Cambodia Export Facilitation Manual

Cambodia Export
Diversification and
Expansion Program
(CEDEP II):
Marine Fisheries
Component
EXPORT
FACILITATION
MANUAL
Practical Guide for Fish and Fishery
Products Export
United Nations Industrial Development Organization

Fisheries Administration, Ministry of Agriculture, Forestry and Fisheries
January 2016
Cambodia Export Diversification and Expansion Program (CEDEP II)

Marine Fishery Component
Table of Content
List of Abbreviations
Chapter 1: Introduction to Trade Facilitation
1.
2.
3.
4.
What is Trade Facilitation?

Why it matters?
What it involves?
Export Facilitation Manual
Chapter 2: Export Procedure

1. Pre-Export Considerations
1.1. Sales Contract
1.2. Methods of Payment in Export Trade
1.3. Using International Incoterms
1.4. Preparing Shipping Documentations
1.5. Freight Forwarders and Customs Brokers
1.6. Packaging and Labelling
1.7. Export Tax
2. Export Documentation
2.1. Company Registration Certificate
2.2. Tax Registration Certificate
2.3. Exporting Permit
2.4. Transportation Permit
2.5. Health Certificate
2.6. Certificate of Origin
2.7. Customs Permit
2.8. Customs Valuation
2.9.CAMCONTROLs Approval on Verification of Export Documents
3. Custom Declaration Procedures
4. Export Mean (Land, Sea and Air)
4.1. Exporting by Land
4.2. Exporting by Sea and River
4.3. Exporting by Air
Chapter 3: Requirements of the Importing Countries
1.
2.
3.
4.
5.
6.
7.
8.
Vietnam
China
Hong Kong
South Korea
Japan
Canada
European Union
Other Countries
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Chapter 4: Trade Related Institution

Appendixes: Samples and Forms of Export Documentations
References
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List of Abbreviations
Acronym
Full title
APEC
APHIS
ASYCUDA
CBP
CEDEP
CFR
CIF
CIP
Asia-Pacific Economic Cooperation

Animal Plant Health Inspection Service
Automated System for Customs Data
Customs and Border Protection
Cambodia Export Diversification and Expansion Program
Cost and Freight
Cost, Insurance and Freight
Carriage and Insurance Paid
CO
CPT
DAALI
DAF
DDP
DDU
DEQ
DES
ECE
EU
EXW
FAS
FCA
FDA
FDI
FOB
FSANZ
FSIS
FSMA
HACCP
ICON
IFC
IFIS
ITC
MOU
MRP
MAFF
NMFS
OECD
PAS
PPIA
PREDICT
SEZ
SMEs
SSI
Certificate of Origin
Carriage Paid To
Department of Agronomy and Agricultural Land Improvement
Delivered at Frontier
Delivered Duty Paid
Delivered Duty Unpaid
Delivered Ex-Quay
Delivered Ex-Ship
Economic Commission for Europe
European Union
Ex-Works
Free Alongside Ship
Free Carrier
Food and Drug Administration
Foreign direct investment
Free on Board
Food Standards Australia New Zealand
Food Safety Inspection Service
Food Safety Modernization Act
Hazard Analysis and Critical Control Points
Import Conditions Database
International Finance Cooperation
Imported Food Inspection Scheme
International Trade Center
Memorandum of Understanding
Multiple release permit
Ministry of Agriculture, Forestry and Fisheries
National Marine Fisheries Service's
Organization for Economic Co-operation and Development
Sihanoukville Autonomous Port
Phnom Penh International Airport
Dynamic Import Compliance Targeting
Special Economic Zone
Small and Medium Enterprises
Single Stop Inspection
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SPS
SWI
UN/CEFACT
UNCTAD
UNIDO
USDA
USFWS
WCO
WTO
Sanitary and Phytosanitary

Single Window Inspection
United Nations Centre for Trade Facilitation and Electronic
Business
United Nations Conference on Trade and Development
United Nations Industrial Development Organization
The United States Department of Agriculture
U.S. Fish and Wildlife Service
World Custom organization
World Trade Organization
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Chapter 1: Trade Facilitation

Trade facilitation is increasingly recognized as the key to unlocking further gains from
international trade. While tariffs are no longer the main obstacle to trade following their
substantial reductions over the last 60 years, major nontariff barriers to trade have also
diminished in significance.
1. What is Trade Facilitation?
Procedures, regulations, and related documentation for international trade arise in
response to the need of governments and trade operators to monitor and control the
movement of goods, delivery of services, and related financial flows. This is necessary
to ensure compliance with each countrys particular requirements (e.g., health
requirements), to collect tariff revenues, and to observe regulations such as (i)
preventing the cross-border movement of illegal drugs, arms, protected species,
hazardous waste, and other controlled products; (ii) ensuring national security; and (iii)
collecting relevant information for statistical purposes.
However, trade procedures and documentation can sometimes be major impediments to
trade. The main objective of trade facilitation is to simplify the process and minimize
transaction costs in international trade, while maintaining effective levels of government
control.
There is no universal definition of trade facilitation. But since it focuses on the
transparent and efficient implementation of trade rules and regulations, it is often
referred to as the plumbing of international trade. In its narrowest sense, trade
facilitation may be defined as the systematic rationalization of customs procedures and
documents. In a broader sense, it covers all the measures that affect the movement of
goods between buyers and sellers, along the entire international supply chain. Questions
of what to include in behind-the-border trade costs are especially controversial.
A distinction is often made between costs of domestic trade and the extra costs of
international trade, although the difference may be hard to identify in practice.
International agencies and regional initiatives have adopted various definitions of trade
facilitation, emphasizing its different aspects. These different definitions, however, all
emphasize the need for coordination at the border (e.g., between customs, quarantine,
and other agencies, often referred to as integrated border management) and
coordination between the border countries exit and entry posts. The narrowest
definitions limit trade facilitation to customs and other border operations such as, in
practice, at-the-border measures.
For example, the WCOs definition of trade facilitation is associated with its mission,
which is to enhance the efficiency and effectiveness of customs administration by
harmonizing and simplifying customs procedures. The definition by APEC also focuses
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on at the-order processes and procedures. These cover facilitation measures related to

preparation of customs and trade documents, customs clearance procedures, border
control, and release of goods.
2. Why it Matters?
The benefits of trade facilitation can be evaluated in terms of its effect on trade
transaction costs. Estimates of such costs vary significantly, and it is useful to
distinguish between direct and indirect costs. Direct costs include the cost of preparing
documentation, and complying with various customs and other regulations. These may
also include the cost of moving goods from factory to port, handling costs at the port,
finance and insurance, and international transport costs. Indirect costs include the
opportunity costs associated with time and delays in moving the goods from the buyer
to the seller.
Reduction in trade transaction costs, which is one of the expected benefits of trade
facilitation measures, does not fully capture the potential benefits associated with trade
facilitation. Trade facilitation is also expected to reduce uncertainties in trade
transactions and a more inclusive participation of the private sector in international
trade. Trade facilitation can bring significant benefits to both government and traders as
shown in
Table 1.1: Trade Facilitation Benefits Governments and Traders
Benefit to Government
Increased effectiveness of control methods

More efficient deployment of resources
Correct revenue yields
Improved trader compliance
Encouragement of foreign investment
Accelerated economic development
Benefit to Trader
Lower costs and reduced delays
Faster customs clearance and release through

predictable official intervention
Simpler commercial framework for doing both

domestic and international trade
Enhanced competitiveness
Source: Economic Commission for Europe (ECE). 2002
In the medium to long term, trade facilitation may contribute to the following benefits:
(i) Improved trade competitiveness. The WTO, with its rules-based approach to trade
policy, has created a fair playing field. Tariff rates have been reduced and many
traditional nontariff barriers have been dismantled. Emerging economies cannot rely on
further tariff concessions alone to further develop their exports. They have to be
competitive to export. Thus, existing products must be improved, new products must be
developed, and new markets must be found.
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A national policy on trade facilitation is a key factor in the development of export

competitiveness. Inefficient trade-related procedures and processes can delay the
delivery of products to overseas markets. Such inefficiencies can affect the ability of
manufacturers and exporters to meet the needs of their overseas customers, and prevent
them from taking part in the growing number of regional and global production
networks.
(ii) Increased foreign direct investment (FDI). A significant share of FDI in developing
economies is in production facilities whose products are exported to other countries
rather than supplied in the domestic market. Many of these production facilities need to
source some of their inputs from overseas. As a result, foreign direct investors will pay
attention to a countrys ease and cost effectiveness of importing and exporting goods
and services before making an investment decision. A country that has committed itself
to facilitating trade will tend to secure more FDIs and become more integrated into
regional and global production networks.
(iii) Increased participation of SMEs in international trade. Most small and mediumsized enterprises (SMEs)often acknowledged as a major growth engine in both
emerging and developed economieslack experience in international trade. SMEs that
attempt to get involved in direct imports or exports are often discouraged by complex
and nontransparent trade procedures. Streamlining and simplifying trade procedures can
facilitate SME participation in international trade. The efficiency brought about by the
computerization and automation of trade procedures, and the growing availability of
information technology (IT) services, will be particularly beneficial to exporting SMEs,
and will increase SMEs propensity to export.
(iv) Improved economic growth prospects. Overall, an efficient trading environment
will translate into more reliable services and lower production costs. Given an inclusive
development policy framework and appropriate income distribution policies, the
resulting increase in trade, investment, and economic activity will ensure a better
standard of living for all.
3. What it involves?
Practices of Trade facilitation involve five key areas:
(i) Publication and Administration of Trade Regulation which addresses the need for
timely publication of trade regulations and procedures and increased transparency in the
administration of trade transactions;
(ii) Trade Procedures and Documents which discusses simplification of trade
procedures and documents using relevant international instruments;
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(iii) Products standard and conformance which discusses trade facilitation issues arising
from increasing number of product standards and conformity assessment procedures;
(iv) Trade-Related Infrastructure which emphasizes the importance of increasing the
efficiency of trade-related infrastructure and services and
(v) Transit trade which tackles transit trade facilitation, a priority for many landlocked
developing countries and an important aspect of regional integration and inclusive
development.
4. Export Facilitation Manual
The fisheries sector of Cambodia plays an important role in the national economy
contributing significantly to employment and livelihoods of the poor, to food security
and to GDP. There are significant opportunity to further develop the sector through
increasing productivity, better management of resources, upgrading of the
infrastructure and strengthening the institutional climate.
Royal Government of Cambodia has recognized the need for improving the trade
sector competitiveness which is critical to growth, and, in turn, to the creation of new
and better jobs and income generation, in its Cambodia Trade Integration Strategy and
Trade SWAp Roadmap 2014-2018.
Cambodias access to international fish markets will continue to depend on the
countrys capacity to meet the regulatory requirements of importing countries. At the
moment, except for a few large processors that have access to investment, production,
SPS know-how, and market access information, the sector is mostly dominated by
small and medium processors with far more limited resources and know-how.
Export diversification on fish and fishery products have been considered as an
important contribution to the national economy. This Export Facilitation Manual has
been developed to provide practical information on trade facilitation, export procedure,
institutional support and importing requirements of the potential international markets.
The objectives of Export Facilitation Manual are as follows:
1. To generate more knowledge and understanding on trade facilitation
2. To provide practical guidance on export procedures and documentations for
exports of fish and fishery products
3. To provide information on importing requirements of key international
markets for fish and fishery products
4. To promote export diversification through increased exports of fish and fishery
products of Cambodia
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Chapter 2: Export Procedure

1. Pre-Export Considerations
At preparation stages, exporters of fish and fishery products should always give
consideration to the documents required and matters related to:
Sales contract
Methods
Using
of Payment in Export Trade
International Commerce Term
Preparing
Freight
Shipping Documentation
Forwarders and Customs Brokers
Packaging and Labeling

Export
Taxes
1.1 The Sales Contract

When negotiating an international sales contract, the terms of sales is equally important
as important as the sales price. From origin to destination, the goods you are shipping
will likely involve several different parties and several modes of transportation. The
buyer and seller therefore need to be clear at each stage regarding who takes
responsibility and risk and who pays any associated charges and fees while the
merchandise is in transit.
Contract issues to consider:
When
does the transfer of ownership/title take place?
What
am I liable for?
Who
pays for charges or taxes that arise during transit?
What
if the shipment is lost or damaged?
To address these types of questions, exporters use standard international shipping terms
and have sales contracts that are as clear, precise and comprehensive as reasonably
possible. At a minimum, the terms and conditions of your sales contract should specify:
Who is involved
(The parties to the contract)
What is being exported
(Details of the goods being
provided)
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License and permit requirements

(Who is responsible for obtaining import or
export licenses and permits)
Payment instructions and terms
(Purchase price of the goods and terms of
payment)

Ownership/Responsibility
(Where transfer of title to the
goods takes place)
Contract details
(The contracts validity
conditions)
Cancellation terms
(What to do if the buyer defaults
or cancels)
Warranty and guarantees

(Warranty and/or maintenance terms and
conditions)
Insurance and taxes
(Who is responsible for paying insurance and
taxes)
Timing
(The contract completion date)
Source: IFC, Handbook on Export Procedures, Practical Guides for Small and Medium Enterprises in
Cambodia, 2008.
The model contracts for small firms developed by ITC is available at: http://www.intracen.org/modelcontracts-for-small-firms/.
1.2 Method of Payments in Export Trade

The payment method is a crucial aspect when dealing with exports. There are five primary methods
of payment for international transactions. During or before contract negotiations, you should
consider which method in the figure is mutually desirable for you and your customer
Export Payment methods
Risk Level
Cash in advance
Most secure
Letters of credit
Secure
Documentary collection
Open Account
Less secure
Consignment
Least secure
Source: export.gov, trade finance guide.
Cash in advance: With cash-in-advance payment terms, an exporter can avoid credit risk
because payment is received before the ownership of the goods is transferred. For
international sales, wire transfers and credit cards are the most commonly used cash-inadvance options available to exporters
Letters of Credit: Letters of credit (LCs) are one of the most secure instruments available
to international traders. An LC is a commitment by a bank on behalf of the buyer that
payment will be made to the exporter, provided that the terms and conditions stated in the
LC have been met, as verified through the presentation of all required documents. The
buyer establishes credit and pays his or her bank to render this service.
Documentary collection (D/C): D/C is a transaction whereby the exporter entrusts the
collection of the payment for a sale to its bank (remitting bank), which sends the
documents that its buyer needs to the importers bank (collecting bank), with instructions
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to release the documents to the buyer for payment. Funds are received from the importer
and remitted to the exporter through the banks involved in the collection in exchange for
those documents. D/Cs involve using a draft that requires the importer to pay the face
amount either at sight (document against payment) or on a specified date (document
against acceptance). The collection letter gives instructions that specify the documents
required for the transfer of title to the goods. Although banks do act as facilitators for their
clients, D/Cs offer no verification process and limited recourse in the event of nonpayment. D/Cs are generally less expensive than LCs.
Open Account: An open account transaction is a sale where the goods are shipped and
delivered before payment is due, which in international sales is typically in 30, 60 or 90
days. Obviously, this is one of the most advantageous options to the importer in terms of
cash flow and cost, but it is consequently one of the highest risk options for an exporter.
Consignment: it is a variation of open account in which payment is sent to the exporter
only after the goods have been sold by the foreign distributor to the end customer. An
international consignment transaction is based on a contractual arrangement in which the
foreign distributor receives, manages, and sells the goods for the exporter who retains title
to the goods until they are sold. Clearly, exporting on consignment is very risky as the
exporter is not guaranteed any payment and its goods are in a foreign country in the hands
of an independent distributor or agent.
Exporter would also need to discuss with commercial banks for various payment options.
1.3 Using International Commerce Term
Incoterms are standard definitions of terms used in international commerce, developed
by the International Chamber of Commerce (ICC). They make international trade easier,
ensure that sellers and buyers in different countries understand one another and can
minimize potential misunderstandings. Incoterms also clearly define when responsibility and
risk transfers from the seller to the buyer and who pays charges and when.
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Source: New Zealand Trade & Enterprise, https://www.nzte.govt.nz/en/.

