viet nams market access requirements for white offals in march 2018 the united states raised concerns regarding viet nams market access requirement for white offals. the united states noted that viet nam had signed a letter of agreement with the united states in 2006 as part of its wto accession accepting the export certificate issued by the usda fsis as proof that its exported meat and poultry products had been inspected and passed by fsis. however since the implementation of circular 25 in 2011 us exporters now faced a burdensome administrative process due to the requirement for meat poultry and fishery establishments to submit a questionnaire for subsequent approval by viet nams national agro-forestry-fisheries quality assurance department nafiqad in order to be eligible to export to viet nam. the united states indicated that its understanding of the circular 25 approach was that viet nam would accept and review questionnaires on an ongoing basis and that as fsis inspected and passed new establishments viet nam would add these facilities to its list of entities eligible to export to viet nam. instead the united states noted that viet nam had appeared to institute a process of registration of individual facilities rather than focusing on the overall effectiveness of the fsis inspection and certification system. such an approach was contrary to codex guidelines which stated that the importing country should evaluate the effectiveness of the inspection and certification system of the exporting country rather than engage in an establishment by establishment approach. the united states observed that the regulation had created uncertainty for market access and had stalled the addition of new establishments and the flow of exports to viet nam. in addition there had been changes in the administrative responsibility for the implementation of circular 25 which had resulted in extensive delays in the reopening of viet nams market. the united states acknowledged the bilateral engagements with viet nam and urged viet nam to resolve the issue expeditiously. new zealand shared the concern raised by the united states in particular as it related to the consistency of the regulation with codex guidelines on evaluating the effectiveness of the inspection and certification system of the exporting country. new zealand also noted that its exporters faced similar issues to those reported by the united states. viet nam explained that during the visit of its inspection team to the united states in 2014 several instances of non-compliance had been identified in some us establishments. viet nam indicated that it had informed the united states of these issues and had also temporarily halted the addition of new registrations until the corrective and preventive methods had been taken at these establishments. viet nam stated that several requests had been made for usda and fsis representatives to facilitate a visit of the vietnamese delegation to a number of establishments that had been registered for exporting white offals to viet nam. the purpose of the mission would be to inspect and review us regulatory programmes and food safety systems in order to ensure that all establishments met the requirements. viet nam indicated its willingness to continue working closely with us authorities on the issue and further underscored its commitment to ensure that its sps regulations were consistent with international standards and the sps agreement. in march 2019 the united states appreciated the bilateral engagement with viet nam on its concerns regarding its decree no. 15 but nonetheless regretted that they had not been fully addressed. the united states noted viet nams addendum dated 16 may 2018 notifying the invalidation of circular no. 25 of 2010 and the entry into force on 2 february 2018 of decree no. 15 of 2018 regulating imports of food products derived from animals. the united states was concerned that viet nam had not notified decree no. 15 which overhauled pr