The treatment of articles subject to plant quarantine is a conditional business activity intended to prevent, eliminate, or eradicate harmful organisms that may spread through goods, plant products, and other articles subject to plant quarantine.
Under Vietnamese law, an organization carrying out the treatment of articles subject to plant quarantine must obtain a Certificate of Eligibility to Practice Phytosanitary Treatment of Articles Subject to Plant Quarantine from the competent authority before commencing such activities.
From 2026, the conditions, application dossier, and procedures for issuance of the Certificate have undergone several notable changes under Law No. 146/2025/QH15 and Decree No. 33/2026/ND-CP. This article summarizes the key matters enterprises should take into account when carrying out this procedure.
1. What is the practice of phytosanitary treatment of articles subject to plant quarantine?
Pursuant to Article 36 of the Law on Plant Protection and Quarantine, the treatment of articles subject to plant quarantine must be carried out by an organization holding a Certificate of Eligibility to Practice Phytosanitary Treatment of Articles Subject to Plant Quarantine.
Phytosanitary treatment activities include:
- fumigation;
- heat treatment;
- hot-water treatment;
- irradiation; and
- other technical treatment activities.
Accordingly, this Certificate is not issued for each individual consignment. Rather, it certifies the conditions and capacity of the organization carrying out phytosanitary treatment activities.
An organization may only conduct phytosanitary treatment after obtaining the Certificate and may only operate within the scope, treatment method, and scale recognized by the competent authority.
2. What conditions must an organization satisfy?
Pursuant to Article 37 of the current Law on Plant Protection and Quarantine and Article 5 of Decree No. 66/2016/ND-CP, as amended and supplemented by Decree No. 33/2026/ND-CP, an organization applying for the Certificate must satisfy conditions relating to facilities, technical capacity, and personnel.
2.1. Conditions applicable to the person directly responsible for management and operation
The person directly responsible for managing and operating the treatment organization must:
- hold a university degree or higher;
- have professional qualifications appropriate to the registered treatment method; and
- have professional qualifications satisfying the requirements prescribed by the applicable national technical regulations or national standards on phytosanitary treatment of articles subject to plant quarantine.
This is an important requirement because the application dossier for the Certificate must include the diploma of the person directly responsible for management and operation.
2.2. Conditions applicable to persons directly carrying out treatment
Persons directly carrying out phytosanitary treatment must:
- have received relevant training; and
- have their professional qualifications and practical skills assessed by the central specialized plant protection and quarantine authority.
Notably, from 1 January 2026, the law abolished the requirements for the issuance of a practice card and for health qualifications applicable to persons directly carrying out treatment. The health requirement applicable to the person directly responsible for management and operation was also abolished.
Accordingly, when preparing an application under the current regulations, enterprises should not mechanically continue to apply outdated document checklists requiring a Practice Card or Health Certificate.
2.3. Conditions regarding treatment premises, workshops, and storage facilities
The organization must have:
- treatment premises;
- workshops;
- storage facilities; and
- means and facilities serving the treatment activities,
which must be appropriate to the scale, treatment method, and type of treatment in accordance with the applicable national technical regulations.
Accordingly, the regulatory authority does not merely consider whether the enterprise has a business location; it also assesses whether that location is suitable for the particular treatment method for which registration is sought.
2.4. Conditions regarding equipment
The organization must have adequate equipment corresponding to each registered treatment method.
The required equipment is determined in accordance with Appendix I to Decree No. 66/2016/ND-CP and the relevant amending and supplementing regulations.
The equipment must be suitable for:
- the treatment method;
- the type of treatment;
- the scale of operations;
- the technical process; and
- the requirements for measurement and control of technical parameters during treatment.
Therefore, merely investing in machinery may not be sufficient if the organization cannot properly control, monitor, or record the relevant technical parameters required for appraisal.
3. The technical treatment process is a key component
In addition to facilities and machinery, the organization must develop a specific technical process for each registered treatment method.
