IN-DEPTH HANDBOOK: PRODUCTION UNIT CODE (PUC)

Mandatory for official-channel export of Vietnamese fruit to China

Handbook overview

Mandatory for official-channel export of Vietnamese fruit to China

Updated with the latest regulations & data, 2025 – 2026

• Audience: traders, farmers and cooperatives wishing to register codes
• 9 priority fruits: durian, dragon fruit, mangosteen, banana, watermelon, mango, lychee, longan, rambutan

Table of Contents

1. Quick Summary (TL;DR)
2. Legal Framework: The Vietnam–China Protocols
3. What is a Production Unit Code (PUC)?
4. Registration Process – 5 Steps
5. Mandatory Technical Requirements (TCCS 774:2020/BVTV)
6. Actual Costs (2025–2026 estimates)
7. Common Errors Causing Rejection or Code Revocation
8. Updated Statistics 2025–2026
9. The 2024–2025 Durian Crisis – A Critical Lesson
10. Action Recommendations
11. Important Warnings

Quick Summary (TL;DR)

Five things to remember before exporting

• 1. No code, no entry. Without a Production Unit Code (PUC) and a Packing House Code (PHC) approved by the General Administration of Customs China (GACC), official-channel export is absolutely impossible. Both codes must be printed on the shipment's packaging.
• 2. Current scale (May 2026). Nationwide there are 9,546 PUCs and 1,525 PHCs for export; for China specifically there are 4,323 PUCs and 1,332 PHCs. Durian has 1,191 PUCs and 128 PHCs in active operation.
• 3. The rules just changed. Decree 38/2026/NĐ-CP (effective 24 Jan 2026) for the first time codifies the entire process of granting – suspending – revoking – restoring codes. All old codes must be converted to the new structure (e.g. 01-PHC-BUOI01-000001-CHN) and reported to the Ministry before 26 June 2026.
• 4. The durian crisis is a hard-won lesson. Due to Cadmium and Auramine O (Basic Yellow) contamination, durian exports in Q1/2025 fell 52.7% in volume and 61.1% in value; exports to China alone dropped 78.3%. A total of 167 PUCs and 99 PHCs have been suspended/revoked.
• 5. The testing bottleneck. As of 11 May 2026 Vietnam has only 21 GACC-recognized Cadmium-testing labs and 22 Auramine O-testing labs (16 and 19 currently operating). Building a single compliant lab costs over 20 billion VND.

Legal Framework: The Vietnam–China Protocols

The original protocol and subsequent expansions

The foundation for official-channel export is a series of bilateral Protocols between the Ministry of Agriculture (now the Ministry of Agriculture and Environment) and the General Administration of Customs China (GACC). The first protocol for fresh fruit – covering durian – was signed on 11 July 2022. It is valid for 3 years and automatically renews in 3-year cycles unless one party gives written notice at least 3 months in advance.

Three core requirements of the durian protocol:

• Every growing area and packing facility must be registered with the Ministry of Agriculture and approved by GACC; the list is published publicly on the GACC website.
• In the first two years, phytosanitary sampling is at 2%; after two years without violations it drops to 1%.
• If a live quarantine pest, leaves, or soil is found on the fruit, the entire shipment is barred from export.

Protocols expanded over time:

By the end of 2025, roughly 14–16 plant commodities were exported via official channels to China. Of these, 8 have dedicated protocols (watermelon, mangosteen, black jelly grass, durian, banana, sweet potato, passion fruit, chili); the remaining 6 (dragon fruit, rambutan, mango, lychee, longan, jackfruit) are in the process of being standardized into protocols.

The Chinese legal framework

• Order 248 (14 Apr 2021, effective 1 Jan 2022): "Regulations on the Registration and Administration of Overseas Manufacturers of Imported Food" – mandatory GACC code registration; valid for 5 years.
• Order 249 (same date): "Administrative Measures on Import and Export Food Safety".
• Order 280 (issued 14 Oct 2025, effective 1 Jun 2026): a major reform – automatic 5-year renewal (except meat and bird's nest), list-based registration, and a "dynamic" product catalogue updated according to risk.
• Online registration system: CIFER – cifer.singlewindow.cn.

The Vietnamese legal framework (updated 2026)

The chain of legal documents that farmers, cooperatives and traders must know:

Key points of Decree 38/2026/NĐ-CP

• The decree raises code management to decree level, sets out code-format principles in Article 9, and establishes a mechanism for inspection – suspension – revocation – restoration for each import market. Under Clause 1, Article 19, codes already granted may continue to be used for 1 year while being converted to the new format.
• The Ministry of Agriculture and Environment stresses that code conversion is not a new administrative procedure and does not require re-doing the code-granting process.

