   
  
G/C/W/776  
G/STR/Q1/VNM/7  
 
5 March 2020 
(20-1780) Page: 1/8 
Council for Trade in Goods  
Working Party on State Trading Enterprises  Original: English  
 
STATE TRADING  
VIET NAM'S REPLIES TO FURTHER QUESTIONS F ROM THE UNITED STATE S1 REGARDING  
VIET NAM'S STATE TRADING ENTERP RISES2 
The following communication, dated 26 February 2020, is being circulated at the request of the 
delegation of Viet Nam.  
 
_______________  
 
 
Viet Nam provides the following  response s to questions from the  United States regarding  Viet Nam 's 
State Trading Enterprises , as set forth  in document G/C/W/760  - G/STR/Q 1/VNM/6 , dated 
9 October  2018. 
Question 1 -2 
1. Vinafood I  
2. Vinafood II  
Viet Nam states that Vinafood I and II are "currently not granted any exclusive or special 
privileges from the Government in exporting rice and food." Viet Nam also states that the 
two companies' export quantity and price "are determ ined on the basis of market factors 
such as supply and demand balance, crop yield, stocks, rice prices in international 
markets, etc."  
 
However, the legal authority cited by Viet Nam, Decree No. 109/2010/ND -CP, provides 
certain rights to traders that imple ment "centralized contracts", defined as a contract 
"signed under agreement between a competent agency of the Vietnamese government 
and a foreign government or foreign territory, or the one signed under the Prime 
Minister's direction ."3 Other measures cite d in the U.S. counter -notification, including 
Office of the Government Announcement 78/TB -VPCP4 and Ministry of Foreign Affairs 
Announcement 24/2011/TB -LPQT5, clearly designate Vinafood  I and II as the traders 
responsible for implementing or negotiating specific state export contracts to Iraq and 
the Philippines, respectively. It would thus appear that minimally in these two instances, 
measures explicitly naming Vinafood I and II establi sh special rights in Viet Nam's 
conduct of rice export conducted through state (i.e., government -to-government) trading.  
 
The United States notes Viet Nam's response to a question from Japan in its Trade Policy 
Review in 2013 in which it appears to acknowledge the exclusive rights of Vinafood II to 
sell to certain markets and to supply government -to-government contracts, but claims 
 
1 G/C/W/760 - G/STR/Q1/VNM/6. 
2 G/ADP/N/1/VNM/2 – G/SCM/N/1/VNM/1 – G/SG/N/1/VNM/2 (dated 3 0 October 2018).  
3 Article 16, Government Decree 109/2010/ND -CP dated 4 November 2010 on the Rice Export Business.  
4 Office of the Government Announcement 78/TB -VPCP dated 9 March 2009 on Conclusions of Prime 
Minister Nguyen Tan Dung at meeting with the Northern Food Corporation and the Southern Food Corporation.  
5 Ministry of Foreign Affairs Announcement 24/2011/TB -LPQT dated 18 April 2011 on an international 
conven tion going into effect: Memorandum of Understanding between the Government of the Socialist Republic 
of Vietnam and the Government of the Republic of the Philippines regarding supply of Vietnamese rice to the 
Philippines.  G/C/W/776 • G/STR/Q1/VNM/7  
 
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  that the appointment of exclusive exporters does not constitute an exclusive right.6 Could 
Viet Nam please explain why it believes that the apparently exclusive right granted to 
Vinafood II to implement a government -to-government MOU for the export of up to 1.5 
million tons of rice per year to the Philippines between 2011 and 2013 does not constitute 
an exclusive or special privilege, in the exercise of which Vinafood II may have influenced, 
through its purchases or sales, the level or direction of i mports or exports ? 
 
Additionally, each entity's charter states that it may "{e}njoy subsidies, price supports or 
other state preference policies when undertaking duties for the public interest, defense, 
security, food security, natural disaster prevention or supply of products or services 
according to State price policy."7 For example, in Office of the Government Announcement 
5159/VPCP -KTN, the Prime Minister stated that "{t}he Southern and Northern Food 
Companies are required to immediately develop measure s to purchase approximately 
400-500 thousand tons of rice in August 2008."8 In light of these two entities' apparently 
exclusive or special rights or privileges, could Viet Nam please explain why it does not 
view these entities as STEs?  
 
