February 13, 2019
We are disappointed to report that USDA APHIS has notified some stakeholders that it considers Vietnam’s zero tolerance for CT seeds to be justified and APHIS will be taking action effective March 1, 2019 not to issue phytosanitary sanitary certifications for consignments of wheat and soybeans from the U.S. if a yet to be defined APHIS regime detects the presence of CT. Moreover, the APHIS action will not prevent Vietnam from taking any action at import – including continuing to visually inspect consignment shipments upon arrival, and to require reexport if Canadian thistle is detected. As a result, USDA APHIS and Vietnam’s Plant Protection Department (VN PPD) will be using a zero-tolerance approach to CT in wheat and soybean shipments.
Over two weeks after a bilateral meeting in Vietnam between USDA APHIS and VN PPD ended, we were quite surprised and disappointed to learn that, during the January 23 -24 talks, APHIS acquiesced to the Vietnamese position that, based on what APHIS said were controlled laboratory (greenhouse) experiments conducted by Vietnam, CT seeds are capable of propagating in Vietnam’s climate. Based upon this outcome and without any evidence of exposure or consideration for management of risk to Vietnam’s agriculture, APHIS has conceded that Vietnam’s zero tolerance for CT seeds is justified and shall result in APHIS action not to issue phytosanitary sanitary certifications for consignments of wheat and soybeans from the U.S. if a yet-to-be-defined APHIS regime detects the presence of Canadian thistle in U.S. export shipments of wheat and soybeans to Vietnam. USDA APHIS said it had written to Vietnam stating the understanding that the certificate issuance requirement to be imposed by APHIS will apply to vessels loaded on or after March 1, not to shipments en-route on or before that date and has not received a contrary response from Vietnam. PLEASE NOTE: The agreement codified by the APHIS communication with Vietnam’s Plant Protection Division (VN PPD) does not prevent Vietnam from taking any action at import – including continuing to visually inspect consignment shipments upon arrival, and to require reexport if Canadian thistle is detected.
A detailed and updated reporting, including discussion actions exporters as well as NAEGA might take can be found here.