What is a Production Unit Code (PUC)?

Per section 3.2 of TCCS 774:2020/BVTV: "A Production Unit Code (PUC) is an identifier code for a growing area, intended to track and control production status; control pests; and trace the origin of agricultural produce."

Distinguishing PUC from PHC

• PUC (Production Unit Code) = growing-area code – granted to an orchard/field/cooperative.
• PHC (Packing House Code) = packing-facility code – granted to a factory/warehouse for pre-processing, sorting and packing.
• Both are mandatory on the shipment's packaging. Goods must originate from a growing area with a PUC and be packed at a facility with a PHC to be imported into China.

The new code structure (per Decree 38/2026 & Official Letter 4547)

Format:

• [Province code] – [PUC or PHC] – [Crop code] – [6-digit sequence number] – [Import country code]
• Official example published by the Ministry of Agriculture and Environment: 01-PHC-BUOI01-000001-CHN (the CHN suffix is for goods bound for China)

Breakdown of each component:

All information (name, address, representative, phone, email, crop type, area, output, capacity, market, operating status) must be declared simultaneously in Vietnamese and English, together with the document number and issue date.

Registration Process – 5 Steps

Note: individuals/smallholders under 10 ha cannot be granted their own code and must link up through a cooperative or production group.

Step 1 – Prepare the dossier at the cooperative/enterprise

• Technical declaration per Appendix A of TCCS 774:2020/BVTV (facility, growing-area, variety, tree-age, GPS positioning, number of households, representative, pest-management measures, compliance commitment).
• A growing-area map with accurate boundaries and polygon GPS coordinates.
• A list of farming households with their areas.
• A cultivation logbook per Appendix F of TCCS 774:2020/BVTV, covering at least one season.
• VietGAP/GlobalGAP certificate, if available (not mandatory, but China prioritizes areas meeting GAP or equivalent).
• A commitment by the enterprise/cooperative on offtake and not undercutting farmers' prices; actual photos of the growing area.

Step 2 – Submit the dossier to the provincial Sub-Department of Crop Production and Plant Protection

Per Official Letter 1776/BNN-BVTV (2023), authority has been decentralized to localities. Submit in person or via the electronic system of the Department of Agriculture and Environment. Avoid intermediaries and brokers.

Step 3 – Field inspection

Sub-Department officials visit the orchard to check: (i) field sanitation; (ii) plant-protection product use (only permitted-list products, no banned active ingredients); (iii) pest management; (iv) logbook keeping; (v) the import country's specific phytosanitary requirements. GACC may inspect alongside (online or in person).

Step 4 – Code issuance and submission to GACC

The Sub-Department reports to the Department of Crop Production and Plant Protection. The Department appraises, issues the PUC/PHC, and submits it to GACC. The Department compiles lists quarterly (March, June, September). GACC may conduct online inspection before approval.

Step 5 – Approval and use

After GACC approves and publishes the code on its website, the new code becomes valid for official-channel export. A code is valid for 5 years; from 1 June 2026, under Order 280, it will renew automatically for 5 years (except meat and bird's nest).

• Actual timeline
• According to the Vietnam Fruit and Vegetables Association (Vinafruit), obtaining a PUC can take 6 months to 1 year. If revoked and re-applied for, the time can be 2–3 times that of a new application – i.e. 1.5 to 3 years.

Mandatory Technical Requirements (TCCS 774:2020/BVTV)

Minimum area

• Fruit trees: minimum 10 ha per code.
• Herbs/spice crops: based on net-house/greenhouse area and the import country's requirements.
• Where a buffer zone is required, follow the import country's rules.

Pest management

The growing area applies a single unified process; there are specific measures for each pest group per the import country's requirements. China is particularly concerned with fruit flies (for durian) and aphids – thrips – red spider mites (for banana).

Plant-protection products

Use only products on the permitted list (Circular 25/2024/TT-BNNPTNT); do not use active ingredients banned by the import country; Auramine O (Basic Yellow) is absolutely prohibited; follow the "4 Rights" principle and pre-harvest intervals so that residues do not exceed the Maximum Residue Limit (MRL).

Logbook keeping (Appendix F)

• A logbook of crop development stages.
• A fertilizing logbook (date, type, dosage).
• A plant-protection product logbook (date, product name, active ingredient, dosage, reason).
• A logbook of pest detection and treatment measures.
• A harvest and offtake logbook.

Re-registration before each season

If you do not re-register before harvest, the code will be revoked.

Actual Costs (2025–2026 estimates)

• State fee for code issuance: free – there is no administrative fee. The real costs lie in preparation, testing and maintenance.

