Chương 14 · Phần IV
14. What we do not know, and who can tell us
Desk research has reached diminishing returns. The twenty unknowns that matter most can mostly be closed by a letter to a ministry, a phone call to a feed mill or a query to customs. We list them in priority order, with the play each one unblocks and who to ask. The full register holds 127 open questions and 142 recorded disagreements between sources.
Nội dung trang này bằng tiếng Anh. Đọc bản tóm tắt tiếng Việt
Trong trang này
In one paragraph. This report was built from public sources over two research waves, and by the end each new search added little. The remaining gaps are of a different kind: they sit in ministry files, company plants and customs records, not on the open web. Most can be closed cheaply, by a written question to a ministry, a call to a feed mill's technical manager or a customs data request. We list the twenty that matter most, ranked by how much they would change a decision in this report, with the play they unblock (Plays) and who to ask. The full register holds 127 open questions (open_questions.csv) and 142 disagreements between sources, each with the position we took (disagreements.csv).
14.1 The twenty unknowns that matter most
| # | Unknown | Unblocks | Who to ask, or the cheapest way to close it |
|---|---|---|---|
| 1 | Does the draft Food Safety Law (August 2026 version) define "new food" or "new food ingredient", or delegate that to the Government? | P1 and all food plays | Draft portal of the National Assembly; the WTO notification attachment; the Vietnam Food Administration's legal division |
| 2 | Do purified precision-fermented proteins need a GMO food-use certificate beyond labelling, and what is the closed-production certificate's timeline and fee? | T7 | Written question to the MAE Department of Nature Conservation and Biodiversity and to the Vietnam Food Administration |
| 3 | Is a livestock-listed raw material (yeast, duckweed, insect meal) legal in aquafeed without a trial, given the aquafeed list has no raw-material section? | T2, T3, T6 | Written opinion from the MAE Department of Fisheries (aquafeed division) |
| 4 | Will Vedan, Ajinomoto or Daesang toll-ferment for third parties, and how much tank time is idle? | T2, T3, T5 | Direct inquiry to their R&D and corporate planning teams |
| 5 | What fishmeal share do Vietnamese shrimp and pangasius feeds actually use? | T2, T3 | One call each to technical managers at Uni-President Vietnam, Sheng Long and Grobest, or the Research Institute for Aquaculture No. 2 |
| 6 | How much Chinese microbial protein enters Vietnamese feed, and at what price? | T2, T3 | Customs lines HS 2309.90 and 2102.20; a quote from the importer (V-Group / CK Vietnam) |
| 7 | Is any textured soy protein extruded in Vietnam, and by whom? | T1 | Ask chay makers where their textured protein comes from; ask ingredient distributors which brands they sell |
| 8 | Import volumes of textured protein, soy isolate and gluten at 8-digit level, 2024 to 2025 | T1 | Vietnam Customs statistics or a trade-data service |
| 9 | Gate price of cassava pulp, and how it is used (wet sale, drying, biogas, dumping) | T3, T4 | Calls to three to five Tay Ninh starch factories; the Vietnam Cassava Association |
| 10 | Current prices of cassava starch, glucose syrup and molasses in Vietnam | T4 | Vietnam Cassava Association; Vietnam Sugarcane and Sugar Association; starch factories |
| 11 | Official aquafeed output by species (industry 3.9 to 4.8 Mt against USDA 6.5 Mt) | Market sizing for T2, T3 | The MAE Department of Fisheries annual review (feed chapter) |
| 12 | Does the 2030 target of 30 to 32 Mt of industrial feed cover aquafeed? (Edition 1.1: answered at Medium confidence, livestock feed only; Protein balance 2050) | Market sizing; policy | MAE Department of Livestock Production and Animal Health |
| 13 | Which Vietnamese laboratories hold amino-acid and digestibility methods in their accreditation scope? | P4, T1, T10 | NACEFA, NIFC, Eurofins Sac Ky Hai Dang, CASE; the national accreditation body's search |