Finally, Viet Nam  asserts that Office of the Government Announcement 78/TB -VPCP and 
Office of the Government Announcement 5159/VPCP -KTN are not legal normative 
documents and that they have no legal effect in the period of notification. Is Viet Nam 
representing that orders from the Prime Minister do not carry legal authority? 9 The United 
States notes that the period of the counter -notification is 2006 -2016, and, thus, measures 
issued in 2008 -2009 would fall within that period.  
 
Reply : 
Vinafood I  
Vinafood I is a single membe r limited liability corporation with 100% of the charter capital invested 
by the State, and operates in accordance with the Laws on Enterprises and other concerned legal 
provisions. As a member of the Viet Nam Food Association, Vinafood I currently operate s in 
accordance with the Vietnamese legislation and in an equivalent manner with other enterprises in 
production and business activities. It is self -accountable for its business results.  
The Announcement No. 78/TB -VPCP dated 9 March 2009 on the Prime Minis ter's conclusions on the 
meeting with Vinafood I and II, under which Vinafood I is assigned "the focal point in negotiating 
and signing rice contracts to export to Iraq ", holds no validity during the notification period 
(2012 -2014) stated in document G/STR/N/15/VNM of Viet Nam. In addition, Vinafood I is no longer 
granted any exclusive or special privileges in rice exports to the Iraqi market.  
At present , any enterprises, including Vinafood I, which meet the requirements stipulated in the 
Government 's Decree No. 109/2010/ND -CP dated 4 November on Rice Export Businesses and 
Circular No. 44/2010/TT -BCT dated 31 December 2010 of the Ministry of Industry and Trade 
detailing a number of articles of the Government 's Decree No. 109/2010/ND -CP dated 
4 November  2010 on rice export businesses, are allowed to get engaged in this field in an equal 
manner.  
Vinafood II  
Vinafood II is a single member limited liability corporation with 100% of the charter capital invested 
by the State, and operates in accordanc e with the Laws on Enterprises and other concerned legal 
provisions. As a member of the Viet Nam Food Association, Vinafood II currently operates in 
 
6 WT/TPR/M/287/Add.1 (dated 12 Nov ember 2013) . 
7 Government Decree 12/2014/ND -CP dated 25 February 2014 on the Charter for the Organization and 
Operations of the Northern Food Corporation; Government Decree 10/2014/ND -CP dated 13 February 2014 on 
the Charter on the Organization and Operati ons of the Southern Food Corporation.  
8 Office of the Government Announcement 5159/VPCP -KTN on Solutions to promote the purchase and 
consumption of the entire 2008 Summer -Autumn rice harvest in the Mekong Delta, dated 7 August 2008.  
9 The United States not es that Article 4.6 of the Law 80/2015/QH13 on the Promulgation of Legal 
Documents includes Prime Ministerial Decisions within Viet  Nam's System of Legal Documents.  G/C/W/776 • G/STR/Q1/VNM/7  
 
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  accordance with the Vietnamese legislation and in an equivalent manner with other enterprises in 
production  and business activities. It is self -accountable for its business results.  
The Announcement No. 24/2011/TB -LPQT dated 18 April 2011 of the Ministry of Foreign Affairs, 
under which Vinafood II is appointed as the state -owned enterprise executing the Memoran dum of 
Understanding (MoU) between the Government of Viet Nam and the Government of the Philippines, 
holds no validity during the notification period (2012 -2014) stated in document G/STR/N/15/VNM of 
Viet Nam. In addition, this Announcement holds no practic al value any longer, for the Philippines 
liberated its rice market on 20 April 2019. Since this date, Vinafood II 's rice export to the Philippines 
no longer follows the mechanism laid out in the MoU between the Governments of Viet Nam and the 
Philippines; rather, it is undertaken equally as any other enterprises on the market.  
At present , any enterprises, including Vinafood II, which satisfy the conditions stipulated in the 
Government 's Decree No. 109/2010/ND -CP dated 4 November on Rice Export Businesses an d 
Circular No. 44/2010/TT -BCT dated 31 December 2010 of the Ministry of Industry and Trade 
detailing a number of articles of the Government 's Decree No. 109/2010/ND -CP dated 
4 November  2010 on rice export businesses, are allowed to get engaged in this fiel d in an equal 
manner.  
Question 3 
PetroVietnam (PVN) and PV Oil  
Viet Nam states that "the Government of Viet Nam has no longer granted any exclusive 
or special privileges for PVN  in importing and exporting crude oil" and that "{t}herefore, 
PVN is no longer considered as a state trading enterprise under WTO rules." However, as 
Viet Nam notes, Law  10/2008/QH12 amending the Law on Petroleum states that PVN "is 
a state -owned company w hich conducts oil and gas activities and signs petroleum 
contracts with organizations and individuals conducting oil and gas activities in 
compliance with laws."10 The law further grants PetroVietnam "the preemptive right to 
buy part or whole of an oil and gas contract to be transferred."11 Viet Nam's submission 
additionally acknowledges that PVN engages in the export of crude oil. Is Viet Nam 
asserting that the above statutory rights are not special or exclusive to PVN? Furthermore, 
is Viet Nam asserting tha t the exercise of these rights does not influence, through 
purchases or sales, the level or direction of crude oil imports or exports?  
 