The explanatory statement prepared under Form No. 13 requires the enterprise to provide information on:
- the technical process;
- means and facilities;
- list of treatment equipment;
- personnel;
- treatment method;
- type of treatment; and
- registered scale.
Accordingly, an enterprise should not simply register in general terms for the “treatment of articles subject to plant quarantine.” Instead, it must clearly identify the actual method, type, and scale of treatment activities.
During the appraisal process, the specialized authority will also conduct an on-site inspection and assess the organization’s practical ability to perform the treatment. Therefore, the process described in the application dossier must be capable of being implemented in practice.
4. Application dossier for issuance of the Certificate
Under the current regulations, the organization must prepare 01 set of application documents, comprising:
First, an application for issuance of the Certificate
The application must be prepared using Form No. 12 in Appendix III to Decree No. 33/2026/ND-CP.
Second, an explanatory statement on the conditions for practice
The explanatory statement must cover:
- the technical process;
- means and facilities;
- list of treatment equipment;
- personnel;
- each treatment method;
- type of treatment; and
- registered scale,
and must be prepared using Form No. 13 in Appendix III to Decree No. 33/2026/ND-CP.
Third, the diploma of the person directly responsible for management and operation
The enterprise must submit:
A certified copy, or a copy accompanied by the original for comparison, of the university or higher-level diploma of the person directly responsible for management and operation.
These constitute the complete application documents currently published for the new issuance procedure under administrative procedure code 1.002417.
Compared with the previous regulations, the current application dossier has been significantly simplified. In particular, certain documents concerning health, Practice Cards, fire prevention and firefighting, and environmental conditions are no longer required as components of the Certificate application dossier.
However, the fact that a particular document is no longer required as part of the licensing dossier does not mean that the enterprise is exempt from independent compliance obligations under environmental protection, fire prevention and firefighting, chemicals, occupational safety, or other specialized laws where the actual activities fall within their scope of regulation.
5. Where should the application be submitted?
The authority responsible for processing the application is:
The Department of Crop Production and Plant Protection – Ministry of Agriculture and Environment.
This is a ministerial-level administrative procedure with code:
1.002417 – Issuance and Re-issuance of the Certificate of Eligibility to Practice Phytosanitary Treatment of Articles Subject to Plant Quarantine.
The organization may submit its application through one of the following methods:
- direct submission;
- online submission; or
- submission by postal service.
6. Procedure for obtaining the Certificate
Under Decree No. 33/2026/ND-CP, the procedure is carried out as follows:
Step 1: Submission of the application
The organization submits 01 set of application documents to the central specialized plant protection and quarantine authority assigned to process the procedure.
For applications submitted directly, the receiving authority will immediately confirm whether the application is complete.
For applications submitted online or by postal service, the competent authority will notify the applicant of the completeness of the dossier within 01 working day.
Step 2: Appraisal of the application dossier
Within 05 working days from receipt of the application, the specialized authority will appraise the dossier and notify the applicant organization of the appraisal results.
If the application does not satisfy the requirements, the enterprise must amend or supplement it in accordance with the authority’s instructions.
Step 3: On-site inspection of practice conditions
Within 10 working days from the date on which the application dossier is determined to be valid, the specialized authority will conduct an on-site inspection of the organization’s practice conditions.
The inspection is not limited to documentary verification but also examines:
- the condition of the facilities;
- workshops;
- storage facilities;
- machinery and equipment;
- personnel;
- technical processes; and
- the organization’s ability to perform the registered treatment method.
The specialized authority will also assess the organization’s practical ability to carry out phytosanitary treatmentbefore deciding whether to issue the Certificate.
Step 4: Issuance of the Certificate
If the organization satisfies all applicable conditions, the competent authority will issue the Certificate of Eligibility to Practice Phytosanitary Treatment of Articles Subject to Plant Quarantine using Form No. 14 in Appendix III to Decree No. 33/2026/ND-CP.
If issuance is refused, the competent authority must provide a written response stating the reasons for refusal.
