquatic animal feed is imported (2016: 159 000 tonnes; 62.8 percent), principally from India and Thailand.

With respect to carbohydrate sources, the country supplies approximately75 percent of industry requirements. Local carbohydrate sources used in aquafeed include rice bran and broken rice, which are sourced as by-products form the rice milling industry. In 2016, approximately 6.0 million tonnes of rice bran(USD0.22–0.24/ kg) and 1.50 million tonnes of broken rice were available to the terrestrial and aquatic animal feed industry (Tran, 2017). Similarly, approximately2.0 million tonnes of locally produced cassava (USD0.22/kg) was available to the terrestrial and aquatic animal feed industry, and represents one of the principal carbohydrate sources currently used in pangasius formulations. Wheat was reported to be another principal carbohydrate source used in pangasius feed, which is imported as Viet Nam does not produce wheat. It imported 2.90 million tonnes of wheat in 2016, of which 1.40 million tonnes was used for terrestrial and aquatic animal feeds (Tran, 2017). In 2016, the country produced 5.28 million tonnes of corn, with 80 percent used in the terrestrial and aquatic animal feed industries. While it would be suitable for use in pangasius feeds, it appears that under the current ingredient cost structure, corn was not reported as a feed ingredient in pangasius feed, with cassava, wheat and rice products are the preferred carbohydrate sources.

With respect to lipid sources, the dietary lipid levels used in commercial feeds is relatively low (estimated at 3–5 percent for grower fish >20 g, Table 7) and thus the lipid component of the feeds can largely be supplied from endogenous sources within existing animal feed materials, with little need to add lipids. Nevertheless, both imported and locally produced fish oil (USD0.77/l and squid liver oil (USD1.53/l) were used in aquafeed, both of which are good sources of essential fatty acids. Feed additives used included supplemental amino acids and choline, imported from China and India, and vitamin and mineral mixes, that are either locally manufactured or imported. Crystalline amino acids (principally methionine and lysine) were commonly used to improve the essential amino acid profile of the feeds. Choline was used by some manufacturers to support phospholipid production. Vitamin C and other assorted vitamin and mineral mixes were also reported as used in formulations. Ethoxyquin use was widely reported and added as an antioxidant/feed preservative.



TABLE 5

Feed ingredients used in the production of pangasius aquafeed (2017)

Ingredients (% crude protein) Price (USD/kg) Country of origin

Mean Max Min

Protein sources

Fishmeal(50%CP) 0.76 0.85 0.65

Viet Nam, PeruFishmeal(55%CP) 0.88 1.00 0.76

Fishmeal(60%CP) 1.05 1.18 0.87

Fishmeal(65%CP) 1.29 1.38 1.07

Poultrymeal(60%CP) 0.76 - - Australia

Meatmeal(50%CP) 0.51 0.52 0.49 Viet Nam, imported from countries not specified

Meat&bonemeal(50%CP) 0.49 0.53 0.47 Viet Nam, Italy, Ukraine,United States of America

Bloodmeal(92%CP) 1.33 - - Italy

Soybeanmeal(45–46%CP) 0.51 0.62 0.27 Viet Nam, Argentina, Brazil, India,United States of America, Singapore,the Netherlands, Malaysia

Peanutmeal(28–40%CP) 0.33 0.35 0.31 Viet Nam

Brewer’syeast(41–46%CP) 0.67 0.71 0.67 Viet Nam

Copra/coconutmeal(21%CP) 0.21 0.22 0.20 Viet Nam, India, Thailand

Carbohydrate sources

Cassava(15%CP) 0.22 0.24 0.20 Viet Nam, Cambodia

Broken rice

Rice bran 0.26 0.42 0.19 Viet Nam

Rice bran (de-oiled) 0.24 - - Viet Nam

Wheat 0.24 - - United States of America, Australia, ArgentinaRussian Federation, Romania, Bulgaria and countriesin the Eurasian Economic Union

Wheat bran 0.27 0.32 0.22 Russian Federation, Sri Lanka

Lipid sources

Squid liver oil 1.53/l - - Viet Nam

Fish oil 0.77/l 0.88 0.67 Viet Nam, imported from countries not specified

Feed additives

Vitamin and mineral mixtures 2.08 4.36 0.58 Viet Nam, China, India

Lysine(98.5%) 1.63 1.82 1.41 Imported, not specified

Methionine(99%) 3.36 - - Imported, not specified

Choline(60%) 0.77 - - Imported, not specified

Vitamin C 2.33 - - Viet Nam

Mono calcium phosphate 0.56 - - Viet Nam

Ethoxyquin - - - Imported, not specified

Sources: 2017 Field Survey; Tran (2017).


TABLE 6

Availability of feed ingredients (protein and carbohydrate) commonly used in pangasius

aquafeed (2017)

Ingredients Domestic production (tonnes) Imported (tonnes) Total (tonnes)

Protein sources

Fishmeal 460 000 114 000 574 000

Meat & bone meal Minimal 616 920 616 920

Distillers grains/corn gluten meal

Minimal 1 371 104 1 371 104

Soybean meal/oil cake 775 000 4 890 000 5 665 000

Peanut meal Negligible 2 143 2 143

Copra meal 94 000 159 000 253 000

Canola oilseed 2 000 89 764 91 764

Palm kernel meal Negligible 332 872 332 872

Sunflower meal Negligible 16 728 16 728

Carbohydrate sources

Rice bran 6 000 000 Negligible 6 000 000

Broken rice 1 500 000 Negligible 1 500 000

Cassava 2 000 000 Unknown 2 000 000

Wheat None 2 900 000 2 900 000

Corn 5 280 000 7 700 000 12 980 000

Source: Tran (2017); Agrolife (2017).

3.4.3 Commercially manufactured aquafeedCommercial pangasius aquafeed are manufactured for all life stages of this fish(Table 7), with the exception of broodstock conditioning feed, for which there are no dedicated products. All the manufactured feeds are floating extruded pellets. The feeds are generally classified by fish size, from larval stages (1 – 5 g) through to on-grower feeds (>500 g fish). In line with other fish species, the proximate composition of the feed changes according to the size of the fish, with protein, lipid and gross energy reducing with fish size (Table 7). The reduction in the protein level, in particular, reduces formulation costs, and this is reflected in the price paid for feeds which range from USD0.84/kg for larval feeds to USD0.50/kg for on-grower fish (>500 g).

The feed regulations (Decree NO.08/2010/ND-CP dated 05/02/2010; Circular 66/2011/TT-BNNPTNT) require that each manufactured feed is registered/licensed by the D-Fish. To ensure that it remains compliant to the registered proximate composition, it is tested for proximate composition not more than twice a year.


TABLE 7

Characteristics of commercially manufactured pangasius aquafeed

ParametersFish size

1 – 5 g 5 – 20 g 20 – 200 g 200 – 500 g >500 g

Pellet size (mm) 1 – 1.5 1.5 – 2.5 2.5 – 5 10 10

Crudeprotein(%) 35 – 40 30 28 – 26 24 22 – 20

Crudelipid(%) 5 – 8 5 – 6 3 – 5 3 – 5 3 – 5

Crudefiber(%) 6 7 7 – 8 8 8

Ash(%) 14 12 10 10 10

Moisture(%) 11 11 11 11 11

Gross energy (kcal/kg) 2 800 – 2 900 2 400 – 2 900 1 800 – 2 900 1 800 – 2 300 1 800 – 2 950

Phosphorus(%) 1 – 2 1 – 2 1 – 2 1 – 2 1 – 2

Calcium(%) 1 – 2 1 – 2 1 – 2 1 – 2 1 – 2

Lysine(%) 1.8 – 2 1.5 1.3 1 – 1.1 1

Methionine(%) 0.8 – 0.9 0.7 0.6 0.5 0.4

Ethoxyquin (ppt) 150 150 150 150 150

Feed cost (USD/kg)

Mean 0.84 0.49 0.52 - 0.50

Maximum 0.89 0.53 0.60 - 0.52

Minimum 0.80 0.45 0.45 - 0.48

FCR (mean) - 1.50 1.58 1.60 1.54

Notes: parts per thousand; “-“data not available.


While the feed manufacturers keep their formulations as proprietary information, the feeds have to conform to the feed specifications outlined under the Vietnamese National Standard for pangasius and tilapia feeds (Feed Standard: TCVN 10300: 2014). The standard has been compiled by D-Fish, Ministry of Agriculture and Rural Development (MARD), and approved by the Directorate for Standards, Metrology and Quality. The standard proscribes the physio-chemical parameters for feeds including their physical size, colour, integrity and the minimum and maximum inclusion levels for selected dietary components including crude protein, crude lipid, ash, moisture, phosphorus, calcium and lysine and methionine. A summary of the standard is presented in Table 8.


Discussions with a number of the feed manufacturers suggest that the standards are not reflective of the nutritional requirements of the species, and in many cases the feed manufacturers exceed the standard specifications to enhance the performance of their feeds. For example, Glencross et al. (2010) estimated that the crude protein requirement for 5 – 50 g juvenile fish falls within the range of 34 – 36 percent crude protein. According to the standard, 5 – 20 g fish require a minimum protein content of 30.0 percent, significantly below their nutritional requirement defined by Glencross et al (2010). Likewise, from a technical perspective, the adoption of standards for both ash and acid insoluble ash levels, to establish the amount of indigestible material in the feed is unnecessary, and will simply result in increased costs in terms of product monitoring and certification, because ash alone can be viewed as a reliable way to measure the non-nutritive fraction of the feed. The inclusion of other dietary requirements, such as the energy density of the feed, which has a profound influence on its efficacy, are absent. Consideration should be given to including this parameter in the standard.

An additional issue with the standard is that it restricts feed formulations to just six feed types, with for example, protein components of not more than 40, 35, 30, 28, 22 and 20 percent respectively. Feed manufacturers reported that approximately 80 percent of the grow-out feeds (larger feed sizes) that are currently manufactured contain 26 percent protein, and thus they are not in compliance to the standard.

There is clearly a need to review the current standard in terms of the parameters included in the standard, and to ensure that the feeds are fit for purpose with respect to addressing the nutritional requirements of the fish, and also whether it is appropriate to be so prescriptive that it limits the number of feeds that can be manufactured.

TABLE 8

Feed standard applicable to pangasius feeds (TCVN 10300: 2014)

Parameters Types of feed

No 1 No 2 No 3 No 4 No 5 No 6

1. Size

a.) Pellet diameter 1.0 1.5 2.5 5.0 10.0 12.0

b.) Length in comparison with diameter, times between

1.0 – 1.5

2.Broken(%),notmorethan 1.0

a.) Water stability 60

b.)Moisture(%),notmorethan 11.0

5.Crudeprotein(%)notlessthan 40.0 35.0 30.0 28.0 22.0 20.0

6.Crudefibre(%)notmorethan 6.0 6.0 7.0 7.0 8.0 8.0

7.Calciumcontent(%)between 1.5 – 2.0

8.Phosphoruscontent(%)between 1.0 – 2.0

9.Lysinecontent(%)notlessthan 2.0 1.8 1.5 1.3 1.1 1.0

10.Methioninecontent(%)notlessthan 1.0 0.8 0.7 0.6 0.5 0.4

11.Ashcontent(%)notmorethan 16.0 14.0 12.0 10.0 10.0 10.0

12.HCL10%insolubleashcontent(%)notmorethan 1.0

13.Crudelipidcontent(%)between 8.0 – 10.0 6.0 – 8.0 5.0 – 6.0 5.0 – 6.0 3.0 – 5.0 3.0 – 5.0

14.Sodiumchloride(%)notmorethan 1.5

Source: Viet Nam National Standards TCVN 10300:2014 - compound feeds for sutchi catfish and tilapia.


3.4.4 Product quality monitoring The feed manufacturers have widely adopted and comply to HACCP and ISO standards, principally ISO 9001: 2008, 2001 related to Quality Management Systems, and ISO 22000:2005 related to Food Safety Product Quality Monitoring. All the feed manufacturers reported testing the quality of their feeds and feed ingredients on a regular basis. Typically, this entails testing the proximate composition of feed ingredients on arrival at the feed manufacturing plant to ensure that the feed ingredients being supplied by the feed ingredient dealers corresponds to the specification supplied on the manifest. The proximate composition of the finished feed is also usually monitored on a batch basis to ensure that it complies to the specification presented on the packaging. The majority (78 percent) of the feed manufacturers reported having their own in-house laboratories with the remaining 22 percent reporting using the services of an external laboratory. Evidently those feed manufacturers that reported using the services of external laboratories were the smaller operators (installed capacity: >75 000 tonnes per annum) where the costs of setting up and operating a laboratory would have been relatively high. The diagnostics used for proximate composition analysis typically comprised a combination of traditional wet chemistry techniques, and increasingly, NIRS (Near-infrared spectroscopy) which while being relatively expensive to install, significantly reduces sample processing periods, enabling manufacturers to improve monitoring and rapidly respond to quality issues in their production lines.

3.4.5 Feed packaging, transportation and storageTypically, commercially manufactured fingerling and grower feeds are packaged in either 25 kg or 40 kg polypropylene bags that are mechanically sewn and closed with string. Larval feeds are usually supplied in 20 kg bags. The Vietnamese National Standard for pangasius and tilapia feeds (TCVN 10300: 2014) regulates feed labelling (Table 9).

TABLE 9

Feed labelling standard applicable to pangasius feed (TCVN 10300: 2014)

No. Identifier

1 Name of product “Compound feeds for sutchi catfish”

2 Quantity (net weight)

3 Name, address, telephone number of the manufacturer and manufacturing location

4 Standard declared

5 Number of different stages and sizes

6 Batch number and manufacturing date

7 Expiry date

8 Storage conditions

9 Maximummoisture(%)

10 Minimumcrudeprotein(%)

11 Min–maxtotalcrudelipidcontent(%)

12 Ethoxyquin (ppm)

13 Maximumcrudefibrecontent(%)

14 Min-maxcalciumcontent(%)

15 Min-maxphosphorouscontent(%)

16 Minimumtotallysinecontent(%)

17 Minimumtotalmethionine+cystinecontent(%)

18 Antibiotics: none

19 Main ingredients

20 “Contain no substances banned in relevant regulations”

Source: Viet Nam National Standards TCVN 10300:2014 Compound feeds for sutchi catfish and tilapia (Appendix B).

The feed manufacturers adherence to the labelling standard appears to be good, and during the survey all feedbags that were inspected were found to comply to the standard. While the standard provides much of the necessary information that farmers can use to differentiate feed quality, some potentially useful information is missing. For example, while the ash level in the feed is appropriately regulated in the feed standard, this information is missing from the proximate composition data required on the label. As high levels of ash are usually associated with the use of poor or adulterated feed ingredients, its inclusion in the proximate composition data will be useful for farmers when assessing feed quality. Ingredient composition also provides good evidence of the quality of feed, and rather than requiring “main ingredients” to be listed, all ingredients used in the formulation should be included on the label. While the standard calls for the label to display specific additives such as ethoxyquin (preservative) and some essential amino acids (lysine, methionine and cystine) and some elements (calcium and phosphorus), there are many other feed additives that provide an indication of feed quality, including fungicides and mould inhibitors, probiotics, enzymes, flavourants, colourants, and binders. In this regard, it would be useful to revise the labelling requirements to enable the farmers to better assess the quality of the feeds available to them.

Feeds are generally transported either by trucks or vessels. While transport costs vary according to distance, mode of transport, and the volume of product being transported, transporting feed by land is generally more expensive than by boat. Reported land transport costs ranged between USD0.13 and USD0.20/km/tonne while vessel transport costs ranged between USD0.10 and USD0.06/km/tonne, with the costs reducing with the size of the vessel used. In the case of the vertically integrated enterprise farms, the feed manufacturers reported owning their own trucks or vessels to transport their feeds from their feed manufacturing operations to their farming operations. Feed wholesalers, retailers and farmers are generally responsible for organizing the transport to move their purchased feeds from the feed manufacturers to their farms or storehouses. Transport costs generally accrue to the purchaser and are therefore borne by the farmer or feed wholesaler/retailer.

3.4.6 CertificationIncreasing consumer demand for certified products has resulted in product certification becoming commonplace along the value chain, and is effectively mandatory for accessing some export markets. Farm certification programmes require farmers to demonstrate that their feeds are sourced from sustainable sources and well-managed feed manufacturers, and this, in effect, has driven the need for feed manufacturers to adopt certification as a means of ensuring and maintaining sales. Of those feed manufacturers surveyed, nine percent did not respond to the question and 91 percent reported that they adhered to at least one certification programme; and of these,50 percent reported to be certified to two or more different programmes.

While there is a larger number of certification programmes available to the feed manufacturing sector, common programmes reported include VietGap, GlobalGap and the Global Aquaculture Alliance (GAA) certification programmes. VietGap is promoted by the government as a national certification program and is a mandatory requirement for farmers when selling products to the local market. The Global Aquaculture Alliance administers Best Aquaculture Practices Certification(BAP Certification) that is generally required to enter markets in the United States of America. Sixteen feed manufacturers (33 percent) are currently registered to the program. Thirty-six feed manufacturers (75 percent) are registered to the Global Feed Manufacturing Standard. The standard is administered by GlobalGap and is viewed as particularly important for accessing Western European markets.

