Lobster exporters to China must secure official approval

Tightening food safety requirements and import market conditions

At the conference on “Sustainable Development of Lobster Farming and Consumption” held in Khanh Hoa province on the morning of August 8, Le Ngoc Can, Head of the Quality and Food Safety Division under Regional Quality, Processing and Market Development Center No. 3 (NAFIQPM), said that Vietnam’s exports of live aquatic products are currently subject to an increasingly stringent system of legal regulations.

Specifically, Vietnam’s domestic regulations include the Law on Food Safety No. 55/2010/QH12, Decree No. 15/2018/ND-CP, Decree No. 115/2018/ND-CP, Decree No. 124/2021/ND-CP, Circular No. 17/2018/TT-BNNPTNT and Circular No. 17/2021/TT-BNNPTNT. Notably, Circular No. 80/2025/TT-BNNMT, issued on December 31, 2025, on the inspection and certification of food safety for exported fishery products, officially took effect on February 2, 2026, providing an important legal foundation for the entire supply chain.

On the importing-market side, China has introduced a range of stringent requirements, including the amended 2015 Food Safety Law; national standards governing food safety, microbiological and chemical requirements for different products; Order No. 249, which sets out measures for the administration of food safety in imports and exports; and the Wildlife Protection Law.

Of particular note, Announcement No. 219/2025, effective from December 15, 2025, requires foreign enterprises exporting agricultural products to China to comply with declaration and registration requirements. In addition, China’s Decree No. 280, issued on October 14, 2025 and effective from June 1, 2026, replaced Order No. 248 on the registration and administration of overseas manufacturers of imported food. This is complemented by Announcement No. 27, issued on March 18, 2026, which provides detailed guidance on implementing Decree No. 280.

For Vietnam’s live aquatic products to be cleared for entry into the Chinese market, production and export packing facilities must undergo inspection and certification of their food safety conditions and be included on the list of establishments approved by the competent Chinese authorities. Each export shipment is subject to mandatory inspection and must be accompanied by a certificate issued by NAFIQPM in the prescribed format. In addition, the products must belong to the list of 48 live aquatic animal species approved by China for import and must complete the registration procedures required under Announcement No. 219/2025.

With regard to spiny lobsters, China classified the species as a Category II endangered animal on February 1, 2021, and officially banned their capture as of May 2023 under the Wildlife Protection Law. Under current regulations, farmed spiny lobster must be produced through at least the F2 generation of breeding stock rather than being directly harvested from the wild.

Cases in which the broodstock is sourced from the wild are still considered wild-caught lobster. In such cases, Chinese importers must obtain a permit from the Fisheries Bureau under China’s Ministry of Agriculture before the products can be legally imported.

As of August 2026, the country has 84 live aquatic product packing facilities on China’s list of establishments approved for export. China currently accounts for 98-99% of Vietnam’s total live aquatic product exports, while other markets such as Thailand, Singapore, Hong Kong and Taiwan account for only 1-2%.

In the area managed by the Regional Quality Center No. 3, 30 packing facilities are currently on China’s approved list, including 27 facilities in Khanh Hoa and three in Dak Lak. The main exported products are green spiny lobster and spotted Babylon snail.

Coordinated solutions

To strengthen controls and ensure the sustainability of the supply chain, the Regional Quality Center conducts inspections and monitors establishments involved in the collection, storage, packing, transportation and export of live aquatic products. The center focuses on assessing the development of production linkages and coordinates the review and cross-checking of declarations concerning farming establishments and the origin of raw materials.

Post-inspection monitoring of export shipments has also been strengthened, alongside the establishment of a database on farming areas, including information on names, addresses, areas, production volumes and farmed species, to support verification. Violations involving inaccurate declarations, untraceable origins or unreliable documentation will be strictly handled, with establishments proposed for removal from the list of approved exporters.

For live aquatic product and chilled seafood packing facilities involved in exports, full compliance with the requirements set out in Appendix VII of Circular No. 80/2025/TT-BNNMT is mandatory. Businesses must maintain complete supporting documentation for their production linkages, including commitments from farming establishments certified by commune-level authorities, contracts and harvest records.

Businesses should proactively review their HACCP-based quality management programs to strengthen controls over chemical residues, antibiotics and heavy metals, while adjusting the frequency of verification sampling prior to export. They are also responsible for supporting farmers in maintaining production logs, coordinating with the Regional Quality Center to update information on the number of cages and ponds, as well as expected output, and jointly organizing training courses on food safety and disease prevention and control.

For farming establishments, raw-material agents and intermediaries, the requirements include proactively reviewing facility conditions, registering for certification of farming-area codes, and maintaining complete farming records covering seed stock, feed, veterinary medicines and disease-control products through to sale. All parties involved are required to cooperate in verifying information on farming areas when products are sold, assume legal responsibility for the accuracy of declared data, and retain all relevant supporting documents.

At the local level, commune- and ward-level authorities play a key role in strengthening training, inspection and supervision of farming establishments in their respective areas, particularly in handling violations. Local authorities should support farmers in signing commitments to safe food production and trading in accordance with Circular No. 17/2018/TT-BNNPTNT, while working closely with the Regional Quality Center to review and verify the information contained in these commitments, ensuring transparency and facilitating traceability.

To meet market requirements, every stage of the supply chain from farming, harvesting, collection and transportation to packing and export, must be subject to strict controls covering production planning, farming-area codes, water quality, feed, veterinary medicines, packaging, labeling and traceability.