Resolution 36 shifts to self-declaration, post-inspection model

Connecting to national database

Under the new regulation, for organizations and individuals not registering to export to markets that require production unit or packing-facility codes, chairpersons of commune-level People's Committees must issue notification of a production unit code or packing-facility code within no more than three working days of receiving a complete application. If a code is not issued, the competent authority must respond in writing with a clear explanation.

For applicants registering to export to markets that do require such codes, the processing period is capped at 10 working days. During this window, the commune-level People's Committee inspects compliance with the importing country's technical requirements before issuing the code notification or proceeding to further steps if the importing market requires formal approval.

Beyond shortening processing times, Resolution 36/2026/NQ-CP also simplifies how the procedure is carried out.

Rather than going through multiple intermediary bodies, organizations and individuals now submit code-application dossiers directly to the commune-level People's Committee where the growing area or packing facility is located, via the National Public Service Portal. If the system experiences technical issues or an applicant is unable to submit electronically, localities will still accept paper applications and update them into the system once the portal is back online.

Another new feature is greater flexibility in defining growing areas. Plot location is determined based on the identification code in the national land database. However, if a plot does not yet have an identification code, or the code cannot yet be retrieved, the applicant may self-declare the area and location. The commune-level People's Committee chairperson will then direct verification of this information during on-site inspection or post-issuance review.

The resolution also clarifies that a production unit code is issued for a single, specified crop tied to the location of one or more land plots, and does not establish or replace an organization's or individual's land-use rights. At the same time, the resolution encourages organizations, individuals, cooperatives, and cooperative groups to link production together to form large-scale, concentrated growing areas eligible for a production unit code.

For growing areas or packing facilities that have already been issued a code, the resolution adds a provision allowing registration for additional export markets while retaining the code originally issued. In cases involving a change of the representative organization or individual's name, or a change in administrative boundaries, reissuance must be resolved within two working days of receiving the application.

Another significant change is that data on production unit codes and packing-facility codes will be centrally managed within a database system run by the Ministry of Agriculture and Environment, and linked to the agricultural product traceability system and other databases as prescribed. Localities are responsible for publicly disclosing the operating status of each code, active, pending approval, suspended, or revoked, so organizations and individuals can look it up.

Management requirements not being loosened

The resolution stipulates that code issuance and management will follow the principle of self-declaration and self-accountability by organizations and individuals, with state agencies shifting their focus toward post-inspection, monitoring, oversight, violation handling, and traceability. Pre-inspection will only apply in cases where the importing country requires a production unit code or packing-facility code.

For codes issued under the streamlined process, the commune-level People's Committee must carry out post-issuance inspection within a maximum of three months from the date of issuance. Applicants are legally responsible for the completeness, accuracy, and truthfulness of the information declared in their applications.

Growing-area and packing-facility codes that were issued, approved, or converted before Resolution 36 took effect will continue to be used in their existing format.

Technical requirements for export continue to be implemented in accordance with international treaties, agreements, protocols, or the official requirements of the importing country's competent authority; these requirements do not trigger a renewed domestic code-issuance procedure.

The procedural simplification comes amid growing demand for production unit code management. According to the Plant Production and Protection Department, from the implementation of Decree 38/2026/ND-CP through July 15, the country has issued 481 production unit codes and 349 packing-facility codes to support exports of products such as pomelo, mango, jackfruit, dragon fruit, banana, coconut, and durian to markets including China, the United States, South Korea, the EU, New Zealand, and others.

In addition, the department has reviewed and cut numerous administrative procedures, reducing processing time by 47 percent and compliance costs by 34 percent for procedures in the crop production and plant protection sector. Resolution 36 on production unit codes is regarded as a further step in this trajectory, continuing to decentralize authority, digitize procedures, and shift management firmly from pre-inspection toward post-inspection.