Summary
Details
- Vietnam
Covered producers and importers must generally:
Determine whether their products or packaging are subject to EPR.
Calculate obligated quantities.
Meet applicable mandatory recycling rates.
Organize compliant recycling or make the prescribed financial contribution.
Maintain supporting documentation.
Submit applicable declarations and reports.
Use compliant recycling providers.
Deep dive
- What’s Required
- 1. Determine whether the company is a covered producer or importer
- 2. Meet mandatory recycling requirements
- 3. Choose a compliance route
- 4. Use compliant recycling providers
- 5. Register and report recycling activity
- 6. Maintain accurate packaging and product data
- 7. Consider contract manufacturing and entrusted imports
- 8. Meet separate waste-treatment contribution obligations
- Important Deadlines
- Current Status
- Penalties for Non-Compliance
- Examples of Known Violations / Failure Modes
- Resources
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What’s Required
1. Determine whether the company is a covered producer or importer
EPR applies to specified products and commercial packaging placed on the Vietnamese market.
Packaging categories include packaging associated with products such as:
Food and beverages.
Cosmetics.
Pharmaceuticals.
Fertilizers.
Animal feed.
Detergents.
Household products.
Agricultural products.
Medical products.
Cement.
The framework also extends to tires, batteries, accumulators, lubricating oils, electrical and electronic products, and eventually vehicles.
2. Meet mandatory recycling requirements
Covered producers and importers must ensure that a prescribed proportion of the products or packaging they place on the market is collected and recycled.
Decree No. 110/2026 further specifies recycling rates for several packaging materials, including:
Paper and cardboard packaging: 20%.
Multilayer composite paper packaging: 15%.
Aluminum packaging: 22%.
Rigid PET packaging: 22%.
Iron and other metal packaging: 20%.
Different rates apply to other materials and product categories.
3. Choose a compliance route
Producers and importers generally have two principal options:
Option A: Organize recycling
A company may organize recycling itself or use an authorized recycling organization or qualified recycling service provider.
Option B: Financial contribution
A company can instead make the required financial contribution to the Vietnam Environment Protection Fund to support recycling activities.
4. Use compliant recycling providers
Where recycling is outsourced, the service provider must have the appropriate environmental authorization covering the relevant recycling activity.
Businesses cannot rely on unqualified service providers to demonstrate compliance.
5. Register and report recycling activity
Under the revised framework, producers and importers carrying out recycling obligations must provide prescribed declarations and reports concerning products and packaging placed on the market and recycling performance.
The previous 2025 framework required registration and reporting by March 31. Vietnam continued refining these procedures through the 2026 EPR reform, so companies should use the current EPR system and forms applicable for the reporting year.
6. Maintain accurate packaging and product data
Companies need information covering:
Product quantities placed on the Vietnamese market.
Packaging materials.
Packaging weights.
Imported quantities.
Recycled quantities.
Recycling methods.
Service-provider documentation.
Financial contributions.
7. Consider contract manufacturing and entrusted imports
Vietnam’s EPR framework addresses situations where manufacturing or importing is performed on behalf of another organization.
Responsibility can depend on which entity commissions manufacturing, owns the relevant label or brand, or is legally responsible for placing the product on the market.
8. Meet separate waste-treatment contribution obligations
Vietnam distinguishes between:
Recycling responsibility, for products and packaging considered recyclable.
Waste treatment responsibility, for specified products that are difficult to recycle or require other end-of-life management.
Certain producers and importers therefore make financial contributions specifically for collection and treatment rather than recycling.
Important Deadlines
November 17, 2020: Law on Environmental Protection 2020 adopted.
January 1, 2022: Law on Environmental Protection entered into force.
January 10, 2022: Decree No. 08/2022/ND-CP issued.
January 1, 2024: Recycling responsibility began for packaging, tires, lubricating oils, batteries and accumulators.
January 1, 2025: EPR recycling obligations began for covered electrical and electronic products.
January 6, 2025: Decree No. 05/2025/ND-CP revised important EPR provisions.
January 29, 2026: Decree No. 48/2026/ND-CP amended aspects of the earlier environmental implementation framework.
April 1, 2026: Decree No. 110/2026/ND-CP established a more specific legal framework for producer and importer recycling and waste-treatment responsibilities.
January 1, 2027: Recycling responsibility is scheduled to apply to covered road vehicles.
Current Status
Active and legally binding.
Vietnam’s EPR framework is now operational for packaging and several product categories.
The system changed substantially between 2024 and 2026. Businesses should therefore rely on the current 2026 framework rather than treating the original Decree 08/2022 provisions as the complete current compliance regime.
Decree No. 110/2026/ND-CP is particularly important because it further clarifies responsible entities, recycling rates, financial contributions, and EPR implementation procedures.
Penalties for Non-Compliance
Non-compliance can trigger enforcement under Vietnam’s environmental legislation.
Potential consequences include:
Administrative fines.
Orders to correct non-compliance.
Additional environmental obligations.
Enforcement for inaccurate declarations.
Liability for unpaid financial contributions.
Regulatory inspections.
Business and reputational consequences.
Exact penalties depend on the type of breach and applicable administrative sanctions legislation.
Examples of Known Violations / Failure Modes
Failing to determine EPR status.
Underreporting packaging placed on the market.
Incorrect material classification.
Missing mandatory recycling rates.
Using an unqualified recycling service provider.
Reporting recycled quantities without evidence.
Double counting recycled material.
Failing to make the required financial contribution.
Incorrectly applying the VND 30 billion exclusion.
Ignoring imported packaging.
Failing to distinguish recycling responsibility from waste-treatment responsibility.
Using outdated requirements after regulatory amendments.
Failing to account for contract manufacturing arrangements.
Incorrectly treating reusable packaging as automatically exempt.
Resources
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