QCVN 40:2025/BTNMT, the new national technical regulation on industrial effluent, will officially take effect on September 1, 2025. It is set to replace several outdated standards, including QCVN 11-MT:2015/BTNMT, the national technical regulation on effluent from the aquatic products processing industry. Enterprises in the aquatic product processing industry must comply with the new, stricter technical regulations and prepare accordingly to avoid production disruptions.
See also: Roadmap for the transition and implementation of QCVN 40:2025/BTNMT for enterprises
So, what is the optimal solution for seafood processing enterprises? Should they optimize operations or upgrade the existing wastewater treatment system? Let's analyze and determine the most suitable option with Nanoen.
Key changes in QCVN 40:2025/BTNMT are as follows:
Columns A, B, and C (wastewater discharge zones) are specified as follows:
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Column A specifies the permissible limit values for pollutant parameters in wastewater discharged into receiving water bodies that are used for domestic water supply or environmental water quality management and improvement purposes as Level A of Tables 2 and 3 of QCVN 08:2023/BTNMT, the national technical standard for surface water quality, or as specified by the provincial People's Committee.
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Column B specifies the permissible limit values for pollutant parameters in wastewater discharged into receiving water bodies for water quality management and improvement purposes as Level B in Tables 2 and 3 of QCVN 08:2023/BTNMT, the National Technical Regulation on Surface Water Quality. These purposes may also be stipulated by the provincial People's Committee.
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Column C specifies the permissible limit values for pollutant parameters in wastewater discharged into receiving water bodies that are not covered by the cases specified in Columns A and B
Note
For wastewater generated during food production and processing, including the processing and preservation of aquatic products. In addition to the parameters listed in Table 1 (pH, total coliform, BOD, COD/TOC, and TSS), it is necessary to monitor ammonia, TN, and TP (Column 4, Appendix 2).
If the investment project or industrial wastewater discharge facility uses chlorine or chlorinebased disinfectants, then chlorine and chloroform must be monitored as well.
1. Simplify the calculation mechanism
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Old standard: QCVN 11-MT:2015/BTNMT used the formula Cmax=C×Kq×Kf to determine the limit value. This formula allowed for adjusting discharge limits according to the receiving body's actual conditions (Kq coefficient) and the discharge flow rate (Kf).
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New standard: QCVN 40:2025/BTNMT eliminates the aforementioned adjustment factors entirely. Instead, it specifies a uniform limit value for each pollutant parameter, regardless of the flow rate or the receiving body of water. This makes the standard more transparent and eliminates the practice of exploiting the natural self-purification capacity of water bodies to meet standards
2. Tightening Discharge Limits
The new standards significantly tighten pollution limits for many key parameters. Specifically, the limit values for indicators such as COD, ammonia, total nitrogen (T-N), and total phosphorus (T-P) are lower than in the previous standards, especially in column B. This change reflects the regulatory authority's focus on improving environmental quality, minimizing the impact of industrial activities, and limiting the risk of water eutrophication.
3. Enhance monitoring and surveillance requirements
QCVN 40:2025/BTNMT requires continuous, automatic monitoring of pollution parameters, such as flow rate, temperature, pH, TSS, COD, and ammonia. While this creates pressure in terms of initial investment costs, the system enables enterprises to monitor operations in real time, thereby minimizing the risk of violations and penalties. Concurrently, regulatory authorities can conduct remote monitoring, enhancing transparency and environmental management efficiency.
These changes present an urgent challenge: What must enterprises do to ensure that their wastewater treatment systems meet the standards of QCVN 40:2025/BTNMT and guarantee sustainable development?
Specific and Important Action Steps
To ensure that the wastewater treatment system meets the standards of QCVN 40:2025/BTNMT, enterprises must implement an action plan. This plan should start with a clear understanding of the existing system and compliance with legal regulations.
1. Internal Assessment: Collect wastewater samples and analyze them according to both the old and new standards to accurately determine the compliance gap. This data is important because it helps enterprises make subsequent decisions, from upgrading technology to financial planning
2. Professional Collaboration: Seek guidance on treatment technologies and legal procedures from reputable environmental consulting firms. This helps enterprises avoid errors, save time and money, and ensure efficient system operation.
3. Enhance Human Resource Capabilities: Train and upgrade the skills of the system operations team. Competent personnel will optimize operations after upgrading the existing system.
