Responding to the State Bank of Vietnam's official dispatch requesting comments on the Draft Decree amending and supplementing a number of articles of Decree 24/2012/ND-CP on the management of gold trading activities, the Vietnam Federation of Commerce and Industry (VCCI), based on feedback from businesses, has made a number of comments related to the conditions for producing gold bars, trading in gold jewelry and procedures for importing gold...
Article 11a of the draft stipulates that enterprises producing gold bars must also have a license to trade in gold bars.
According to VCCI, these are two different activities in the value chain, production and trade, so it is impossible to force manufacturing enterprises to have additional business licenses. This is not only unnecessary in terms of management, but also creates a situation of "licenses nested in licenses", increasing compliance costs and prolonging administrative procedures.
In addition, the draft requires enterprises to have a minimum charter capital of VND1,000 billion to be eligible to produce gold bars. VCCI believes that this capital threshold is too high, creating barriers to market entry, reducing competitiveness and diversifying supply sources.
“Such regulations could lead to only a few large enterprises controlling the gold bar market, affecting consumer rights,” VCCI emphasized.
VCCI also proposed to abolish the business conditions currently applied to the business of gold jewelry and gold art. According to VCCI's explanation, this is a group of common consumer goods, not affecting national defense, security or public interests to the extent necessary to apply business restrictions under the Investment Law.
In addition, the current conditions mainly relate to facilities and equipment, similar to many other industries, which are not sufficient to maintain the status of a conditional business. Continuing to impose conditions is contrary to the spirit of administrative procedure reform under Resolution 68/NQ-TW and is not consistent with the development orientation of the domestic gold jewelry market that the General Secretary concluded at the meeting on May 28, 2025.
Regarding gold bar import activities, the draft currently requires businesses to have: gold import-export license, annual import limit and separate license for each import.
VCCI believes that simultaneously requiring these three types of licenses causes overlap, creating additional administrative burdens and compliance costs for businesses. Especially in the context of the gold market's frequent fluctuations, having to wait for each license causes businesses to lose business opportunities and lack flexibility in operations.
Therefore, VCCI proposed to abolish the gold import-export license because gold production enterprises are already under strict supervision from the State Bank. Instead of abolishing the license for each import, technological solutions such as connecting data with customs agencies or requiring enterprises to report periodically to ensure control can be applied.
Source: https://doanhnghiepvn.vn/kinh-te/chinh-sach/vcci-khong-nen-long-giay-phep-trong-quan-ly-kinh-doanh-vang/20250626053114102
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