| 14 | How much chiller energy does a Vietnamese aerobic fermentation plant use per m³ of broth? | All fermentation plays | Vedan, Ajinomoto or AB Mauri plant engineers |
| 15 | Can a product made in Vietnam be sold in Singapore under an SFA novel-food approval? | T7; Scenario 3 | Singapore Food Agency import and overseas-establishment rules |
| 16 | ScaleUp Bio's 2026 capacity, pricing and willingness to take Vietnamese clients | T5, T7 | ScaleUp Bio business development |
| 17 | Whether Thailand's EECi pilot plant is food-grade, its fees and foreign-client terms | T5, T7 | EECi pilot plant contacts |
| 18 | Where Vietnam's high-protein plant drinks source their pea protein | T10 | Vinamilk procurement or investor relations; customs consignee data |
| 19 | Does a new feed ingredient such as single-cell protein automatically count as "animal feed" (not subject to VAT)? | T2, T3 | General Department of Taxation |
| 20 | Are fermentation-derived ingredients made in Vietnam accepted as halal by Malaysian and Indonesian certifiers? | Export plays | HALCERT (under MOST); a Malaysian certifier |
Source: open_questions.csv (fields priority_rank, unblocks, cheapest_way_to_close, owner_org_to_ask) .
Reading. Items 1 to 3 are regulatory and time-sensitive: each could be settled by a single written reply, and together they decide whether most plays have a clear route. Items 4 to 10 decide the economics of T1 to T4 and need industry calls rather than more desk research. Items 11 and 12 affect how large the future feed-protein market looks.
14.2 Where sources disagree
We recorded 142 disagreements between sources and stated the position we took for each (R. Disagreements). The ones that most affect this report's conclusions:
| Topic | The disagreement | Position taken |
|---|---|---|
| Aquafeed volume | Industry 3.9 to 4.8 Mt (2025) against USDA 6.5 Mt | Unresolved; both shown, never averaged (Why Vietnam) |
| Displaceable fishmeal pool | Earlier drafts 350 to 450 kt against 120 to 245 kt central | 120 to 245 kt; the higher range needs unsourced inclusion rates (Plays) |
| Entobel financing | "About USD 36 million" against USD 32.5 million documented | USD 32.5 million (Capital) |
| E10 start date | 1 January 2026 against 1 June 2026 | 1 June 2026; January was the circular's effective date (Outlook) |
| Fishmeal price | USD 1,600 per t (a trade quote) against USD 1,794 per t (World Bank, same month) | World Bank series as benchmark; the quote is probably a lower grade |
| Precision-fermentation titer benchmark | "Above 50 g/L" presented as a calculated threshold | An expert assertion, not a modelled figure (Technology fit) |
| Protein-ingredient import tonnage | Vietnam-reported against China-reported mirror data | China's mirror data for tonnage; Vietnam's weights are estimated (Region) |
| Hawkwood cost structure | Feedstock 10 to 18% of cost in the model against 30 to 65% in cited studies | Either way labour and power are a minor share (Region) |
14.3 Limits of this report
- Tools. The general web-search budget ran out part-way through the first wave. After that, research used direct reads of known pages, legal databases, scholarly indexes (Scite and OpenAIRE) and trade data (WITS). Some sources could not be reached; each is logged (A. Method).
- Language. Vietnamese-language legal texts and press were read directly. Vietnamese-language journals are only partly indexed, so Vietnamese research output is undercounted (Knowledge and talent).
- Field data. The retail audit is a convenience sample of 186 products in 11 stores in two cities in September 2026 (D. Retail formulation audit).
- Cost stacks. Indicative, not feasibility studies (Economics).
- No interviews. This edition relies on documents. The unknowns above are the agenda for a round of interviews.
14.4 How to help close the gaps
Readers who hold any of these answers (ministries, feed mills, starch factories, laboratories, investors) can help. AltProtein Vietnam will record corrections in open_questions.csv and disagreements.csv and date each change, so the website can show what has been closed since publication.
Related: Q. Open questions (all 127), R. Disagreements (all 142), A. Method.