The cost of certification varies, and while some costs are incurred to ensure that the production facility complies to the certification requirements, the cost of being


21

registered and accredited on an annual basis was reported to be between USD6 000 and USD10 000 per annum per certification programme. Despite the costs associated with certification, the fact that the vast majority of the feed manufacturers report being accredited to at least one certification programme is evidence that certification can now be considered as standard practice. Further, with the general adoption of traceability and certification along the pangasius value chain (feed manufacturers, farmers, processors) the feed manufacturers clearly view certification as a prerequisite for market access.

Within Viet Nam, the regulatory requirement for farmers to comply with the VietGap certification programme to access local markets appears to have been an effective regulatory intervention in promoting the adoption of local standards. Moreover, the increasing requirement from retailers/consumers for certified and traceable products in global markets has driven certification, and with the recent addition of feed manufacturing certification to many certification programmes, it effectively means that in order to maintain market share, the feed manufacturers have to be certified.

3.5 Feed wholesalers and traders Feed is distributed to the farmers either directly from the feed manufacturers, many of whom maintain their own marketing departments, or through a network of feed wholesalers and, to a lesser extent, retailers (Figure 4). Of the feed that is supplied to the farming community, 22.1 percent is produced and supplied by vertically integrated enterprises (comprising both feed manufacturing and farming operations) for their own internal use. A further 43.3 percent of the feeds are sold by the feed manufacturers directly, to farming operations (enterprise, family and cooperative farms) under supply contracts (see section 3.6.4), and a further 34.6 percent of the feeds are sold through wholesalers. Of the feeds sold through wholesalers, 94.3 percent are sold directly to farming operations, and the remainder (5.7 percent) sold to retailers who in turn sell onto the farming operations. None of the wholesalers reported exporting feed products.

A total of 747 feed wholesalers and retailers are registered as pangasius feed sellers. The sub-sector is dominated by privately owned family businesses (94 percent). The rest are large integrated enterprise farms/feed manufacturing companies that also retail

FIGURE 4Diagram of feed production flow among the value chain

Aquafeed value chain analysis


feeds directly to smaller enterprise farms and family farms. There is no data to ascertain the percentage of feed being produced by enterprise farms with feed manufacturing capacity, and the percentage of feed attributed to the stand-alone feed manufacturers. The wholesalers are characterized by a large number of small family businesses. While the average wholesaler was found to trade 643 tonnes per annum, it varied between a maximum of 4 000 tonnes to a minimum of 10 tonnes. Ninety-four percent of retailers supply between 10 and 1 000 tonnes per annum, with the remainder supplying over 1 000 tonnes per annum. The wholesalers employ an average of 3.4 workers (maximum: 13; minimum: 1) at a ratio of approximately one worker for each 176 tonnes of feed traded.

The sub-sector is dominated by relatively new entrants. The average age of a pangasius feed dealership is 6.4 years (maximum: 15 years; minimum: 1 year), with56 percent being established within the past 5 years, 27 percent between 6 and 10 years, and 20 percent over 10 years old. Evidently the growth of the feed wholesale sub-sector has mirrored the growth of the production sector, with the concomitant increase in demand for feeds.

With respect to financing their businesses, 50 percent of the feed sellers reported financing their feed sales independently, with a further 40 percent financing sales through a combination of private capital and bank loans, and 10 percent financing their operations from bank loans only. Government agencies do not provide any financial support to the wholesalers or retailers.

As the feed wholesalers purchase feeds from the feed manufacturers in large quantities they are able to negotiate price reductions. The discount prices offered to the dealers varied according to the company’s’ discount policies and the volume of the feed traded, and varied up to 23 percent of the retail price. The dealers profit margins were reported at 4.07 ± 0.46 percent (mean ± standard error). Similarly, farmer cooperatives are also in a position to negotiate price reductions in feed, and this can assist the smaller family farmers significantly, because individually they are too small to be of commercial interest to the feed manufacturers, and would otherwise be forced to pay higher prices for their feed from retailers. Specific issues for cooperatives and small farmers remain (Box 2).

BOX 2

Feed availability, per se, is not the issue for cooperativesand small farmers in the value chain

It was interesting to note that for cooperative farmers, their constraints to running financially viable farming operations were not so much related to access to cost-effective feeds, impacting the economics of their production as to market access for their products. One cooperative noted that the size of the association had fallen from 800 farmers in 2010, to 200 farmers in 2017. The reason offered was that it used to be easy to sell their harvest to fish processors, but recently the large increase and associated consolidation in farm production, particularly by the enterprise farmers, has led the processors to focus their contractual agreements on larger producers. Even with economies of scale provided by the cooperatives the fish processors were increasingly reluctant to process the still smaller volumes from the cooperative farmers.

A similar situation was reported by some of the smaller family farmers; their small production volumes were likewise unattractive to the processors. With reduced access to processors, the cooperative farmers have been forced to sell to the local market, which is also problematic because local markets are often located far from the farms, which entails more investment in additional logistical support such as transport and refrigeration. While cooperatives currently account for a small volume of annual production (2014: 11 cooperatives; 4 percent of installed production; 53 856 tonnes of production), they will require support to enable them to access processing capacity and markets so they can continue contributing to the production sector.

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While the installed storage capacity that feed wholesalers have for storing feed products varied between 2 and 3 000 tonnes, but it was evident that the majority of feeds that are supplied by the wholesalers are transported directly from the feed manufacturers to the farms with no intermediate storage. Fifty-seven percent of the feed wholesalers indicated that they had less than 10 tonnes of storage capacity, a further 28 percent had 11–50 tonnes of storage capacity, and just 14 percent had over 50 tonnes of storage capacity. Storage periods at the wholesalers were relatively short with 80 percent of the feeds being stored for less than 15 days. Minimum storage periods were reported at five days, and the maximum period was 90 days. Product quality monitoring for the proximate composition of the feed products that were traded was uncommon and was reported by just 17 percent of the wholesalers. Of those wholesalers that tested their products, the monitoring was infrequent and at 60 to180 days intervals. Testing was most likely at the request of clients that were unhappy with their products. None of the wholesalers reported having their own diagnostic facilities for proximate composition analysis, and all used private independent laboratories.

With respect to the organization of the wholesale/retail sub-sector, there is no representative trade association to support and promote the interests of the sector, and in addition, no training or capacity building programmes were reported.

3.6 Farmers In 2014, the grow-out sector had a total farming area of 5 170 ha ponds and was comprised of:

•143 enterprise farms with a 3 389 ha of ponds used to produce 780 004 tonnes of production;

•1 490 family farms, totaling 1 572 ha of ponds to produce 309 937 tonnes; and•11 cooperatives2 with access to 209 ha ponds to produce 53 567 tonnes.

Enterprise farms are large vertically integrated companies that typically comprise integrated fingerling production, feed manufacturing, fish production, and fish processing units. The 20 enterprise farms surveyed were relatively large farms with an average production area of 14.8 ha (maximum:51.0 ha; minimum: 3.0 ha), and an average production of 3 545 ± 412 tonnes per annum(Table 10). Based on all enterprise farms (143) and areas (3 389 ha) and production(780 004 tonnes) the overall average area per farm equates to 23.7 ha and an average production of 5 454.6 tonnes per annum.

In contrast, the 15 family farms surveyed had an average production area of2.5 ha (maximum 2 ha; minimum: 0.2 ha), and a production level of 529 ± 148 tonnes per annum, although the overall averages are 1.05 ha per farm and 208 tonnes per annum respectively. They are therefore significantly smaller businesses compared to enterprise farms. The family farms purchase their feed and sell their products to the fish processing companies for export or to the local market traders, without the means to vertical integration. Based on all family farms (1 490) and area (1 572) and production (309 937 tonnes) the overall average area per family farm equates to 1.05 ha and an average production of 208 tonnes per annum.

2 Only one of the eleven co-operative farms was surveyed in this study, so the results cannot be viewed as being representative of the group. Cooperatives account for only 4 percent of production. Survey findings from the surveyed cooperative was excluded from further analysis.



3.6.1 Production characteristics

3.6.1.1 Grow-out productionThe enterprise farms surveyed were more efficiently operated than the family farms with an average production yields of 362 tonnes/ha/cycle and 317 tonnes/ha/cycle respectively. The production yield of the enterprise farms was 14 percent higher(45 tonnes/ha/cycle) than those of the family farms. Notwithstanding differences between the farm management practices, that are inherently difficult to quantify, the increased yields reported by the enterprise farms are likely to be partially attributed to the increased pond depths, which were 0.4 m (or 11 percent) deeper than those reported by the family farmers. The increased depth at the enterprise farms also allowed higher fingerling stocking densities, with enterprise farms reporting 14 percent higher stocking densities, equating to an additional 6.3 fingerlings/m2. In addition, enterprise farms stocked a slightly smaller fish (34.0 g) than the family farms (39.9 g), but maintained higher survival rates, at 74.8 percent, compared to figures reported by the family farms (70.4 percent).

While it is difficult to empirically determine why reported yields were higher in the enterprise farms, it is likely that deeper ponds, higher stocking densities, smaller size at stocking, and higher survival rates reported by the enterprise farms contribute to this. Due to size, the number of employees and technicians employed by enterprise farms were significantly higher than in the family farms, but the overall productivity per workers were relatively similar at 116 tonnes/worker/annum for enterprise farms and 112 tonnes/worker/annum at family farms.

TABLE 10

Production characteristics of enterprise and family farm production systems

Farm characteristics1 Enterprise farms2 Family farm3

Farm size (ha)

Mean 14.8 2.5

Maximum 51.9 5.0

Minimum 3.0 0.2

Production per annum 3 545 ±412 529±148

Yield (tonne/ha/cycle) 362±48.6 317±34.7

Pond depth (m) 3.9±0.3 3.5± 0.3

Stocking density (fingerlings/m2) 48.8±6.2 42.5±3.0

Size at stocking (g) 34.0±5.0 39.9±5.4

Survival(%) 74.8±2.8 70.4±2.9

Workers per farm 23.6±3.2 5.6±1.5

Technicians per farm 2.5±1.5 1.3 ±0.2

Production (tonne/worker/annum) 116±23 112± 27

Notes: 1 Whereindicateddatasuppliedasmean±standarderror;2data for 20 surveyed farms (out of 143 farms present in the country); 3data for 15 surveyed farms (out of 1 490 present in the country).

Source: 2015 Field Survey

3.6.1.2 Fry and fingerling productionFingerling production is usually undertaken at specialist farms that receive 16 – 24 hour old larvae from hatchery suppliers and grow them out to an average weight of 25 to30 g over a period of 60 -70 days. The larvae are stocked in ponds at a density of1 000 larvae/m2 (5 million per 0.5 ha pond). Typically, the survival rate from larvae to the fingering stage is 10 percent, so mortality is high and related primarily to disease issues. The use of antibiotics was reported as commonplace during this phase of

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production. When antibiotics are used, they are purchased from local retailers, with the Provincial D-Fish officers advising on their use and the dosage.

The production period is short and up to three crops may be produced per annum. The fry/fingerlings are fed extruded feeds during the on-growing period typically containing 35 to 40 percent crude protein and 5 to 8 percent crude lipid.

Competition between the fingerling producers is relatively high, and depending upon the supply at the time of harvest, prices for the product can vary considerably. Average prices paid for fingerlings were reported as 1.10 USD/kg, but depending on supplies the price can be as low as USD0.75/kg and as high as USD2.64/kg.

Typically, the fingerlings are transported to the grow-out farms in well boats. The fingerling and grow-out farmers are generally close-by, and transit times reported varied between 40 minutes and two hours. A typical fish transport protocol, as described by one of the fingerling farmers surveyed, was as follows:

1. No feeding for a 24-hour period prior to transport to evacuate fish digestive systems.2. Fish are concentrated in the pond using a seine net.3. Fish are transported from the pond to a well boat. The fish are carried by hand in

buckets in quantities of 70 – 100 kg. Transport between the pond to the boat takes approximately 5 minutes during which time the fish are exposed to the air – there is no water in the bucket.

4. A 20 tonne (20 m3) well boat is used to transport 3 – 6 tonnes of fingerlings. Journey times are dependent on the distance but usually last for between40 minutes to one hour. Water exchange occurs during this period, through holes in the well boat that allow water to pass freely between the canal and the well boat. Additional oxygen is not provided to the fish.

5. On arrival at the grow-out ponds, the fish are moved in buckets according to the protocol outlined in point 3 above.

Evidently the high densities at which the fish are transported, and the general transport conditions could result in stress and physical injuries that could lead to the elevated mortality rates, upon arrival at the farm, tough other reasons cannot be ruled out (Box 3).

BOX 3

Issues for fingerlings delivered to farmers

A major issue raised by farmers is unrelated to fingerling production per se, but rather to the low survival rates of the fingerlings once they have been delivered to the grow-out farms.

Typically, the grow-out farmers report that during the first month of grow-out, the mortality of the fingerlings can be as high as 30 percent. This is considered very high for fingerlings weighing 25 to 30 g. The reasons for the high mortalities are difficult to establish.

While poor water quality in the receiving waters (grow-out ponds) was viewed by many of the fingerling farmers as a causative factor, the grow-out farmers generally suggested that the problem lay in the quality of the fingerlings or the poor transport protocols (see text for general description) being applied resulting in physical stress and damage to the fish.

Unfortunately, the study was unable to collect empirical data characterizing the water quality in the grow-out ponds to rule out poor water quality as a causative factor. However, it was repeatedly reported that fingerling mortality lasts for a period of about one month after delivery to the grow-out ponds, after which mortality reduces significantly. The prolonged period of mortality suggests that inappropriate fish handling/transport protocols, that may result in the fingerlings being injured or stressed during the transit period, also likely plays a role in the high level of mortality. Pangasius have a strong and serrated dorsal spine and physical injuries to the fish, sustained as a result of poor handling and confinement at high densities, cannot be ruled out either, and may account for the extended period of elevated mortalities after stocking in the grow-out ponds.

It is recommended that further studies are undertaken to establish the impacts of the current transportation protocol on the welfare of the fingerlings, and if necessary, an improved fingerling transportation protocol should be developed.



3.6.2 On-farm production costsThe on-farm production costs associated with the on-growing production of one tonne of pangasius are presented in Table 11. Production costs accruing to the enterprise and family farms are comparable. With marginally lower costs for enterprise farms (USD964/ tonne) compared to the family farms (USD974/ tonne). The highest elements of production costs relate to farm inputs, notably costs for feed and fingerlings which account for between 81.0 – 81.5 percent and 8.3 – 6.4 percent of the production costs respectively. Medical therapeutants and chemical use accounts for a further 3.0 – 2.4 percent of production costs. In combination, farm inputs (fingerlings, feed and chemicals) accounted for USD890/tonne (92.4 percent) and USD880/ tonne (90.4 percent) of the overall production costs for enterprise and family farms respectively, and in this regard, the data suggests that being a part of a vertically integrated enterprise does not appear to confer significant input cost advantages over the smaller family operated farms. It may be that the enterprises companies may operate their individual production platforms (feed manufacturing, fingerling production, farming and processing) as individual cost centers, and cost savings associated with the company’s feed manufacturing plant may accrue to the feed manufacturing component of the business and not the farm itself. Unfortunately, the current data is insufficiently detailed to provide wider understanding of this issue and further research is required.

Labour costs on enterprise and family farms were reported at USD15.9/tonne and USD26.8/tonne of fish production respectively, and are likely a reflection of the slightly higher productivity of workers on the enterprise farms (Table 7). While the remaining production costs are largely comparable. The third highest production costs after feed and fingerling supply costs relate to relatively high finance costs at 3.4 percent and 3.7 per cent for enterprise and family run farms respectively.

TABLE 11

On-farm production costs (USD/tonne of fish)

Production cost elementsEnterprise farms (n=12) Family farms (n=6)

Mean±S.E Percent Mean ±S.E Percent

Fingerling 80.2 ±8.8 8.32 62.3±8.3 6.40

Feed 781.3 ± 11.6 81.05 794.4±10.8 81.52

Medical therapeutants and chemicals 29.1 ±2.2 3.02 23.9±5.6 2.46

Labour 15.9 ±3.3 1.65 26.8±11.7 2.75

Pond preparation 7.9 ±2.2 0.82 8.8±3.6 0.91

Environmental/water quality control 6.0 ±2.5 0.62 7.1±5.1 0.73

Harvest 9.1 ±1.8 0.94 8.2±3.1 0.84

Finance (loans/interest) 32.6 ±10.4 3.39 36.1±10.6 3.71

Other 14.4 ±4.3 1.49 17.5±7.6 1.80

Total 964.0 ±15.9 974.5±20.2



3.6.3 On-fam feed management practicesThe mean feed conversion ratios (FCRs) reported by the farmers varied from 1.50 for fingerling (5 – 20 g) rising to 1.58 for juvenile fish (20 – 200 g), and 1.6 for adult fish (>200 g) (Table 7). On-farm feed management practices varied considerably with 27 percent of the enterprise farmers reporting feeding their grow-out fish once a day and the remaining 73 percent feeding twice a day (Table 12). Fingerling farmers reported feeding twice a day with rations being calculated according to fish size. Feed records were maintained by all the farmers and were used to monitor feed use and calculate FCRs. Satiation feeding was adopted by 27 percent and 25 percent of the enterprise and family farms respectively, and 18 percent of the enterprise farms reported adopting either restrictive feeding regimes (feeding to 75 percent satiation, Table 11), or calculating feed requirements according to fish size and the biomass in the pond. Neither of these feeding regimes were reported by the family farmers. This finding was reflected in the fact that 75 percent of the family farmers reported that they fed according to their own experience while only 37 percent of the enterprise farmers reported basing their feeding regimes on their experience.