CFR
Cost and Freight
International carriage is paid by the seller. The exporter pays the costs of
the freight and transportation to get the goods to the named destination.
The risk of loss or damage is assumed by the buyer once the goods are
loaded at the port of departure.
CIF
Cost, Insurance and
Freight
International carriage is paid by the seller. The exporter pays for the costs
of the freight, insurance and miscellaneous charges from the point of
origin to destination.
CIP
Carriage and
Insurance Paid
International carriage is paid by the seller. The exporter pays for the
transportation costs and insurance to the named place or port of
destination. The term is used for air or ocean containerized shipments
CPT
Carriage Paid To
International carriage is paid by the seller. The exporter pays for the
transportation costs to the named place or port of destination. The term is
used for air or ocean containerized shipments.
on B
The exporter assumes responsibility for delivering the goods to the named
DAF
Delivered at Frontier place of destination by land. The buyer is responsible for unloading.
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DDP
Delivered Duty Paid
The exporter assumes responsibility for delivering the goods, paying duty
and risk of damage or loss to the named place of destination. The buyer
pays for unloading.
DDU
Delivered Duty
Unpaid
The exporter assumes responsibility for delivering the goods and risk of
damage or loss to the named place of destination. The buyer is responsible
for paying duty, unloading and clearing import.
DEQ
Delivered Ex-Quay
The exporter assumes responsibility for delivering the goods to the buyer at
the named port of destination. The buyer is responsible for unloading and
clearing import. This term is used for ocean shipments only.
DES
Delivered Ex-Ship
The exporter makes the goods available to the buyer at the named port of
destination. The buyer is responsible for unloading. This term is used for
ocean shipment only.
EXW
Ex-Works
States the place where the shipment is available to the buyer. The seller is
not responsible for loading the goods. The buyer assumes all responsibility
for transportation.
FAS
Free Alongside Ship
International carriage is NOT paid by the seller. The exporter delivers the
goods to named ocean port of shipment and is responsible for the
unloading and wharf fees. The buyer is responsible for loading aboard the
vessel, ocean transportation, and the ocean cargo insurance.
FCA
Free Carrier
International carriage is NOT paid by the seller. The exporter is

responsible for delivering goods into the custody of the international
carrier or agent, not loaded. The risk of loss/ damage is transferred to the
buyer at this time.
FOB
Free on Board
International carriage is NOT paid by the seller. The exporter is responsible

for placing the goods on board the vessel at the port of shipment. The
buyer assumes responsibility for ocean transportation and insurance.
Cambodia, 2008.
1.4 Preparing Shipping Documentations

Fish exporters should become familiar with the shipping documents required for an export
sales transaction. These documents are essential for moving goods through the channels
of distribution, transferring possession and responsibility, clearing product through
customs and facilitating payment. Incomplete, missing or incorrectly filled out
paperwork delays the export process and adds costs to the exporter.
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The following is an overview and description of shipping documents typically used in

the export process.
Shipping documents prepared by you or your freight forwarder:
Airway Bill
An Air Waybill is issued by an airline when goods are received for

transport. The waybill travels with the cargo.
Authorization
Letter
An Authorization Letter allows a freight forwarder or authorized agent to

export goods on the sellers behalf.
Bill of Landing
A Bill of Landing is a contract between the seller and the carrier,

typically prepared by the carrier or forwarder. The buyer usually needs an
original copy as proof of ownership to take possession of the goods.
Commercial
Invoice
A Commercial Invoice is essentially a bill for goods from the seller to the
buyer. The document is prepared by the exporter or freight forwarder and
provides information about the transaction including description of goods,
address of shipper and seller and delivery and payment terms. It is also
used as a basic document in determining the customs duty.
Insurance
Certificate
An Insurance Certificate is a document prepared by the exporter or freight

forwarder that provides evidence that insurance will cover the loss of or
damage to the goods during transit.
Packing List
A Packing List is an itemized list describing the quantity and type of

merchandise in a shipment. It includes the type of package, such as a box,
crate, pallet, drum, carton or container and the dimensions and weight.
Customs officials will use this list to check the cargo and buyers will use
it to inventory merchandise received.
Cambodia, 2008.
1.5 Freight Forwarders and Customs Brokers

Freight Forwarders are service companies that handle all aspects of export shipping
for a fee. They act as the exporters agent and can improve delivery time and customer
service. Additional advantages of using a freight forwarder include:
Providing customized services for physical transportation of goods

Advising on rates and routing
Offering assistance with packing and documentation
Arranging consolidations or full container movements
Offering Customs clearance services
Providing quotes on insurance and freight
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Freight forwarders often do not own their own trucks but hire transport and contract
with local brokers as needed. In general, these companies provide quality services at
competitive prices.
Customs Brokers prepare customs documentation and clear goods through customs.
Customs brokers in Cambodia needs to be authorized by MEF in order to performance
customs brokerage tasks.
Choosing a Freight Forwarder or
Customs Broker
Exporter Hints
If you decide to use a freight forwarder or

While the main function of freight a customs broker, you should:
forwarders is to pick up, transport, and
deliver cargo and the main function of Understand the essentials of the document
customs brokers is to clear cargo through preparation needed.
customs, there is often significant overlap
Review the prepared documents
in the services the two provide. Both tend
Talk with other exporters and learn
to be facilitatorsa customs broker may
about their experiences
provide a freight forwarding service and a
Compare service offered and
freight forwarder may offer customs
pricing of several candidates.
brokering services.
Find out about all fees that you
The decision to use a customs broker or
might have to pay.
freight forwarder will largely depend on
Ask the freight forwarder/broker if
whether you think you have the expertise
they have experience with handling
and time to carry out the process yourself.
your type of export.
If you are new to exporting, consider using
a customs broker or freight forwarder for
your first few shipments. It can save time
and money and help you become familiar
and confident with the export process. It
should also alert you to any unofficial
processes and payments that might be
involved.
Cambodia, 2008.
1.6 Packaging and Labeling

Exporters of fish and fishery products must comply with country-specific packaging and
labelling regulations, and packaging and labelling requirements for transporting of
products.
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The requirements can vary from country to county. In addition, exported goods may be
transported using several of modes of transport before reaching final destinations,
packaging needs to be suitable for each mode of transport and withstand repeated
loading and uploading. Clear labelling helps to prevent goods becoming lost in transit or
delayed at customs clearance.
Exporter would consider the following points regarding packaging and labelling
requirements:
Product name and form (smoke or frozen fish)

Name and address of importer and manufacturer, and country of origin
Date of manufacture and date of expiry
Storage requirements
Translation of information into local languages of importing countries
Compositions and use of different packaging materials
Use of reusable or disposable packaging
Packaging requirements to suit various modes of transports
Various verification certificates for packaging and labelling
Freight forwarding company may offer packaging service and be able to advise on
suitable packaging.
1.7 Export Taxes
There are a number of products whose exports are subject to export taxes, including fish
and fishery products. Most of fish and fishery products are subject to 10% export tax. It
is advised that exporters of fish and fishery products consult with GDCE prior to
exports. Exporters can also check the tariff at: http://www.customs.gov.kh/publicationand-resources/commodity-code-en/
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2. Export Documentation
The key documents for exports of fish and fishery products are as follows:
Company Registration
Tax Registration
Export Permit
Transportation Permit
Health Certificate
Custom Permit
Customs Valuation
CAMCONTROLs Verification on Export Documents
2.1. Company Registration Certificate
Exporter is required to register the company with Ministry of Commerce. Exporter
needs to register online Business Registration. However, Business Registration
Department located at the Ministry of Commerce still accepts the paper application
form and provide a service to register business Online on behalf of company. The
information
about
company
registration
is
available
at:
http://www.businessregistration.moc.gov.kh/
Exporter would need to choose the following forms of business:
Sole proprietorship
Partnership
Company or
Foreign company
The registration forms of each business, applicable fees, and information and documents
required for business registration are in appendixes.
After company registration is approved by MOC, exporter obtains the company
registration certificate. Company is also required to file the annual declaration of
company by providing updates of business operation.
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2.2. Tax Registration Certificate

Export company is obliged must go to register tax at Administration of Taxation within
15 working days after having registered company with Ministry of Commerce. The tax
application can be submitted either at Administration of Taxation or via E-registration
of the website of Administration of Taxation at: www.tax.gov.kh.
Conditions of Tax Registration
The chair of governing board or enterprise owner or organization director must come
to be photographed and have their fingerprint scanned and fill out the application
form as required by the Administration of Taxation and be accompanied by original
documents so that the tax officers in charge certify it as copied from the original one
or copied documents certified by the concerned ministry/institution as follows:
1. Registration documents issued by the Ministry of Commerce or relevant
ministry/institution
- Letter certifying the registration of the Ministry of Commerce or relevant
ministry/institution
- Companys statute for legal entity
- Letter certifying the deposit of capital registered at the bank
2- Documents identifying the chair of governing board, governor and owner or
shareholder and manager
- Cambodian Identity Card or Passport
- Family book or family record book or letter certifying residing place issued by
competent authority
- Current photo, not over the past three months with its size: 35 x 45 millimeters (one
photo) of the chair of governing board, governor and owner or shareholder and
manager and specify the name of the owner of the photo, with signature to be
responsible for by the chair of governing board.
3- Documents certifying the office of the enterprise, business, enterprise branch and
warehouse
- Location ownership certificate or contract of leasing the business location
- Letter certifying the payment of immovable property tax or immovable property
information
4- Other documents
- Registration certificate of the Cambodian Investment Board or Special Economic
Zone Committee of the Council for the Development of Cambodia or
Municipal/Provincial Investment Sub-committee (for Qualified Investment Project)
Company is required to complete the following registration forms:
Application Form For Tax Registration

Additional Bank Account Information
Additional Information For Shareholders
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Application Form For Tax Registration For Company Branch Or Warehouse (if
any)
Additional Information For Company Branch Or Warehouse (if any)
All registration forms are attached in appendixes.

E-registration would take from 1 to 7 working days for Administration of Taxation to
issue tax certificate and tax registration ID, while paper registration at Administration of
Taxation would take from 7 to 10 working days to issue tax certificate and tax ID. The
export company fulfill obligations of relevant taxes. Currently, E-registration allows
company to fill in the forms, then scan and send them to GDT. However, company will
need to bring original or certified copies of required documents as specified in
registration forms (in appendixes) to GDT.
Importantly, company will need to provide clear office address, email and telephone
numbers. GDT has notification system in place, which send email and SMS on tax
calendar or due dates to registered companies.
Company must pay 400,000 Riel (four hundred thousand Riel) for issuance of tax
certificate and tax registration ID.
2.3. Export Permit

After company and tax registration, exporter of fish and fish product request export
permits (licenses) from MAFF. The export permit is valid for one year.
Step to obtain export permit for fish and fish products
Step 1
Fill in Request Letter for Export Permit

Applicant prepare the request letter to export. Applicant can prepare
the request letter in its own format or can request example of request
letter from Department of Planning, Finance and International
Cooperation.
Step 2
Submit Request Letter for Export Permit

- Applicant or assigned representative submits a Request Letter to
Export and attach supporting documents to the Department of
Planning, Finance and International Cooperation of the Fishery
Administration. If applicant assigns representative, power of attorney
or authorization letter is required to include in the application.
- The supporting documents include: business registration certificates,
and tax registration certificate. The copies of business registration and
tax registration certificates are required to certify from competent
authorities.
- After receiving approval technical offices in Fishery Administration,
the Department of Planning, Finance and International Cooperation
will prepare the request for export permit to obtain the approval from
19 | P a g e

Step 3
the Ministry of Agriculture, Forestry and Fisheries.

- During the approval process, the applicant may be asked to provide
further information and documents for the completeness of the
application.
Obtain export permit
- After receiving the request letter approval from the Fishery
Administration, Fishery Administration advises the applicant to collect
a copy of request approval letter. The copy of request approval letter
serves as export permit.
- The validity of export permit depends on the request from applicant,
but with maximum two years.
- No fee is presently charged for issuance of export permit.
2.4. Transportation Permit

After receiving the export permit from the Ministry of Agriculture, Forestry and
Fisheries, applicant must request transportation permit for each shipment.
Step 1
Fill in Request Letter for Transportation Permit

Applicant can obtain the sample of Request Letter from Department
of Planning, Finance and International Cooperation.
Step 2
Submit Request Letter for Export Transportation Permit

- Applicant or assigned representative submits a Request Letter for
Transportation Permit and attach supporting documents to the
Department of Planning, Finance and International Cooperation of
the Fishery Administration. If applicant assigns representative,
power of attorney or authorization letter is required to include in the
application.
- The supporting documents include: business registration
certificates, tax registration certificate, and export permit. The copies
of business registration and tax registration certificates are required
to certify from competent authorities.
- During the approval process, the applicant may be asked to provide
further information and documents for the completeness of the
application.
- The Transportation permit is issued by Fishery Administration.
Collect Transportation Permit
- After approval, the applicant is advised to pay service fee and to
collect the transportation permit from Department of Planning,
Finance and International Cooperation.
- The service fee of issuance Transportation Permit is 40,000KHR.
- The process of issuance Transportation Permit takes three (03)
Step 3
20 | P a g e

working days.
- The export transportation permit is valid for seven (07) days and
contains the details of product specification and quantity.
2.5. Health Certificate

Fish exporter may be required by importing countries and international buyers to
provide health certificate issued by Cambodian authority. Fish exporter can request
health certificate from Department of Fisheries Post-Harvest Technologies and Quality
Control (DPHT) by following the procedures as follows:
Step 1
Step 2
Step 3
Fill in Application of Health Certificate

Applicant can obtain the sample of application of health certificate
from Department of Fisheries Post-Harvest Technologies and
Quality Control (DPHT)
Submit Application of Health Certificate
- Applicant or assigned representative submits an Application of
Health Certificate and attach supporting documents to Department of
Fisheries Post-Harvest Technologies and Quality Control (DPHT). If
applicant assigns representative, power of attorney or authorization
letter is required to include in the application.
- The supporting documents include:
a. Short curriculum of applicant with photos (2 copies)
b. Copies of Cambodian national ID (2 copies)
c. Export permit from Fishery Administration (2 copies)
d. Company registration (2 copies)
e. Packaging Lists (2 copies)
f. Invoices (2 copies)
g. Other relevant documents if required.
- During the process, the applicant may be asked to provide further
information and documents for the completeness of the application.
- After examination of the application, DPHT will proceed to the
next step or reject the application.
Inspection and Sample Analysis
- After the submission of application is completed, officials of DPHT
will conduct inspection and take sample for laboratory testing.
- The choix of laboratory testing depends on the requirements of
importing countries or international buyers. If not indicated by
importing countries or international buyers, DPHT generally uses
Pasteur laboratory for testing. The exporter will bear fee of
laboratory testing.
- Officials of DPHT examine the results of laboratory sample testing
and inspection.
21 | P a g e