7. Processing time
The processing time for a new Certificate is:
15 working days from the date of receipt of a complete and valid application dossier.
This period essentially consists of:
- 05 working days for appraisal of the application dossier; and
- 10 working days for the on-site inspection and consideration of issuance of the Certificate.
Enterprises should note that the statutory processing period begins only once the application dossier is complete and valid. The period during which the enterprise amends or supplements the dossier should not automatically be counted toward the authority’s processing period.
8. Appraisal fee
Under the currently published administrative procedure, the appraisal fee for issuance of the Certificate is:
VND 12,000,000 per appraisal.
Enterprises should distinguish this administrative fee from the actual costs associated with:
- investment in workshops and facilities;
- purchase of equipment;
- adjustment and calibration of machinery;
- personnel training;
- development of technical procedures; and
- completion of other specialized regulatory requirements.
9. How long is the Certificate valid?
Pursuant to Article 40 of the Law on Plant Protection and Quarantine, the Certificate of Eligibility to Practice Phytosanitary Treatment of Articles Subject to Plant Quarantine is valid for:
05 years.
If the organization wishes to continue its operations, it must submit an application for re-issuance at least 03 months before the Certificate expires.
Enterprises should therefore establish an internal system to monitor the validity period of the Certificate in order to avoid continuing treatment services after the Certificate has expired.
10. Obligations of an organization after obtaining the Certificate
Obtaining the Certificate does not mean that the enterprise only needs to satisfy the applicable conditions at the time of appraisal.
Pursuant to Article 42 of the Law on Plant Protection and Quarantine, a treatment organization is required to:
- commence practice only after obtaining the Certificate;
- continuously maintain all practice conditions throughout its operations;
- provide services only within the scope stated in the Certificate;
- carry out treatment as directed and under the supervision of the specialized authority where required by law;
- ensure that treatment does not adversely affect the quality of the treated articles or public health;
- take responsibility for treatment results;
- comply with other relevant legal obligations; and
- submit annual reports on its operations to the authority that issued the Certificate.
Enterprises should pay particular attention to this requirement because practice conditions must be continuously maintained throughout the entire validity period of the Certificate, rather than merely at the time of issuance.
11. Risks of conducting treatment activities without a Certificate
From 5 August 2026, Decree No. 214/2026/ND-CP provides new administrative penalties for violations relating to the treatment of articles subject to plant quarantine.
Under Article 34 of this Decree, the act of:
“Practicing the treatment of articles subject to plant quarantine without a Certificate of Eligibility to Practice Phytosanitary Treatment of Articles Subject to Plant Quarantine”
is subject to a fine ranging from VND 7,000,000 to VND 10,000,000 for an individual.
The monetary penalties stipulated in the relevant chapter of the Decree apply to individuals. An organization committing the same violation is subject to a fine equal to twice the amount applicable to an individual. Accordingly, an organization practicing without the Certificate may be fined from VND 14,000,000 to VND 20,000,000.
In addition to operating without the required Certificate, administrative penalties may also apply in cases where:
- the person directly responsible for management and operation does not have appropriate professional qualifications;
- treatment is not carried out in accordance with the registered technical process;
- required means or equipment are insufficient;
- treatment is not carried out in accordance with the prescribed process; or
- fumigants are used in a manner inconsistent with applicable technical regulations.
The organization must continuously maintain the conditions and comply with the processes registered throughout its operations.
12. Conclusion
The Certificate of Eligibility to Practice Phytosanitary Treatment of Articles Subject to Plant Quarantine is a mandatory legal requirement for organizations directly carrying out phytosanitary treatment activities in accordance with Vietnamese law.
To facilitate the licensing process, enterprises should not focus solely on preparing the documentary application dossier. They must also ensure that their actual facilities, equipment, personnel, and ability to operate the treatment process fully satisfy the applicable requirements, as these matters are subject to direct inspection by the specialized authority before the Certificate is issued.