With feed costs accounting for over 80 percent of farm production costs (Table 11), optimizing on-farm feed management practices to ensure that feed is used efficiently and in a cost-effective manner is of paramount importance to the economic performance of the farming operation. The study showed that while less than 10 percent of the farmers applied restricted feeding regimes, those that did so reported a mean reduction in feed production costs of 0.03USD/kg fish (mean feed production costs per kilogram of fish: non-restricted feeding: 0.80USD/ kg fish; restrictive feeding: 0.77USD/ kg fish). While the efficacy of reducing feed production costs through the application of restricted feeding regimes and regimes that alternate high and low protein rations was demonstrated by Duong, Ly and Nguyen (2011), it would appear that very few famers, and none of the family farmers have considered applying these cost-saving feed management techniques. Evidently there is scope to provide training to many of the farmers to update their on-farm feed management practices. Nevertheless, feed management training was reported by 80 percent and 91 percent of the enterprise and family farms respectively (Table 13). The feed manufacturers were responsible for the majority of the training with 54 and 45 percent of the enterprise and family farms respectively reporting receiving training from the feed manufacturers. Thirty seven percent of the family farmers reported receiving training from government agencies as opposed to just 14 percent of the enterprise farmers. For both groups, commercial training courses accounted for less than ten percent of the training provided.

At 10.8 days and 14.3 days respectively, the feed storage periods employed by the enterprise farmers were slightly shorter that those of the family farms, but in both cases the relatively short feed storage periods would suggest that the potential for feeds to deteriorate on the farms was minimal. In this regard, the maximum period within which feeds were stored by both farm types was 30 days. Storage conditions were generally reported as good with all the enterprise farms reporting permanent feed stores, and 75 percent of the family farms reporting permanent storage facilities, and 25 percent reporting the availability of temporary feed storage facilities.


TABLE 12

On-farm feed management practices

Management practices Enterprisefarms(%oftotal) Familyfarm(%oftotal)

Feeding Frequency:

Once a day

Twice a day

27

73

50

50

Feeding ration:

Satiation feeding

75%ofsatiation

Farmers’ experience

Pond biomass

27

18

37

18

25

0

75

0

Maintain feed records 100 100

Feed storage

Permanent 100 75

Temporary - 25

Feed storage (days)

Mean

Max

Min

10.8±2.4

30

3

14.3± 3.4

30

6


TABLE 13

Percentage of farmers receiving training on feed management from different agencies

Agencies Enterprisefarms(%oftotal) Familyfarms(%oftotal)

Government agencies

NGO

Feed manufacturers

Commercial training courses

No training

14

6

54

6

20

37

0

45

9

9


3.6.4 Feed affordability The feed investment costs required to fund farming operations, particularly for grow-out operations, are high and feed affordability is of significant concern to farmers, especially for the small-scale family farmers where access to capital and maintaining sufficient cash flows to support business operations may be problematic. Typical feed production costs accruing for operation of a one-hectare grow-out pond for one production cycle are estimated at approximately USD249 0003, and thus financing production requires significant capital investment. In response to farmers need for feed products and the concomitant need for the feed manufacturers to trade, a number of funding/sales mechanisms have developed:

a) Feed supply contracts – Feed supply contracts between the feed manufacturers and farmers are common. Such arrangements are advantageous to both parties as the feed manufacturer is guaranteed a market for their feed, and the farmer is able to negotiate a competitive feed price, and is ensured an uninterrupted supply of good quality feed during the season. In addition, as many of the feed manufacturers are vertically integrated companies and have associated fish processing capacity, the contracts often have an agreement in which the feed manufacturer agrees that on harvest, the feed

3 Feed cost calculated as: At a production intensity of 300 tonnes/ha per cycle and an FCR of 1.6. Total feed requirements to support 1 ha of pond production for one production cycle will be 480 tonnes (300 x 1.6 = 480 tonnes). At a feed cost of USD0.52/kg, the cost of 480 tonnes feed will be USD249 600 (480 000 kg x USD0.52 = USD249 000).


manufacturing company will purchase and process the fish at the prevailing market price. Such agreements confer important advantages to the farmer in that their market is secured, and in those years in which there is over-supply of fish, they know that they will still be able to sell their fish. In contrast, farmers that do not have such purchase agreements in place may find that they are unable to sell their fish at the optimal size for processing (700 g – 1 kg), and be forced to grow them to a larger size (over 1 kg) which adds considerable production costs and is a less profitable alternative.

While some farmers report developing long-term relationships with individual feed manufacturers, other farmers report changing contracts between the feed manufacturers on a regular (annual) basis. Evidently there is considerable competition between the feed manufactures to secure contracts with the farmers, and it was reported that sales representatives from the feed manufacturers regularly visit individual farms to sell their products.

Feed supply contracts represent significant investments for the farmer, and significant sales for the feed manufacturer. For example, a typical 7 ha family farm (grow-out) producing 2 500 tonnes of fish per annum would require a feed supply contract for approximately 4 000 tonnes feed valued at approximately USD2 million. Clearly the high value of these contracts is of significance to the feed manufacturers, are highly valued, and as the loss of such contracts would be detrimental to their business operations, they have a vested interest in maintaining feed quality. To some extent, the contracting arrangement promotes a degree of self-regulation in terms of the feed manufacturers maintaining their product quality.

The feed supply contract terms are variable and are dependent upon the relationship between the manufacturer and the farmer. The simplest contracts guarantee that the feed manufacturer will supply feeds at an agreed price, and the farmer pays for the feeds on a cash-on-delivery (CoD) basis. In the event that the farmer experiences cash flow problems during the production cycle, the additional feeds that are required to complete the production cycle will usually be supplied on credit, depending on the relationship that has developed between the parties. In cases where the feed manufacturer and farmer have built a long-term relationship over a number of years, the feed manufacturer may choose to supply the feeds on credit at no additional cost (interest) to the farmer. In other cases, the feed manufacturer may charge interest on the cost of the additional feeds that are supplied. The farmer may also resort to using commercial bank loans to purchase feeds. In such cases the interest rates provided by either the feed manufacturer or the commercial banks are usually similar (currently 7 – 8 percent per annum).

More complex feed supply contracts typically involve the farmers effectively becoming “contract farmers” to the feed manufacturers/enterprise companies. These contracts are usually considered when the farmers are unable to fund their feed costs from their capital reserves. Typically, the feed manufacturer agrees to cover the feed costs, and on harvest, agrees to purchase the fish for processing at a pre-agreed price that takes into consideration the feed cost. The farmer is responsible for the purchase of the fingerlings and all associated on-farm production costs. The feed cost is calculated on the understanding that the farmer will attain an FCR of 1.6, which is reported as the industry norm for pangasius grow-out production. Should the farmer fail to attain an FCR of 1.6, then the additional feed cost resulting from the poor production performance is borne by the farmer. For example, if the feed price is USD0.52/kg and the farmer attains an FCR of 1.6, they will receive the agreed fish purchase price stated in the contract. If the FCR is lower than 1.6, the money saved as a result of the reduced feed production cost accrues to the farmer. However, should the farmer perform poorly and attain an FCR of 1.7, they will receive the agreed fish price minus the feed cost accruing to the additional feed required to increase the FCR by 0.1. Thus, USD0.52 × 0.1 = USD0.052/ kg is deducted from the contractually agreed fish sale price.


b) Cash and credit terms – Farmers that have not entered into contract agreements with feed manufacturers are forced to purchase feeds either directly from the feed manufacturers or through the wholesale/retail dealerships. These sales are usually made on CoD terms but, typically, there is a minimum amount of feed that needs to be ordered - one feed manufacturer indicated that their minimum order requirement was 5 tonnes per month. Feed orders below the minimum requirement are referred to the feed wholesalers/dealers. Generally, feed manufacturers do not provide credit services to the famers, and those that did, reported providing only short-term credit (c. 1 week – 1 month). This was not the case for the feed wholesalers/dealers. Many farmers reported developing long-term relationships with their feed wholesalers/dealers in which credit was made available throughout the production cycle and in the event of a crop failure, the loan could be extended until the next crop had been harvested. In this regard, the feed wholesalers and dealers provide an important service to the small-scale famers that have relatively low requirements for feeds.

3.7 Services

3.7.1 Inspection systemsThe People’s Committees of the Provinces and D-Fish are the responsible agencies for coordinating

•the inspection and licensing of feed manufacturing establishments (Government Circular: 45/2014/TT-BNNPTNT);

•monitoring the feed manufacturing plants (Government Circular: 44/2014/TT-BNPTNT); and

•monitoring the quality of fish feeds (Government Circular: 66/2011/TT-BNNPTNT).

In order to undertake their mandate, D-Fish operates a network of centrally funded Regional Aquaculture Surveying, Testing and Accreditation Centers. Feed manufacturing establishments are provided a license to operate and the quality of their manufactured feeds are inspected to ensure the production facility conforms to national standards, and the quality of the feeds complies to the feed license specifications.

According to Government Circular: 45/2014/TT-BNNPTNT, feed manufacturing plants are graded A to C. Grade A facilities are establishments that fully satisfy the requirements of assurance for quality and safety of food. Grade A facilities are inspected once every two years; Grade B facilities applies to establishments that satisfy the basic requirements for food safety and quality, but have a number of violations that may not seriously affects the food safety and quality. These facilities are inspected on an annual basis. Grade C facilities are those that have been found not to satisfy the standards and are subject to repeated inspections within six monthly periods. Compliance to the regulations appears to be good. In 2016–17, 20 feed manufacturers were inspected in Dong Thap province. Of those inspected 17 were classified as grade A facilities and the remaining 3 were classified as Grade B facilities (Mrs. Nguyen Thi Kieu Trang, Deputy Director of Fisheries Department, Dong Thap, pers. com.). Nevertheless, compliance is constrained by the absence of sanctions in the Government Circular: 45/2014/TT-BNNPTNT. In the absence of a sanctions regime, a factory that has been found to be unsatisfactory in some manner and relegated from Category A to Category B or C simply has to undergo a more rigorous inspection regime. The lack of sanctions provides no incentive for the feed manufacturing plant to improve their production systems/feed quality. Clearly, it would be preferable for all the manufacturing plants to be operating at the highest grade (Grade A), and therefore to promote compliance to the highest standards, it would be appropriate to revise Government Circular: 45/2014/TT-BNNPTNT to include an appropriate sanctions regime.

31

With respect to monitoring the quality of the manufactured feeds, the feed manufacturers register each new feed product that they want to manufacture and provide the regulators with the feed specifications (proximate composition information). The composition of the feeds are reviewed and accredited by specialist scientific council set up by D-Fish. The bureaucratic requirements to register new feeds was generally viewed by the feed manufacturers as onerous, not only in terms of the time required to register new feeds, but also the costs and regulatory burden. Many feed manufacturers indicated that the requirement to register of feeds prior to production was unnecessary and led to increased time and costs in bringing new products to market. The quality of the feeds that are registered for manufacturing are monitored by the Aquaculture Surveying, Testing and Accreditation Centers no more than twice a year, or when or if quality may be deemed to be problematic, spot checks may be made. Likewise, the quality of imported feeds and feeds that are manufactured for export are also monitored for proximate composition. Feeds that fail to meet the quality criteria can be recalled and destroyed, or in the case of imported feeds, the feeds may be re-exported.

Some famers reported independently monitoring the quality of their purchased feeds. In such cases proximate composition analysis was undertaken at independent laboratories at a cost of approximately USD35 – 25 per sample (crude protein, crude lipid, ash, crude fibre and moisture). Monitoring was reportedly undertaken on an ad hoc basis once or twice during the grow-out period, or in the event that the farmer suspected that there was a problem with feed quality. In the event that the laboratory analysis revealed that the proximate composition of the feed failed to meet the specification listed on the feed packaging, the results are generally used to renegotiate the feed cost, or alternately return the feed and terminate any supply contracts.

3.7.2 Financial servicesAccess to finance, and in particular financing the high feed cost associated with super intensive production is problematic for many of the farmers, and particularly the smaller family farms (section 3.6.4). The farmers report commercial lending rates at 7–8 percent per annum making many reluctant to take out bank loans. Collateral to support bank loans was also reported as problematic by some of the farmers. While crop insurance is available, and could be used in lieu of collateral, none of the farmers reported insuring their crops. While some farmers reported that they did not want to pay the insurance premiums, others indicated that they did not know enough about the policies to make informed decisions.

The low uptake of crop insurance services is of concern. Arguably, the high feed investment costs and the potential for crop losses that are an inherent risk in aquaculture mean that farmers stand to lose considerable sums of money should they experience a crop failure. While the larger enterprise farms are likely to be able to absorb such losses, these would likely prove harder for the small family or cooperative farmers to accommodate. This being the case, consideration could be given to reviewing the crop insurance products that are available in the market to establish why the use of these products are so low, whether they provide cost effective and adequate insurance cover, and how uptake could be improved.

In the absence of loan/credit, many of the family farmers rely on the feed dealers to provide access to short term loans, and to a lesser extent loans from feed manufacturers. As the feed manufacturers appear reticent to extend credit terms to small-scale farmers, the feed retailers/wholesaler provide an important service in terms of providing access to credit to small famers that would otherwise be unable to purchase their feeds.



3.7.3 Tax regimes In 2014, the Vietnamese National Assembly (VNA) approved Law 71/2014/QH13 to eliminate value added taxes (VAT) on animal feed products. The law applies to both imported and domestically produced animal feed products. The law encompasses animal feed ingredients, compound feed, concentrated feed, supplemental feed, feed additives, and premixes; and effectively exempts feed manufacturers and traders from paying VAT on the purchase of their ingredients and feed products, and the farmers from paying VAT on the feeds purchased.

With respect to import and export duties, Viet Nam is a member of the World Trade Organization (WTO) and is subject to their tariff rules and regulations. The country is a signatory to a number of global, regional and country trade agreements that are designed to reduce tariff barriers under the WTO rules. These include global agreements such as Global System of Trade Preferences Among Developing Countries (GSTP), regional agreements such as the Eurasian Economic Union (EUAEU) and the ASEAN free trade area agreements that includes trade agreements with China, Australia, India, Japan and the Republic of Korea. There are also bilateral country agreements in place such as the trade agreement between Chile and Viet Nam. These agreements are designed to reduce tariff barriers where possible. Wheat imports, for example, are nominally taxed at fifteen percent, however, under the ASEAN Australia-Viet Nam Free Trade Agreement and the EUAEU Free trade agreements, wheat can be imported into Viet Nam tax free from Australia, the Russian Federation, Belarus, Kazakhstan, Armenia, and Kyrgyzstan.

33

SECTION 2:REVIEW OF AQUAFEED REGULATORY FRAMEWORK

1. Introduction

In April 2017, the government of Viet Nam promulgated Decree No. 39/2017/ND-CP “Providing the regulatory framework for terrestrial and aquatic animal feeds”. Successful implementation of the new regulatory framework will require its adoption by government agencies, regulatory bodies and industry stakeholders. The analysis presented in this section was designed as a review of the regulatory provisions, with a view to developing recommendations for its adoption by all parties.

Effective regulatory frameworks are those that strengthen enforcement and facilitate compliance. Briefly, “strengthening enforcement” refers to improving the capacity of the government to pursue policy, enforce laws, rules and enabling regulations. Facilitating compliance refers to improving the ability of the firms and farms (the governed) to understand and comply with rules, regulations and legally prescribed standards.

In addition, there are governance mechanisms other than regulatory requirements. These complement and strengthen enforcement and enhance compliance. The outcome is a more effective, less costly and more sustainable management of the sector. Governance mechanisms comprise:

1. Command and control (regulatory and administrative). This draws on the policies that define the rights and obligations of stakeholders (i.e. feed millers, traders, farmers, etc.). Obligations can include acquiring a permit to establish and operate a feed mill, trade in feed, and operate a farm. The Decree embodies this governance mechanism. Its provisions include measures to protect the environment and health of people; means of surveillance, control and enforcement; penalties to impose on violations; ways to redress or compensate for damage; standards of products, standards for manufacturing as well as trading and farming practices; and certification systems for the quality and safety of products.

2. Market instruments. These set standards of compliance for the quality of a product and/or the manner in which it is produced for the purpose of better market access and on the expectation of a higher price. Examples are product and process certifications, eco-labels, and social labels. An eco-label or a social label takes into account the attributes of the products other than price, quality and safety. These other attributes relate to environmental, economic, social and ethical values such as fair trade, support to small and poor farmers, fair treatment of workers, discouraging child and forced labour, and related properties such as being organic, or having other environment protection-related attributes. Another instrument is one that is based on the polluter pays principle: either the producer bears the cost of polluting (by paying a tax on emissions, for example) or not polluting the environment through mitigation actions, such as paying for the construction and maintenance


of a treatment facility. Either measure affects profitability so that its purpose is to induce firms and farmers to be environmentally and socially responsible.