Step 4
- If the results are satisfactory, DPHT issues the certificate,

otherwise DPHT will inform its rejection to applicant.
Collect Certificate of Health
After certificate of health is approved, DPHT informs applicant to
pay service fee and collect the certificate.
- The service fee for health certificate is KHR 400,000
- It is currently advised that applicant submits the application for
health certificate at least 10 days prior to exports.
2.6. Certificate of Origin

Certificate of Origin (CO) is an official document used to certify the product originated,
wholly obtained, produced or manufactured in Cambodia. Fish exporter only asks for
CO if importing countries or international buyers require.
Forms of CO
MOC issues two type of CO: Preferential and Non-preferential
Non-Preferential Tariff CO
Form N
Preferential Tariff CO
ASEAN-Australia-New Zealand
Form AANZ
China
Form AC
India
Form AI
Korea
Form AK
Japan
Form AJ
General System of Preferences (LDC and LLDC)
Form A
How to apply for CO

Exporters of fish and fishery products can ask CO applications from at the ExportImport Department of MOC. The exporters follow the procedures of application for CO
as follows:
Export Means
Required Documents and Procedures
Export by sea
Application form for CO submitted by the company

A copy of cheque proving the payment of administrative fee and
EMF, if it is required by any regulation
Invoice
22 | P a g e

Packing list
Bill of lading
Cambodia outward declaration
Certificate of quantities of exported fish and fishery products
issued by CAMCONTROL
Custom declaration by GDCE
Companys relevant documents that can prove the origin of
products
Companys letter of authorization of its representative
Export by air
Application form for CO submitted by the company

Invoice
Packing list
After having exported the goods, the following documents must be
submitted further:
Airway Bill
Joint Inspection Report of the exported goods by GDCE and
CAMCONTROL
Export by truck Application form for CO submitted by the company

(land)
Invoice
Packing list
Bill of lading
After having exported the goods, the following documents must be
submitted further:
Certificate of quantities of exported fish and fishery products
issued by CAMCONTROL
Custom declaration by GDCE
Companys relevant documents that can prove the origin of
products
23 | P a g e

Source: Prakas No. 112MOC/SM2013 on Revision of Certificate of Origin Procedures, 2013.
Online CO Application
Exporter of fisher and fishery product can apply CO via online:
http://www.certificateoforigin.moc.gov.kh/. Currently, exporters can apply online for
the CO form A. MOC works gradually to move all forms of CO to automation system.
Exporter need register for user ID for applying CO online.
For the registration, exporters need to upload the following documents:

1.
2.
3.
4.
5.
6.
Company name and address

Business registration certificate
GSP registration certificate
List of exported goods
List of costs breakdown or reference documents to determine the origin of goods
Power of attorney or authorization letter to representative of company to sign on
CO forms
7. IDs or passports of authorized representative and owner of company, and one
photo (4x6) of each of them
8. Other supporting documents if required.
Then, exporter can apply CO online by following the workflow below:
24 | P a g e

Exporters of fish and fishery products are required to provide and submit the following
documents for applying CO online:
Required documents for applying online
CO (before exports of goods)
1. Invoice
2. Packing List
3. Officials report on production chain
and goods to be transported crossing land
borders to export by air in neighboring
counties.
Submission of original documents (within

30 days after CO is issued
1. Copy of CO form A
2. Invoices
3. Packing List
4. Transportation Permit
5. Certificate of Quantity issued by
CAMCONTROL
6. Customs declaration
7. Supporting document to determine the
origin of goods
8. Copy of export permit
Source: Prakas No. 298 on Procedures of Issuance of Certificate of Origin Form A

through Automation System, MOC, December 2015.
Exporter can follow the Exporters Operation Guide to apply CO online. The guide is
available at: http://www.certificateoforigin.moc.gov.kh/.
Fees for issuance of CO
Fish exporters need to pay for Export Management Fee (EMF) and public service and
administration fee.
25 | P a g e

CO Form
Admin Fee
Service Fee
EMF Fee
Form N
USD 30
USD 8
EMF
Form A
USD 50
USD 8
EMF
Other Forms
USD 50
USD 8
EMF
EMF is varied according to the products ad exception for exports of products that have
value under 6,000 Euro for European countries and under 800 USD for other countries.
Currently, EMF for export of seafood is 2000 KHR per ton. EMFs of other types of fish
and fishery will be determined when they are ready for exports.
Timeframe of issuance of CO
CO is issued within 11hours and 55 minutes (working days) from the time that
complete CO application is submitted to the department of export-import at MOC.
2.7. Custom Permit
Export of fish and fishery products need to request custom permit from GDCE for each
shipment. All exports of goods including fish and fishery products which are in the list
of prohibited and restricted goods in sub-decree 209 ANK.BK dated 31 December 2007
require custom permit prior to export.
Exporter of fish and fishery products applies for custom permit at Department of
Custom Procedure at GDCE by submitting:
1. Export permit and transportation permit from MAFF
2. Request letter attaching with the invoice, packing list, transportation documents,
authorization letters for representatives, and other documents as necessary.
There is no fee presently charged for the request of custom permit. It takes 1-2 working
days to process and to issue the custom permit after the completed and correct
documents are submitted.
2.8. Customs Valuation

The export of fish and fishery products are subject to export tax. The export tax is
generally 10%, but exporter is advised to verify the export tax rate for the particular fish
and fishery product to be exported.
26 | P a g e

For time saving, exporter can start to apply for custom valuation in parallel when
exporter applies for custom permit. Exporter can apply for custom valuation at one of
the following places:
1. Department of Planning, Technique and International Affair at GDCE
2. Customs Valuation Units at branches and local customs and excise offices
within decentralized framework. Currently, the customs valuation is
decentralized at the borders of Cambodia except Sihanouk Ville port customs
and excise branch and Phnom Penh International Airport.
The required documents to request for customs valuation are as follows:
1. Three copies of commercial invoices, packing lists and bill of lading
2. VAT certificate, patent, authorized letter, national ID or passport of the owner or
representatives.
3. Export permit and transportation permit
In some cases, competent custom officers may require additional supporting documents
such as:
1. Sales contract, purchase order, telegraph transfer (TT), public price chart and
other documents related to transaction or payment
2. Documents which specify the identity or details of specification of products.
2.9. CAMCONTROLs Verification on Export Documents
Exporter of fish and fishery products also needs an approval on verification of export
document from general department of CAMCONTROL in Phnom Penh. Exporter can
draft letter of approval request by itself or obtain the letter sample from
CAMCONTROL. Exporter needs to provide the following documents:
Company registration certificate
Export license
Transportation permit
Health certificate
Other related documents
The approval process would take one day. Exporter pays US$15 for each time of
request for verification on export documents.
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3. Custom Declaration Procedures in ASYCUDA

The ASYCUDA WORLD system has been implemented at 54 major customs branches
and offices, which covered almost 99% of Single Administrative Declaration (SAD).
3.1. ASYCUDA User Registration
Exporter is required to register the company in ASYCUDA system at GDCE and to
create user ID. Exporters need to provide company documents for user registration:
Business License from Ministry of Commerce
VAT certificate
The authorized user for SAD process:
Legal person or company with Value Added Tax certificate
Owner of the goods or representatives
Customs broker recognized by Customs
Legally authorized Employee of the company
3.2. Required Documents for Customs Declaration
The documents to be attached with SAD are as follows:
Invoice and Packing list
Transportation documents (Bill of lading/ Airway Bill/Truck bill)
If necessary
Manifests
Licenses
Permit
Certificate of Insurance and
other related documents
1.3. Customs Declaration Procedures
ASYCUDA follows the processes in diagram of ASYCUDA below. The declaration in
ASYCUDAY is the web system and can be performed either in the declarants office,
custom branches at borders or anywhere which can connect to web system.
28 | P a g e

1: Preparation and Printing of Customs Declaration

The Customs Broker/Declarant inputs information of SAD directly into the ASYCUDA.
The computer checks and verifies the customs declaration with reference documents in
the system, and performs some examinations. The system will allow registration of
customs declaration when information is completed and valid. Registered customs
declarations can be cancelled with authorization from the GDCE. Only registered
customs declaration is considered legal document.
After registration, the Customs Broker/Declarant shall print and sign two (2) copies of
SAD attached with all required documents and summit to competent Customs officer.
The system will automatically inform the Customs Brokers /Declarant about the
situation of the customs declaration process.
2: Lodgement of the Customs Declaration
The customs officer in charge of face vetting examines hard copies of registered SAD
and attached documents with information in the system to ensure that the SAD is
properly filled, clear and legible and signed by the Customs Broker/Declarant, and all
required documents are submitted together with the hardcopy registered SAD.
The customs officer may reject any SAD which does not fulfil the above requirements.
3: SAD Processing Lanes:
29 | P a g e

When the SAD is completely and satisfactorily checked, the customs officer assesses
the SAD by using the system. By using risk management criteria, the system will assign
the processing Lane for the Declaration as below:
RED Lane: The SAD must be scrutinized (checked against documents). Goods are
subject to physical inspection before re-routing the SAD to GREEN lane and
assessment by Customs.
YELLOW Lane: The SAD must be scrutinized (checked against the documents)
before re-routing to GREEN lane and assessment by Customs.
GREEN Lane: The SAD is automatically assessed and a clearance document issued.
The hardcopy SAD may be subject to post-clearance audit (PCA).
BLUE Lane:
The SAD is provided the same treatment as for GREEN Lane and
with specific reasons subject to post-clearance audit.
If customs declaration is under Red and Yellow lane, Customs officer shall verifies the
selectivity criteria that caused the declaration to be set in these lanes. The system will
show special requirements such as requirement for import license, withdrawal of sample
and history of smuggling etc.
4: Query Desk:
If there are some errors in data entry or irregularities found during physical
examinations, SAD will be routed to the Customs Query Desk. Customs
Broker/Declarant will be notified that the SAD status has changed to query and the
reasons for the query.
Upon receiving the notification, Customs Broker/Declarant shall go to the Customs
Query Desk. If any amendments to SAD are required, Customs Officer in charge of
Query Desk will discuss with Broker/Declarant. If agreement is not reached, the
customs officer will prepare a report or record to GDCE for further action.
When the above action is fulfilled and agreement is reached, customs officer shall sign
on SAD and update the inspection act based on the results of inspection and settlement
at query desk or upon the decision of GDCE. Then SAD will be re-routed to GREEN.
5: Container Scanning
Container scanning is done independently of SAD processing. The system will be
available in the Scanning Office enabling the scanning officer to compare the goods
declared on the SAD with those found on the scanning image/scanning information.
Any irregularity found should be recorded in the Inspection Act Form by Customs.
6: Assessment Notice
30 | P a g e

When the SAD is assessed by the ASYCUDA, the system will inform the amount of
duties, taxes and fees to be paid. The notice of assessment will be used as a reference
document for payment of duties, taxes and fees.
7: Accounting
Duties, taxes and fees are paid in accordance with regulations in force. If payment is
made via the National Bank of Cambodia or other authorized financial institutions, the
receipt issued these institutes shall be submitted to Customs and the system will issues a
Customs receipt in return.
8: Release of Goods
After payment of duties, taxes and fees Customs will issue the Cargo Release Note,
which details the amount of duties, taxes and fees related to the declaration. This note is
used to authorize release of the cargo from customs.
9: Post Clearance Auditing (PCA)
SADs processed under blue and green lane are subject to post-clearance audit.
31 | P a g e

Tip: Responsibility of Customs Broker/Declarant in Customs Declaration

Customs Broker/Declarant shall perform the following responsibilities:
Declarant shall input data on Customs declaration including valuation note until
registration
When finish inputting data on Customs declaration, declarant shall verify and
then register Customs declaration if there is no mistake or after the correction of
mistake. After registration ASYCUDA will provide registration number and
date automatically.
Declarant shall print 2 copies of the registered Customs declaration and
valuation note (in case necessary) in A4 size paper (Note: Customs declaration
can be printed after registration).
Registered Customs declaration attached with necessary documents shall be
submitted to Customs officer in charge face vetting. Declarant shall sign on
Customs declaration in front of Customs officer.
In case Customs officer in charge face vetting does not accept Customs
declaration, declarant shall contact query desk official.
If there is official in charge of manifest, declarant shall bring the copy of
Customs declaration to Customs officer in charge of manifest in order to write
off goods in Customs declaration from manifest.
If scan is required, declarant shall bring the copy of Customs declaration to
Customs unit in charge of scanning the container.
If physical inspection is required, declarant shall contact chief examiner for
inspecting the cargo.
If additional information is need by Customs officer, declarant shall go to query
desk.
If payment is made via banking system, declarant shall provide bank receipt to
Customs officer in charge of accounting in order to certify the payment in
ASYCUDA.
If payment is made on cash/check, declarant shall provide cash/check to
Customs officer in charge of accounting in order to certify the payment in
ASYCUDA.
After payment of duties and taxes or in case goods are declared under advance
payment, declarant shall receive Customs receipt from cashier and then Customs
receipt on vehicle (if exist) and cargo release note of Chief of accounting.
Declarant shall take transportation note from Customs officer in charge of
warehouse or Customs area and then take the cargo out.
In case there is an approval and permission to totally or partially return duties
and taxes, declarant shall bring necessary documents include decision of the
competent authority, Customs declaration, Customs receipt, Billetc to
accountant and cashier in order to certify the return of duties and taxes in
ASYCUDA.
32 | P a g e

1.4. Public Services

Exporter or declarant pay the relevant public services as follows:
Descriptions
Amount of
tax due
Service
fee
Processing
duration
(working
days)
Validity
Custom Processing Fee (CPF)

One container from 20 feet up
60,000 Riel 0 Riel
1-2 days
One custom clearance for

product stored outside a
container or inside a container
smaller than 20 feet
40,000 Riel 0 Riel
1-2 days
Container checking fee using TH-SCAN System

One container smaller than 40
feet
25 US
Dollar
0 Riel
1-2 days
One container from 40 feet up
32 Dollar
0 Riel
1-2 days
Provisional customs warehouse

license fee (per year)
20,000,000
Riel
0 Riel
1-2 days
Fee for storing goods in the

provisional customs warehouse
over due date (per day)
0.1% of the 0 Riel

customs
calculation
based
Immediately Note (1)
Transiting fee-Fishery product

(per kilogram)
500 Riel
0 Riel
Immediately
Sale of custom clearance form

(per number)
0 Riel
15000
Riel
Immediately
Sale of custom taxs stamp (per

sheet)
0 Riel
100 Riel
1-2 days
Sale of transport or stock

authorization letter (per sheet)
0 Riel
500 Riel
Immediately
Sale of seal in the container

(per piece)
0 Riel
8000 Riel 1-2 days
1 year
Note (1): Stored over 30 days at the airport and over 45 days outside the airport
Source: Prakas No. 1151 on Provision of Public Service of GDCE, MEF, 15 Sep. 2015.
33 | P a g e

2. Export Mean (Land, Sea and Air)

Before exporting by any mean, make youre the exporters have the following four
Items:
No.
Item
Description
Shipping Documents
Prepare all the necessary documents for

exportation. This usually includes the Packing
List, Commercial Invoice and Authorization
Letter.
Company and Tax

Registration
Documentation
Proof of registration with the Ministry of

Commerce, such as registration certificate,
companys VAT number or patent tax license,
demonstrating that the business is legitimate.
Ministerial permits or
certificates
Prepare export permits or certificate issued by

Cambodian authorities. This usually includes
export permit, transportation permit, health
certificate (if required), and certificate of origin.
Custom Permit and

Custom Valuation
Exports of fish and fishery products need to

request custom permit and custom valuation
from GDCE in Phnom Penh.
CAMCONTROLs
approval on verification
of export document
34 | P a g e
Exporter also needs approval for verification of

export documents from CAMCONTROL.