PVN subsidiary PV Oil states on its website, under the heading "Crude Oil Export – Import 
and Trading", that "PVOIL is t he only company in Vietnam that handles marketing and 
sale services for crude oil from offshore Vietnam and overseas oil blocks invested by 
Vietnam Oil and Gas Group (PetroVietnam) and/or its subsidiaries; supplying Vietnamese 
crude oil and importing crude  oil for Dung Quat refinery."12 In addition, a 2016 letter to 
potential strategic investors from the chair of the PV Oil board stated that "PV Oil is still 
the only enterprise in Vietnam that exports all Vietnamese crude oil extracted 
domestically and abroa d, as well as importing crude oil for refineries."13 Is this 
information inaccurate? If still accurate, in light of this information and given the working 
definition, please explain how PV Oil is not a state trading enterprise.  
 
 
10 Article 14, Law 10/2008/QH12, Amending and Supplementing Several Articles of the Petroleu m Law, 
dated 3 June 2008.  
11 Article 24.2, Law 10/2008/QH12, Amending and Supplementing Several Articles of the Petroleum 
Law, dated 3 June 2008.  
12 https://www.pvoil.com.vn/en -US/business -activities/international -trading -of-crude -oil-and-
petroleum -products .  
13 Letter no. 8973/DVN -KH dated 29 December 2016 from Nguyen Hoang Tuan representing PV Oil, 
regarding "Invitation to participate in selection process for  strategic investors." The letter is on PV Oil's website 
at: http://www.pvoil.la/thu -moi-tham-gia-qua-trinh-lua-chon-nha-dau-tu-chien -luoc, at pp. 1.  G/C/W/776 • G/STR/Q1/VNM/7  
 
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  Reply : 
Vietnam Oil & Gas Corporation (PVN)  
According to the Law No. 10/2008/QH12 2008 on the amendment of some articles of the 
Petroleum  Law 1993, PVN's business activities in the oil and gas sector are regulated as follows: 
PVN "is a state -owned company which conducts oil and gas  activities and signs petroleum contracts 
with organizations and individuals conducting oil and gas activities in compliance with laws". 
Accordingly, PVN, as assigned by the Government, can only conduct oil and gas activities (mainly 
exploring and exploiti ng oil and gas), and are not granted any exclusive or special privileges in crude 
oil imports and exports. The export of crude oil is carried out solely under oil sale agreements 
between PVN and other oil owners (including foreign oil owners). Therefore, P VN is not considered 
a state trading enterprise under WTO regulations, which then results in no obligation to notify WTO.  
PetroVietnam Oil Corporation (PV Oil)  
PV Oil is an enterprise that supplies crude oil buying/selling services (including entrust buyin g/selling 
and buying/selling agent of crude oil) and gets entrust fees or agent commissions as agreed by the 
oil owners and consumers.  
PV Oil is not regulated by the Law on Petroleum (1993) and the Law on Amendment of a number of 
articles of the Law on Pet roleum No. 19/2000/QH10 in 2000.  
At present , the Government does not grant PV Oil any exclusive or special privileges in crude oil 
imports and exports. These activities of PV Oil are based on crude oil trading contracts between oil 
owners, PV Oil and buyer s, under which PV Oil will receive agency service fees agreed by the parties. 
All activities of buying/purchasing crude oil carried out by PV Oil follow the instructions of the oil 
owners/oil refinery factories through transparent and competitive bidding/o ffering selection 
processes, and detailed provisions laid out in the General Agreements/Trust Contracts/Agency 
Contracts. The selection of Buyer/Seller will be decided by the oil owner. This means that P V Oil 
cannot manipulate or make an influence on the s cope or direction of Viet Nam 's crude oil exports 
and imports.  
In addition, the information on PV Oil 's website has been updated to reflect its actual production and 
business situation. Therefore, PV Oil is not a state trading enterprise under WTO regulati ons. 
Question 4 
Viet Nam National Coal – Mineral Industries Holding Corporation Limited 
(Vinacomin/TKV)  
Viet Nam states that "{i}n fact, TKV has not been granted any exclusive or special 
privileges from the Government of Viet Nam in importing or exporting  coal." However, 
Office of the Government Announcement 346/TB -VPCP clearly states that two companies, 
including Vinacomin or TKV, are designated by the state as coal intermediaries:  
 