3. Self-regulation or voluntary management. Faced with difficulty and the cost of regulating aquaculture activities, increasing importance is given to self-regulatory and voluntary management schemes. Their practical application is in the adoption of best management practices, codes of conduct and codes of practice, developed by trade bodies such as those representing feed manufacturers’ or farmers’ organizations; developed with the aid and assistance of government and other stakeholders, to which individual businesses sign up to. Voluntary management reduces the need for government functioning in surveillance and monitoring of compliance and imposing penalties for violation of rules and regulations, which add to the overall cost of governance, although compliance with specific codes developed still needs to be undertaken. They also minimize irresponsible practices (e.g. corruption) by the regulator and the regulated.

4. Stakeholder participation. The principle of stakeholder participation in the regulatory process is that the State is one of the major stakeholders, but not the dominant one. Stakeholder participation assumes that the pool of information and experiences – from all the primary stakeholders - makes it easier to develop, decide on and implement policies and plans: there is consensus rather than stalemate or conflict, greater support for decisions agreed through consensus rather than imposition, and little or no political interference.

35

2. Methods

Initially a rapid stakeholders survey was conducted, administered through brief mailed questionnaires that requested information and opinions on issues related to enforcement of and compliance with the new Decree 39. A position paper outlining the issues raised in the survey was presented for discussion at a national workshop held at the Trade Hotel, Hanoi, on 7th October 2017.

Stakeholders that participated in the review process included, on the government agency side, MARD with representation provided by D-Fish, the Analysis and Verification Center, Department of Legislation and Inspection, and the Aquaculture Surveying, Testing and Accreditation Centre. At the provincial level, DARD representation was provided by Provincial Aquaculture Departments from Dong Thap, Can Tho, An Giang, and Tra Vinh, and representation from respective Provincial People’s Committees. Industry representatives included those from feed manufacturing companies, wholesalers and retailers. On the scientific and technical support side, academics from research and development institutions and certification bodies.

3. Review of Decree No. 39/2017/ND-CP

The review and the independent analysis found that the Decree is, in places, vague. In some areas, the provisions can be onerous on feed manufacturers with, for example, the need to conduct experiments that simply add to costs while having little impact on quality; that in turn deters investment in formulating and developing new formulations.

The review resulted in proposals for substantive revisions to some of the provisions of the Decree, that aim to:

(i) improve enforcement and/or facilitating compliance, and (ii) simplify procedures to reduce regulatory costs, facilitate the production of

new feeds, and improve the ability of the regulated parties to comply with the requirements.

The analysis is presented in an “issues and analysis format”. Individual provisions (articles) in the regulations are identified on a case-by-case basis, and an analysis of their appropriateness for adoption or issues regarding their implementation is provided. The section on Recommendations (Section 3) offers ways to address the issues raised.

Review of aquafeed regulatory framework


CH

APT

ER I:

G

ENER

AL

PRO

VIS

ION

S

Pro

visi

on

(cl

ause

no

.)C

om

men

t

Art

icle

3. D

efin

itio

ns

Cla

use

1d

: N

ew t

erre

stri

al a

nd

aq

uat

ic a

nim

al f

eed

s re

fer

to o

ne

or

mo

re f

eed

(s)

imp

ort

ed i

nto

or

man

ufa

ctu

red

in

Vie

t N

am f

or

the

firs

t ti

me,

wh

ich

co

nta

ins

new

act

ive

ing

red

ien

ts t

hat

hav

e n

ot

un

der

go

ne

any

exp

erim

ent

in V

iet

Nam

This

def

init

ion

is

un

clea

r an

d m

akes

it

dif

ficu

lt t

o e

stab

lish

wh

ich

fee

ds

nee

d t

o b

e te

sted

an

d w

hic

h d

o n

ot.

Cla

rity

is

req

uir

ed w

ith

re

spec

t to

“n

ew a

ctiv

e in

gre

die

nts

”. I

s th

e d

efin

itio

n l

imit

ed t

o f

eed

s th

at i

nco

rpo

rate

no

vel

feed

in

gre

die

nts

an

d f

eed

ad

dit

ives

th

at

hav

e n

ot

bee

n t

este

d in

th

e co

un

try,

or

is t

he

def

init

ion

res

tric

ted

to

no

vel f

eed

fo

rmu

lati

on

s.

Art

icle

5. R

egu

lato

ry p

olic

ies

for

terr

estr

ial a

nd

aq

uat

ic a

nim

al f

eed

s

Cla

use

1:

Pro

vid

e in

cen

tive

po

licie

s to

en

cou

rag

e al

l so

cio

-eco

no

mic

se

cto

ral

invo

lvem

ents

in

res

earc

h,

trai

nin

g,

agri

cult

ura

l an

d i

nd

ust

rial

ex

ten

sio

n a

nd

tra

nsf

er o

f sc

ien

tifi

c an

d t

ech

no

log

ical

ad

van

ces

in t

he

nu

trit

ion

, an

d p

roce

ssin

g o

f te

rres

tria

l an

d a

qu

atic

an

imal

fee

ds.

Ince

nti

ve p

olic

ies

are

as y

et u

nd

efin

ed. I

nce

nti

ves

wo

uld

gen

eral

ly a

pp

ly t

o t

he

pri

vate

sec

tor

bu

t al

so t

o in

div

idu

als

in p

ub

lic o

r p

riva

te

org

aniz

atio

ns.

Th

ese

cou

ld b

e in

th

e fo

rm o

f:

•re

cog

nit

ion

fo

r in

no

vati

on

s an

d s

up

po

rt f

or

com

mer

cial

izin

g t

he

inn

ova

tio

n•

sup

po

rt t

o a

dap

tive

an

d o

n-f

arm

res

earc

h b

y g

ove

rnm

ent

and

th

e p

riva

te s

ecto

r th

rou

gh

pu

blic

-pri

vate

par

tner

ship

s (P

PP)

•p

artn

ersh

ip in

far

mer

tra

inin

g a

nd

tec

hn

ical

ad

vice

pro

vid

ed t

o f

eed

man

ufa

ctu

rers

•fa

cilit

atio

n o

f re

gis

trat

ion

an

d li

cen

sin

g o

f n

ew p

rod

uct

s an

d p

roce

sses

Cla

use

2:

Prio

riti

ze i

nve

stm

ent

in a

nd

en

cou

rag

e va

rio

us

eco

no

mic

se

cto

rs t

o g

et i

nvo

lved

in

dev

elo

pm

ent,

pro

du

ctio

n,

exp

loit

atio

n a

nd

ef

fect

ive

uti

lizat

ion

of

terr

estr

ial

and

aq

uat

ic a

nim

al f

eed

in

gre

die

nts

o

r m

ater

ials

an

d o

ffer

oth

er p

olic

ies

wh

ich

in

clu

de

the

allo

cati

on

of

mo

re la

nd

an

d e

xten

sio

n o

f co

nce

ssio

nal

cre

dit

s fo

r cu

ltiv

atio

n, h

arve

st,

sto

rag

e,

pro

du

ctio

n,

pre

par

atio

n

and

p

roce

ssin

g

of

terr

estr

ial

and

aq

uat

ic a

nim

al f

eed

in

gre

die

nts

or

mat

eria

ls.

As

abo

ve,

ince

nti

ves

for

inn

ova

tio

ns

and

su

pp

ort

fo

r co

mm

erci

aliz

ing

an

in

no

vati

on

; in

cen

tive

s sh

ou

ld a

lso

be

pro

vid

ed o

n i

nve

stm

ents

in

ad

dit

ion

to

lan

d a

lloca

tio

n a

nd

cre

dit

on

eas

y te

rms.

Fo

r ex

amp

le:

tax

ho

liday

s; p

rice

su

pp

ort

fo

r lo

cally

pro

du

ced

fee

d i

ng

red

ien

ts;

sup

po

rt f

or

rese

arch

to

id

enti

fy s

ou

rces

an

d t

esti

ng

th

e ef

fica

cy o

f lo

cal

ing

red

ien

ts.

It s

ho

uld

in

clu

de

rese

arch

in

cen

tive

s fo

r th

e d

evel

op

men

t o

f n

ew a

nd

eff

icie

nt

feed

fo

rmu

lati

on

s (r

egar

dle

ss o

f in

gre

die

nt)

, wh

ich

imp

rove

s th

e q

ual

ity

of

feed

.

Cla

use

3: M

ake

inve

stm

ents

an

d e

nco

ura

ge

pri

vate

sec

tor'

s in

volv

emen

t in

th

e im

pro

vem

ent

of

the

cap

acit

y fo

r te

stin

g a

nd

cer

tifi

cati

on

of

con

form

ity

as t

he

bas

is f

or

insp

ecti

on

, au

dit

an

d c

on

tro

l o

f q

ual

ity

of

terr

estr

ial

and

aq

uat

ic a

nim

al f

eed

s. I

nte

nsi

fy t

he

pri

vate

sec

tor’

s in

volv

emen

t in

pu

blic

ser

vice

s fo

r d

evel

op

men

t o

f th

e te

rres

tria

l an

d

aqu

atic

an

imal

fee

d in

du

stry

.

A n

um

ber

of

inte

rven

tio

ns

cou

ld b

e co

nsi

der

ed b

y M

AR

D.

Thes

e co

uld

in

clu

de

sup

po

rt f

or

trai

nin

g o

f te

chn

icia

ns;

acq

uis

itio

n o

f eq

uip

men

t (

tax

exem

pti

on

or

red

uce

d t

axes

); u

pg

rad

ing

of

cap

acit

ies

of

test

ing

an

d c

erti

fica

tio

n l

abo

rato

ries

; as

sure

in

dep

end

ence

o

f th

e te

stin

g a

nd

th

e ce

rtif

icat

ion

of

lab

ora

tori

es;

su

pp

ort

to

th

e la

bo

rato

ries

fo

r th

em t

o b

e ab

le t

o p

rovi

de

affo

rdab

le o

r ev

en f

ree

serv

ices

to

sm

all f

eed

man

ufa

ctu

rers

.

37

Art

icle

6. P

rin

cip

les

of

the

reg

ula

tory

man

agem

ent

of

feed

s co

nta

inin

g a

nti

bio

tics

Cla

use

1: P

roh

ibit

usi

ng

an

tib

ioti

cs in

aq

uaf

eed

Cla

use

1 p

roh

ibit

ing

th

e u

se o

f an

tib

ioti

cs in

aq

uaf

eed

is in

con

sist

ent

wit

h C

lau

se 5

of

Art

icle

6, w

hic

h a

llow

s a

max

imu

m o

f 2

anti

bio

tics

to

be

use

d.

Cla

use

5:

Allo

w a

max

imu

m o

f 2

typ

es o

f an

tib

ioti

cs u

sed

in

an

an

imal

an

d a

qu

a fe

ed p

rod

uct

.C

lau

se 5

is n

ot

con

sist

ent

wit

h C

lau

se 1

ab

ove

.Th

ere

is a

gro

win

g c

on

sen

sus

wit

hin

th

e g

lob

al a

qu

acu

ltu

re c

om

mu

nit

y o

n t

he

nee

d t

o r

edu

ce t

he

use

of

anti

bio

tics

. In

vie

w o

f th

e d

iffi

cult

ies

in d

evel

op

ing

mo

nit

ori

ng

an

d c

om

plia

nce

sys

tem

s, a

n o

utr

igh

t b

an i

n V

iet

Nam

co

uld

be

con

sid

ered

. A

pp

end

ix A

of

the

Vie

t N

am F

eed

Sta

nd

ard

fo

r C

om

po

un

d F

eed

s fo

r su

tch

i cat

fish

an

d t

ilap

ia (T

CV

N 1

0300

:201

4) li

sts

a n

um

ber

of

ban

ned

su

bst

ance

s fo

r u

se

in a

qu

afee

d. W

hile

th

e lis

t is

no

t ex

hau

stiv

e, it

incl

ud

es s

om

e cl

asse

s o

f an

tib

ioti

cs (

e.g

. Nit

rofu

ran

s, C

hlo

ram

ph

enic

ols

). A

t a

glo

bal

leve

l, so

me

anti

bio

tics

rem

ain

in

use

wh

en a

dm

inis

tere

d u

nd

er v

eter

inar

y su

per

visi

on

. Fo

r ex

amp

le,

the

U.S

. Fo

od

an

d D

rug

Ad

min

istr

atio

n

(USF

DA

) ap

pro

ves

the

use

of

Oxy

tetr

acyc

line,

Flo

rfen

ico

l an

d S

ulf

adim

eth

oxi

ne

in a

qu

afee

d t

o c

om

bat

am

on

g o

ther

s en

teri

c se

pti

cem

ia

in c

atfi

sh.

Bas

ed o

n i

nte

rnat

ion

al b

est

pra

ctic

e, c

on

sid

erat

ion

co

uld

be

giv

en t

o t

he

use

of

rest

rict

ed a

nti

bio

tics

un

der

str

ict

vete

rin

ary

sup

ervi

sio

n (

acco

rdin

g t

o A

rtic

le 6

, C

lau

se 3

of

Dec

ree

39/2

017/

ND

-CP)

. C

on

sid

erat

ion

sh

ou

ld b

e g

iven

to

up

dat

ing

th

e lis

t o

f b

ann

ed

anti

bio

tics

list

ed in

Ap

pen

dix

A o

f th

e Fe

ed S

tan

dar

ds

(TC

VN

103

00:2

014)

, pu

blis

hin

g a

list

of

anti

bio

tics

th

at c

an b

e u

sed

in a

qu

acu

ltu

re,

and

pro

mu

lgat

ing

ap

pro

pri

ate

reg

ula

tio

ns

for

thei

r u

se.

The

pre

sen

ce o

f an

tib

ioti

cs a

nd

an

tib

ioti

c re

sid

ues

in im

po

rted

fee

d in

gre

die

nts

, pri

nci

pal

ly f

rom

an

imal

by-

pro

du

ct m

eals

, is

of

con

cern

to

fee

d m

anu

fact

ure

rs a

s th

ey m

ay i

nad

vert

entl

y in

corp

ora

te t

hes

e m

ater

ials

in

to t

hei

r fe

ed f

orm

ula

tio

ns.

Th

e fi

nis

hed

fee

ds

will

su

bse

qu

entl

y ap

pea

r to

be

no

n-c

om

plia

nt

to t

he

reg

ula

tio

ns.

Exi

stin

g f

eed

qu

alit

y in

spec

tio

n s

yste

ms

nee

d t

o b

e ex

pan

ded

to

mo

nit

or

anti

bio

tics

an

d t

hei

r re

sid

ues

in f

eed

ing

red

ien

ts o

f b

oth

loca

l an

d im

po

rted

ori

gin

.

6. E

nsu

re t

hat

fac

iliti

es m

anu

fact

uri

ng

an

imal

fee

ds

use

d f

or

lives

tock

an

d p

ou

ltry

dis

ease

pre

ven

tio

n a

nd

tre

atm

ent

pu

rpo

ses

are

staf

fed

b

y ve

teri

nar

ian

s h

old

ing

p

ract

icin

g

cert

ific

ates

in

an

imal

d

isea

se

pre

ven

tio

n

and

tr

eatm

ent

in

acco

rdan

ce

wit

h

app

licab

le

law

s an

d

reg

ula

tio

ns

on

an

imal

hea

lth

.

Som

e fe

ed m

anu

fact

ure

rs p

rod

uce

bo

th t

erre

stri

al a

nim

al (l

ives

tock

/po

ult

ry) f

eed

an

d a

qu

afee

d.

Wh

ere

app

rop

riat

e an

imal

vet

erin

aria

ns

sho

uld

be

trai

ned

in

th

e re

leva

nt

asp

ects

of

fish

dis

ease

pre

ven

tio

n,

con

tro

l an

d t

reat

men

t. A

lter

nat

ivel

y, c

om

pan

ies

sho

uld

be

allo

wed

to

hir

e a

qu

alif

ied

co

nsu

ltan

t ve

teri

nar

ian

/fis

h h

ealt

h c

on

sult

ant.



Art

icle

10.

Elig

ibili

ty r

equ

irem

ents

an

d c

on

ten

ts o

f ex

per

imen

ts w

ith

ter

rest

rial

an

d a

qu

atic

an

imal

fee

ds

1. C

on

ten

ts o

f ex

per

imen

ts w

ith

new

ter

rest

rial

an

imal

fee

d

and

aq

uaf

eed

.

a) T

erre

stri

al a

nd

aq

uat

ic a

nim

al f

eed

s th

at r

equ

ire

exp

erim

ents

sh

all b

e n

ew t

erre

stri

al a

nd

aq

uat

ic a

nim

al f

eed

s.

and

b)

Terr

estr

ial

and

aq

uat

ic a

nim

al f

eed

s sh

all

no

t re

qu

ire

exp

e-rimen

tsifitistheresultofaresearch

projectorschem

ereco

-g

niz

ed b

y th

e M

inis

try

of

Ag

ricu

ltu

re a

nd

Ru

ral

Dev

elo

pm

ent

as a

tec

hn

olo

gic

al a

dva

nce

or

if i

t p

asse

s ex

per

imen

ts a

nd

is

app

rove

d f

or

sale

in

co

un

trie

s w

ith

wh

ich

Vie

t N

am h

as m

ade

mu

tual

rec

og

nit

ion

ag

reem

ents

on

th

e p

roce

du

res

for

exp

e-ri

men

ts w

ith

an

d r

eco

gn

itio

n o

f n

ew t

erre

stri

al a

nd

aq

uat

ic

anim

al f

eed

s.