4.3. Exporting by Land

4.3.1 Poi Pet Border
The Poipet-Aranyaprathet
border is situated in the
northwest of Cambodia and
is located in Ou Chrov
district
of
Banteay
Meanchey province. In 1994
the Poipet border crossing
became
an
official
International
Border
Checkpoint. Poipet is one of
four districts that borders
Thailand. The border gate is
approximately 50km from
the provincial capital of
Banteay Meanchey and
serves as the primary land
crossing for people and
goods moving between
Cambodia and Thailand.
Poipet Hours of Operation

Border Gate:
People: 6:00-22:00 daily
Goods: 6:00 - 22:00 daily
CAMCONTROL: 24 hours daily
Customs and Excise: 24 hours daily
Poi Pet Border Export Process

The Poipet Border export process can be captured in THREE key steps. The
documentation and requirements are outlined below.
Step 1: Custom
Declaration
Step 2: Joint
Inspection
Step 3. Exit Poi Pet

Border
Step1: Customs Declaration

The processes of customs declaration at the Poi Pet border are as follows:
1. Exporter or authorized person shall request the permission of export at Poi Pet
customs and excise branch by attaching supporting documents such as invoice,
packing list, export permit, and authorization letter (if needed).
2. Custom and excise branch check the request and supporting documents and then
gives, in case no irregularity, permissions. The customs declaration process can take
place.
35 | P a g e

Customs Declaration Process

3. Exporter or declarant follows the custom declaration procedures in ASYCUDA and
pays relevant tax due and fee as described in the section 3.
4. For exports of fish and fishery products, exporter also need to attach approvals on
custom valuation and customs permit with other supporting documents for customs
declaration.
Step 2: Joint Inspection
Joint Inspection conducted by Custom and Excise and CAMCONTROL officials can
take place once the Customs Declaration process has begun.
Joint Inspection Process:
1. Custom and CAMCONTROL officials review the following documents: invoice,
packing list, export permit, transportation permit, and authorization letter (if
needed). If a representative is handling the cargo for the exporter, he/she will need
to provide a photocopy of an ID card and two photographs. If possible, provide a
request or authorization letter to let officials know who will be clearing the cargo
and if they have power of attorney. This process would take quickly about 10-15
minutes on average. In case there is any irregularity, the physical inspection of
exported goods will be conducted.
2. Then, an Inspection Report is filled in and jointly signed by officials of Custom and
Excise and CAMCONTROL, and owner or representative of goods (sample of joint
inspection report in appendixes).
3. Next, the exporter or declarant will pay an inspection fee of KHR 2,5000 per ton at
the CAMCONTROL cashier.
4. Lastly, a Certificate of Quantity document is issued if needed.
Step 3: Exit Poi Pet Border

After the customs declaration and joint inspection process are complete, the exporter
can proceed to the border.
Exit Process
1. Go to the border and present the completed declaration form and supporting
documents to the Customs and Excise border officials.
2. The consignment is then allowed to pass through the Poi Pet border.
36 | P a g e

4.3.2 Bavet Border
Bavet Hours of Operation

Border Gate:
People: 6:00-22:00 daily
Goods: 6:00-17:00 daily
The
Bavet-Moc
Bai
border is located in the
province of Svay Rieng in
the
southeast
of
Cambodia. Bavet is one
five districts that borders
Vietnam.
The
Bavet
border
gate
is
approximately 50 km
from the provincial capital
of Svay Rieng and is the
primary land crossing for
people and goods moving
between Cambodia and
Vietnam.
Bicycles,
garments,
and
shoe
products comprise a large
percentage of exports
through Bavet border as
these goods are produced
in the nearby special
economic zone (SEZs).
Currently, there are 10
SEZs and four of them are
in operation.
Bavet Border Export Process

The Bavet Border export process is similar to that of Poi Pet. Favorably, if exported
goods are produced in SEZs nearby Bavet border, exporter would further benefit from
trade facilitation and facilities available in the zones.
The Bavet Border export process can be captured in THREE key steps. The
Step 1: Customs
Declaration
37 | P a g e
Step 3: Exit Bavet Border


The processes of customs declaration at the Bavet border are as follows:
1. Exporter or authorized person shall request the permission of export at Bavet customs
and excise branch by attaching supporting documents such as invoice, packing list,
export permit and authorization letter (if needed).
place.
4. For exports of fish and fishery products, exporter or declarant also needs to attach
approvals on custom valuation and customs permit with other supporting documents for
customs declaration.
packing list, export permit, transportation permit, and authorization letter (if needed). If
a representative is handling the cargo for the exporter, he/she will need to provide a
photocopy of an ID card and two photographs. If possible, provide a request or
authorization letter to let officials know who will be clearing the cargo and if they have
power of attorney. This process would take quickly about 10-15 minutes. In case there
is any irregularity, the physical inspection of exported products will be conducted.
Excise branch and CAMCONTROL, and owner or representative of goods.
3. Next, the exporter or declarant will pay an inspection fee of KHR 2,5000 per ton at
the CAMCONTROL cashier.
Step 3: Exit Bavet Border
After the custom declaration and inspection processes are complete, the exporter can
proceed to the border.
Exit Process
1. Go to the border and present the completed declaration form and supporting
documents to the Customs and Excise border officials.
2. The consignment is then allowed to pass through the Bavet border.
38 | P a g e

4.4. Exporting by Sea and River

4.4.1 Port of Sihanoukville
Port of Sinhanoukville Hours of Operation

Port Authority: 24 hours daily
The
Sihanoukville
Autonomous Port (PAS) is
the only deep sea port in
Cambodia. PAS is state
owned entrprise which is
under
the
direct
management
of
the
Chairman & CEO and
assistace of three Deputy
Directors General. The
container terminal annual
storage
capacity
is
370,000
TEUs.
PAS
offers:
navigational
service, handling service,
storage and warehosing
services, special economic
zone, and logisitic supply
base for offshore oil
exploitation.
Port of Sihanouk Ville Export Process

The Port of Sihanoukville export process can be captured in FOUR key steps. The
Step 1: Customs
Declaration
Step 2: Joint
Inspection
Step 3: PAS Port

Authority
Step 4: Exit PAS Port

Authority

The processes of customs declaration at the Port Authority are as follows:
1. Exporter or authorized person shall request to customs and excise branch at PAS the
permission of export by attaching supporting documents such as invoice, packing list,
export permit and authorization letter (if needed).
39 | P a g e

place
declaration.
packing list, export permit, transportation permit, and authorization letter (if needed). If
3. Next, the shipper will pay an inspection fee of KHR 2,5000 per ton at the
CAMCONTROL cashier.
Step 3: PAS Port Authority
The shipper will also need to make arrangements with the PAS Port Authority to unload
and load cargo at the Port. The following steps can occur at any time after Customs has
approved the shippers request to export.
1. First, provide the PAS Port Authority official at the entry gate with either the
approved Customs Declaration (if available) or Joint Inspection Report (if
available), demonstrating that the shipper has authorization to export.
2. After all documents are checked, the truck is allowed into the port.
Step 4: Exit PAS Port Authority
In order for the PAS Authority to unload, move and store cargo in the container yard,
the exporter must first make all necessary payments to the PAS Port Authority.
Exit Process
1. First, present Delivery Order (DO) issued by CAMSAB to the PAS Business
Department which issues service invoice by automation system.
40 | P a g e

2. Next, pay loading and unloading (LoLo) fees, and storage fee (if any) to PAS
Accounting and Finance Department:
Container LOLO fee: $47 (20-feet container) or $67 (40-45-feet container), plus
VAT. If the same container is previously imported through PAS, LOLO fee: $24
20-feet container) or $19 (40-45- feet container) plus VAT.
Storage charge is free for the first 5 days. If exceeding 5 days, storage charge is
applied back from the day one of storage: $3/day (20-feet container) or $6/day
(40-45-feet container) plus VAT.
Stevedoring pricing: $57 (20-feet container) or $86 (40-45-feet container) plus

VAT. This fee is directly charged from the shipping line.
Then, Accounting and Finance Department issues a receipt after the necessary
payment is made.
3. The Port Authority Container Operation Department will then proceed with loading
and unloading container.
4. Last, the PAS Invoice (Stevedoring charge) will be sent to the Shipping Line. The
Shipping Line will work closely with the Port officials and make a load list for the
cargo. The goods will then be moved from the container yard to the ship for export.
4.4.2 Phnom Penh Autonomous Port
Phnom Penh Autonomous Port

Port Authority: 24 hours daily
The Phnom Penh Autonomous

Port (PPAP) is publically listed
company with majority of
shares
owned
by
the
government. The Port Authority
is independent and has its own
Board of Directors and
managment.
PPAP new container terminal in
Kien Svay district accomodate
150,000
TEUs/year,
and
planned to expand to 300,000
TEUs/year after 2015, and
500,000 TEUs/year after 2018.
PPAP offers: handling services,
warehousing services, inland
container depot, passenger and
tourist terminal, and surveying
and dreging services.
The Phnom Penh Autonomous Port export process

The Phnom Penh Autonomous Port export process can be captured in FOUR key steps.
41 | P a g e

Step 1: PPAP
Port Authority
Step 2: Customs
Deckaration
Step 3: Joint
Inspection
Step 4: Exit
PPAP
Step 1: PPAP Port Authority

Before transporting goods to the Port, the exporter must receive approval from the
PPAP Port Authority. Exporters can receive approval and make arrangements several
days in advance.
Port Authority Approval Process
1. First, obtain a copy of Delivery Order (DO). The Delivery Order will be issued by
KAMSAB.
2. Next, bring the Port Authority for approval. Arrangements can then be made for the
cargo to be unloaded at the Port and later loaded on to the ship.
3. The fees for this service (LoLo fees) and storage charges will need to be paid. The
payment is made via bank account situated in the Port Authority. Then, exporter
need to bring the receipt of payment to the Port Authority cashier.
Container LOLO fee: $47 (20-feet container) or $71 (40-45-feet container), plus
VAT for general exported goods. For exports of agricultural products (including
fish and fishery products), LOLO fee: $36 (20-feet container) plus VAT.
Storage charge is free for the first 5 days. If exceeding 5 days, $3.5/additional
day (20-feet container) or $6.5/additional day (40-45-feet container) plus VAT.
For exports of agricultural products (including fish and fishery products),
storage charge for export is free for 18 days.
Stevedoring pricing (Terminal Handling Charges): $49 (20-feet container) or

$74 (40-45-feet container) plus VAT. This fee is directly charged from the
shipping line. The Port Authority will send the invoice and charge stevedoring
directly from the ship.
4. An invoice will then be issued. The invoice will need to be shown at the Port in
order for the container to be unloaded, stored and loaded onto the vessel.
Step 2: Customs Declaration
After the cargo is allow to enter the Port Authority, exporter must follow the custom
declaration at custom and excise office at PPAP.
42 | P a g e


declaration.
1. Custom and CAMCONTROL officials review the following documents: Invoice,
Packing List, export permit, transportation permit, and authorization letter (if needed). If
Excise and CAMCONTROL, and owner or representative of goods.
CAMCONTROL cashier.
Step 4: Exit PPAP
Upon completion of the Customs and Excise and joint inspection process, go to the Port
Authority official at the port and arrange for the cargo to be loaded.
Exit Process
1. Present the Port Authority Invoice Receipt and arrange for the cargo to be loaded
from the Port to the ship.
2. The cargo will be loaded onto the vessel for export.
43 | P a g e

4.5 Exporting by Air

4.5.1 Phnom Penh International Airport (PPIA)
The
Phnom
Penh
International Airport is
located
10km
from
downtown Phnom Penh on
Road # 4 (Russian Blvd).
The airport export process at
Sihanoukville and Siem
Reap,
while
slightly
different, should closely
match the process below.
PPIA
cargo
facilities
include
mechanical
handling,
air-conditioned
storage, refrigerated and
deep freeze storage, fresh
meat inspection, livestock
handling,
security
for
dangerous goods and very
large/heavy cargo.
Hours of Operation
CAMS Operation: 05:00 - 01:00 daily
Phnom Penh International Airport Export Process

The Phnom Penh International Airport export process can be captured in FOUR key
steps. The documentation and requirements are outlined below.
Step 1: CAMS
Permission
Step 2: Customs
Declaration
Step 3: Joint
Inspection
Step 4: Exits CAMS
Step 1: CAMS Permission

The PPIA export process begins with Cambodia Airport Management Services (CAMS)
located in the Cargo Terminal, adjacent to the airport. The Customs and Excise and
CAMCONTROL offices are also located inside the building.
CAMS Receiving Process
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1. To begin the export process, CAMS first needs to receive a copy of Airway Bill
document. The Airway Bill can be obtained directly from the airline or may be
provided by the shipping agent.
2. Next, move the cargo to the unloading dock. At this time a Shipper Declaration
Checklist (see specimen copy in appendix) will be filled out by CAMS staff and
signed off by the shipper. This document captures basic information about the
cargo, the number of pieces and weight (used to calculate gross weight) and declares
if the goods are dangerous or require special handling.
3. A Counting Report (see specimen copy in appendix) will then be completed by a
CAMS Official. This document is used to tally the goods being shipped and to
check that the labeling and packaging is appropriate for air transport.
4. Then Customs Declaration and joint inspection process can begin.
Step 2: Customs Declaration
After the cargo has been received, exporter must follow the custom declaration at
custom and excise office at PPIA.
declaration.
3. In addition, exporter declarant also attach shipper checklist and counting report with
declaration documents
packing list, airway bill, export permit, transportation permit, and authorization letter (if
needed). If a representative is handling the cargo for the seller, he/she will need to
provide a photocopy of an ID card and two photographs. If possible, provide a request
or authorization letter to let officials know who will be clearing the cargo and if they
have power of attorney. This process would take about 10-15 minutes on average. In
case there is any irregularity, the physical inspection of exported products will be
conducted.
CAMCONTROL cashier.
Step 4: Exits CAMS
After receiving approval from Customs and Excise, the exporter can begin the exit
process at the CAMS Administrative Office.
45 | P a g e

Exit Process
1. First, complete an Export Cargo Acceptance Form. The following supporting
documents need to be provided: airway bill, shipper declaration checklist, counting
report, customs declaration and any additional supporting documentation for exporting
special cargo such as live fishery products
2. Next, bring the completed Export Cargo Form to the cashier and pay the warehouse
handling charges. Payment is based on the cargos gross weight and if special handling
was needed.
For the first 3 days, from date of cargo arrival at warehouse including national
holidays, $0.04 per kg
For additional days, $0.04 per kg
Fractions of 50 kg will be charged as 50 kg
100% surcharges is applied if the cargo requires cold storage or the exported
product is live fish or fishery products
All payments are subject to 10% VAT.
3. Lastly, cargo is moved by CAMS into export storage and prepared for flight. Then,
CAMS follow instructions received from the airline. The goods will then be moved to
the aircraft for export.
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Chapter 3: Requirements of the importing countries

