Vietnam Updates EPR Policy

The Vietnamese Government has introduced important amendments to the Extended Producer Responsibility (EPR) framework under Decree 05/2025/NĐ-CP, which revises and supplements Decree 08/2022/NĐ-CP guiding the Environmental Protection Law.

Overall, these updates establish clearer recycling rates, introduce mandatory recycling standards, and provide more practical compliance mechanisms for producers and importers operating in Vietnam.

The government has introduced significant amendments to the Extended Producer Responsibility (EPR) policy.

1. Mandatory Recycling Rates: What Businesses Must Know

First and foremost, the amended EPR policy sets out mandatory recycling rates — the minimum percentage of products and packaging that producers and importers must collect and recycle.

These rates are calculated based on several key factors, including:

• Product lifecycle

• Disposal and collection rates

• National recycling targets

• Environmental protection requirements

• Socio-economic conditions

This rate is calculated based on the product’s lifecycle, disposal rate, collection rate, national recycling targets, environmental protection requirements, and socio-economic conditions.

1.1 Three-Year Adjustment Cycle

Importantly, recycling rates will be issued for an initial three-year period. After that, they will be reviewed and adjusted every three years to gradually strengthen recycling performance nationwide.

The Ministry of Natural Resources and Environment will officially announce updated rates for each cycle.

1.2 Flexible Recycling Options

To comply with EPR obligations, producers and importers may:

• Recycle their own products and packaging; or

• Recycle equivalent products and packaging from other companies.

However, imported scrap materials, industrial waste packaging, and defective production waste are not counted toward mandatory recycling rates.

In addition, if a company exceeds its required recycling rate in one year, it may carry forward the surplus to offset future obligations. This flexibility supports long-term recycling strategies.

The Ministry of Natural Resources and Environment will officially announce updated rates for each cycle.

2. New Mandatory Recycling Standards

Beyond recycling rates, Decree 05/2025/NĐ-CP introduces a major shift: mandatory recycling standards.

Previously, regulations mainly focused on minimum material recovery levels. Now, the new framework specifies approved recycling solutions for each product and packaging category, ensuring higher-quality and more consistent recycling practices.

Producers and importers can either recycle their own products and packaging

2.1 Approved Recycling Facilities and Authorized Entities

To ensure compliance:

• Recycling facilities must hold a valid environmental permit covering recycling activities.

• Authorized recycling entities must be contracted by at least three producers or importers subject to EPR rules.

• The Ministry will publish a list of qualified facilities and entities on the National EPR Information System.

As a result, businesses can easily identify compliant partners and reduce legal risks.

3. Practical Alignment with Business Operations

Notably, the updated decree aligns EPR compliance with real business activities.

For example:

• Recycling obligations are calculated after year-end, based on actual production, import, and sales figures.

• Recycling performance achieved in 2024 can be carried forward to meet 2025 obligations.

• Companies choosing financial contributions instead of self-recycling must pay a lump sum before April 20 of the reporting year.

This approach improves transparency and reduces administrative uncertainty.

If businesses choose not to self-recycle, they must contribute financially to the Vietnam Environmental Protection Fund.

 

4. Exemptions and Special Cases

The decree also clarifies several exemptions:

• Chewing gum manufacturers and importers are exempt from EPR responsibilities for commercial packaging.

• Companies using refillable packaging systems (such as returnable beverage bottles) are not required to recycle that packaging under EPR rules.

• Packaging compliance is determined based on revenue from regulated products only.

Therefore, not all packaging automatically falls under mandatory recycling obligations.

5. Financial Contributions and Environmental Fund

If businesses choose not to self-recycle, they must contribute financially to the Vietnam Environmental Protection Fund.

These funds will support:

• Waste classification and collection

• Transportation and recycling

• Waste treatment and disposal

• Compliance monitoring

Additionally, interest earned from fund deposits will cover management and supervision costs. The Ministry will publish an annual fund usage report before March 31 each year.

Financial Contribution Deadlines

• Declaration deadline: March 31

• Payment deadline: April 20

• Contributions paid in 2024 may be carried forward to 2025

Additionally, interest earned from fund deposits will cover management and supervision costs.

 

6. Implementation Timeline for Mandatory Recycling

The recycling obligations will take effect in phases:

• January 1, 2024 – Packaging, batteries, accumulators, lubricating oil, and tires

• January 1, 2025 – Electrical and electronic products

• January 1, 2027 – Vehicles

Furthermore, regulations on end-of-life vehicle disposal are expected before January 1, 2026.

In summary, Decree 05/2025/NĐ-CP significantly strengthens Vietnam’s EPR framework by introducing structured recycling rates, clear compliance standards, and transparent financial contribution rules.

Consequently, producers and importers must carefully review their recycling strategies to ensure compliance while optimizing costs.

Ultimately, these reforms are designed to improve recycling efficiency, align Vietnam’s waste management policies with international practices, and promote long-term environmental sustainability.

 

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