G/SPS/GEN/1788  
 
12 June  2020 
(20-4179) Page: 1/2 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
 
CIRCULAR NO. 04/2020 /TT-BNNPTNT "NATIONA L TECHNICAL REGULATI ON, 
ANIMAL  FEEDS - MAXIMUM ALLO WABLE LIMITS OF SAFE TY INDICATORS IN ANI MAL 
FEEDS AND INGREDIENT S FOR PRODUCTION OF AQUATIC FEEDS "; DECREE 13/2020 
"DETAILING THE LAW O N ANIMAL HUSBANDRY"  
SUBMISSION FROM  THE UNITED STATES  OF AMERICA  
The following document , received on 12 June  2020, is being circulated at the request of the 
delegation of the United States . 
 
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1  VIETNAM 'S MEASURES FOR FEED AND FEED INGREDIENTS : NATION AL TECHNICAL 
REGULATIONS AND CERT IFICATE OF FREE SALE  
1.1.  At the outset, we thank Vietnam for our bilateral engagement to date on its new testing  and 
certification requirements on imported feed and feed ingredients for livestock and aquatic animals.  
1.2.  However, t he United States remains concerned regarding the requirements contained in 
Vietnam 's Circular 4/2020 promulgating National Technical Regulation (NTR) 190:2020 – Maximum 
Allowable Levels (MLs) of Safety Indicators in Animal Feed and Feed Ingredients.  
1.3.  We are also concerned about Vietnam 's Decree 13/2020, detailing the Animal Husbandry Law 
and Certificate of Free Sale (CFS) requirement for feed and feed ingredients.  
1.4.  Vietnam issued these measures in January and March 2020, respectively.  Yet, Vietnam has not 
notified these measures to WTO Members.  
1.5.  The United States understands that this NTR Circular will require examinations of imported 
animal feed and feed ingredients for compliance with MLs for several microorganisms, heavy metals, 
and mycotoxins, beginning  July 1, 2020.  Imports subject to testing would include products intended 
for animal or aquaculture feed, such as cereal grains, rice, wheat, corn, oilseeds, cotton seeds, and 
additional agricultural products.  
1.6.  The United States notes that the NTR Circular  sets a zero -tolerance policy for Salmonella , with 
no distinction for serotype, as well as for Escherichia coli , and renews MLs for heavy metals and 
mycotoxins in feed ingredients.  
1.7.  Decree 13/2020 requires that imported animal feeds and feed ingredients, in cluding corn, rice, 
wheat, soybeans, and additional agricultural products, be accompanied by a Certificate of Free Sale 
for registration of quality examination prior to arrival of shipments.  The United States notes that 
Vietnam has suspended Decree 13/2020  until further notice.  
1.8.  We anticipate that both the NTR Circular and Decree, if implemented, would create significant 
trade disruptions for Members that export feed and feed ingredients to Vietnam.  
1.9.  We request that Vietnam notify these measures to the WTO SP S and TBT Committees and 
allow for comments and consultations from Vietnam 's trading partners and take such comments into 
account in finalizing the measures.  G/SPS/GEN/1788  
 
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  1.10.   We also request that Vietnam delay implementation of the NTR Circular until 2021, to allow 
sufficient time for exchange of technical information regarding sampling, testing, and corrective 
procedures, as well as time to discuss an assessment of risk and he alth concern for each ML.  
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