The summaries of requirements of importing countries are based on the compilation of
legal and SPS requirements of fishery products of potential importing countries which
has been prepared under the Project Standards Assessment for the Marine Fishery
Component of the Export Diversification and Expansion Program (CEDEP II),
implemented by UNIDO.
The content of such compilation has the objective to support and provide guidance for
the target two main outcomes of the Marine Fisheries Product component:
#1 - The needs of the marine fisheries product export sector are better
understood, the sector is better structured, the policy dialogue with the
Government is enhanced, and the enabling business environment is
improved;
#2 - A group of marine fisheries processors have become export-ready

and are increasing their export business including to new markets;
This compilation is however limited to the existing information made available by each
Official source of the selected importing countries, identified in each section of the
document. In complement it was also used the information made available from the
Canadian Food Inspection Agency by each exporting jurisdiction. Other exporting
country conditions may be found at CFIA at:
http://www.inspection.gc.ca/food/fish-and-seafood/exports/byjurisdiction/eng/1304197334656/1304197442121
This document was prepared acknowledging that the Kingdom of Cambodia does not
have any Import/Export Bilateral Agreement on Fish Products with any other country
and has not been listed in the EU country list for authorized establishments to export to
the European Market.
The document is therefore a guide for comprehensive understanding of the legal and
SPS requirements of fishery products necessary for exporting to the set of countries here
by identified.
47 | P a g e

1. VIETNAM
Competent Authority: National Agro-Forestry-Fisheries Quality Assurance
Department (NAFIQAD)
1. Bilateral dispositions and Summary of import requirements
A formal Bilateral Agreement signed between the exporting country and
Vietnam is advisable for ease of the exports. Most exporting countries to
Vietnam have signed a Bilateral Agreement covering this purpose,
facilitating the food safety controls and guarantees of the exported products.
Nevertheless the following requirements are applied:
a) Establishment need to be registered and approved in terms of having
implemented HACCP System (usually it is considered acceptable a
lower level of HACCP compliance in comparison with EU approved
establishments, when establishments are graded in terms of compliance
performance)
b) Processors must be on the Approved List of Cambodian FFP FBOs for
Export to Vietnam as maintained on the website of Vietnam's National
Agro-Forestry-Fisheries Quality Assurance Department (NAFIQAD).
c) Products are exported with specific Health Certificate;
Scope: the entire marine animals for human consumption, except
amphibians and reptiles sea.
Summary of Vietnamese applicable Legislation:
Circular No. 25/2010 / TT-BNNPTNT (8 April 2010) Guidelines on food

hygiene and safety on the import of foodstuffs of animal origin.
Circular No. 51/2010 / TT-BNNPTNT (8 September 2010) Changes /
amendments to Circular No. 25/2010 / TT-BNNPTNT and Circular
06/2010 / TT-BNNPTNT.
These are available at:
http://www.nafiqad.gov.vn/b-legal-documents
2. Procedure for the Food Hygiene and Safety Inspection to Exporting

Countries
a) The National Agro-Forestry-Fisheries Quality Assurance Department
(NAFIQAD) is the contact point in Vietnam for the export of fishery
products
into
Vietnam.
http://www.nafiqad.gov.vn/?set_language=en&cl=en
It is in particular the contact point:
48 | P a g e

to receive Registration documents from Competent Authorities of

exporting countries relating FHS conditions of FBOs registering to
export to Vietnam;
communicate to adopt annual inspection plan with Competent
Authorities of exporting countries and submit the Minister for
establishment of inspection mission to exporting countries;
to publish lists of FBOs approved to export products of animal
origin to Vietnam; to suspend FBOs to export to Vietnam;
communicate notifications on noncompliance cases, request to
investigate non-compliance causes and establish corrective actions
to Competent Authorities of exporting countries;
to build up Pre-mission questionnaires for Competent Authorities of
exporting countries;
to set up and carry out inspection plans and programs to exporting
countries to access their FHS control system and FBOs of products
of animal origin.
b) Submission of application for exporting to Vietnam.

Competent authorities of exporting countries provide the National AgroForestry Fisheries Quality Assurance Department of Vietnam with the
required registration documents, including:
- List of food business operators registering to export products to Vietnam
- Information on FHS control system and competencies of FHS Competent
Authorities of exporting countries
- Summary on FHS conditions of the food business operator
For all requested documents, forms are available in the appendixes of
Circular No. 25/2010, downloadable at: http://www.nafiqad.gov.vn/b-legaldocuments
c) Within 30 working days of receipt of completed registration document, the
National Agro-Forestry-Fisheries Quality Assurance Department, together
with the Department of Animal Health verify registration document, inform
Competent Authorities of the exporting country of the verification result
and inspection plan to the exporting country if necessary.
d) Inspection items:
1. Legal system on food hygiene and safety control;
2. Competencies of FHS Competent Authorities of exporting countries;
3. FHS conditions of FBOs registering to export to Vietnam.
e) Type of inspection:
1. Initial inspection to assess exporting countries FHS control system
and their FBOs hygiene conditions for approval.
49 | P a g e

2. Follow-up inspection to check the on-going performance of FHS

control system by exporting countries and of FHS conditions by
approved FBOs.
f) Inspection reports and communication on list of FBOs approved for export
to Vietnam:
1. When on-site inspection to the exporting country is considered
unnecessary, the National Agro-Forestry-Fisheries Quality
Assurance Department publishes the result of registration document
checks, together with its list of FBO approved for export to
Vietnam.
2. When on-site inspection to the exporting countries is considered
necessary, within 30 working days after the inspection, the National
Agro-Forestry-Fisheries Quality Assurance Department publishes
the on-site inspection report, its list of FBOs approved for export to
Vietnam.
When inspection result is not satisfactory, the National AgroForestry-Fisheries Quality Assurance Department informs
Competent Authorities of exporting countries of the noncompliance.
3. In case of request for additional FBOs approved to export to
Vietnam, the Competent Authority of the exporting country submits
additional registration document.
As the result of document check and/or on-site inspection to the
exporting country, additional FBOs shall be approved to export to
Vietnam or not.
g) Inspection of products at the border. Products will be subject to inspection
and random sampling for testing. Criteria are set out in the National
Legislation.
h) Actions in case of Non-compliance.
1. Non-compliant Products.
Depending on the seriousness of non-compliance, appropriate
actions shall be applied to products: being re-dispatched or
destroyed.
Competent Authority of the exporting country shall be required to
investigate cause of non-compliance and apply corrective actions.
2. Non-compliant FBOs.
Import suspension from non-compliant FBOs shall be applied to the
FBOs where the result of follow-up inspection shows that the
FBOs food hygiene conditions have not fully met Vietnamese
regulations.
50 | P a g e

The import suspension shall be lifted providing that the result of

later follow-up inspection reflects the FBOs compliance with
Vietnamese regulations on food hygiene and safety.
3. Non-compliant Exporting Country.
Import suspension shall be applied to an exporting country when the
result of follow-up inspection shows that the FHS control system of
the country has not fully met Vietnamese regulations.
The import suspension shall be lifted providing that the result of
later follow-up inspection reflects that the FHS control system of
the exporting country has fully met Vietnamese regulations.
i) Charges for inspections to exporting countries.
Inspections to exporting countries are covered by the State Budget.
Inspection and supervision to imported products placed on the market is
covered by the State Budget.
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2. China
Last information update: August 28, 2014
Competent Authorities:
General Administration of Quality Supervision, Inspection and Quarantine
(AQSIQ)
Certification and Accreditation Administration of the People's Republic of China
(CNCA).
1. Bilateral dispositions and summary of import requirements

A formal Bilateral Agreement signed between the exporting country and China
is advisable for ease of the exports. Most exporting countries to China have
signed a Bilateral Agreement covering this purpose, facilitating the food safety
controls and guarantees of the exported products. Nevertheless the following
requirements are applied.
a. Establishment must be registered (has a registration number), not
necessary based on product specifications
b. Establishment unit has HACCP implemented (usually it is considered
acceptable a lower level of HACCP compliance in comparison with EU
approved establishments, when establishments are graded in terms of
compliance performance).
c. Products are exported with specific Health Certificate; (Imposition of
appropriate regulatory models includes new HC - 135 June 25, 2012).
d. Products conform with
2. Establishment Registration and Listing
Except in the case of establishments that ship live product only, the fish
processing establishment's name must appear on the list of establishments of the
exporting country for exports to the People`s Republic of China. To be included
on this list: processing establishments and cold storage warehouses.
For any exports to the Peoples Republic of China two separate registration
processes must be carried out in advance of exporting any fishery products to
this destination.
This involves separate registrations with two Chinese authorities as follows, the
General Administration of Quality Supervision, Inspection and Quarantine
(AQSIQ) and the Certification and Accreditation Administration of the People's
Republic of China (CNCA).
Registration with the AQSIQ must be carried out by the exporter / agent
themselves while registration with the CNCA can be carried out through the
exporting country Competent Authority.
Since the 1st of October 2012 Chinas AQSIQ has introduced a system requiring
the registration with its Inspection and Quarantine Bureau of exporters of food
52 | P a g e

products to China. This registration process can be carried out online by the
relevant exporter/agent through their website: http://ire.eciq.cn
In case of registration through the exporting country Authority, information
required as part of this process includes exporter / agents name, address details,
contact details, relevant food category, Chinese trade partner details etc.
A separate registration process is required for fish and fishery products
processed at processing establishments or stored at cold storage warehouses to
be eligible for export to the People's Republic of China, as of the 1st of
May 2013.
These establishments and warehouses must be registered with the CNCA, and
subsequently appear on the List of the exporting country establishments
approved for export to the People's Republic of China as maintained by the
CNCA.
3. Certificate issuance
For fresh and frozen products including bivalve molluscan shellfish, the
certificate should include:
Under Section II. Origin of the fishery products, "Production place"

should be completed by identifying the appropriate Regional Area if
applicable.
For all wild caught fish, the name and registration number of one of the
fishing vessels used to harvest the fish as well as the FAO fishing area
must be provided on the certificate.
For all aquaculture fish, the name and address of one of the fish farms
where the fish were raised must be provided on the certificate.
Under Section II. Origin of the fishery products, "Name(s), registration
number(s) and address(es) of producing and processing enterprise(s),
factory vessel(s), cold store(s) or freezer vessel(s) registered by the
Cambodian Competent Authority for export to the People's Republic of
China," identifying all which are applicable (i.e. the processor and the
cold storage).
For live product, including live bivalve molluscan shellfish: Origin and Hygiene
Certificate for live fish intended for export for human consumption from Canada
to the People's Republic of China (CFIA/ACIA 5584).
For all live bivalve molluscs, under Section II. Origin of the fishery
products, the FAO fishing area and the harvest area must be provided in
the space under the heading "Fishing Region". For Cambodian harvest
areas, the harvest areas must be indicated as they appear on the List to be
done for designating the Cambodian bivalve harvest areas.
Under Section II. Origin of the fishery products, "Name(s), registration
number(s) and address(es) of producing and processing enterprise(s),
factory vessel(s), cold store(s) or freezer vessel(s) registered by the CA
53 | P a g e

for export to the People's Republic of China," identify all which are
applicable.
4. Chemical Contaminants Tolerances and Guidelines
Maximum level of contaminants in fish products:
Lead: 0.5 ppm

Mercury: 1.0 ppm (for carnivores)
Mercury: 0.5 ppm (other fish)
Inorganic arsenic: 0.1 ppm for finfish / 0.5 ppm for all other fish
Cadmium: 0.1 ppm (finfish only)
Total PCB: 2.0 ppm (sum of PCB congeners #28, 52, 101, 118, 138, 153 and
180)
PCB 138: 0.5 ppm
PCB 153: 0.5 ppm
List of Tolerances and Guidelines for Therapeutants and Antibiotics

Item
Products
Standard
Chloramphenicol
Aquaculture and wild caught

fresh water fish
None Detected
Crystal Violet (and

Leucocrystal violet)

fresh water fish
None Detected
Furazolidone
Not specified
None detected
Malachite Green (and

Leucomalachite green)

fresh water fish
None detected
Nitrofurans

fresh water fish
None Detected
Quinolones

fresh water fish
= 0.1 mg/kg
Stilbestrol
Not specified
None detected
Sulfonamide

fresh water fish
= 0.1 mg/kg
Terramycin
Not specified
= 0.1mg/kg muscle
Uritrate (Oxolinic Acid)
Eels
= 0.3 mg/kg muscle

and skin
54 | P a g e

(1 mg/kg = 1 ppm)
5. Microbiological Criteria
Non official information available. However from the practice within other exporting
countries to China the following has been considered:
-
Application of Codex Standards;
Absence / negative testing of: E.coli (0157); Salmonella; Listeria

monocytogenes, Vibrio parahaemolyticus; Vibrio Cholerae.
6. Other Information
Further information on import requirements can be obtained from the General
Administration of Quality Supervision, Inspection and Quarantine of the People's
Republic of China. (http://english.aqsiq.gov.cn/)
Exporters should carefully discuss regulations and their application with Chinese
importers to ensure that their interpretation of the regulations is accurate.
55 | P a g e

3. Hong Kong
Last information update: 2014-09-24
Competent Authority: Food and Environmental Hygiene Department
1. Certification Requirements
Products Cooked Prior to Consumption:
Certification of air-freighted shipments using a Certificate of Origin and
Hygiene will expedite customs clearance.
Products Destined for Raw Consumption (e.g., molluscan shellfish):
Certificate of Origin and Hygiene.
Live Crustacea (i.e., lobster and crabs): Shipments of live lobster must be
accompanied by a Statement of Inspection (for non-registered plants) or a
Certificate of Origin and Hygiene.
2. Hong Kong Acts and Regulations
Food Hygiene Code:
Food and Environmental Hygiene Department, Safe Food and Public Health
http://www.fehd.gov.hk/english/publications/code/code_index.htm
3. Tolerances or Guidelines
Environmental Contaminants - Maximum level permitted in applicable fish
products
Metal
Applicable Fish Products
Maximum level
permitted
(in ppm)
Antimony
All fish products excluding molluscs and

crustaceans other than crab, oyster, prawn and
shrimp
Arsenic
All fish products (excluding molluscs and

crustaceans) in solid form
Arsenic
All fish products in liquid form
Arsenic
All shellfish products (molluscs and

crustaceans) in solid form
10
Arsenic
Marine mammals (seals)
1.4
56 | P a g e
0.14

Cadmium

shrimp
Cadmium
Marine mammals (seals)
Chromium

shrimp
Lead
All fish products in liquid form
Lead
All fish products in solid form
Mercury
All fish products
0.5
Tin
All fish products
230
0.2
The following hormones are prohibited for use in all fish products: dienoestrol,
diethylstilboestrol, hexoestrol and oestradiol.
Fish products exported to Hong Kong cannot contain preservatives or
antioxidants unless specified in the following table.
Preservatives which are permitted in the following Fishery Products only

