The provisions include:
* suspending the export license of a firm that is found to have caused a rejection in a foreign market
* limiting soaking and moisture content of pangasius fillets to 83%, which is well below current practice
* requiring exporters purchase from approved farms, beginning January 2016.
It is unclear how enforcement will occur, and at what level.
One impact will be on treatments with phosphates to retain moisture.
The
new law specifies an acceptable moisture level of no greater than 83%.
At present, most product coming into the US has moisture levels of 84%
to 86%, with some even higher. A common spec is for 85% moisture +/- 1%.
83%
is close to the natural moisture level of pangasius, and it is now
known how much natural variation may push a fish over this limit at
particular times.
Soaking fish has a dramatic impact on price, as
it can substantially change the pounds sold from a given level of raw
material. The same calculation impacts scallop prices as well.
For
example, a packer with 100 pounds of natural fillets containing 83%
moisture could soak this fish to increase the weight to 120 pounds. That
means that 20 pounds of water was added to the 83 pounds of existing
moisture, giving a product with total moisture of 103 pounds, and total
solids – proteins, fats etc, of 17 pounds. This would test out at a
moisture level of 103/120 or 86%.
If the government successfully
enforced an 83% moisture level, it would be similar to the Canadian
requirement that prohibits adding moisture to scallops, and results in a
substantial price difference between "dry”and wet scallops.
In
the above example, it would mean the packer has 20% less product to sell
at the current market price, so presumably they would attempt to
increase their prices to compensate.
The new law will require
certification of all farms to VietGAP standards,or an acceptable
international standard. Processing factories will have to have full
traceability.
The law also limits glazing to 10%, except where
the regulations of importing countries have a different standard either
higher or lower.
The label will have to include net weight, glazing percentage, and the name of any chemical additive used during processing.
Finally, the law provides that the government can suspend the export license for any trader who violates these regulations.