Annual maintenance costs: periodic monitoring inspection at least once a year; sampling and testing; logbook updates; remediation when warnings arise.

Common Errors Causing Rejection or Code Revocation

A. Initial dossier errors

1. The orchard map lacks GPS coordinates or has wrong coordinates.
2. Actual area is below 10 ha or boundaries are not clearly defined.
3. The household list does not match land records.
4. The cultivation logbook is sketchy, not covering at least one season.
5. Lumping multiple different areas under one code (not allowed).

B. Field-technical errors

1. Using off-list plant-protection products or banned active ingredients.
2. Live quarantine pests, leaves or soil found on fruit at customs – the whole shipment is returned.
3. Failing to manage pests uniformly across the area.
4. Plant-protection residues or heavy metals exceeding the MRL.

C. Post-issuance operational errors

This is the main group of causes behind the 167 PUCs and 99 PHCs suspended/revoked from early 2025 to May 2026.

1. Renting, buying/selling, or borrowing codes – the Deputy Prime Minister has directed the Ministry of Public Security to pursue criminal prosecution.
2. Impersonating another cooperative's code.
3. Failing to maintain technical conditions after issuance (the "I already passed the exam" mindset).
4. Code recycling: using one code for goods from multiple different areas.
5. Failing to re-register before the harvest season.
6. Failing to update changes to area, representative or number of households.

D. Food-safety errors (hottest 2024–2025)

1. Cadmium (Cd) exceeding the 0.05 mg/kg threshold in durian – mainly from soil accumulation due to long-term phosphate fertilizer use.
2. Detection of Auramine O (Basic Yellow) from dye-dipping for an attractive yellow rind – a carcinogen that is absolutely banned.

E. CIFER system errors

The CIFER system runs fully automatically, so even a small discrepancy among the business license, labelling, registration dossier or customs declaration can lead to refusal of clearance.

Updated Statistics 2025–2026

National figures (reported by Deputy Minister of Agriculture and Environment Hoàng Trung at the conference chaired by Deputy Prime Minister Hồ Quốc Dũng on 15 May 2026):

By key locality

• Đắk Lắk: 328 PUCs (nearly 9,700 ha); durian alone 277 PUCs (~7,500 ha) + 54 PHCs. The province's total durian area is ~40,000 ha, with 2025 output projected at 392,000 tonnes.
• Lâm Đồng (after merger): 961 PUCs + 362 PHCs. Dragon fruit: 571 PUCs (~98% of area) + 282 PHCs.
• Bắc Giang: 240 lychee PUCs + 39 pre-processing/packing facilities; of which 110 codes are for China. 2025 output projected at 165,000 tonnes from 29,700 ha.
• Sơn La: ~85,500 ha of fruit trees + 35,000 ha of Arabica coffee; maintaining 216 PUCs in 2026.
• Đồng Nai (former): 140 growing areas + 82 PHCs for China, the US, the EU, Australia and New Zealand.

Key milestone, 21 May 2025: GACC approved an additional 829 PUCs and 131 PHCs for Vietnamese durian, raising the total approved durian codes to more than 1,800.

The 2024–2025 Durian Crisis – A Critical Lesson

Developments

Farm-gate prices in the Mekong Delta at one point fell to just 30,000–35,000 VND/kg; farmers had to sell along roadsides for lack of traders.

Technical causes

• Cadmium (Cd): a heavy metal accumulating in soil from long-term phosphate fertilizer use, severe in the Mekong Delta. GACC threshold: below 0.05 mg/kg.
• Auramine O / Basic Yellow 2: a carcinogenic industrial dye used to dip fruit for an attractive yellow rind – completely banned.

The testing-capacity bottleneck

Latest figures, 11 May 2026

• According to Deputy Director-General of the Department of Crop Production and Plant Protection Nguyễn Quang Hiếu (in Tuổi Trẻ), Vietnam has only 21 Cadmium-testing labs (16 operating) and 22 Auramine O-testing labs (19 operating) recognized by GACC.
• Investing in a single small-capacity GACC-standard lab costs over 20 billion VND – a major barrier to rapidly increasing the number of labs. This is the industry's make-or-break bottleneck.

Policy responses

• 8 May 2025: Minister Đỗ Đức Duy chaired an "emergency" meeting, directing faster code issuance and the issuance of durian quarantine procedures.
• 21 May 2025: GACC approved an additional 829 durian PUCs + 131 PHCs.
• 24 Jan 2026: The Government issued Decree 38/2026/NĐ-CP.
• 15 May 2026: Deputy Prime Minister Hồ Quốc Dũng chaired a conference of 34 provinces; calling for simpler procedures, digital transformation, Ministry of Public Security action against code brokering/buying/selling/renting, and negotiations to expand the number of recognized testing labs.