Fishery
Product
Preservative
Fish ball, fish

cake, and dried
shredded fish
Fish sauce
Fish sauce
Sorbic acid / Sodium sorbate / Potassium

sorbate / Calcium sorbate
Benzoic acid / Sodium benzoate / Potassium
Benzoate / Calcium benzoate
Methyl para-hydroxybenzoate
Ethyl para-hydroxybenzoate
Propyl para-hydroxybenzoate
Sulphur dioxide / Sulphurous acid / Sodium

sulphite / Sodium hydrogen sulphite / Sodium
metabisulphite / Potassium sulphite / Potassium
metabisulphite / Calcium sulphite / Calcium
hydrogensulphite

57 | P a g e
Maximum
level
permitted
1000 ppm
350 ppm
800 ppm

Gelatin
Sulphur dioxide / Sulphurous acid/ Sodium

sulphite/ Sodium hydrogen sulphite/ Sodium
metabisulphite / Potassium sulphite/ Potassium
metabisulphite/ Calcium sulphite/ Calcium
hydrogensulphite
1000 ppm
Gelatin
capsules
Sorbic acid / Sodium sorbate / Potassium sorbate /

Calcium sorbate
3000 ppm
Oyster sauce
Prawn, shrimp
and scampi
Shrimp paste

Sorbic acid / Sodium sorbate / Potassium
sorbate / Calcium sorbate
Sulphur dioxide / Sulphurous acid / Sodium

sulphite / Sodium hydrogen sulphite / Sodium
metabisulphite / Potassium sulphite / Potassium
metabisulphite / Calcium sulphite / Calcium
hydrogensulphite

1000 ppm
200 ppm (in

the edible part)
1000 ppm
4. Other Information
For further information please contact the importer/client in Hong Kong.
Further details on the restrictions concerning the sale of food containing
preservatives or antioxidants are available from the Hong Kong Food and
Environmental
Hygiene
Department
(http://www.gov.hk/en/residents/health/hosp/#/en/residents/health/foodsafe/ )
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4. South Korea
Competent Authority
-
KFDA (Korea Food and Drug Administration) - Imported Agricultural Products,

Processed Foods, Food Additives, Utensils, Containers & Packages or Health
Functional Foods:
NFIS (National Fisheries Products Quality Inspection Service) - Imported Marine
products (Fresh, chilled, frozen, salted, dehydrated, eviscerated marine produce which
can be recognized its characteristics)
1. Bilateral dispositions and summary of import requirements
A formal Bilateral Agreement signed between the exporting country and Korea is
advisable for ease of the exports. Most exporting countries to Korea have signed a
Bilateral Agreement covering this purpose, facilitating the food safety controls and
guarantees of the exported products. Nevertheless the following requirements are
applied.
a. Establishment must be registered (has a registration number), not necessary
based on product specifications;
b. Schedule for registration number within the following registration period:
the second week of March, June, October and December;
c. Establishment unit has HACCP implemented (usually it is considered
acceptable a lower level of HACCP compliance in comparison with EU
approved establishments, when establishments are graded in terms of
compliance performance).
d. Products are exported with specific Health Certificate;
e. Establishments are annually inspected by CA of Korea;
f. HACCP and sanitary program consistently implemented and in accordance
with the requirements laid down in Codex Code of Practice for Fish and
Fishery Products (CAC/RCP 52-2003).
See detailed description of import system into Korea in annex.
2. Tolerances or Guidelines
(Last information update: April 22, 2013)
Contaminant
Levels by product type
Cadmium:
2.0 ppm - for molluscs

1.0 ppm - for crustaceans, except swimming blue crab
(Portunus trituberculata) with intestines
5.0 ppm - swimming blue crab (Portunus trituberculata)
68 | P a g e

with intestines
Copper
Zinc
Lead
60.0 ppm
40.0 ppm
1.0 ppm - for crustaceans, except swimming blue crab

(Portunus trituberculata) with intestines
2.0 ppm - swimming blue crab (Portunus
trituberculata) with intestines
0.3 ppm - all other products
0.5 ppm - except for shark, tuna and grouper
Mercury
Antibiotics are prohibited.

Food Additives Approved
Redfish: Sustane Emulsion T

Antioxidant composed of Butylated hydroxytoluene.
Frequency of sampling and testing

South Korea's new government regulations Special Inspections on Imported
Fishery Products in 2014 imposes mandatory specific frequencies of sampling and
testing of fish products according to the substance / contaminant and the country of
provenience of the imported products, namely:
Nitrofuran
Chloramphenicol
Carbonmonoxide
Sulphurdioxide
Benzopyrene (smoked fish products)
Further information can be obtained from the Korean Food and Drug
Administration (http://www.mfds.go.kr/eng/index.do)
2|Page

5. Japan
Last update: June 18, 2013
Competent Authority: Ministry of Health, Labour and Welfare
A) Introduction
Exports to Japan rely specifically on the import procedures to be taken in Japan by the
importer. Food-related business operators including a person who intends to import foods that
have been manufactured, processed, etc., in another country are required to recognize that
they themselves bear primary responsibility for ensuring food safety, and to appropriately take
necessary measures to ensure food safety at each stage of the food supply process. Moreover,
under Article 3 paragraph 1 of the Food Sanitation Law (Law No. 233 of 1947;), they are also
required to take responsibility for obtaining necessary knowledge and techniques, ensuring the
safety of raw materials, practicing self-imposed examination and taking any other measures to
ensure the safety of imported foods, etc.
The Imported Foods Monitoring and Guidance Plan sets out basic matters for guidance
to importers based on these responsibilities, and promotes the practice of hygiene control.
However, owing to recent cases of chemical food poisoning, etc., it has now become
necessary to ensure and confirm the safety of imported processed foods in the exporting
country to a level equivalent to that within Japan, at all stages of the food supply process
including raw materials, manufacturing and processing, storage and transportation.
B) Summary of Requirements imposed to the Japanese importer

These requirements are important to understand in the sense they will therefore identify what
will be indirectly imposed also to the exporter.
1. Food is manufactured and processed in compliance with the laws and regulations of
the exporting country. In particular, when there is a system of registration of
manufactory, a system of permission for product exports, or other such system in the
exporting country, that these are properly observed.
2. That the standard of establishments, facilities and equipment of the manufactory is at
least equal to the standards concerning establishments, facilities and equipment
stipulated in related Japanese laws and ordinances, etc.
3. That the standard of hygiene control in manufactory is at least equal to the following
standards concerning hygiene control stipulated in related Japanese laws and
ordinances, etc. It should be noted that using methods of hygiene control based on
HACCP system is also effective, and the active introduction of these is recommended.
a. Hygiene control in the harvesting of fishery products
b. Hygiene control in food handling establishments, etc.
3|Page

c. Hygiene control by food handlers and others in food handling

establishments, etc.
d. Training for food handlers and others in food handling establishments,
etc.
Specific References:
- Guidelines on Management and Operation Standards to be Observed by FoodRelated Business Operators (Annex to Notice Shoku-an No. 0227012 of February
27th, 2004; hereinafter Guidelines on Management and Operation Standards)
(PDF:33KB)
- Procedure for Implementation of the Total Hygiene Controlled Manufacturing
Process Approval System (Annex to Notice Sei-ei No. 1634 of November 6th, 2000)
(Under translation)
- General Principles of Food Hygiene (CAC/RCP 1-1969, Rev. 4-2003)(PDF:115KB)
- Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its
Application (Annex to CAC/RCP 1-1969, Rev. 4-2003)(PDF:73KB)
4. Importers should confirm the following matters with manufacturers at the stage of
accepting raw materials.
4.1 That quality criteria including Specification and Standards based on Japanese Law
have been established for each raw material, and that it has been confirmed that each
delivery lot complies with these. Specifically, importers should aim to procure raw
materials for which the use of agricultural chemicals, veterinary drugs and other
production materials, etc., is clear from contracts or other documentation shared with
specific producers or vendors. Meanwhile, basic matters for confirmation in
accordance with the characteristics of raw materials are mainly those shown below.
a) Foods in general (universal matters)
That, when harvesting agricultural, livestock and fishery products to be used

as raw materials, measures are taken to prevent contamination by dirt or
wastewater, as well as measures to prevent contamination by agricultural
chemicals, veterinary drugs, feedstuffs, fertilizers, faecal and others, by
appropriately managing poisonous substances, wastes, etc.
That, when harvesting, storing and transporting agricultural, livestock and
fishery products to be used as raw materials, measures are taken to prevent
contamination by rodents, insects, chemicals, foreign matter, microorganisms, etc.
That additives for which there is no designation based on Japanese Law have
not been used.
That additives that do not comply with Specification and Utilization
Standards based on Japanese Law have not been used, and that the
appropriate amount have been used.
In the case of fresh vegetables, fish and shellfish, etc., that no colorants or
other additives that may mislead consumers in the determination of quality or
freshness are used.
4|Page

That compositional standards, manufacturing and processing standards, and

other Specification and Standards based on Japanese Law have been met.
That sterilization or other processes using irradiation not permitted in
Specification and Standards based on Japanese Law have not been conducted.
That the formal names, composition, and other details of raw materials and
additives used are clearly notified.
That drug substances specified in Pharmaceutical Affairs Law have not been
included (Law No. 145 of 1960).
That the history of food use, etc. in the exporting country is available.
b) Fishery products and products processed from them
That measures are taken to prevent contamination by Vibrio

parahaemolyticus and other pathogenic micro-organisms.
That shellfish are caught in seas in which shellfish poisoning is appropriately
monitored.
That species of blowfish are those whose import is permitted.
That measures are taken, through identification of fish species, to prevent
contamination by other species of blowfish.
That measures are taken to confirm the sea area subject to catches and,
through proper identification of fish species, to prevent contamination by
poisonous fish.
That the use of veterinary drugs and feed additives has been confirmed.
That maximum residue limits for veterinary drugs and feed additives based
on Japanese Law have been met.
That the matters listed in above have been confirmed by regular tests, inspections, etc
c) No raw materials should be accepted if it is known to contain parasites,
pathogenic micro-organisms, poisonous substances, decomposed matter,
deteriorated matter or foreign matter which would not be eradicated or
removed to an acceptable level by normal processing, cooking, etc.
4.2 When the monitoring results carried out by an administrative organ or other body in
the exporting country are available, importers should confirm the results, but should
also import samples and confirm said results by means of tests and inspections inside
Japan whenever necessary.
4.3 That each raw material has been subjected to appropriate lot management
5. Importers should confirm the following matters with manufacturers at the stages of
manufacturing and processing products.
5.1 That a system of control has been arranged to ensure that food can be manufactured
and processed under a hygienic condition. As measures for preventing contamination
by poisonous or harmful substances, in particular, that the following matters are
thoroughly observed.
a. Hygiene control of establishments, facilities and equipment, etc.
b. Measures against rodents and insects
5|Page

c. Handling of wastes and waste water

d. Handling of foods, etc.
e. Management of water used, etc.
f. Hygiene control of food handlers
5.2 That persons responsible for food hygiene have been appointed to each food handling
establishments or each division.
5.3 That it has been confirmed, through regular tests and inspections, that final products
comply with Specification and Standards based on the Japanese Law. Importers
should also confirm this, whenever necessary, via tests and inspections by a official
laboratory in the exporting country, or inside Japan.
6. Importers should confirm the following matters with manufacturers at the stages of
storage, transportation and distribution of products.
6.1 That products are handled hygienically during storage, transportation and
distribution, and that the following matters are thoroughly applied as measures to
prevent contamination by poisonous or harmful substances.
a. That measures are taken to prevent contamination of food through appropriate
handling of insecticides, etc.
b. That vehicles, haulage containers and others used for transporting foods are not
those which could contaminate the foods, containers or packaging. Also, that
their structure makes them easy to wash and disinfect, and that they are always
kept in a clean condition.
c. That, when foods and loads other than foods are mixed, if necessary, the food
is put in appropriate containers and separated from the other loads to prevent
contamination.
d. That foods are controled during transportation in such a way as to avoide
contamination by dirt, toxic gases.
e. That, when vehicle or haulage container once used for transporting different
commodities of food or loads other than foods is re-used, the vehicle or
container is washed effectively and disinfected as needed.
f. That appropriate lot management has been carried out, and that any
abnormalities in volume and packaging condition, etc., are confirmed as the
situation demands.
6.2 Besides the matters listed in (6.1) above, that the following matters have been
confirmed.
a. That appropriate temperature control is carried out to prevent the occurrence of
safety hazards owing to the reproduction of micro-organisms.
b. That there is no decomposition or deterioration caused by accidents or
inappropriate temperature control, etc.
c. That, when preservation standards based on the Japanese Law have been
stipulated for foods, these have been observed.
6|Page

d. That salt-cured and other foods, etc., have not been stored outdoors for long
periods.
e. That establishments are managed so that outsiders cannot access them without
permission.
C) Information on Tolerances and Guidelines
(PSP) toxin in the Live Lobster hepatopancreas and Lobster Products, Oysters and
other Bivalves meets Japan's standard of 80 g/100 g.
Total mercury - 0.4 ppm (does not apply to tuna or sturgeon, fish oils, gelatin or other
fish by-products)
Methyl mercury - 0.3 ppm (does not apply to tuna or sturgeon, fish oils, gelatin or
other fish by-products)
PCB - 0.5 ppm (does not apply to fish oils, gelatin or other fish by-products)
Further information can be obtained from the Japan Authority: Ministry of Health, Labour
and Welfare. http://www.mhlw.go.jp/english/
D) Specific PSP Product Control Measures for Lobster
Intent - Exporters ship lobsters that will satisfy the importing country's requirements.
Requirements
1. The plan must provide a full description of the type of lobsters that are being
exported :
the primary method of preservation (eg., fresh/live, frozen, canned), the

form (eg., live, whole, meat, tomalley) and any other secondary
processing (cooked);
the origin of lobsters that specifies as a minimum, the date of harvest and
the Lobster Fishing Area (LFA) designated by the Department of
Fisheries and Oceans; and
the identity of the establishment(s) where the lobsters were stored,
processed, and packaged with confirmation that the establishment(s)
operated with a Quality Management Program Plan or equivalent in
compliance with the Fish Inspection Regulations.
2. The plan must provide a full description of the controls for incoming live
lobsters to ensure that they were harvested, handled and transported to the
establishment under sanitary conditions (according to appropriate sanitary
Schedules).
3. The plan must describe the process to control each lot before shipping to
verify that it will meet the importing countrys standard for PSP.
This control must include testing to check lobsters for the presence or absence
of PSP. Testing may be performed by the exporter or by a third party. The
testing procedures must clearly specify what is being tested, how it is being
7|Page

tested, at what frequency, and by whom. The frequency must be sufficient to

control shipments to satisfy the importing countrys PSP standard.
The procedures to test lobsters should consider factors, such as, but not
limited to:
the size of the LFA and variations in the occurrence of PSP throughout
the LFA;
historical knowledge and other sources of information about the
occurrence of PSP in lobsters from the LFA;
migration patters;
changing conditions that would indicate an increased probability in the
occurrence of PSP in a LFA or portion of the LFA; and
the capacity to segregate lobsters from different parts of the LFA.
Exporters may wish to consider arrangements with other parties to enhance

their knowledge about PSP and lobsters as part of their efforts for continuous
improvement of their testing procedures.
Exporters may supplement product testing with additional controls. Examples
may include, but are not limited to, checking:
documents regarding the origin of incoming lobsters to verify that they

are complete and accurate; or
quantities and description of incoming lobsters to verify that they
correspond to accompanying documents.
The objective of this control is to provide exporters with the means to

continuously gather and review information about the levels of PSP in lobsters
in order to prevent the shipment of lobsters with unacceptable levels of PSP.
E) Non-partner State Rules
JAPAN 24 HOURS ADVANCE FILING RULES (AFR) NEW RULE JAPAN
CUSTOM
The Regulation "Japan 24 hours advance filling" has effect from March 1, 2014. It
consists of the following requirements:
The document should be sent to Japan Customs 24 hours before the ship departed from
the Port of Loading (POL)
Description obligatory on the Bill of Loading (BL) which is in "Advance Filing Rule"
is as follows: nomor telpon; kode pos pengirim dan penerima
1. name; complete address; telephone number; zip code sender and receiver
2. Product code - Minimal consists of 6-digit codes (HS6 codes) per cargo
3. The type and number of packaging
4. size
8|Page

