WORLD TRADE  
ORGANIZATION  G/SPS/GEN/791 
4 July 2007 
 (07-2852) 
Committee on Sanitary a nd Phytosanitary Measures Original:   English 
  
AUSTRALIA'S REVISED IMPORT RISK ANALYSIS AND MEASURES  
ON PRAWNS AND PRAWN PRODUCTS 
 
Statement by Vietnam at the meeting of 27-28 June 2007
 
  
 The following communication, received on 27 June 2007, is being circulated at the request of 
the Delegation of Vietnam.  
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1. The fishery industry, especially prawn culture, plays an important role in Vietnam’s economy.  
Statistically, Vietnam has approximately 4 million labourers depending on the fishery industry, 50 per 
cent of whom are involved in the prawn production chain (manufacturing feed for prawn, prawn culture, processing and other related logistics servi ces).  A lot of farmers have escaped from poverty 
and their living standards have  gradually been improved. 
2. Vietnam’s prawns and the products ther eof, especially black tiger prawns ( Penaeus monodon) 
are of high quality because Vietnam has a well-organi zed system of food safety control.  Our system 
of aquatic animal disease control in general, and for prawns in particular, is also very good.  In 2006, 
prawn products of Vietnam were exported to more than 90 countries and territories worldwide, especially to markets with high demands for food safety and disease control su ch as the United States, 
Japan and the European Communities. 
3. Until now, Vietnam has not received any indicatio ns of the spread of disease from Vietnam's 
and Asia’s prawns to importing countries, includi ng Australia.  Therefore, Vietnam is concerned 
about the strict quarantine measures in the draft IRA delivered by the Australian competent authority.   
4. Upon receipt of the draft IRA, we conducted research, as well as collected opinions from 
experts and scientists, including international on es (from NACA and SEAFDEC).  After that, we sent 
our comments to the Australian competent aut hority (official letter No. 412/CLTY-TY dated 
13 February 2007). 
5. At this meeting of the SPS Committee, we would like to reiterate our comment that the draft 
IRA consists of many evaluations which lack  science-based evidence, including the following: 
6. The disease situation of prawns is different from country-to-country, so the requirement of the 
IRA to apply the same risk analysis for all pr awns imported from differe nt countries is not 
appropriate.  Out of the 5 diseases which the IRA stat ed need to be controlled (Taura syndrome virus 
(TSV), Infectious hypodermal and haematopoi etic necrosis virus (IHHNV), Necrotising 
hepatopancreatis bacterium (NHPB), White s pot syndrome virus (WSSV) and Yellowhead virus 
(YHV)), it is reported that TSV, IHHNV, NHPB diseases have not yet occurred in Vietnam.  Yearly 
statistics on prawn disease monitoring shows that on ly Gill Associated Virus (GAVs) was recorded, 
not YHV.  That is why Biosecurity Australia should carry out independent risk assessments, 
especially for prawns imported from each country (a ccording to the OIE guidelines and in line with G/SPS/GEN/791 
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  the situation of each country), in order to set up the appropriate risk management measures for each 
exporting country. 
7. The claim that "Australian strain of IHHNV is likely related to Indian Ocean strain, 
considered to be less virulent to penaeids than the Philippines strain which is appearing in other 
countries" is not convincing and lacks sufficient scientific evidence. 
8. For NHPB, the causative agent h as not yet been identified, therefore, the application of 
intensified quarantine measures based on import risk for the disease is not feasible.   
9. We should recognize that WSSV and YHV diseases have occurred for more than a decade in 
prawn-culture countries, including China, Thailand, Vietnam, Indonesia and the Philippines.  Australia has imported brackish prawns from these countries for a long time and since 2001, Australia 
has applied strict quarantine measures (such as impo rt prawn size must be larger than 15gr/piece, 
certificates issued by co mpetent authority of exporting country certifying "non-early harvest" and non 
WSSV and YHV clinical signs).  Biosecurity Austra lia has confirmed that WSSV and YHV have not  
occurred in Australia for the past six years. The above-mentioned facts prove that the current 
quarantine measures applied in Australia are efficien t enough to prevent the entry and spread of these 
exotic diseases.  On the other hand, the prevention of dangerous diseases such as WSSV, YHV and 
TSV in Southeast Asian countries has improved signifi cantly, which leads to the fact that the risk of 
dangerous diseases being transmitted through imported prawns into Australia is now lower than 
before and the strict quarantine measures as pr oposed in the draft report are not necessary. 
10. Prawns in Southeast Asia are raised mainly for export to Australia as food and this is clearly 
stated in the documents attached to the consignmen ts or on the labels of products.  The Australian 
Competent Authorities are responsible for post-arriva l food inspection to prevent the misuse of these 
imported food prawns as bait or raw feed in hatc heries.  Australia should tighten its post-arrival 
controls in order to minimize effectively the above a buse instead of intensifying application of strict 
control measures on imported consignments. 
11. Australia intends to test 100% of imported prawn consignments for WSSV and YHV by 
OIE’s updated method.  This is not necessary because: 
(a) The Polymerase chain reaction (PCR) cannot distinguish infective dose from non-
infective doses, nor can it distinguish activ e from non-activated viruses.  For instance, 
cooking always inactivates these viruses, yet a cooked prawn can record a positive 
PCR test.  Such a test is not able to make the distinction between live and dead 
viruses.  Therefore, Australia does not allow the importation of consignments 
containing inactive viruses that are not able to transmit disease. 
(b) Sampling of imported prawns is not representa tive for all consignments, is inefficient 
as a tool for prevention of entry of exotic  diseases and is expensive.  The waiting time 
for test results also causes difficulties for exporters and importers. 
12. We strongly support and agree with Thailand's and China's comments on the Draft IRA, as 
well as with the Singapore Industrial Automation Asso ciation (SIAA), Vietnam Fisheries Association 
(VINAFIS) and  Vietnam Association of Seafood Ex porters and Producers (VASEP).  We would also 
like to emphasize some opinions from th e above-mentioned comments as follows:  
(a) The risk management measures lack scien ce-based evidence and statistics.  For 
instance, all un-cooked products are supposed to have high disease risks.  This view 
is not correct because products from headl ess prawns have much lower disease risks 
than those from whole prawns.  G/SPS/GEN/791 
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  (b) In the Biosecurity Policy Memorandum 2001/06 of  Australia, it is stated that the post-
arrival control measures need to be applied as a supporting tool for pre-arrival control 
measures to facilitate trade development, but the measures mentioned in the Draft 
IRA report run contrary to this statement. 
Conclusion 
 
13. Based on the above comments, we would like to  propose that the Australian Government  
maintain the measures to control diseases of brackis h prawns imported into Australia which have 
proven to be effective since 2001. 
14. The risks analysis of Biosecurity  Australia which lead to the ex tremely strict control measures 
mentioned in the draft IRA was not based on scien tific evidence and the real situation of prawn 
exporting countries and Australia. We have the sense th at this is a kind of trade barrier under the form 
of an SPS measure and obviously it does not conform to the WTO SPS Agreement. 
15. We are concerned that the application of the quarantine measures identified in the draft  IRA 
on imported prawns and prawn produc ts will not only affect the rights of Australian consumers but 
also stakeholders involved in im porting and distributing imported pr awns in Australia, as well as 
millions of prawn farmers in Asia  in general and hundreds of thousands of prawn farmers in Vietnam 
in particular. 
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