The

term

“Ex

per

imen

t” a

nd

its

pu

rpo

se r

equ

ire

clar

ific

atio

n.

Do

es t

he

term

ref

er t

o t

he

nee

d f

or

veri

fica

tio

n t

rial

s to

co

nfi

rm f

eed

pro

du

ctio

n

attr

ibu

tes

clai

med

by

the

feed

man

ufa

ctu

rers

? O

r is

th

ere

a m

inim

um

set

of

crit

eria

th

at a

fee

d m

ust

co

nfo

rm t

o i

n t

erm

s o

f p

rod

uct

ion

ch

arac

teri

stic

s i.e

. g

row

th p

aram

eter

s, c

on

trib

uti

on

to

fee

d c

on

vers

ion

eff

icie

ncy

. Fu

rth

erm

ore

, it

is

un

clea

r w

het

her

th

e p

rovi

sio

ns

exte

nd

to

te

stin

g t

he

effi

cacy

of

new

fee

d in

gre

die

nts

or

feed

ad

dit

ives

use

d in

aq

uaf

eed

. Th

e im

plic

atio

n is

th

at a

ll n

ew f

eed

fo

rmu

lati

on

s ir

resp

ecti

ve o

f th

eir

ing

red

ien

t co

mp

osi

tio

n w

ill r

equ

ire

test

ing

.

In t

he

even

t th

at e

xper

imen

ts a

re u

nd

erta

ken

, th

ey n

eed

to

be

exec

ute

d b

y an

in

dep

end

ent

inst

itu

tio

n i

.e.

a g

ove

rnm

ent

rese

arch

in

stit

uti

on

/U

niv

ersi

ty, w

hic

h h

ave

no

co

mm

erci

al in

tere

sts

or

con

nec

tio

n t

o t

he

feed

man

ufa

ctu

rin

g/im

po

rtin

g c

om

pan

y.

It i

s n

ot

nec

essa

ry t

o t

est

all

new

fee

d p

rod

uct

s fo

r te

rres

tria

l an

d a

qu

atic

an

imal

sp

ecie

s th

at a

re g

ow

n l

oca

lly/r

egio

nal

ly a

nd

fo

r w

hic

h

reco

gn

ized

fee

ds

are

alre

ady

avai

lab

le. A

mo

ng

oth

ers,

th

is w

ou

ld in

clu

de

feed

s fo

r A

sian

sea

bas

s, p

ang

asiu

s ca

tfis

h a

nd

tila

pia

. In

su

ch c

ases

, th

e fe

ed m

anu

fact

ure

rs n

eed

on

ly p

ub

lish

dec

lara

tio

ns

of

qu

alit

y th

at in

clu

de

pro

xim

ate

com

po

siti

on

an

d in

gre

die

nt

pro

file

.

It is

arg

uab

le w

het

her

go

vern

men

t o

vers

igh

t o

f fe

ed r

esea

rch

is n

eces

sary

. Co

nsi

der

atio

n s

ho

uld

be

giv

en t

o w

het

her

all

new

fo

rmu

lati

on

s n

eed

te

stin

g.

If

this

is

the

case

, it

wo

uld

be

on

ero

us

to t

he

man

ufa

ctu

rers

an

d p

rob

ably

no

t n

eces

sary

– h

igh

co

sts

wo

uld

be

incu

rred

an

d b

rin

gin

g

new

pro

du

cts

to t

he

mar

ket

wo

uld

tak

e a

lon

g t

ime.

Th

e lik

ely

resu

lt i

s fe

wer

ch

oic

es i

n f

eed

fo

rmu

lati

on

s av

aila

ble

to

far

mer

s. B

ased

on

th

e kn

ow

n n

utr

itio

nal

req

uir

emen

ts o

f a

cult

ure

d s

pec

ies,

fee

d m

anu

fact

ure

rs o

ften

ap

ply

leas

t co

st p

rog

ram

min

g t

o c

han

ge

form

ula

tio

ns

acco

rdin

g

to v

aria

tio

ns

in w

ho

lesa

le p

rice

s o

f fe

ed i

ng

red

ien

ts.

Hav

ing

to

tes

t ea

ch n

ew f

orm

ula

tio

n w

ou

ld e

ffec

tive

ly m

ake

this

ap

pro

ach

un

wo

rkab

le,

arg

uab

ly a

dd

ing

to

fee

d c

ost

s. I

n t

his

reg

ard

, it

wo

uld

be

mo

re a

pp

rop

riat

e to

dev

elo

p a

fee

d s

tan

dar

d b

ased

on

th

e kn

ow

n n

utr

itio

nal

re

qu

irem

ents

of

the

targ

et s

pec

ies

and

en

sure

th

at a

ll fo

rmu

lati

on

s co

nfo

rm t

o t

he

stan

dar

d.

Withrespecttonove

lfeed

ingredientsandfee

dadditives,thereissomejustificationforgove

rnmen

tove

rsightintheiruse-toensurethat

on

ly g

oo

d q

ual

ity

feed

in

gre

die

nts

or

effi

caci

ou

s fe

ed a

dd

itiv

es a

re u

sed

, an

d t

hat

th

ese

are

no

t h

arm

ful.

Cau

tio

n n

eed

s to

be

app

lied

wh

en

asse

ssin

g n

ove

l fee

d in

gre

die

nts

fo

r u

se in

aq

uaf

eed

- a

s th

eir

effi

cacy

will

dep

end

up

on

a n

um

ber

of

fact

ors

incl

ud

ing

th

eir

nu

trie

nt

pro

file

, th

e d

ieta

ry i

ncl

usi

on

lev

el,

the

bas

e fo

rmu

lati

on

th

at i

s u

sed

du

rin

g t

he

tria

l, an

d t

he

exp

erim

enta

l co

nd

itio

ns

un

der

wh

ich

th

e tr

ial

is u

nd

erta

ken

. W

ith

res

pec

t to

fee

d a

dd

itiv

es,

glo

bal

ly t

her

e is

an

in

crea

sin

g t

ren

d t

ow

ard

s th

e u

se o

f fe

ed a

dd

itiv

es t

o i

mp

rove

th

e n

utr

ien

t p

rofi

le o

f fe

eds,

o

r to

en

han

ce t

he

bio

avai

lab

ility

of

nu

trie

nts

wit

hin

th

e fe

eds,

th

ereb

y im

pro

vin

g f

eed

per

form

ance

. Ty

pic

ally

, th

ese

tren

ds

man

ifes

t as

an

in

crea

sin

g u

se o

f p

re-

and

pro

-bio

tics

, dig

esti

ve e

nzy

me

pre

par

atio

ns,

cry

stal

line

amin

o a

cid

s, p

ho

sph

olip

ids.

Wh

ile t

he

effi

cacy

of

som

e o

f th

ese

pre

par

atio

ns

are

wel

l u

nd

erst

oo

d,

man

y ar

e p

oo

rly

un

der

sto

od

, an

d i

nd

eed

in

tern

atio

nal

ly t

he

effi

cacy

of

som

e fe

ed a

dd

itiv

es h

ave

no

t b

een

ri

go

rou

sly

test

ed, a

nd

th

eir

use

in f

eed

fo

rmu

lati

on

s is

th

eref

ore

qu

esti

on

able

. Un

der

taki

ng

exp

erim

enta

l tri

als

to t

est

the

effi

cacy

of

no

vel f

eed

in

gre

die

nts

an

d f

eed

ad

dit

ives

is

a te

chn

ical

ly c

hal

len

gin

g,

exp

ensi

ve a

nd

tim

e-co

nsu

min

g t

ask

that

on

ly t

he

larg

er f

eed

man

ufa

ctu

rers

wo

uld

b

e eq

uip

ped

to

un

der

take

. Nev

erth

eles

s, s

ign

ific

ant

rese

arch

wo

rk h

as b

een

un

der

take

n t

o e

stab

lish

th

e ef

fica

cy o

f m

any

no

vel f

eed

ing

red

ien

ts

use

d in

aq

uac

ult

ure

- t

he

resu

lts

of

thes

e tr

ials

are

eit

her

pu

blis

hed

in s

cien

tifi

c o

r g

rey

liter

atu

re. W

ith

res

pec

t to

fee

d a

dd

itiv

es, t

he

Euro

pea

n

Un

ion

has

dev

elo

ped

a c

om

pre

hen

sive

reg

iste

r o

f fe

ed a

dd

itiv

es t

hat

can

be

use

d i

n a

nim

al f

eed

s (E

uro

pea

n U

nio

n R

egis

ter

of

Feed

Ad

dit

ives

Pu

rsu

ant

to R

egu

lati

on

(EC

) N

o 1

831/

2003

, Ed

itio

n 2

504 )

as

has

th

e U

nit

ed S

ates

of

Am

eric

a’s

Foo

d a

nd

Dru

g A

dm

inis

trat

ion

(U

SFD

A).

To

avo

id

un

nec

essa

ry e

xper

imen

tal c

ost

s, d

up

licat

ion

of

wo

rk, a

nd

del

ays

in b

rin

gin

g n

ew p

rod

uct

s to

mar

ket,

an

ass

essm

ent

of

the

suit

abili

ty o

f th

e n

ove

l fe

ed in

gre

die

nts

/fee

d a

dd

itiv

es b

ased

up

on

exi

stin

g r

esea

rch

or

use

reg

ula

tio

ns

fro

m o

ther

reg

ion

s o

f th

e w

orl

d c

ou

ld b

e co

nsi

der

ed.

Nev

erth

eles

s, t

he

reg

ula

tio

ns

sho

uld

co

nsi

der

th

e n

eed

fo

r ad

apti

ve r

esea

rch

; o

n-f

arm

tri

als

wo

uld

be

a d

esir

able

par

t o

f th

e re

sear

ch a

nd

d

evel

op

men

t p

roce

ss f

or

new

fee

ds

and

fo

r m

akin

g im

pro

vem

ents

to

exi

stin

g f

eed

fo

rmu

lati

on

s. Id

eally

, th

ese

are

con

du

cted

in d

iffe

ren

t re

gio

ns

to t

est

thei

r su

itab

ility

un

der

dif

fere

nt

agro

-clim

atic

co

nd

itio

ns

and

so

cio

-eco

no

mic

cir

cum

stan

ces

of

farm

ers.

2. b

) Te

chn

icia

ns

wo

rkin

g f

or

thes

e fa

cilit

ies

mu

st h

ave

at l

east

universityd

egreesino

ne

ofthe

follo

wingm

ajors,including

anim

al s

cien

ce -

an

imal

hea

lth

or

bio

tech

no

log

y (i

n t

erm

s o

f an

imal

fee

ds)

or

in t

he

aqu

acu

ltu

re s

cien

ce o

r b

iolo

gy

(in

ter

ms

of

aqu

afee

d).

For

rese

arch

wo

rk, t

he

incl

usi

on

of

a fi

sh n

utr

itio

nis

t in

th

e re

sear

ch t

eam

sh

ou

ld b

e m

and

ato

ry.

4 htt

p://

ec.e

urop

a.eu

/foo

d/sa

fety

/ani

mal

-fee

d/fe

ed-a

ddit

ives

/ind

ex_e

n.ht

m

39

Art

icle

11.

Pro

cess

es a

nd

pro

ced

ure

s fo

r ap

plic

atio

n f

or

exp

erim

ents

wit

h a

nd

reg

ula

tio

n o

f te

rres

tria

l an

d a

qu

atic

an

imal

fee

ds

Cla

use

2b

: Th

at s

et o

f d

ocu

men

ts s

ub

mit

ted

to

ap

ply

fo

r ex

pe-

rim

ents

wit

h n

ew t

erre

stri

al a

nd

aq

uat

ic a

nim

al f

eed

s sh

all

incl

ud

e:

b)

Ou

tlin

e o

f th

e ex

per

imen

t

To d

ate,

no

gu

idel

ines

hav

e b

een

dev

elo

ped

to

ass

ist

rese

arch

ers

to d

esig

n e

xper

imen

ts r

equ

ired

to

ass

ess

no

vel

feed

fo

rmu

lati

on

s. M

AR

D w

ill

nee

d t

o d

evel

op

th

e g

uid

elin

es a

nd

th

e cr

iter

ia t

hat

will

be

use

d t

o a

sses

s th

e ef

fica

cy o

f fo

rmu

lati

on

s.

Cla

use

5: I

nsp

ecti

on

of

exp

erim

enta

l act

ivit

ies:

a) I

nsp

ecti

on

met

ho

d a

nd

deg

ree:

Th

e M

inis

try

of

Ag

ricu

ltu

re

and

R

ura

l D

evel

op

men

t m

ust

es

tab

lish

a

wo

rkin

g

gro

up

co

mp

ose

d o

f re

leva

nt

reg

ula

tors

an

d s

cien

tist

s to

car

ry o

ut

fiel

d

insp

ecti

on

at

leas

t o

nce

du

rin

g t

he

pro

ced

ure

s fo

r ex

per

imen

t w

ith

new

ter

rest

rial

an

d a

qu

atic

an

imal

fee

ds.

b) I

nsp

ecti

on

co

nte

nts

: elig

ibili

ty r

equ

irem

ents

fo

r ex

per

imen

tal

faci

litie

s; c

on

ten

ts o

f ex

per

imen

ts s

pec

ifie

d i

n t

he

app

rove

d

ou

tlin

e o

f ex

per

imen

t.

Co

nsi

der

atio

n s

ho

uld

be

giv

en t

o d

ecid

ing

wh

eth

er i

t is

nec

essa

ry/a

pp

rop

riat

e to

hav

e al

l n

ew f

eed

s te

sted

, an

d i

f so

, w

het

her

g

ove

rnm

ent

ove

rsig

ht

into

th

e ex

per

imen

tal d

esig

n a

nd

pro

cess

es is

nec

essa

ry (

see

Art

icle

10

abo

ve).



CH

APT

ER II

: EL

IGIB

ILIT

Y R

EQU

IREM

ENTS

FO

R M

AN

UFA

CTU

RE

AN

D T

RA

DE

IN T

ERR

ESTR

IAL

AN

D A

QU

ATI

C A

NIM

AL

FEED

S

Pro

visi

on

(cl

ause

no

.)C

om

men

t

Art

icle

7. E

ligib

ility

req

uir

emen

ts a

pp

lied

to

fac

iliti

es m

anu

fact

uri

ng

an

d p

roce

ssin

g o

f te

rres

tria

l an

d a

qu

atic

an

imal

fee

ds

Cla

use

3: E

nvi

ron

men

tal i

mp

act a

sses

smen

t (EI

A) r

epo

rt o

r en

viro

nm

enta

l p

rote

ctio

n p

lan

mu

st b

e p

rep

ared

in

acc

ord

ance

wit

h a

pp

licab

le l

aws

and

reg

ula

tio

ns

on

en

viro

nm

ent

Gu

idan

ce o

n h

ow

to

pre

par

e EI

A a

nd

en

viro

nm

enta

l p

rote

ctio

n p

lan

s ar

e n

ot

avai

lab

le.

The

ind

ust

ry a

nd

en

viro

nm

enta

l p

ract

itio

ner

s d

evel

op

ing

th

ese

stu

die

s an

d p

lan

s re

qu

ire

gu

idan

ce a

nd

tra

inin

g t

o f

acili

tate

co

mp

lian

ce.

Cla

use

4d

: W

ith

res

pec

t to

a f

acili

ty m

anu

fact

uri

ng

an

d p

roce

ssin

g

anim

al f

eed

s co

nta

inin

g a

nti

bio

tics

, it

mu

st s

et u

p a

sep

arat

e ar

ea

for

mix

ing

, p

rep

arat

ion

an

d f

orm

ula

tio

n o

f th

ese

pro

du

cts

in o

rder

to

en

sure

cro

ss-c

on

tam

inat

ion

th

at m

ay o

ccu

r is

co

nta

ined

so

th

at i

t ca

nn

ot

affe

ct t

he

amb

ien

t en

viro

nm

ent.

Ince

nti

ve p

olic

ies

are

as y

et u

nd

efin

ed. I

nce

nti

ves

wo

uld

gen

eral

ly a

pp

ly t

o t

he

pri

vate

sec

tor

bu

t al

so t

o in

div

idu

als

in p

ub

lic o

r p

riva

te

org

aniz

atio

ns.

Th

ese

cou

ld b

e in

th

e fo

rm o

f:

•re

cog

nit

ion

fo

r in

no

vati

on

s an

d s

up

po

rt f

or

com

mer

cial

izin

g t

he

inn

ova

tio

n•

sup

po

rt t

o a

dap

tive

an

d o

n-f

arm

res

earc

h b

y g

ove

rnm

ent

and

th

e p

riva

te s

ecto

r th

rou

gh

Pu

blic

-Pri

vate

Par

tner

ship

s (P

PP)

•p

artn

ersh

ip in

far

mer

tra

inin

g a

nd

tec

hn

ical

ad

vice

pro

vid

ed t

o f

eed

man

ufa

ctu

rers

•fa

cilit

atio

n o

f re

gis

trat

ion

an

d li

cen

sin

g o

f n

ew p

rod

uct

s an

d p

roce

sses

Cla

use

2:

Prio

riti

ze i

nve

stm

ent

in a

nd

en

cou

rag

e va

rio

us

eco

no

mic

se

cto

rs t

o g

et i

nvo

lved

in

dev

elo

pm

ent,

pro

du

ctio

n,

exp

loit

atio

n a

nd

ef

fect

ive

uti

lizat

ion

of

anim

al a

nd

aq

ua

feed

in

gre

die

nts

or

mat

eria

ls

and

off

er o

ther

po

licie

s w

hic

h i

ncl

ud

e th

e al

loca

tio

n o

f m

ore

lan

d

and

ext

ensi

on

of

con

cess

ion

al c

red

its

for

cult

ivat

ion

, h

arve

st,

sto

rag

e,

pro

du

ctio

n, p

rep

arat

ion

an

d p

roce

ssin

g d

om

esti

c an

imal

an

d a

qu

a fe

ed

ing

red

ien

ts o

r m

ater

ials

.