[MOIT] shall direct Electricity Vietnam, PetroVietnam, and other 
enterpr ises with a need for imported coal to sign contracts with the TKV 
and Dong Bac General Corporations (the two enterprises designated as coal 
import intermediaries ) to supply coal in accordance with the law and 
international customs; contracts should include  a guarantee that contracts 
will be executed, to create conditions for these intermediaries to find a 
stable source of supply with appropriate quality and price.14 (emphasis 
added).  
 
Viet Nam asserts that this measure is "not a legal normative document to grant exclusive 
or special privileges to TKV to importing or exporting coal." Again, is Viet Nam 
representing that directives from the Deputy Prime Minister do not carry legal authori ty? 
Furthermore, if Viet Nam is claiming that the announcement does not designate these two 
 
14 Paragraph 3, Section 1, Office of the Government Announcement 346/TB -VPCP on the conclusions of 
Deputy Prime Minister Hoang Trung Hai at the meeting on the coal import situation, dated 26 August 2014.  G/C/W/776 • G/STR/Q1/VNM/7  
 
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  entities as exclusive importers of coal, could Viet Nam please explain the meaning of the 
language referenced above?  
 
Reply : 
TKV is a single member limited liabilit y company with 100% charter capital invested by the State. 
It conducts business activities in accordance with the Law on Enterprises and other relevant laws.  
In practice, TKV is currently not granted any exclusive or special privileges from the Government in 
coal import and export. TKV 's coal export is conducted in accordance with the Circular 
No. 05/VBHN -BCT dated 23 January 2018 on coal export regulation. There is no restriction for coal 
trading enterprises with regard to coal import. Accordingly, the qua ntity as well as prices of coal 
products for export and import are based on factors of domestic and international markets. 
Therefore, TKV is not a state trading enterprise under WTO regulations.  
Question 5 
Saigon Jewelry Holding Company (SJC)  
Viet Nam states that under Decree 24/2012/ND -CP, "the Government monopolizes the 
production of gold bars, the export of material gold and the import of material gold to 
produce gold bars."15 It further states that under Decision 1623/QD -NHNN, SJC "has been 
assigned by the State Bank of Viet Nam to process gold bars on the basis of the contract 
between the State Bank of Viet Nam and SJC."16 Given that the State Bank of Vietnam has 
delegated to SJC the right to exercise its statutory monopoly in the production of gold 
bars, could Viet Nam please explain why it does not consider SJC to be an STE?  
 
Reply : 
SJC was transformed from a parent -subsidiary model into a single limited liability company in 2010. 
Since then, SJC has been an independent enterprise which conducts bus iness activities in accordance 
with the Law on Enterprises, other relevant legal documents and its Certificate of business 
registration. SJC is not granted any exclusive or special privileges from the Government in its 
business activities.  
The Government 's Decree No. 24/2012/ND -CP dated 3 April 2012 on management of gold trading 
stipulates that "the Government monopolizes the production of gold bars, the export of material gold 
and the import of material gold to produce gold bars".  
The Decision No. 1623/QD -NHNN of the State Bank of Viet Nam dated 23 August 2012 on the 
organization and management of gold bars production of the State Bank of Viet Nam stipulates that 
Sai Gon Jewelry Holding Company (SJC) has been assigned by the State Bank of Viet Nam to proces s 
gold bars on the basis of the contract between the State Bank of Viet Nam and SJC.  
Accordingly, SJC is not granted any exclusive or special privileges in importing and exporting gold 
bars and material gold; rather, it only processes gold bars for the Sta te Bank of Viet Nam. Therefore, 
SJC is not a state trading enterprise under WTO regulations.  
Question 6 
Vietnam Air Petrol Company Limited (Vinapco/Skypec)  
 