5. number seal
6. For delivery of goods with a wide range of commodities, shall be specified by
commodity
7. A maximum of 100 containers per BL
8. The exact description of the cargo - general information not allowed
9|Page

6. Canada
Competent Authority: Canadian Food Inspection Agency (CFIA)
A) Bilateral dispositions and summary of import requirements
Fish and fish products imported into Canada are inspected to prevent the marketing of
unsafe or unwholesome or mislabelled products. Inspection effort is directed at foreign
processors which have demonstrated a history of poor compliance with Canadian
standards. On the other hand, inspection effort is reduced through the establishment of
Memoranda of Understanding (MOUs) or Mutual Recognition Agreements (MRAs)
with other countries having reliable inspection systems.
A formal Bilateral Agreement signed between the exporting country and Canada is
therefore advisable for ease of the exports. Most exporting countries to Canada have
signed a Bilateral Agreement covering this purpose, facilitating the food safety
controls and guarantees of the exported products. The following requirements are
applied to the exporting country:
Exporting Establisment is required to have HACCP implemented programme

(usually it is considered acceptable a lower level of HACCP compliance in
comparison with EU approved establishments, when establishments are graded in
terms of compliance performance).
Exported Products are required to have issuance of Health Certificate for Exports
to Canada
Establishments will be subject to a certain testing plan to be implemented by the

Competent Authority of the exporting Country and/or by Canadian Authority. The
sampling frequency will vary depending on the establishment has undergone prior
registration for exporting to Canada and been approved. Example: For Indonesia it
is applied a 5% testing plam, while for non-registered establishments it is applied
15% testing.
B) Overview of Canadian Fish Import Program Policy

1. Purpose
The purpose of the fish import program policy is to define the intent and objectives
of the Fish Inspection Act and Regulations and the approach taken by the Canadian
Food Inspection Agency (CFIA) to enforce the applicable regulations as they relate
to the importation of fish and seafood products into Canada.
2. Authority
This regulatory policy is issued under the authorities of the Fish Inspection Act and
the Fish Inspection Regulations.
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The Canadian Food Inspection Agency is responsible for enforcing the food safety
policies and standards that Health Canada sets.
http://www.hc-sc.gc.ca/fn-an/securit/index-eng.php
http://www.inspection.gc.ca/eng/1297964599443/1297965645317
3. Scope
This policy applies to all individuals or corporations importing fish and seafood
products into Canada for commercial purposes as food for human consumption. This
policy applies to the CFIA and its authorized representatives or agents, who are
involved in the administration and enforcement of the Fish Inspection Act and
the Fish Inspection Regulations.
4. Policy Statement
The objective of the Fish Inspection Act and Regulations is to provide reasonable
assurances that fish and seafood products imported into Canada for commercial
purposes as food for human consumption are safe and meet regulatory requirements.
To achieve this, the CFIA is committed to a fair, open, transparent and consistent
regulatory approach in the development, implementation and continuous
improvements of a Canadian Fish Import Program.
5. Policy Requirements
5.1 Licensed importers are responsible for ensuring that they import fish and seafood
products that meet all applicable regulatory requirements, including the regulations
made under the authority of the Fish Inspection Act, the Food and Drugs Act,
the Consumer Packaging and Labelling Act and the Canadian Food Inspection
Agency Act.
5.2 The CFIA verifies compliance to Canadian regulatory requirements and works
with the competent authorities of Canada's major trading partners to provide
reasonable assurances that imported products are safe and meet regulatory
requirements.
5.3 The Canadian Fish Import Program incorporates a risk-based approach and
provides importers with flexibility to demonstrate product compliance.
C) Product Inspection
Product inspections are conducted in accordance to the procedures set out in the Fish
Products Inspection Manual, Chapter 2 (http://www.inspection.gc.ca/food/fish-andseafood/manuals/fish-products-inspectionmanual/eng/1352139208050/1352145864299 ). Products subject to inspection
undergo an initial inspection for the test(s) which have been identified. The lot is
sampled for testing in accordance to the procedures which apply for the tests being
conducted. Test results are assessed against Canadian standards and guidelines. If the
test result(s) do not meet Canadian standards, the lot is rejected and cannot be sold or
11 | P a g e

distributed in Canada. The lot can undergo a re-inspection for the tests which failed
provided that the product does not have in or upon it any poisonous or harmful
substance.
In Annex 1 it is shown the full procedure and identification of the standards as well as
the links to have access to each.
D) Annual Sampling Plan and basic testing parameters
Available at: http://www.inspection.gc.ca/food/fish-and-seafood/imports/productinspection/eng/1360343085758/1360343335938?chap=4#s1c4
The CFIA develops a risk based annual product sampling plan for assessing the
compliance of fish products considered to be "good order" product. The sampling plan
sets out the type and number of tests to be conducted on an annual basis for the
assessment of imported lots which are not listed on the MIL.
The following schematic provides an overview of the process for the development and
adjustment of the annual product sampling plan.
Description for Schematic - Annual Sampling Plan

The annual sampling plan targets are based on an overall sampling target of 5% of the
estimated annual lots imported by Basic importers and is developed based on an
annual review of following information:
imported fish product risk profiles;

product inspection coverage;
product inspection results;
information acquired through environmental scanning activities; and
program priorities
Based on the results of the annual review assessment, the target sampling frequencies
for the specific species and product risk groups are developed for the upcoming fiscal
year.
The CFIA conducts semi-annual reviews of the product inspection results and makes
adjustments to the annual sampling plan as necessary.
Mandatory Inspection List (MIL)
The MIL, which is maintained by the CFIA, is a list of imported fish products which
have failed inspection. Subsequent imports of the same risk group from the same
producer, as identified on the MIL, are required to undergo testing for the specific
test/analysis indicated on the MIL.
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Addition of Product to the Mandatory Inspection List

When a lot of imported fish product is inspected and the results of a test indicates that
the product does not meet Canadian standards, the fish product and the producer are
added to the Mandatory Inspection List for each test that does not meet regulatory
standard.
Description for Schematic - Import Product Inspection Process

The MIL commonly listed tests
The tests performed are either linked to species risk or to product processing risk. The
following table provides examples of the common tests and test group names that are
linked to the MIL.
Tests Related to Species Risk
Environmental
Contaminants
Polychlorinated biphenyls (PCBs), Dioxin-like PCBs,

Dioxins, Furans, Pesticides, Mercury, other heavy metals
Marine Toxins
PSP, DSP, ASP, Ciguatoxin
Drug
Residues/
Therapeutants
Amphenicols, Tetracyclines, Sulfonamides, Quinolones,

Fluoroquinolones, Nitrofurans, Triphenylmethane dyes,
Avermectins, Macrolides
Spoilage
indicator
Histamine
Other Species
Test
n/a
Tests Related to Product / Processing Risk

Safety
Parameters
salt content, pH, water activity (aw), moisture content
Food
Additives
Borates, Sulphites, Phosphates etc.
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Food
Pathogens
E.
coli, Listeria
monocytogenes, Staphylococcus
aureus, Salmonella spp., Vibrio spp.
Other
Product
Tests
Sensory, net content determination, label1 electrophoresis

species identification
Package Tests
Container integrity; package integrity; can coding, sterility
Footnote 1
Label infractions which pose a Health and Safety risk are posted on the MIL.
All subsequent imports from the same product risk group and producer with
the same Brand Name will be inspected until there is acceptable label
correction made which applies to all subsequent imports. Label infractions of
a technical nature are dealt with at the importer level. The CFIA captures all
label infractions under an importer's record of compliance as a failure to meet
fish import licence requirements.
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7. European Union (EU)

Directorate General for Health and Food Safety European Commission
Food and Veterinary Office
1. Summary of Requirements
1.1. Sanitary Requirements
Three Basic Sanitary Requirements are necessary to be fulfilled:
1st
Official Control, undertaken by formally established Competent
Authority of exporting country, should be equivalent to EU and recognition
shall be acquired by the EU through a Council Decision laying down: Special
Conditions Governing Imports of Fishery and Aquaculture Products
Originating in .. following an audit visit to the country by EU-DG Sanco.
2nd
Industry Operators Export Establishments, need to have an EU
Approval Number and be listed in EU list of approved establishments.
Approval is annually given in reference to their compliance (accomplishment
and performance of EU hygiene requirements) in particular in the
implementation of the HACCP System (and in practice fulfilling high level
performance).
https://webgate.ec.europa.eu/sanco/traces/output/non_eu_listsPerCountry_en.ht
m
3rd
Products when exported require a Health Certificate (EU format). Only
EU Approved Establishments are eligible for exporting their products into EU
market. Every export consignment from individual establishments requires a
HC.
Requires:
A. Officially designated Competent Authority with appropriate legal powers and
capacity (resources, staff, equipment, organization) to fulfill effectively the task of
Official Control.
B. Existence of appropriate Legislation in the country to be equivalent to the
European Legislation, covering the hygiene matters of fishery products and the
organizational scheme for official controls.
C. Control procedures in place and effectively performed for establishment
approval, surveillance and monitoring.
D. Export Health Certification issuance organized in connection with outcomes
of the control system applied to operators.
E. Accredited laboratory testing capacity available and able to support the
surveillance and monitoring activities.
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1.2. Non-Sanitary Requirements

Additionally, it is also essential to fulfill 2 requirements not related with
hygiene requirements:
Catch Certificate - related with protection of fish resources; Products when

exported require also a catch certification in reference to the measures for
preventing, deterring and eliminating illegal, unreported and unregulated
(IUU) fisheries.
Aquatic Animals Health guarantees, when applicable
2. Summary of applicable EU Legislation:

Legislation Reference
Regulation (EC) No 178/2002
Main Contents
Principles and General requirements of food law,
(includes the provisions for Food Safety, Risk and
Traceability) and establishing the European Food
Safety Authority.
Regulation (EC) No 852/2004 General Hygiene requirements for foodstuffs.
Regulation (EC) No.853/2004
Specific
hygiene requirements for foods derived of animals.
Regulation (EC) No 854/2004 Specific rules and criteria for official controls (for
inspection, surveillance, and certification of products
of animal origin for human consumption).
Regulation (EC) No 882/2004 Setting Surveillance System to verify compliance
(suitability + fulfillment) with food law and animal
health regulations and organizing Official Controls
and Competent Authority. (How to setup Official
Controls; How to setup the Competent Authority)
Regulation (EC) No 2406/96
Common marketing standards for fishery products
(Sensory criteria)
Directive 98/83/EC
Quality of water for human consumption
Regulation (EC) No.
Microbiological criteria on foodstuffs
2073/2005
Regulation (EC) No.1881/2006 Maximum levels for certain contaminants on
foodstuffs
Regulation EC No. 1664/2006 regards implementing measures for certain products
amending
of animal origin intended for human consumption
Regulation EC No. 2074/2005 and repealing certain implementing measures.
Directive 2000/13/EC
Product Labelling
Directive 98/72/EC
Food additives (authorized and maximum levels).
Regulation (EC) No.37/2010
Pharmacologically active substances and their
classification, regarding maximum residue limits in
products (defining authorised and non authorised
substances and respective MRLs)
Directive 96/23/EC; Decision Sampling in aquaculture for testing contaminants
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97/747
Regulation (EC) No.1005/2008 To prevent, deter and eliminate illegal, unreported
and unregulated (IUU) fishing.
3. Notes
The following information have been subject to information last update on
March 13, 2015.
Please note that the text information provided does not constitute an official
version of the EU legislation.
The requirements identified in the present document for fish and fishery products
does not cover the provisions for live bivalve molluscs, echinoderms, tunicates and
marine gastropods.
Further, it has been expressed by several exporters that member states may adopt
additional country specific requirements, in particular related with microbiological
testing, that are not addressed by EU legislation. Therefore all exporters should
confirm these product requirements before commencing full scale production for
export.
4. Importing Countries covered
The following countries are member states of the EU:
Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland,
France (including Guyana, Martinique, Guadeloupe and Runion), Germany,
Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta,
Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain (including
Andorra and Canary Islands), Sweden, and the United Kingdom.
While Norway and Iceland are not official EU Member States, they have
adopted EU requirements and fish exported to those countries are subject to the
same requirements. Products landed in either Norway or Iceland may proceed
to EU Member States without any additional import controls.
5. Labelling Requirements
The following applies to Labelling and Packaging Requirements for Fish and
Seafood Products, excluding live bivalve molluscs.
Inner packages and containers for all fishery products exported to the EU must be
labelled to indicate:
1. Establishment Approval Number;
2. Exporting Country name
This information must be in close proximity, easy to understand and marked in a
conspicuous place in such a way as to be easily visible, clearly legible and
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indelible. The information must be placed so that it is not confused with the
product coding information. The approved Exporting Countries establishment
number and the Countries designation must be printed on all packaging materials
for all products exported to the EU, including wrappers, liners, or any other
material used to contain and protect products.
6. Export Certification Requirements
Each shipment must be accompanied by a single, original, fully
completed EU Health certificate. Certificates must be signed and stamped in ink
that is a different colour than the remaining text on the certificate. EU Health
certificates may only be issued for product processed or stored in establishments
that are listed on the relevant EU Approval List for the product being exported.
The name and number of the establishment where the fishery products were
processed for export to the EU must be recorded on the EU Health Certificate.
The information on the List of the Exporting Establishments Approved to Export
Fishery Products to the European Union must match the information about the
exporting establishment that is listed on the certificate and the product labels.
In annex 2 it is shown the Health Certificate full contents and description of the
information to be inserted.
Exporters should ensure that their products are accompanied by the proper EU
documentation prior to being exported from the dispatch country if transhipped via
another country.
The certificate must provide an accurate description of the identity of the approved
processor of the goods, the type of fish being shipped, the quantity of product
being shipped, and the final destination of the goods. The details of the product
description must indicate whether the product originated from an aquaculture
operation or is classified as a fishery product. The certificate must be completed in
an official language for the country where the shipment will be subject to import
controls.
The EU requires certification of any samples of fish and fish products destined for
human consumption.
The details of the product description must indicate whether the product originated
from an aquaculture operation or is classified as a fishery product. The fish health
attestations must be completed if fish originated from an aquaculture operation.
The certificate for fish and fishery products is different from the certificate for live
bivalve molluscs, echinoderms, tunicates and marine gastropods. The process to
complete these certificates is similar with a few exceptions.
7. Tolerances/Guidelines
These are fully presented in Annex 1.
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8. Fish Health and Aquaculture Fish