Lesson from Thailand: two-layer control – sampling at the orchard before purchase (only compliant orchards may be bought from), then a second test before export.

Action Recommendations

Phase 1 – Before submitting the dossier (0–3 months)

1. Link up with a cooperative/production group if your orchard is a smallholding under 10 ha. Individuals cannot be granted their own code.
2. Measure GPS coordinates and draw the orchard map (Google Earth Pro, QGIS, or hire a service).
3. Start keeping a cultivation logbook immediately, at least one season before submitting.
4. Review plant-protection products, eliminate banned active ingredients; never use Auramine O at any stage.
5. For areas suspected of Cadmium contamination (especially the Mekong Delta): test soil and fruit samples first; remediate the soil, raise pH, replace phosphate fertilizers with high Cd content.

Phase 2 – Submission and waiting for approval (3–12 months)

1. Contact the provincial Sub-Department of Crop Production and Plant Protection / Department of Agriculture and Environment directly. Avoid intermediaries.
2. Be ready for GACC online inspection; you should have a Chinese-speaking staff member or hire an interpreter.
3. Attend commune/ward-level training under Decree 38/2026.
4. Exporting enterprises register a GACC code at cifer.singlewindow.cn under Order 248 (or Order 280 from 1 Jun 2026), via the Department of Crop Production and Plant Protection.

Phase 3 – After obtaining the code (long-term operation)

1. Maintain the logbook continuously – the biggest weakness behind many revoked codes.
2. Re-register before each season; report all changes to the Sub-Department.
3. Never rent, lend, or buy/sell codes – this is under criminal investigation.
4. Self-sample for Cadmium and Auramine O at the orchard source, following the Thai model, before loading into containers.
5. Invest in QR-code traceability linked to the PUC/PHC.
6. Convert to the new code structure before 26 Jun 2026 (no need to redo the granting procedure).

Triggers for strategic adjustment

• Durian export prices stable above 65,000 VND/kg and the Cd/Auramine O violation rate below 1%: continue expanding PUCs.
• First warning from GACC: review immediately, report to the Sub-Department, and halt exports until the cause is fixed.
• Suspension/revocation: prepare to lose 1.5–3 years to seek restoration; address root causes (soil, water, processes).
• Orchards with over 30% of samples exceeding the Cadmium threshold: halt exports, remediate the soil for 1–2 years, and pivot to the domestic market or processed frozen durian.

Recommendations specifically for traders

• Only buy from orchards with a valid, active PUC – check on the GACC website and sansangxuatkhau.ppd.gov.vn.
• Require orchards to provide Cadmium/Auramine O test results less than 30 days old before purchasing durian.
• Clearly record the PUC and PHC on invoices, contracts and packaging.
• Only accept result certificates from GACC-recognized labs – certificates from labs outside the list will be rejected at the border gate.

Important Warnings

Read carefully before making business decisions

• 1. Figures differ across sources. For example, PHCs for China: Báo Cần Thơ reports 1,323, most sources report 1,332. The number of testing labs fluctuates weekly. Always re-check at ppd.gov.vn.
• 2. The legal framework is changing fast. Decree 38/2026 took effect 24 Jan 2026; GACC Order 280 takes effect 1 Jun 2026; the Ministry of Agriculture and Environment is drafting a new Circular. Stay updated weekly.
• 3. Chinese regulations change constantly. The Auramine O lesson shows GACC can add new parameters within weeks. Follow the Vietnam SPS Office (sps.mard.gov.vn) and CIFER.
• 4. Codes do not belong to consulting firms. Service providers may speed up procedures, but the PUC/PHC must be owned by the cooperative/enterprise.
• 5. Beware of "code touts". Any offer to "rent a ready-made code for quick export" is illegal. If detected, both the original cooperative and the renter have their codes revoked and may face criminal prosecution.
• 6. The era of "hot" growth is over. The 2025–2030 period is about maintaining quality and post-clearance control, not expanding the number of codes. Tiền Giang, Tây Ninh, Lâm Đồng and Bình Thuận are the localities with the most revoked codes.

Source note

This document is compiled from official sources and reputable press: the Department of Crop Production and Plant Protection (ppd.gov.vn), the Ministry of Agriculture and Environment, the Government's e-Newspaper, the WTO Information Portal (VCCI), Thư Viện Pháp Luật, LuatVietnam, VnExpress, Tuổi Trẻ, Thanh Niên, Tiền Phong, Dân Trí, Báo Đầu Tư, VnEconomy, Báo Nông nghiệp, and the Vietnam Fruit and Vegetables Association (Vinafruit). Data updated through May 2026.