Sett

ing

up

th

e d

edic

ated

pro

du

ctio

n l

ines

to

allo

w f

eed

s co

nta

inin

g a

nti

bio

tics

to

be

man

ufa

ctu

red

was

wid

ely

view

ed a

s p

roh

ibit

ivel

y ex

pen

sive

an

d a

n u

nn

eces

sary

pre

cau

tio

n f

or

the

cro

ss c

on

tam

inat

ion

of

feed

s/en

viro

nm

ent.

In

stea

d,

the

reg

ula

tio

ns

sho

uld

fo

cus

on

en

suri

ng

pro

du

ct q

ual

ity

and

saf

ety

usi

ng

exi

stin

g p

rod

uct

ion

lin

es. C

on

sid

erat

ion

sh

ou

ld b

e g

iven

to

rem

ovi

ng

th

is c

lau

se.

Cla

use

4d

d:

Mea

sure

men

t d

evic

es o

r in

stru

men

ts m

ust

be

in p

lace

in

ord

er t

o c

on

tro

l th

e q

ual

ity

of

terr

estr

ial

or

aqu

atic

an

imal

fee

d

pro

du

cts

and

en

sure

acc

ura

cy i

n a

cco

rdan

ce w

ith

ap

plic

able

law

s an

d

reg

ula

tio

ns

on

mea

sure

men

t.

Pro

du

ct m

on

ito

rin

g in

stru

men

tati

on

will

be

inst

alle

d t

hro

ug

ho

ut

the

pro

du

ctio

n li

ne

as a

co

mp

on

ent

of

com

ple

x a

nd

usu

ally

au

tom

ated

p

rod

uct

ion

sys

tem

s. H

ow

ever

, in

sm

alle

r fe

eds

mill

s, s

uch

in

stru

men

tati

on

may

no

t b

e in

stal

led

at

all

po

ints

alo

ng

th

e p

rod

uct

ion

lin

e.

Co

mp

lian

ce b

y th

ese

smal

ler

man

ufa

ctu

rin

g p

lan

ts m

ay p

rove

pro

hib

itiv

ely

exp

ensi

ve. C

lari

ty in

th

e ap

plic

atio

n o

f th

is c

lau

se is

req

uir

ed

- th

e fo

cus

on

pro

du

ct q

ual

ity

sho

uld

be

on

th

e fi

nal

pro

du

ct.

41

CH

APT

ER II

I: E

XPE

RIM

ENTS

WIT

H N

EW T

ERR

ESTR

IAL

AN

D A

QU

ATI

C A

NIM

AL

FEED

S

No

com

men

ts o

r su

gges

tion

s

CH

APT

ER IV

: TE

RR

ESTR

IAL

AN

D A

QU

ATI

C A

NIM

AL

FEED

S A

PPR

OV

ED F

OR

SA

LE IN

VIE

T N

AM

N

o co

mm

ents

or

sugg

esti

ons

CH

APT

ER V

: IN

SPEC

TIO

N O

F Q

UA

LITY

OF

TER

RES

TRIA

L A

ND

AQ

UA

TIC

AN

IMA

L FE

EDS

Pro

visi

on

(cl

ause

no

.)C

om

men

t

Art

icle

15.

Insp

ecti

on

of

do

mes

tic

anim

al a

nd

aq

ua

feed

s

Gen

eral

co

mm

ent:

Ther

e is

no

pro

visi

on

fo

r th

e in

spec

tio

n o

f q

ual

ity

of

loca

lly a

vaila

ble

fee

d in

gre

die

nts

or

feed

ad

dit

ives

use

d in

fee

d m

anu

fact

uri

ng

.C

lari

ty is

nee

ded

in t

erm

s o

f w

ho

bea

rs t

he

resp

on

sib

ility

fo

r fu

nd

ing

th

e te

sts:

th

e fe

ed m

anu

fact

ure

r? O

r th

e im

po

rtat

ion

/tra

din

g

com

pan

y.

Art

icle

16.

Insp

ecti

on

of

exp

ort

ed o

r im

po

rted

an

imal

an

d a

qu

a fe

eds

Gen

eral

co

mm

ent:

Th

ere

are

pro

visi

on

s fo

r th

e in

spec

tio

n o

f q

ual

ity

of

aqu

afee

d t

o b

e im

po

rted

an

d t

hat

th

ey c

om

ply

to

Vie

tnam

ese

stan

dar

ds.

An

d

at t

he

req

ues

t o

f im

po

rtin

g c

ou

ntr

ies,

th

ere

are

pro

visi

on

s fo

r th

e in

spec

tio

n o

f ex

po

rted

fee

ds

to t

he

reci

pie

nt

cou

ntr

y’s

stan

dar

ds.

H

ow

ever

, th

ere

is n

o m

enti

on

of

insp

ecti

on

of

the

qu

alit

y o

f fe

ed in

gre

die

nts

an

d f

eed

ad

dit

ives

th

at a

re im

po

rted

or

exp

ort

ed.

Cla

use

2: I

nsp

ecti

ng

en

tity

: Th

e in

spec

tin

g e

nti

ty is

a c

om

pet

ent

stat

e au

tho

-ri

ty o

r an

org

aniz

atio

n a

pp

oin

ted

by

the

Min

istr

y o

f A

gri

cult

ure

an

d R

ura

l D

evel

op

men

t as

an

en

tity

ves

ted

wit

h a

uth

ori

ty t

o g

ran

t ce

rtif

icat

ion

of

con

form

ity

to q

ual

ity

stan

dar

ds

for

terr

estr

ial a

nd

aq

uat

ic a

nim

al f

eed

s u

sed

fo

r ex

po

rt a

nd

im

po

rt p

urp

ose

s (h

erei

naf

ter

refe

rred

to

as

the

app

oin

ted

o

rgan

izat

ion

) in

ord

er t

o p

erfo

rm c

erta

in i

nsp

ecti

on

act

ivit

ies

in t

he

enti

re

insp

ecti

on

pro

cess

wh

ich

are

sp

ecif

ied

by

the

app

oin

tmen

t d

ecis

ion

.

Ther

e is

a n

eed

to

ass

ure

bo

th t

he

com

pet

ence

an

d i

nd

epen

den

ce o

f an

y ap

po

inte

d o

rgan

izat

ion

. Fi

sh n

utr

itio

n s

ho

uld

be

on

e o

f th

e ar

eas

of

exp

erti

se o

f th

e in

spec

tin

g a

nd

cer

tify

ing

lab

ora

tory

.

The

insp

ecti

on

of

new

tes

tin

g e

stab

lish

men

ts s

ho

uld

be

dec

entr

aliz

ed a

nd

co

ord

inat

ed w

ith

insp

ecto

rs o

f th

e Pr

ovi

nci

al D

epar

tmen

ts

ofAgricu

ltureandRuralD

evelopmen

ttoensureaccuracyandobjectivity.



CH

APT

ER V

I: R

ESPO

NSI

BIL

ITIE

S O

F EN

TITI

ES, O

RG

AN

ISA

TIO

NS

OR

IND

IVID

UA

LS E

NG

AG

ED IN

TER

RES

TRIA

L A

ND

AQ

UA

TIC

AN

IMA

L FE

ED

IND

UST

RIE

S

Pro

visi

on

(cl

ause

no

.)C

om

men

t

Art

icle

23.

Res

po

nsi

bili

ties

fo

r re

gu

lato

ry m

anag

emen

t o

f te

rres

tria

l an

d a

qu

atic

an

imal

fee

ds

Cla

use

2 li

sts

14 im

ple

men

tati

on

cla

use

s o

utl

inin

g t

he

reg

ula

tory

res

po

nsi

bili

ties

fo

r M

AR

D

Cla

use

2a:

MA

RD

sh

all t

ake

char

ge

of

and

co

op

erat

e w

ith

rel

evan

t m

inis

trie

s o

r se

cto

ral

dep

artm

entsine

stab

lishmen

tofstrategicp

lans,a

imsan

do

bjectives,polic

iesfor

dev

elo

pm

ent

and

uti

lizat

ion

of

terr

estr

ial a

nd

aq

uat

ic a

nim

al f

eed

s ac

ross

th

e n

atio

n.

Effe

ctiv

e st

rate

gic

pla

nn

ing

is

a m

ult

i-d

isci

plin

ary

acti

vity

, is

co

mp

lex,

tim

e co

nsu

min

g a

nd

exp

ensi

ve t

o i

mp

lem

ent.

St

rate

gic

pla

nn

ing

an

d p

olic

y m

akin

g i

mp

acts

man

y g

ove

rnm

ent

dep

artm

ents

an

d i

s a

lon

g-t

erm

pro

cess

th

at r

equ

ires

su

ffic

ien

t b

ud

get

ary

allo

cati

on

.

Cla

use

2c:

Pre

par

e n

atio

nal

sta

nd

ard

s an

d n

atio

nal

tec

hn

ical

reg

ula

tio

ns

on

ter

rest

rial

an

d a

qu

atic

an

imal

fee

ds

and

Cla

use

2e:

Set

a l

imit

on

th

e m

inim

um

nu

mb

er o

f in

dic

ato

rs t

hat

mu

st b

e in

clu

ded

in

th

e ap

plie

d s

tan

dar

d

The

dev

elo

pm

ent

of

feed

sta

nd

ard

s, i

nd

icat

ors

an

d t

ech

nic

al r

egu

lati

on

s re

qu

ires

bo

th s

ign

ific

ant

bu

dg

etar

y al

loca

tio

n

and

ava

ilab

ility

of

qu

alif

ied

aq

uac

ult

ure

nu

trit

ion

ists

. Th

e p

rob

lem

s as

soci

ated

wit

h d

evel

op

ing

sta

nd

ard

s ar

e fu

rth

er

exac

erb

ated

by

the

nee

d t

o d

evel

op

sp

ecie

s-sp

ecif

ic s

tan

dar

ds

that

sat

isfy

th

e n

utr

itio

nal

req

uir

emen

ts o

f th

e cu

ltu

re

spec

ies.

Th

e n

utr

itio

nal

req

uir

emen

ts o

f m

any

cult

ure

d s

pec

ies

are

po

orl

y u

nd

erst

oo

d,

and

co

gn

izan

ce o

f lim

itat

ion

s o

f “c

urr

ent

kno

wle

dg

e” n

eed

s to

be

take

n i

nto

co

nsi

der

atio

n w

hen

dev

elo

pin

g s

tan

dar

ds.

Fu

rth

erm

ore

, fe

ed s

tan

dar

ds

sho

uld

no

t b

e vi

ewed

as

stat

ic d

ocu

men

ts –

sta

nd

ard

s n

eed

to

be

revi

sed

as

new

sci

enti

fic

kno

wle

dg

e em

erg

es a

nd

ou

r u

nd

erst

and

ing

of

the

nu

trit

ion

al r

equ

irem

ents

of

a cu

ltu

re s

pec

ies

imp

rove

s.

A r

evie

w o

f th

e V

ietn

ames

e N

atio

nal

Sta

nd

ard

fo

r C

om

po

un

d F

eed

s fo

r su

tch

i ca

tfis

h a

nd

tila

pia

(TC

VN

103

000:

2014

) su

gg

ests

th

at t

he

curr

ent

stan

dar

d d

oes

no

t re

flec

t th

e n

utr

itio

nal

req

uir

emen

ts o

f th

e sp

ecie

s, a

nd

req

uir

es r

evis

ion

(s

ecti

on

3.4

.3).

Cla

use

2l:

Pro

mo

te i

nte

rnat

ion

al c

oo

per

atio

n i

n t

erre

stri

al a

nd

aq

uat

ic a

nim

al f

eed

in

du

stri

es.

To d

ate,

ad

equ

ate

fun

din

g h

as n

ot

bee

n m

ade

avai

lab

le f

or

MA

RD

to

eff

ecti

vely

imp

lem

ent

inte

rnat

ion

al c

oo

per

atio

n.

Cla

use

4 li

sts

five

res

po

nsi

bili

ties

of

the

Peo

ple

s C

om

mit

tees

of

cen

tral

ly a

ffili

ated

cit

ies

and

pro

vin

ces

Cla

use

4a:

Dra

w u

p t

he

pla

n f

or

the

dev

elo

pm

ent

and

use

of

terr

estr

ial

and

aq

uat

ic

anim

alfee

dswithintheirjurisdictions

Sect

or

dev

elo

pm

ent

pla

nn

ing

fo

r fe

ed m

anu

fact

uri

ng

an

d u

se i

s a

com

ple

x ta

sk,

and

it

will

be

dif

ficu

lt t

o d

evel

op

an

d

exec

ute

su

ch p

lan

s at

th

e le

vel

of

the

Peo

ple

s C

om

mit

tee.

Arg

uab

ly a

mo

re a

pp

rop

riat

e le

vel

for

sect

or

dev

elo

pm

ent

planningw

ouldbeatanationalle

vel.Fu

rthermore,fee

dm

anufacturersarealrea

dysubjecttoasector-specificreg

ulatory

fram

ewo

rk t

hat

reg

ula

tes

thei

r ac

tivi

ties

, an

d c

on

sid

erat

ion

sh

ou

ld b

e g

iven

to

th

e ap

pro

pri

aten

ess

for

the

Peo

ple

C

om

mit

tees

to

in

terf

ere

wit

h t

hei

r b

usi

nes

s p

lan

nin

g o

per

atio

ns.

As

ou

tlin

ed i

n A

rtic

le 2

3: C

lau

se 4

dd

, at

th

e Pe

op

le

Co

mm

itte

e le

vel,

ther

e is

a c

om

plia

nce

ro

le t

hat

is n

eces

sary

to

en

sure

th

at t

he

feed

s av

aila

ble

to

far

mer

s co

nfo

rm t

o t

he

nat

ion

al q

ual

ity

stan

dar

ds,

an

d n

on

-co

nfo

rmin

g f

eed

s ar

e re

mo

ved

fro

m t

he

mar

ket,

it

is u

nre

alis

tic

to s

ug

ges

t th

at t

he

Peo

ple

s C

om

mit

tees

dic

tate

th

e ty

pes

of

feed

/bra

nd

s th

at f

arm

ers

sho

uld

use

.

43

Cla

use

4b

: D

irec

t g

uid

ance

on

eff

ecti

ve a

nd

en

viro

nm

enta

lly f

rien

dly

uti

lizat

ion

of

terr

estr

ial a

nd

aq

uat

ic a

nim

al f

eed

sC

urr

entl

y, m

any

feed

man

ufa

ctu

rers

pro

vid

e fa

rmer

s w

ith

gu

idan

ce o

n h

ow

bes

t to

use

th

eir

feed

pro

du

cts,

an

d m

any

farm

ers

sub

scri

be

to c

erti

fica

tio

n p

rog

ram

mes

th

at,

amo

ng

oth

er c

rite

ria,

req

uir

e fa

rmer

s to

han

dle

th

eir

feed

s in

an

en

viro

nm

enta

lly r

esp

on

sib

le m

ann

er a

nd

ob

tain

an

acc

epta

ble

FC

R. N

ever

thel

ess,

so

me

of

the

smal

ler

fam

ily f

arm

s re

po

rt

hig

her

FC

Rs

than

th

eir

cou

nte

rpar

ts i

n e

nte

rpri

se f

arm

s. I

n s

uch

cas

es,

pro

du

ctio

n o

utc

om

es a

nd

th

e en

viro

nm

enta

l im

pac

ts o

f th

eir

farm

ing

op

erat

ion

s co

uld

be

imp

rove

d t

hro

ug

h i

mp

rovi

ng

th

eir

on

-far

m f

eed

man

agem

ent

pra

ctic

es.

Wh

ile t

he

nee

d f

or

such

gu

idan

ce e

xist

s, i

t m

ay b

e ar

gu

ed t

hat

su

ch s

pec

ialis

t tr

ain

ing

wo

uld

bes

t b

e co

ord

inat

ed a

t a

nat

ion

al le

vel t

hro

ug

h M

AR

D a

nd

D-F

ish

.

Cla

use

4c:

Ad

op

t in

cen

tive

po

licie

s fo

r an

d c

om

man

d c

om

pet

ent

auth

ori

ties

wit

hin

theirjurisdictionstop

rovidefacilitationforen

terpriseslocatedw

ithintheirjurisdic

-ti

on

s to

imp

rove

ter

rest

rial

an

d a

qu

atic

an

imal

fee

d q

ual

ity

and

saf

ety

Imp

rove

men

ts t

o a

qu

afee

d q

ual

ity

and

saf

ety

req

uir

e in

vest

men

t in

new

tec

hn

olo

gie

s. A

pp

rop

riat

e fu

nd

ing

to

su

pp

ort

su

ch i

nit

iati

ves

is u

nlik

ely

to b

e av

aila

ble

at

the

leve

l o

f th

e Pe

op

les

Co

mm

itte

es.