Viet Nam states that "Decision 1139/QD -TTg of Prime Minister dated 31 July 2009 
approving the plan to develop a stockholding system for crude oil and petroleum products 
of Viet Nam until 2015 with a vision toward 2025 is not a legal normative document 
stipulating the Government to provide SKYPEC w ith exclusive or special privileges in 
exporting and importing aviation fuel." However, the Decision assigns to Vinapco/Skypec 
"temporary" responsibility for implementation and management of the national reserves 
 
15 Government Decree 24/2012/ND -CP dated  3 April 2012 on the Management of Gold Trading.  
16 State Bank of Vietnam Decision 1623/QD -NHNN  dated 23 August 2012 on the organization and 
management of gold bar production of the State Bank of Vietnam.  G/C/W/776 • G/STR/Q1/VNM/7  
 
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  of jet fuel products (Jet A1).17 Furthermore , Viet Nam states in its submission that Skypec 
is engaged in export, import and supply of aviation fuel in Vietnamese airports to 
Vietnamese and international airlines.  
 
In light of Skypec's import and export activities and its apparently exclusive right to 
manage national reserves of jet fuel, could Viet Nam please explain why it does not 
consider Skypec to be an STE? Furthermore, could Viet Nam please clarify its statement 
that a Prime Ministerial Decision is not a "legal normative document"? Is Viet Nam  
asserting that decisions by the Prime Minister do not have legal authority?  
 
Reply : 
Skypec is an enterprise with 100% charter capital owned by Vietnam Airlines Corporation 
(Vietnam  Airlines). Vietnam Airlines completed all legal procedures in transforming  from a state -
owned model into a joint stock model, and has since October 2016 officially become a joint stock 
company. Skypec operates in export, import, and supply of aviation fuel at Vietnamese airports for 
Vietnamese airlines and other international on es with flights to Viet Nam.  
As stipulated in the Decision No. 1139/QD -TTg dated 31 July 2009 of the Prime Minister approving 
the plan to develop a reserve system for crude oil and petroleum products of Viet Nam until 2015 
with a vision toward 2025, "The n ational reserve of jet fuel products (Jet A1) shall be temporarily 
continued to be assigned to the Vietnam Air Petrol Company Limited for organization, 
implementation, and management. " 
Nevertheless, the management of national reserve of fuel used for civil  aircrafts has been transferred 
to the Ministry of Industry and Trade since 2016 in accordance with the Government 's Decree 
No. 128/2015/ND -CP dated 15th December 2015 amending the detailed list of national reserve 
commodities and agencies assigned to mana ge national reserve commodities promulgated together 
with the Government 's Decree No. 94/2013/ND -CP dated 21 August 2013. Since then, Skypec is no 
longer granted the monopolistic rights to import and export petroleum as fuel for civil aircrafts. For 
this reason, Skypec is not a state trading enterprise under WTO regulations.  
Question 7 
General Aviation Import Export Joint Stock Company (Airimex)  
 
Viet Nam notified Airimex  as an STE to the WTO in its 2006 revised notification, stating 
that "{t}he Company is the exclusive importer and distributor of spare parts of airplanes 
and most of {sic} other equipment in the aviation industry."18 The United States has not 
identified any  legal measure that has changed Airimex's status as an exclusive importer 
and distributor of these products. Could Viet Nam please identify any legal measures that 
have changed Airimex's status or otherwise authorized other enterprises to import these 
good s? 
 
Reply : 
Airimex is a joint stock company with a partial charter capital owned by Vietnam Airlines. In 2006, 
the company was transformed from state -owned into joint -stock entity in accordance with 
Decision  No. 3892/QD -BGTVT dated 17 October 2005 of the M inistry of Transport.  
From then until present (13 years in total), Airimex  has not been granted any exclusive or special 
privileges by the Government in importing and exporting goods. The company 's business and 
import/export activities are carried out on the basis of market supply and demand, as well as fair 
competition with oth er enterprises. Therefore, Airimex is not a state trading enterprise under WTO 
regulations.  
 