4. Preparing legal documentation: Understanding the regulations and procedures for adjusting environmental license. Significant changes in scale, capacity, or treatment technology require timely permit adjustments to help the enterprises comply with the law and reduce risks.
Choosing a Solution: Optimizing operations or upgrading the system?
After assessing the existing wastewater treatment system, the enterprise must make the appropriate choices to comply with the new standards. To comply with QCVN 40:2025/BTNMT, the enterprise has two main options: optimizing operations or upgrading the system. Each option has its advantages and is suitable for specific circumstances.
1. Operational Optimization: A Timely Solution at a Reasonable Cost
It is a less costly solution than comprehensive refurbishment. This approach is suitable when the wastewater treatment system is relatively new, not yet overloaded, and monitoring results show that output parameters are close to meeting the limits of QCVN 40:2025/BTNMT.
There are several technical measures that enterprises can implement, including:
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Regular Inspection and Monitoring: Monitor the electrical system, pumps, blowers, and pipelines to promptly detect malfunctions.
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Strictly control and optimize operating parameters: Control the pH level, dissolved oxygen (DO) concentration, and F/M ratio in the biological tank to enhance treatment efficiency.
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Add specialized microorganisms. Specific strains of microorganisms break down oils, fats, proteins, and high organic matter in aquatic wastewater, reducing odors and limiting sludge.
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Implement basic automation: Install sensors and simple control systems for processes such as chemical dosing and recirculation pumps to reduce risks and labor costs.
Although the above technical measures may improve performance, enterprises will face difficulties in implementation. Without experienced internal staff to continuously monitor the system, it may operate inconsistently, which could lead to exceeding standards and incurring penalties.
In this context, partnering with a professional organization can help enterprises minimize risks and optimize resources. At Nanoen, we offer two tailored solutions for each requirement:
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System Operation Training: This training equips internal staff with the necessary knowledge and skills to enable the enterprises to operate independently and control risks.
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Provide professional operational personnel: Ensure that the system always operates smoothly, minimize production downtime, and optimize personnel management costs.
See also: Operating the wastewater treatment system
Hence, optimizing operations is an effective short-term solution for promptly complying with QCVN 40:2025/BTNMT. However, comprehensive renovation remains a mandatory solution for systems that are deteriorating or operating at overload capacity to ensure sustainable compliance.
2. System Renovation and Upgrading: A Long-Term, Sustainable Solution
Comprehensive renovation is mandatory if the wastewater treatment system is outdated, uses obsolete technology, is overloaded, or fails to meet QCVN 40:2025/BTNMT standards despite optimized operation. This is a legal requirement and a strategic investment to ensure stable, sustainable production.
To reduce financial and technical pressure, enterprises should proactively engage with consultants early. This gives them more time to prepare, develop a suitable roadmap, and select optimal solutions, such as enhancing operations, adding treatment facilities, or upgrading the system comprehensively.
In the context of pressure to comply with new standards, upgrading wastewater treatment systems requires more than a technical solution—it demands a long-term strategy. As an environmental consultancy, Nanoen focuses on developing appropriate upgrade solutions that balance technical effectiveness and financial feasibility, which are optimized for each individual enterprises:
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Detailed assessment of the current situation: This is the most important step in identifying why the system does not meet standards and selecting an optimal, cost-effective solution for the investor.
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Proposal to supplement or modify certain processing stages as appropriate: Proposal to modify or supplement processing stages. Depending on the production characteristics, such as seafood processing, the project may be supplemented or adjusted to improve efficiency.
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Optimize investment costs: A flexible renovation design based on the old system maximizes the use of existing infrastructure, reducing costs while maintaining efficiency.
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Ensure compliance with QCVN 40:2025/BTNMT: Minimize legal risks and avoid penalties or production disruptions.
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Long-term partnership: We provide post-renovation monitoring, operation, and training support to ensure the system maintains stable performance.
See also: Upgrading the wastewater treatment system
Compliance with QCVN 40:2025/BTNMT is not only a legal obligation but also the key to sustainable development for seafood processing enterprises. Depending on the current state of their systems, enterprises can choose to optimize operations or invest in comprehensive upgrades.
Contact Nanoen today to receive a free consultation from our team of experts and find the most suitable solution for your enterprises!
Nanoen
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