Wh

ile R

aw M

ater

ial

Zon

es d

edic

ated

to

th

e p

rod

uct

ion

of

loca

l fe

ed i

ng

red

ien

ts t

hat

can

be

use

d i

n a

qu

afee

d h

ave

bee

n d

evel

op

ed i

n s

om

e ar

eas,

th

ey a

re

gen

eral

ly p

oo

rly

pla

nn

ed, a

nd

fee

d m

anu

fact

ure

rs u

sual

ly h

ave

to im

po

rt a

co

mp

on

ent

of

the

feed

ing

red

ien

ts r

equ

ired

to

man

ufa

ctu

re t

hei

r fe

eds.

Im

pro

vin

g t

he

effe

ctiv

enes

s o

f th

e R

aw M

ater

ials

Zo

nes

in

th

e co

un

try

req

uir

es c

han

ges

to

re

gu

lato

ry f

ram

ewo

rks

that

go

vern

tax

ince

nti

ves

and

cre

dit

pro

visi

on

. Ch

ang

es t

o t

hes

e re

gu

lati

on

s h

ave

to b

e m

ade

at

the

nat

ion

al l

evel

an

d a

re b

eyo

nd

th

e le

gal

rem

it o

f th

e Pe

op

les

Co

mm

itte

es.

The

dev

elo

pm

ent

of

ince

nti

ve p

olic

ies

is

dee

med

to

be

a n

atio

nal

go

vern

men

t re

spo

nsi

bili

ty a

nd

no

t o

ne

accr

uin

g t

o t

he

Peo

ple

s C

om

mit

tees

.



Art

icle

24.

Res

po

nsi

bili

ties

of

enti

ties

or

ind

ivid

ual

s en

gag

ed in

pro

du

ctio

n o

f te

rres

tria

l an

d a

qu

atic

an

imal

fee

ds

Cla

use

2:

Dec

lare

th

e ap

plie

d s

tan

dar

ds

and

mak

e d

ecla

rati

on

of

con

form

ity

(if

any)

w

ith

qu

alit

y st

and

ard

s o

f te

rres

tria

l an

d a

qu

atic

an

imal

fee

ds

as p

resc

rib

ed a

nd

dep

osi

t o

ne

set

of

do

cum

ents

at

thei

r o

ffic

es

Feed

qu

alit

y as

sess

men

t p

roce

du

res

are

on

ero

us,

an

d t

ake

a lo

ng

tim

e to

co

mp

ly w

ith

. C

on

sid

erat

ion

co

uld

be

giv

en t

o

sim

plif

yin

g t

he

pro

ced

ure

s.

Cla

use

4:

Car

ry o

ut

test

ing

an

d f

ile r

esu

lts

of

test

ing

raw

mat

eria

ls a

nd

fin

ish

ed f

eed

p

rod

uct

s as

a m

ann

er t

o s

atis

fy r

equ

irem

ents

fo

r in

-pro

cess

qu

alit

y co

ntr

ol

and

to

ac

cess

th

ese

resu

lts

for

the

imp

osi

tio

n o

f sa

nct

ion

s fo

r an

y fu

ture

vio

lati

on

. St

ore

tes

t re

sult

s fo

r a

du

rati

on

of

two

yea

rs a

nd

dep

osi

t an

d p

rese

rve

test

sam

ple

s fo

r a

per

iod

o

f 30

day

s af

ter

the

exp

iry

dat

e.

Wh

ile t

est

resu

lts

sho

uld

be

kep

t fo

r tw

o y

ears

, sa

mp

les

pre

serv

atio

n p

erio

ds

are

too

sh

ort

an

d t

her

e is

a c

han

ce t

hat

in

th

e ev

ent

of

pro

lon

ged

dis

pu

tes,

sam

ple

s co

uld

be

spo

iled

or

dis

po

sed

bef

ore

th

ey c

an b

e re

-tes

ted

/th

e d

isp

ute

res

olv

ed.

In t

his

reg

ard

, co

nsi

der

atio

n c

ou

ld b

e g

iven

to

pre

serv

ing

sam

ple

s fo

r a

year

. Th

e co

rolla

ry i

s th

at t

he

add

itio

nal

sto

rag

e p

erio

ds

wo

uld

incr

ease

co

sts

to t

he

man

ufa

ctu

rers

as

the

mat

eria

ls w

ill h

ave

to b

e st

ore

d f

or

lon

ger

per

iod

s. It

sh

ou

ld b

e re

cog

niz

ed t

hat

th

e cl

ause

cal

ls f

or

self

-reg

ula

tio

n o

f q

ual

ity

mo

nit

ori

ng

, an

d t

he

effi

cacy

of

such

a s

yste

m i

n e

nsu

rin

g

feed

qu

alit

y sh

ou

ld b

e co

nsi

der

ed.

In t

erm

s o

f in

dep

end

ent

test

ing

an

d m

on

ito

rin

g,

con

sid

erat

ion

sh

ou

ld b

e g

iven

to

d

evel

op

ing

an

in

dep

end

ent

nat

ion

al f

eed

an

d f

eed

in

gre

die

nt

mo

nit

ori

ng

pro

gra

mm

e in

wh

ich

go

vern

men

t ag

enci

es/

ind

epen

den

t b

od

ies

test

th

e q

ual

ity

of

the

feed

in

gre

die

nts

/fin

ish

ed p

rod

uct

s an

d h

ave

the

nec

essa

ry r

eso

urc

es/le

gal

fr

amew

ork

to

en

sure

co

mp

lian

ce.

Cla

use

8:

Pro

du

ce t

erre

stri

al a

nd

aq

uat

ic a

nim

al f

eed

s fo

r V

ietn

ames

e m

arke

ts o

nly

in

acc

ord

ance

wit

h C

hap

ter

IV h

ereo

f. (

no

te:

Ch

apte

r IV

co

nd

itio

ns

for

the

sale

of

terr

estr

ial a

nd

aq

uat

ic a

nim

al f

eed

s in

Vie

t N

am)

The

tim

e an

d c

ost

ass

oci

ated

wit

h d

evel

op

ing

new

fee

ds

are

sub

stan

tial

. Th

ese

cost

s m

ake

som

e co

mp

anie

s re

luct

ant

to

intr

od

uce

new

fee

ds

sole

ly f

or

the

Vie

tnam

ese

mar

ket.

Co

nsi

der

atio

n c

ou

ld b

e g

iven

to

incr

easi

ng

th

e sc

op

e o

f th

is c

lau

se

to in

clu

de

acce

ss t

o e

xpo

rt m

arke

ts.

Cla

use

10:

On

25th

day

of

ever

y m

on

th,

pre

par

e a

revi

ew r

epo

rt o

n m

anu

fact

uri

ng

of

terr

estr

ial

and

aq

uat

ic a

nim

al f

eed

s fo

r su

bm

issi

on

to

th

e M

inis

try

of

Ag

ricu

ltu

re a

nd

R

ura

l D

evel

op

men

t an

d a

n a

d-h

oc

rep

ort

up

on

th

e re

qu

est

of

com

pet

ent

auth

ori

ties

h

avin

g r

egu

lato

ry a

uth

ori

ty o

ver

acti

viti

es r

elat

ing

to

ter

rest

rial

an

d a

qu

atic

an

imal

fe

eds.

Prep

arin

g a

nd

su

bm

itti

ng

pro

du

ctio

n r

epo

rts

is a

n o

ner

ou

s u

nd

erta

kin

g,

and

pre

par

ing

mo

nth

ly r

epo

rts

pla

ces

a h

igh

ad

min

istr

ativ

e b

urd

en o

n t

he

feed

man

ufa

ctu

rers

. It

wo

uld

be

des

irab

le a

nd

in

dee

d m

ore

ap

pro

pri

ate

to h

ave

eith

er

six-

or

twel

ve-m

on

th r

epo

rtin

g p

erio

ds.

Co

nsi

der

atio

n s

ho

uld

be

giv

en t

o s

ub

mit

tin

g t

he

pro

du

ctio

n r

epo

rts

to p

rovi

nci

al

D-F

ish

dep

artm

ents

rat

her

th

an t

o t

he

Min

istr

y.

Art

icle

26.

Res

po

nsi

bili

ties

of

enti

ties

or

ind

ivid

ual

s u

sin

g t

erre

stri

al a

nd

aq

uat

ic a

nim

al f

eed

s

Cla

use

1: C

om

ply

wit

h t

he

go

vern

men

t re

gu

lati

on

s an

d in

stru

ctio

ns

giv

en t

o t

erre

stri

al

and

aq

uat

ic a

nim

al f

eed

su

pp

liers

fo

r tr

ansp

ort

atio

n, s

tora

ge,

co

nse

rvat

ion

an

d u

se o

f te

rres

tria

l an

d a

qu

atic

an

imal

fee

ds.

Avo

id u

sin

g p

roh

ibit

ed s

ub

stan

ces

in f

arm

an

imal

p

rod

uct

ion

sys

tem

s.

Co

mp

lian

ce t

o t

hes

e re

gu

lati

on

s is

dif

ficu

lt f

or

farm

ers

as t

he

reg

ula

tio

ns

are

com

ple

x an

d c

on

tain

ed in

var

iou

s se

par

ate

do

cum

ents

. Th

e sy

stem

s ar

e o

verl

y co

mp

lex,

an

d f

arm

ers

fin

d i

t d

iffi

cult

to

lo

cate

th

e ap

pro

pri

ate

reg

ula

tio

ns.

A s

et o

f co

mp

reh

ensi

ve g

uid

elin

es s

ho

uld

be

dev

elo

ped

to

pro

mo

te c

om

plia

nce

.

Cla

use

2:

Co

mp

ly w

ith

req

ues

ts f

or

aud

it o

r in

spec

tio

n o

f q

ual

ity

of

terr

estr

ial

and

aq

uat

ic a

nim

al f

eed

s m

ade

by

reg

ula

tors

.Fa

rmer

s ar

e th

e en

d u

sers

of

the

feed

pro

du

cts,

an

d it

is t

her

efo

re in

eve

ry o

ne’

s in

tere

sts

to e

nsu

re t

hat

th

ey r

ecei

ve g

oo

d

qu

alit

y p

rod

uct

s. I

n t

his

reg

ard

, th

ey s

ho

uld

hav

e ac

cess

to

co

st e

ffec

tive

qu

alit

y in

spec

tio

n s

yste

ms

(lab

ora

tory

ser

vice

s)

so t

hat

th

ey c

an i

nd

epen

den

tly

test

th

e q

ual

ity

of

thei

r fe

eds

(as

man

y cu

rren

tly

do

on

an

ad

ho

c b

asis

), a

nd

th

ereb

y en

sure

th

at t

hey

are

rec

eivi

ng

go

od

qu

alit

y p

rod

uct

s, o

r p

rod

uct

s th

at c

on

form

to

th

e p

urc

has

ed t

ech

nic

al s

pec

ific

atio

ns.

Incontrast,themajorfocu

sofgove

rnmen

tqualityco

mplia

ncesystemsshouldb

emonitoringthefeed

supplychains

– th

e fe

ed i

ng

red

ien

t su

pp

liers

, fe

ed m

anu

fact

ure

rs a

nd

fee

d w

ho

lesa

lers

/ret

aile

rs.

Farm

ers

nee

d g

uid

ance

on

ho

w t

o

app

rop

riat

ely

asse

ss t

he

qu

alit

y o

f th

eir

feed

s an

d t

he

tech

nic

al r

equ

irem

ents

of

the

aud

it s

yste

m.

Cla

use

4:

Kee

p a

lo

gb

oo

k th

at r

eco

rds

the

use

of

anim

al f

eed

s co

nta

inin

g a

nti

bio

tics

fo

r th

e p

urp

ose

of

anim

al d

isea

se p

reve

nti

on

an

d t

reat

men

t.

Forfarm

man

agem

entpurposes,allfeed

susedshouldbereco

ded

,notjustthosethatcontainantibiotics.T

hisisnecessary

for

asse

ssin

g f

arm

pro

du

ctiv

ity

and

sh

ou

ld b

e a

com

po

nen

t o

f st

and

ard

op

erat

ion

al p

roce

du

res.

45

Art

icle

27.

Res

po

nsi

bili

ties

of

org

aniz

atio

ns

gra

nti

ng

cer

tifi

cati

on

of

con

form

ity

in t

he

terr

estr

ial a

nd

aq

uat

ic a

nim

al f

eed

ind

ust

ries

Cla

use

1:

Ass

um

e lia

bili

ty a

nd

acc

ou

nta

bili

ty t

o t

he

app

oin

ted

en

tity

fo

r th

e re

sult

of

cert

ific

atio

n o

f co

nfo

rmit

y in

th

e te

rres

tria

l an

d a

qu

atic

an

imal

fee

d in

du

stri

es.

The

reg

ula

tio

ns

for

the

lab

ellin

g o

f aq

uaf

eed

man

ufa

ctu

red

an

d s

old

in

Vie

t N

am a

re i

n p

lace

. Im

po

rted

an

d e

xpo

rted

aq

uaf

eed

als

o r

equ

ire

pro

du

ct l

abel

ling

th

at c

an b

e u

sed

to

ass

ess

com

plia

nce

. C

urr

entl

y, t

her

e ar

e n

o r

egu

lati

on

s re

gar

din

g p

rod

uct

s th

at a

re t

rad

ed w

ith

ou

t la

bel

s o

r i

mp

ort

ed f

eed

s w

ith

lab

els

that

are

dif

ficu

lt t

o r

ead

– s

uch

as

tho

se i

n E

ng

lish

, Th

ai,

Ch

ines

e an

d A

rab

ic.

The

lan

gu

age

issu

e co

mp

licat

es c

om

plia

nce

pro

cess

es f

or

the

cert

ific

atio

n

org

aniz

atio

ns.

The

stan

dar

ds

app

lied

to

imp

ort

ing

en

terp

rise

s ar

e in

exac

t an

d d

iffi

cult

to

en

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Feed is transported to an integrated enterprise farm by a mechanized boat, Mekong Delta, Viet Nam.(©FAO/Mohammad R. Hasan)

47

SECTION 3:RECOMMENDATIONS TO IMPROVE VALUE CHAIN PERFORMANCE AND REGULATORY FRAMEWORKS

The recommendations to improve the performance of the value chain were derived from the aquafeed value chain analysis presented in Section 1 and the consultative review of Decree 39 presented in Section 2. The recommendations are technical and strategic; the technical recommendations relate to issues of feed quality and safety, feed use, efficiency and the cost of compliance and quality assurance; the strategic recommendations focus on the need to adopt policy interventions to stimulate and improve the functioning of the aquafeed value chain. A number of the recommendations should be considered when formulating the Decree’s enabling regulations.

1. Technical recommendations

a. Feed Quality and safety

1. Revisions to the National Feed Standards. The National standard for Sutchi Catfish and Tilapia (TCVN 10300:2014) are outdated and should be revised. Under Article 23 of Decree 39, MARD is the responsible agency for setting the standard. The following issues need to be addressed:

a) The standards do not reflect the nutritional requirements of the species and, in many cases, the feed manufacturers exceed the standard specifications to enhance the performance of their feeds. A technical review of the nutritional requirements of pangasius needs to be undertaken and the standard modified accordingly.

b) Feed additive listings are insufficient. While Appendix A provides a limited listing of those feed additives that are banned, it is not comprehensive. Decree 39 is conflicting in terms of both prohibiting and allowing the use of antibiotics in feeds (Article 6, clauses 5 and 6) and this conflict needs to be resolved. In some countries, selected antibiotics are registered for use in catfish culture under veterinarian supervision, and consideration could be given to allowing their use in Viet Nam under similar provisions. The revision to the feed additive listings could be based on best practice from other regions, for example, such as those of the European Register of Animal Feed Additives Pursuant to Regulation (EC) No 1831/2003 or the United States of America’s Food and Drug Administration (USFDA) or the Association of American Feed Control Officials (AAFCO) extensive registers for animal feed additives.


c) The feed label standard is outlined in Appendix B and provides limited information to adequately assess feed quality. It would be useful to revise the standard to include information relating to the ash content of the feed, and a list of all feed ingredients and feed additives used in the formulation. This additional information would improve farmers’ ability to make informed choices when buying feed.

d) A standard for broodstock conditioning feeds needs to be developed. Currently broodstock conditioning feeds are not commercially available. Developing a standard for these feeds would assist feed manufacturers in their production, and provide the broodstock farms with specialist feeds to enhance production outcomes.

e) The feed standard should be revised and updated on a regular basis to ensure that it remains relevant with recent advances in nutrition research and conforms to international best practice.