The EU has set certification requirements affecting the marketing of fishery
products harvested from aquaculture operations to prevent the introduction and
spread of diseases within its territories.
8.1. Fish and Fish Products intended for Human Consumption
Fish health requirements apply only if the fish are:
- of aquaculture origin;
- whole, uneviscerated fish;
- not packaged for retail.
If the fish in the consignment meet all three criteria, see annex 2 which shows the
Instructions for Part II.2 of Health Certificate for Imports of Fishery Products
Intended for Human Consumption related to fish health.
8.2. Fish and Fish Products not intended for Human Consumption
Live aquaculture and wild fish not intended for human consumption will require
Fish Health certificates. Requirements for these certificates are not included in
this document.
For more See Annex 2 - Part II of Certification
9. EU Traceability Requirements
The EU has established a system to prevent, deter and eliminate illegal, unreported
and unregulated (IUU) fishing. It is formally known as Regulation
(EC) No. 1005/2008. View the complete regulation at EU IUU regulation .
http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:286:0001:0032:EN:PDF
The EU IUU regulation will require exporting countries to provide the EU with a
Government-validated Catch Certificate attesting that fish and fish products
originate from non-IUU (legal) fisheries. Compliance with the EU regulation is
mandatory for anyone in the fishing industry who exports their products to the EU.
This means that it will be mandatory the existence of a Fisheries Certificate System
in the country.
The regulation will apply to catch landed after January 1, 2010 (i.e. not inventory
in holding that was caught prior to this date). It generally includes all marine
fishery products including live, fresh, chilled, frozen, prepared and preserved
product forms.
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All freshwater fisheries and aquaculture products are exempt from this
regulation, as well as some forms of mollusks such as scallops, mussels, oysters
and snails. Annex I of the Regulation (EC) No. 1005/2008 has the list of fishery
products excluded from the scope of implementation of the catch certificate.
In case of Fish Processed from Imported Raw Materials for Export to the EU
it will be applied a Foreign Catch Export Certificate to meet the Annex IV
requirements of the European Union's Illegal, Unreported and Unregulated (IUU)
catch regulation.
10. Guidance documents

Guidance document on the implementation of certain provisions of Regulation (EC)
No 852/2004 on the hygiene of foodstuffs:
http://ec.europa.eu/food/food/biosafety/hygienelegislation/guidance_doc_8522004_en.pdf
Guidance document on the implementation of certain provisions of Regulation (EC)
No 853/2004 on the hygiene of food of animal origin:
http://ec.europa.eu/food/food/biosafety/hygienelegislation/docs/guidance_doc_8532004_en.pdf
Guidance document on the implementation of procedures based on the HACCP
principles, and on the facilitation of the implementation of the HACCP principles in
certain food businesses:
http://ec.europa.eu/food/food/biosafety/hygienelegislation/guidance_doc_haccp_en.pdf
Guidance document on sanitary export requirements:
http://ec.europa.eu/food/safety/international_affairs/trade/docs/im_cond_fish_en.pdf
Guidance document on IUU catch certification requirements:
http://ec.europa.eu/fisheries/cfp/illegal_fishing/info/technical_note_en.pdf
http://www.seafish.org/media/Publications/SeafishInfoNote_Guidefor3rdCountryExpo
rters_201002.pdf
20 | P a g e

8. Other Countries
For introducing other exporting country conditions and requirements it is suggested as
starting point to check the available information at the Canadian Food Inspection
Agency website in reference to the conditions by country:
http://www.inspection.gc.ca/food/fish-and-seafood/exports/byjurisdiction/eng/1304197334656/1304197442121
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Chapter 4: Trade Related Institutions

DEPARTMENT OF PLANNING, FINANCE AND INTERNATIONAL
COOPERATION, FISHERY ADMINISTRATION
Phone:
(855) 23 215 470
Email:
thorsensereivorth.fia@maff.gov.kh
admin@fia.gov.kh
Address: No. 186, Norodom Boulevard, Sangkat Tonle Basac, Khan Chamcar Mon,
Phnom Penh, Cambodia
Website: www.fia.gov.kh
DEPARTMENT OF FISHERIES, POST-HAREST TECHNLOGIES AND
QUALITY CONTROL, FISHERY ADMINISTRATION
Phone:
(855) 23 215 470
Email:
chhounchamnan@gmail.com
admin@fia.gov.kh
Address: No. 186, Norodom Boulevard, Sangkat Tonle Basac, Khan Chamcar Mon,
Phnom Penh, Cambodia
Website: www.fia.gov.kh
BUSINESS REGISTRATION DEPARTMENT, MINISTRY OF COMMERCE
Phone1:
(855) 23 866 048
Phone 2: (855) 12 993 188
Email:
omdararith@yahoo.com
Address: Lot 19-61, MOC Road (113B Road), turn in from Russian Blvd, Phum Teuk
Thla, Sangkat Teuk Thla, Khan Sen Sok, Phnom Penh, Kingdom of Cambodia.
Website: www.moc.gov.kh
EXPORT-IMPORT DEPARTMENT, MINISTRY OF COMMERCE
Phone:
(855) 12 838 909
Email:
hosivyong@yahoo.com
Website: http://ico.moc.gov.kh
TRADE PROMOTION GENERAL DIRECTORATE, MINISTRY OF COMMERCE
Phone:
(855) 12 313 333
Email:
seangthay@yahoo.com
Website: http://tpd.gov.kh
CAMBODIA IMPORT EXPORT INSPECTION AND FRAUD REPRESSION
DIRECTORATE-GENERAL (CAMCONTROL), MINISTRY OF COMMERCE
23 | P a g e

Phone1:
(855) 12 553 375, (855) 88 836 1016

Email:
ccdg@camcontrol.gov.kh
Address: building no. 55, Street 144, Sangkat Phsar Kandal I, Khan Daun Penh, Phnom
Penh, Cambodia.
Website: http://www.camcontrol.gov.kh
GENERAL DEPARTMENT OF TAXATION
Phone:
(855) 23 886 708
Email:
gdt@tax.gov.kh
Address: Corner Russian Federation & Mao Tsetong Blvd. Sangkat Toek La ak I, Khan
Tuol Kork, Phnom Penh, Kingdom of Cambodia.
Website: www.tax.gov.kh
GENERAL DEPARTMENT OF CUSTOMS AND EXCISE OF CAMBODIA

Phone:
(855) 23 214 065
Fax:
(855) 23 214 065
Email:
info-pru@customs.gov.kh
Address: No. 6-8, Preah Norodom Blvd., Sangkat Phsar Thmei III, Khan Daun Penh,
Phnom Penh, Cambodia.
Website: www.customs.gov.kh
CAMBODIA PEST CONTROL SERVICE
Phone:
(855) 12 943434
(855) 89 818126
Fax:
(855) 23 21 6655
Email:
hsvuth@gmail.com
Address: #216H, Street Preah Trasak Paem (63), Sangkat Beung Keng Kong 1, Khan
Chamkamorn, Phnom Penh, Cambodia
Website: www.campestcontrol.com
INSTITU PASTEUR DU CAMBODGE
Phone:
(855) 23 426 009
Email:
info@pasteur-kh.org
Address: No. 5, Monivong Boulevard, 12201 Phnom Penh, Kingdom of Cambodia.
Website: www.pasteur-kh.org
INDUSTRIAL LABORATORY CENTER OF CAMBODIA (ILCC), MINISTRY OF

INDUSTRY AND HANDICRAFT
Phone:
(855) 11 877 319
Email:
hcs_cambodia@yahoo.com
Address: National Road No. 5, Phum Boeng Chhouk, Sangkat Km. No. 6, Russey Keo
District, Phnom Penh, Cambodia.
Website: www.mih.gov.kh
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LABORATORY DEPARTMENT, CAMCONTROL, MINISTRY OF COMMERCE

Phone:
(855) 11 884 067
Email:
ccdg.lab@gmail.com
Address: Building no. 55, Street 144, Sangkat Phsar Kandal I, Khan Daun Penh, Phnom
Penh, Cambodia.
Website: www.camcontrol.gov.kh
CAMBOIDA AIRPORT MANAGEMENT SERVICES
Phone:
(855) 23 890 520, (855) 23 890 890
Fax:
(855) 23 890 254
Email:
chhun-khim.tan@cambodia-airports.aero
Address: Phnom Penh International Airport, National Road No.4, Phnom Penh,
Cambodia.
Website: www.cambodia-airports.aero
PHNOM PENH AUTONOMUS PORT
Phone:
(855) 23 427 802
Email:
ppapmpwt@online.com.kh, info@ppap.com.kh
Address: Kandal Leu Village, Banteay Dek Commune, Kien Svay District, Kandal
Province, Cambodia.
Website: www.ppap.com.kh
SIHANOUKVILLE AUTONOMUS PORT
Phone:
(855) 34 933 416
Email:
pith_prakath@pas.gov.kh, pasinfo@pas.gov.kh
Address: Sangkat No.3, Sihanoukville City, Preah Sihanouk Province, Cambodia.
Website: www.pas.gov.kh
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References
ADB and UNESCAP (2013). Trade Facilitation in Asia and the Pacific. 2013 update.
Chris Milner, Oliver Morrissey and Evious Zgovu (2005). Trade Facilitation in Developing
Countries.
CREDIT
Research
Paper
No.
08/05.CREDIT.
Available
at:
www.nottingham.ac.uk/economics/credit/
Dourng Kakada (2006). Approaches to Overcome Standard and Conformity Assessment
Barriers: Options for Cambodia Exports. Economic Review. April June 2006. Phnom Penh:
Economic Institution of Cambodia.
Dourng Kakada and Sok Hach (2007). Preferential Rule of Origin: Case Study of Cambodia.
Policy Research Report. The World Bank, 64-75.
GDCE (2015). Handbook on Customs Clearance. MEF and GDCE. October 2015. Available
at:
http://www.customs.gov.kh/handbook-on-customs-clearance-and-feasibility-study-oncargo-tracking-system-in-cambodia/
GDT (2015). Instruction of Tax Application Registration and Enterprise Updates for Real
Regime (Form 101). April 2015.
IFC (2008). Handbook on Export Procedures: Practical Guides for Small and Medium
Enterprises in Cambodia. April 2008. Available at:
http://documents.worldbank.org/curated/en/2008/04/9543924/cambodia-handbook-exportprocedures-practical-guide-small-medium-enterprises
ITC (2014). Cambodia: Company Perspectives. An ITC Series on Non-Tariff Measures.
ITC (2010). Model Contracts for Small Firms. Legal Guidance for Doing International
Business.
Kees van der Meer and Sakura Samrith (2013). Implementing SPS measures to facilitate trade
in Cambodia. The Standards and Trade Development Facility (STDF).
MAFF (2014). Prakas No. 502 on Application Sample and Procedures of Health Certificate
for Certifying Quality of Fish and Fishery Products. October 2014.
MEF (2014). Prakas No.1139 on Tax Registration. October 2014.
MEF and MOC (2014). Joint Prakas No. 1643 on Modification of the Annexes of Joint Prakas
985 on Provisions of Public Services of MOC (2012). December 2014.
MEF and MOC (2014). Joint Prakas No. 1644 on Modification of the Annexes of Joint Prakas
986 on Incentives of MOC and MEF (2012). December 2014.
MEF (2015). Prakas No. 1151 on Provisions of Public Services of GDCE of MEF. September
2015.
MEF (2012). Prakas N. 970 on Provisions of Public Services for Institutions under MEF.
December 2012.
MEF and MAFF (2012). Joint Prakas No. 1013 on the Provisions of Public Services of
MAFF. December 2012.
MOC (2013). Prakas No. 112 on Revision of Certificate of Origin Issuance Procedures. May
2013.
MOC (2016). Exporters Operation Guides. MOC Certificate of Origin Website. Draft
Revision 01. January 2016. Available at: www.certificateoforigin.moc.gov.kh
26 | P a g e

MOC (2015). Prakas No. 298 on Procedures of Issuance of Certificate of Origin Form A
through Automation System. December 2015.
MEF and MAFF (2012). Joint Prakas No. 1014 on the Incentives of MAFF. December 2012.
Stephen Golub and Abir Varma (2014). Fishing Exports and Economic Development of Least
Developed Countries: Bangladesh, Cambodia, Comoros, Sierra Leone and Uganda. February
2014. UNCTAD.
RGC (2007). Anukret No.209 on the Enforcement of the List of Prohibited and Restricted
Goods. December 2007.
RGC (2006). PREAH REACH KRAM NS/RKM/ 506/011 on Law on Fisheries. May 2006.
UNIDO (2015). An Assessment of Cambodian Standards on Fish and Fishery Products and
Foods.
US Commercial Service (2014). Doing Business in Cambodia. 2014 Country Commercial
Guide for US Companies.
27 | P a g e

Appendixes: Samples and Forms of Export Documentations
28 | P a g e

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Cambodia Export

United Nations Industrial Development Organization

Cambodia Export Diversification and Expansion Program (CEDEP II)

What is Trade Facilitation?

Chapter 2: Export Procedure

Export Facilitation Manual

Cambodia Export Diversification and Expansion Program (CEDEP II)

Chapter 4: Trade Related Institution

Export Facilitation Manual

Cambodia Export Diversification and Expansion Program (CEDEP II)

Asia-Pacific Economic Cooperation

Export Facilitation Manual

Cambodia Export Diversification and Expansion Program (CEDEP II)

Sanitary and Phytosanitary

Export Facilitation Manual

Cambodia Export Diversification and Expansion Program (CEDEP II)

Chapter 1: Trade Facilitation

Cambodia Export Diversification and Expansion Program (CEDEP II)

on at the-order processes and procedures. These cover facilitation measures related to

Increased effectiveness of control methods

Encouragement of foreign investment

Accelerated economic development

Lower costs and reduced delays

Faster customs clearance and release through

Simpler commercial framework for doing both

Source: Economic Commission for Europe (ECE). 2002

Export Facilitation Manual

Cambodia Export Diversification and Expansion Program (CEDEP II)

A national policy on trade facilitation is a key factor in the development of export

Export Facilitation Manual

Cambodia Export Diversification and Expansion Program (CEDEP II)

Cambodia Export Diversification and Expansion Program (CEDEP II)

Chapter 2: Export Procedure

of Payment in Export Trade

International Commerce Term

Forwarders and Customs Brokers

Packaging and Labeling

1.1 The Sales Contract

does the transfer of ownership/title take place?

pays for charges or taxes that arise during transit?

if the shipment is lost or damaged?

Export Facilitation Manual

License and permit requirements

Cambodia Export Diversification and Expansion Program (CEDEP II)

Warranty and guarantees

1.2 Method of Payments in Export Trade

Source: export.gov, trade finance guide.

Export Facilitation Manual

Cambodia Export Diversification and Expansion Program (CEDEP II)

Export Facilitation Manual

Cambodia Export Diversification and Expansion Program (CEDEP II)

Source: New Zealand Trade & Enterprise, https://www.nzte.govt.nz/en/.

Export Facilitation Manual

Cambodia Export Diversification and Expansion Program (CEDEP II)

International carriage is NOT paid by the seller. The exporter is

International carriage is NOT paid by the seller. The exporter is responsible

1.4 Preparing Shipping Documentations

Export Facilitation Manual

Cambodia Export Diversification and Expansion Program (CEDEP II)

The following is an overview and description of shipping documents typically used in

An Air Waybill is issued by an airline when goods are received for

An Authorization Letter allows a freight forwarder or authorized agent to

A Bill of Landing is a contract between the seller and the carrier,

An Insurance Certificate is a document prepared by the exporter or freight