Vietnam Seafood Association Seeks EU Clarification on EVFTA Tuna Export Volume Calculation Method

The Vietnam Association of Seafood Exporters and Producers (VASEP) has submitted a written document to Vietnam's Directorate of Fisheries and Fisheries Inspection, providing information and data for use in explaining to the EU the issues of rules of origin and tuna catch volumes under the EU-Vietnam Free Trade Agreement (EVFTA). VASEP noted that the EU's method for calculating the proportion of domestic yellowfin tuna (黄鳍金枪鱼, Thunnus albacares) catches used to produce frozen fillets exported under EVFTA fails to adequately reflect the realities of production, processing, and export.

According to the EU analysis cited in VASEP's document, Vietnam exported 3.004 tonnes of frozen tuna fillets to the EU enjoying EVFTA tariff preferences in 2022, while Vietnam's domestic yellowfin tuna catch that year was 19.941 tonnes. On this basis, the EU concluded that approximately 33.3% of Vietnam's yellowfin tuna catch that year was exported to the EU as frozen fillets.

VASEP considers this judgement to inadequately reflect the actual production and business operations of the tuna industry. The association noted that raw materials used to process export products in 2022 were not necessarily caught in the same year; raw material procurement, preservation, storage, and processing proceed continuously across years, so some of the 2022 export products may have been processed from raw materials caught in 2021, stored under refrigeration and then used for production and export. In addition, comparing only the yellowfin tuna catch in the single year 2022 with the total weight of all export products in the same year fails to account for inventory factors, processing timing, and the difference between raw material weight and finished product weight after processing.

The document also pointed out inconsistencies in the EU's calculation: the annex to the EU analysis gives a ratio of 33.3%, but the formula it lists is 3.004/19.941 tonnes, which equals approximately 15.1%; only when the 3.004 tonnes of finished product is converted to 6.608 tonnes of raw material using the EU's assumed 2.2:1 loss rate does the ratio come to approximately 33.1%. VASEP therefore requests clarification of the calculation basis and methodology to avoid confusion between finished product weight and raw material weight.

VASEP also requests clarification of the product scope used in the EU analysis—namely, whether "frozen tuna fillets" and the statistical weight under HS 0304.87 refer only to frozen tuna fillets or also include other product forms such as loins, steaks, saku, cubes, tartar, and burgers. Different product forms have different processing techniques and yields, and the product mix must be determined before applying conversion loss rates.

On the other hand, according to reports from some companies, most tuna arrives at the factory already in GG (gilled and gutted) primary processed form completed at sea, so the basis for calculating yield must be clarified as to whether it is whole fish or GG-form raw material. Actual data provided by the association show that the raw material-to-finished product ratio for frozen tuna fillet products is typically 1.25:1 to 1.5:1; for loin products, 1.5:1 to 2.0:1; and for specifications such as steak, saku, and cube, 2.0:1 to 2.7:1. These ratios depend on fish size, quality, raw material form, degree of primary processing, technical requirements, and the production processes of individual factories. VASEP therefore considers that the EU's uniform application of a 2.2:1 loss rate (corresponding to approximately 55% loss and by-products) lacks sufficient basis and is inadequate as an average processing ratio for all Vietnamese frozen tuna fillets exported under HS 0304.87.

Regarding the species composition of raw material fish, VASEP's summary of tuna export data to the EU, based on customs data and the actual situation of some companies, shows that yellowfin tuna is the main species used to produce frozen tuna fillets exported to the EU; however, determining the exact share of each species in total exported goods requires reference to companies' actual raw material, production, and export records. VASEP recommends that, pending specific verification results on species composition and product specifications, it should not be assumed by default that all products exported to the EU under HS 0304.87 are processed from yellowfin tuna.

VASEP requests that the Directorate of Fisheries and Fisheries Inspection study and compile the above information and use it in the process of communication and explanation with the EU, so that the assessment of data, processing loss rates, and determination of tuna raw material sources conform to the actual production, business, and export operations of Vietnamese enterprises.