17 Article 1.4(b), Decision 1139/QD -TTg of Prime Minister dated 31 July 2009 approving the plan to 
develop a stockholding system for crude oil and petroleum products of Viet Nam until 2015 with a vision 
toward 2025.  
18 Accession of Vietnam: Notification on State Trading Enterprises Revision, WT/ACC /VNM/14/Rev.1 
(dated 6 October 2006), at pp. 8.  G/C/W/776 • G/STR/Q1/VNM/7  
 
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  Question 8 
Vietnam National Petroleum Group (Petrolimex)  
 
Viet Nam notes that Petrolimex is not named in the list of enterprises regulated by 
Decision  58/2016/QD -TTg dated 28 December 2016 of the Prime Minister on criteria for 
classification of state -owned enterprises, enterprises with state capital and the list of 
state -owned enterprises to be restructured for 2016 -2020. But that Decision also states 
that petroleum  and gasoline importers controlling more than 30% of market share 
"contribute to balancing the economy and stabilizing the market."19 According to 
Petrolimex's website, "{e}ach year, Petrolimex imports over 8 million metric tons of 
gasoline, accounting for around 50% of domestic market share."20 Furthermore, 
according to the Ministry of Finance, Petrolimex was the largest contributor to or user of 
the government's Petroleum Price Stabilization Fund for multiple years between 2006 and 
2016.21 According to Decre e 83/2014/ND -CP, this fund is used "only for the purpose of 
stabilizing the petroleum market and petroleum prices in accordance with the law."22  
 
It would thus appear that Petrolimex  meets the market share threshold of Decision 58 
and also in practice plays a role in stabilizing the domestic petroleum market. In light of 
these facts, could Viet  Nam please clarify whether Decision 58 encompasses Petrolimex, 
despite the company not bein g explicitly named? Additionally, in light of Petrolimex's 
participation in import activities and its apparent role in stabilizing the domestic gasoline 
market, could Viet Nam please explain why it does not believe that Petrolimex is a STE?  
 
Reply : 
Petroli mex was formed by the equitization and restructuring of Vietnam Petroleum Corporation under 
the Prime Minister 's Decision No. 828/QD -TTg dated 31 May 2011, and is a public entity in 
accordance with Document No. 2946/UBCK -QLPH dated 17 August 2012 of the St ate Securities 
Committee.  
Petrolimex's main business is trading petroleum, refining petrol and gasoline and investing capitals 
in other enterprises to conduct businesses in the fields of petroleum as well as other business 
activities in accordance with law s. 
Petrol and oil trading is a conditional business line, the requirements of which apply equally to all 
enterprises in accordance with the Government 's Decree No. 83/2014/ND -CP dated 
3 September  2014 on petrol and oil trading. Petrolimex is not granted an y exclusive or special 
privileges in petrol and oil trading. Its transactions of petrol and oil imports are carried out based on 
a market mechanism and in accordance with the Government 's Decree No. 83/2014/ND -CP as any 
other Vietnamese petroleum enterpris es. 
That Petrolimex imports an annual amount of more than 8 million MT of petroleum, accounting for 
approx. 50% of the domestic market share, is statistics from the 2010s and results from business 
activities of the past. At present , Petrolimex only imports  an average amount of approx. 2  million  MT 
of petroleum each year.  
Regarding the petrol price stabilization fund, this fund is deducted from the retail price per litr e of 
petrol and oil, is based at the enterprises themselves, and can only be used for the purpose of price 
stabilization under the guidance of the Ministry of Finance. This is considered a tool for the State to 
regulate the domestic petrol price, so as to harmonize the interests of the state, businesses, and 
consumers. Petrolimex is not granted  any exclusive or special privileges by the State in the use and 
management of Viet Nam 's petrol price stabilization fund.  
 
19 Section III, Appendix 1, Decision 58/2016/QD -TTg dated 28 December 2016 of the Prime Minister on 
criteria for classification of state -owned enterprises, enterprises with state capital and the list of state -owned 
enterprises to be restructured for 2016 -2020.  
20 https://www.petrolimex.com.vn/nd/xang -dau/kinh_doanh_xang_dau.html .  
21 Reports on the "General situation on withdrawals and use of the Price Stabilization Fund" covering the 
2009-2016 period are available on the Ministry of Finance website at www.mof.gov.vn . 
22 Article 37, Decree 83/2014ND -CP dated 3 September 2014 of the Government on petroleum trading.  G/C/W/776 • G/STR/Q1/VNM/7  
 
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  As such, Petrolimex has until now been operating and trading petrol and oil as equally as other 
enterprises in this field. Petrolimex  is not granted any exclusive and special privileges in exporting 
and importing petrol and oil. Accordingly, Petrolimex is not a state trading enterprise under WTO 
regulations.  
 
__________  