MARD is responsible for setting feed standards, and this role is enhanced by its collaboration with the research and development institutions, which are ideally placed to take a lead technical role in the revision of the standards. 2. Chapter 3 of Decree 39 calls for new animal feeds to be tested before they are licensed

for manufacture. Clarity needs to be provided with respect to the need to test all new feeds, feed additives and feed ingredients used in aquafeed. Consideration must be given to the need for government oversight in feed research, and whether feed manufacturers need to test all their new formulations or feed ingredients prior to their licensing. Animal feed testing is a lengthy and expensive process requiring significant technical skills and financing. From a technical perspective, it is arguably unnecessary to test all new feeds because adherence to a science-based National Feed Standard should be sufficient to ensure that the farmers are provided with feeds that satisfy the nutritional requirements of the cultured species. From a financial perspective, the additional costs and time taken to bring new feed formulations to market would likely deter the feed manufacturers from developing new feeds, reducing feed choices for farmers. Consideration should therefore be given to revising the feed standard and then ensuring that feed manufacturers comply with the revised standard.

3. Oversight of the quality of feed ingredients that are available to feed manufacturers should be improved. In Decree 39, Articles 15 and 16 are silent on the requirements for the inspection/monitoring of the quality of imported and locally available feed ingredients and additives used in aquafeed manufacture. While many of the larger feed manufacturers have on-site laboratories and use these to test the proximate composition of their feed ingredients, smaller feed manufacturers do not have the same facility, making it difficult and relatively expensive for them to evaluate the quality of their feed ingredients. Of significant concern is the adulteration or contamination of local and imported feed ingredients with substances such as melamine, aflatoxins, antibiotic residues, and other banned substances. Monitoring for the presence of many of these chemicals is expensive and would be beyond the technical capacity of most of the feed mills. There is some technical capacity to monitor for these chemicals at the Regional Aquaculture Surveying, Testing and Accreditation Centers, and consideration could be given to co-opting these centers to provide a screening service and, where necessary, upgrading their diagnostic capacity and providing appropriate funding for a monitoring programme.

4. Under Article 16 of Decree 39, there are provisions for the inspection of the quality of imported aquafeed to ensure that they comply with Vietnamese standards. At the request of importing countries, there are provisions for the inspection of exported feeds to the recipient country’s standards. However, there is no mention of inspection of the quality of feed ingredients and feed additives that are imported or exported. Regulations to inspect these materials should be developed.

49

5. Mortality rates of newly stocked fingerlings in the grow-out out ponds are higher than would be reasonably anticipated. This has a relatively small impact on aquafeed use (depending on when mortality occurs and how much feed has been given to that point), but it reduces production efficiencies and will manifest as reduced production and eFCRs in the grow-out systems. The high mortality rates are likely the result of physical damage and stress to the fish during transport from nursery to farm. Consideration should be given to reviewing the handling and transportation protocols to identify the critical points during transport that result in stress/damage to the fish. For example, it is likely that the fish suffer physical damage when they are moved in 70 kg dry baskets from the nursery ponds to the transport vessels. Likewise, consideration should be given to the stocking densities used in transit, water quality in the transport vessel, transport period, and the quality of the receiving waters in the grow-out ponds.

b. Efficiency and cost of compliance1. Better feed management guidelines should be developed to provide farmers with

updated guidance on how to optimize their feed use. The guidelines should address issues of on-farm feed management and describe best practices in feeding strategies (e.g. feeding to satiation vs. restricted feed practices vs. feed tables). The regulatory guidelines on the transportation, storage, conservation and use of prohibited substances that are currently described in various documents should be included. The guidelines would provide the basis for training programmes to assist farmers to improve their feed use practices. Particular attention should be given to providing training to family farmers and co-operative farmers that are currently not applying best practice. D-Fish should take the lead role in the development of the guidelines with R&D institutions providing the scientific and technical inputs. Training could be organized at the local level by the People’s Committees and conducted through a partnership among government agencies, feed manufacturers and R&D institutions.

2. Consideration could be given to revising selected provisions of Decree 39 and associated regulations to reduce compliance costs and facilitate compliance. The following are suggested:

a) To maintain appropriate technical production standards, a fish nutritionist (technical staff) should satisfy the eligibility requirements for facilities that manufacture and process feeds and for research and development organizations that are involved in feed experiments. An alternative to hiring a fish nutritionist is to engage the fish nutritionist as a consultant.

b) Some feed mills produce both terrestrial and aquatic animal feeds. There are few veterinarians with expertise in aquatic diseases so that terrestrial animal veterinary experts employed by the feed manufacturing company need to be trained in relevant aspects of fish disease prevention, control and treatment. The alternative is to hire a consultant fish health specialist.

c) The requirements to develop separate production lines for each type of terrestrial and aquatic animal feed products and those using antibiotics (Decree 39,

Article 7, 4d) is viewed as prohibitively costly by the industry. It is also technically unnecessary. While the government regulatory frameworks rightly promote the production of quality and safe feeds, the requirement for separate production lines would have minimal or no impact on maintaining the quality and safety of feeds. If the requirement is implemented the feed manufacturers should develop protocols to show how they will ensure there is no cross-contamination between feeds containing and not containing antibiotic.

Recommendations


d) Feed manufacturers are required to present an Environmental Impact Assessment (EIA) report and Environment Protection Plan (EMP) as components of their eligibility requirements to Article 7, 3. Guidelines for the development of the reports and plans need to be developed to assist the feed manufacturers and environmental practitioners to comply with the requirements.

c. On quality assurance

Article 23 of Decree 39, outlines the statutory requirements that the feed manufacturers have to comply with in terms of testing and monitoring the quality of their product. The requirements for product monitoring, testing and reporting are rigorous. While the feed manufacturers should be monitoring their product quality on a continuous basis, the regulations call for feed samples to be stored for a period of 2 years. Furthermore, reporting their testing and monitoring activities, on a monthly basis, results in a heavy administrative burden on the companies. For example it can take between 10 and 15 days to certify some aspects of feed quality. In cases where the feed quality parameters are not met, it takes additional time for the laboratory to re-test the feed. This being the case, it would be appropriate to extend the monitoring reporting period to three- or six-month intervals.

In many respects the current system calls for self-regulation of feed quality monitoring, and the efficacy of such a system in ensuring feed quality should be considered. With respect to government sponsored independent testing and monitoring, consideration could be given to developing a national feed and feed ingredient monitoring programme – this could be developed through D-Fish and the Regional Aquaculture Surveying, Testing and Accreditation Centers.

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2. Strategic recommendations

1. On incentives to encourage all socio-economic sectors’ involvement in research, training, agricultural and industrial extension and the transfer of scientific and technological advances in the nutrition, and processing of terrestrial and aquatic animal feed industry, the policy should consider appropriate forms of incentive and support, such as: •Support to research, recognition for innovations, and support for commercializing

those innovations.•Support to adaptive and on-farm research by government and the private sector

through public–private partnership ventures. •Partnerships among government regulatory and development agencies, Research

and Development institutions and feed companies in the provision of farmer training and technical advice.

•Facilitation for the registration and licensing of new products and processes.

2. On encouraging various economic sectors to take part in the development, production, exploitation and utilization of terrestrial and aquatic animal feed ingredients with incentives such as the allocation of more land and the extension of concessional credits for cultivation, harvest, storage, production, preparation and processing of domestic terrestrial and aquatic animal ingredients or materials, the policy should also consider the following incentives: •Support for commercializing an innovation; •Tax holidays and price support for locally produced feed ingredients; •Support for research on the development of local feed ingredients;•Incentives for the development of new and efficient feed formulations (regardless

of ingredients) which improves the quality of feed; and•Specific support for farmers to grow soybean as a replacement for fishmeal.

3. On the policy to encourage private sector's involvement in the improvement of the capacity for testing and certification of conformity as the basis for inspection, audit and control of quality of terrestrial and aquatic animal feeds and intensify the private sector’s involvement in public services for development of the terrestrial and aquatic animal feed industry, the policy should consider:•Support for training of technicians; •Support for the acquisition of equipment (through tax exemption or reduced

taxes);•Support for upgrading of capacities for testing and certification laboratories; •Assurance of the independence of laboratories;•Support to enable laboratories to provide affordable or even free services to small

feed makers and also farmers wishing to verify the quality of the products they purchased.

4. The Provincial People’s Committees should consider organizing multi-stakeholder consultations to develop a provincial aquafeed development plan that is in line with the national programme. They should assume a greater role in and strengthen their capacity for local enforcement of the regulations, and promotion of good practices in the manufacture, trade and utilization of aquafeed in their jurisdictions.


5. Consideration should be given to developing national associations of feed manufacturers and feed traders. At present, there are no producers or trade organizations that can represent the interests of the feed manufacturers or feed traders when interacting with government agencies or the wider aquaculture production sector. In the absence of such associations, industry Codes of Practice, that are designed to promote best practice within the sectors, have not been developed.

6. Consideration could be given to the development of a policy to support investments in technology for fishmeal processing, its commercialization, and use in aquafeed. While Viet Nam has access to low-value fish that could be used as the raw material for fishmeal production, the fishmeal production sector has a limited output.

7. A review of the crop insurance market could be undertaken, and policy and support measures developed to promote the use of insurance services. The uptake of existing aquaculture crop insurance programmes is low. As a result, farmers especially the small-scale family and cooperative farmers that have limited cash reserves, are highly vulnerable to financial risks from crop loss. The likelihood of serious losses has been exacerbated by climate change variability.

8. Policy interventions to improve access to processing capacity for small-scale farmers should be developed. Due to their relatively low level of production, small family farms and co-operatives are usually unable to negotiate processing contracts. At times, this forces them to maintain their stock for a longer period than necessary, and beyond the desired size for processing. Fish grown over the optimal size for processing are less profitable for the farmers, significantly reducing returns on farming operations.

9. In line with Viet Nam’s policy on environmental and biodiversity conservation, provisions need to be included on the development of a traceability mechanism and certification scheme to assure that fish-based materials (fishmeal and fish oil) are not sourced from illegal fishing or over-exploited fishery resources.

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References

Agrolife. 2017. Vietnam. Oilseeds and Products. Annual 2017. https://www.agrochart.com/en/news/6325/vietnam-oilseeds-and-products-annual-2017.html

D-Fish. 2015. Report of work plan 2014 and key direction, solution for the work plan 2015 (in Vietnamese) 16 pp.

De Silva, S.S. & Nguyen, T.P. 2011. Striped catfish farming in the Mekong Delta, Vietnam: a tumultuous path to a global success. Reviews in Aquaculture 3: 45–73.

Duong, H.T., Ly, T.M. & Nguyen, T.P. 2011. Effects of restricted and alternative feeding methods on the growth of the striped catfish (Pangasianodon hypophthalmus) fingerlings. In T.P. Nguyen, Q.P. Truong and T.T.H. Tran, eds. Proceedings of the 4th Aquaculture and Fisheries Conference, pp. 178–190. Can Tho, Viet Nam, Can Tho University. 543 pp. (In Vietnamese).

Glencross, B. Tran, T.T.H, Nguyen, T.P. & Tran, L.C.T. 2010. A factorial approach to defining the energy and protein requirement of tra catfish, Pangasianodon hypophthalmus. Aquaculture Nutrition, 17(2): 398–405.

Kim Quyen, N.K., Berg, H., Gallardo, W. & Thi Da, C. 2017. Stakeholders’ perceptions of ecosystem services and Pangasius catfish farming development along the Hau River in the Mekong Delta, Vietnam. Ecosystem Services, 25: 2–14.

Lam, T.P., Tam, B.M., Thuy, T.T.N., Gooley, G.J., Ingram, B.A., Hao, N.V., Phuong, N.T. & De Silva, S.S. 2009. Current status of farming practices of striped catfish, Pangasianodon hypophthalmus in the Mekong Delta, Vietnam. Aquaculture, 296 (3–4): 185–382

Lovell, R.J. 2019. Identifying alternative wetting and drying (AWD) adoption in the Vietnamese Mekong river delta: A change direction approach. ISPRS International Journal of Geo-Information, 8(7), 312; https://doi.org/10.3390/ijgi8070312

Nguyen, T.P. 2013. On-farm feed management practices for striped catfish (Pangasianodon hypophthalmus) in Mekong River Delta, Viet Nam. In M.R. Hasan & M.B. New, eds. On-farm feeding and feed management in aquaculture, pp. 241– 267. FAO Fisheries and Aquaculture Technical Paper No. 583. Rome, FAO. 585 pp.

Nguyen, T.P., Sinh, L.X., Thinh, N.Q., Chau, H.H., Anh, C.T. & Hau, N.M. 2007. Economics of aquaculture feeding practices: Viet Nam. In M.R. Hasan, ed. Economics of aquaculture feeding practices in selected Asian countries, pp. 183–205. FAO Fisheries Technical Paper No. 505. Rome, FAO. 205 pp.

Piesse, J. & Thirtle. C. 2009. Three bubbles and a panic: an explanatory review of recent food commodity price events. Food Policy, 34(2): 119–129.

Rola, W.R. & Hasan, M.R. 2007. Economics of aquaculture feeding practices: a synthesis of case studies undertaken in six Asian countries. In M.R. Hasan, ed. Economics of aquaculture feeding practices in selected Asian countries, pp. 1–31. FAO Fisheries Technical Paper No. 505. Rome, FAO. 205 pp.

Tran, V.N. 2005. Evaluation of the use of locally available feedstuffs for catfish (Pangasianodon hypophthalmus) cage culture in An Giang province. MA thesis. Can Tho, College of Aquaculture and Fisheries, Can Tho University. 79 pp. (In Vietnamese).

Tran, Q. 2017. Vietnam - Grain and Feed Annual 2017. Global Agricultural Information Network. GAIN Report Number: VM7016. April, 2017. https://gain.fas.usda.gov/Recent%20GAIN%20Publications/Grain%20and%20Feed%20Annual_Hanoi_Vietnam_4-13-2017.pdf

https://doi.org/10.3390/ijgi8070312

https://gain.fas.usda.gov/Recent%20GAIN%20Publications/Grain%20and%20Feed%20Annual_Hanoi_Vietnam_4-13-2017.pdf



An intensive catfish pond with fishcoming to the surface during feeding, Mekong Delta, Viet Nam.(©FAO/Thomas A. Shipton)

55

APPENDIX ACompound feed for sutchi catfish and tilapia: TCVN 10300:2014

Banned substances (chemicals, antibiotics) in compound feeds for sutchi catfish and tilapia

1. Aristolochia spp and their products2. Chloramphenicol3. Chloroform4. Chlorpromazine5. Colchicine6. Dapsone7. Dimetridazole8. Metronidazole9. Nitrofuran (including Furazolidone)10. Ronidazole11. Green Malachite (Xanh Malachite)12. Ipronidazole13. Other Nitroimidazoles14. Clenbuterol15. Diethylstilbestrol (DES)16. Glycopeptides17. Trichlorfon (Dipterex)18. Gentian Violet (Crystal violet)19. Fluoroquinolones (banned in production and trading of seafood for export to

USA and North America)20. Cypermethrin21. Deltamethrin22. Enrofloxacin

Harvest of striped catfish in small-scale catfish farm, Mekong Delta, Viet Nam.(©FAO/T.P. Nguyen)

57

APPENDIX B Compound feed for sutchi catfish and tilapia: TCVN 10300:2014

Items to be presented on a label

1. Name of product “compound feeds for shutchi catfish” or “compound feeds for tilapia”

2. Quantity (net weight).3. Name, address, telephone number of the manufacturer and manufacturing

location4. Standard declared.5. Number for different stages and sizes.6. Batch number, manufacturing date.7. Expiry date.8. Storage conditions.9. Maximum moisture (%).10. Minimum crude protein (%).11. Min-max total fat content (%).12. Ethoxyquin (ppm).13. Maximum crude fibre content (%).14. Min-max calcium content (%).15. Min-max total Phosphorous content (%).16. Minimum total Lysine content (%).17. Minimum total Methionine + Cystine content (%).18. Antibiotics: none.19. Main ingredients.20. “Contain no substances banned in relevant regulations”.21. Notes (if any).

Harvested catfish are transported from an enterprise farm to the processing Centre, Mekong Delta, Viet Nam.(©FAO/Mohammad R. Hasan)

Viet Nam’s current production of some 1.2 million tonnesof striped (pangasius) catfish is 30 percent of its total aquaculture output;

much of it is exported to 140 countries. By 2020, the value of the sector is expected to reach USD2.0 billion a year. Among several technological improvements,its growth in previous years has primarily been contributed by quality feed.

But growth has stabilized. To give it another boost that ensures a responsible feed manufacturing and distribution sector, responsible feeding practices, and

an equitable sharing of the additional benefits from increased productivity throughout the value chain, the Government deemed it necessary to further

improve the performance of the feed value chain. The actors in the value chain comprise input suppliers, including feed ingredients suppliers, feed manufacturers,

hatchery operators (seed producers), fingerling and grow-out farmers,processors, exporters, consumers and service providers.Regulation in feeds — defined by Decree 39/2017/ND-CP

“Providing the regulatory framework for terrestrial and aquatic animal feeds” — was reviewed. The combined studies suggested recommendations to improve

value-chain functioning. Substantive revisions were also made on some provisions of the Decree to improve enforcement or facilitate compliance or both.

Measures were outlined to simplify pprocedures that would reduce cost of regulation, facilitate the production of new feeds, and improve the ability

of the regulated to comply.

CA7177EN/1/12.19

ISBN 978-92-5-132004-4 ISSN 2070-7010

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Documents

Aquafeed value chain analysis and a review of regulatory ... · technology and high-quality production inputs. In 2014, annual production of pangasius was 1 143 797 tonnes. The key