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Remove black pepper from the list of conditional exports and not subject to risk management

22 July 2021

According to Official Letter No. 31/CV-VPA dated 12/07/2021 of the Vietnam Pepper Association sent to the General Department of Customs about some pepper exporting enterprises reflecting the classification of inspection declarations for pepper products. black export. Reports of some enterprises recently said that the rate of declaration of gold flow has increased from 8% to 60% and mainly concentrates on black pepper products . This has increased cost pressure for businesses and potential risks of Covid-19 exposure during travel to process customs declarations.On July 21, 2021, the General Department of Customs responded to the Association's complaint according to Official Letter No. 173/QLRR-P3 . old, pepper is currently on the list of conditional exports inspection, and the customs authority must conduct according to specialized management documents. In case it is determined that the exporter of pepper is a medicinal material not used for medicinal purposes according to Article 2 of Circular No. 03/2021/TT-BYT of the Ministry of Health, the customs authority shall carry out customs clearance on the system. ensure convenience for businesses.

Circular No. 37/2018/TT-BNNPTNT of the Ministry of Agriculture and Rural Development dated December 25, 2018 promulgating the list of national key agricultural products, of which pepper is one of 13 key commodities. included in the list . specifically, according to the General Department of Vietnam Customs, in 2020, Vietnam exports 285,000 tons of pepper to more than 110 countries around the world, with a total export turnover of 660 million USD. In the first 6 months of 2021, Vietnam exported 154,000 tons, export turnover reached 497 million USD, compared to the same period last year, the export volume decreased by 7.5% but the turnover increased by 39.8%. According to statistics of the Vietnam Pepper Association,the percentage of exported black pepper products (HS code 0904.11.20) accounts for 80% of the total export volume of Vietnam's pepper.  (the remaining items include: ground black pepper, white pepper, ground white pepper, pickled pepper, etc.), which are exported by enterprises in the form of pepper.

Circular No. 03/2021/TT-BYT dated March 4, 2021 on the removal of a number of items listed in Appendix 1 issued together with Circular No. 48/2018/TT-BYT, including pepper.  (HS code 0904.11.20).  Also in Article 2 of Circular 03 stipulates: “In case the exported or imported goods specified in the Appendix issued together with this Circular are used for the purpose of making drugs and medicinal ingredients, the following provisions shall apply. provisions of legal documents on pharmacy”. However, currently exported black pepper is a common agricultural export commodity mainly used as a spice in food processing in the import market. .Although pepper is used as a medicine, the import markets set very strict standards for medicinal products while so far no Vietnamese enterprises have met them. Black pepper is used as a medicine, currently only used in Vietnam through traditional medicine and accounts for an extremely small percentage. In addition, Vietnamese pepper exporters do not have a pharmaceutical business function, but only register for import and export business of agricultural products.

From the above information, the Vietnam Pepper Association respectfully requests the Ministry of Health to consider removing black pepper (HS code 0904.11.20) from the list of conditional export and not subject to risk management. Risks in the division of inspection channels of the Customs to create favorable conditions for enterprises to export pepper. In case the enterprise's request is not considered, the Glass Association proposes the Ministry of Health to provide specific instructions on documentation procedures in certifying that the enterprise's exported pepper is not for medicinal purposes and raw materials. medicine for enterprises to submit to the customs office as Instruction.



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