A new decree in Vietnam brings significant implementation clarity to the country’s existing extended producer responsibility (EPR) legal framework.
An EPR mechanism was first codified in Vietnam in the 2020 Law on Environmental Protection amid ongoing challenges surrounding the collection and treatment of product and packaging waste. The mechanism was progressively detailed through Decree No. 08/2022/ND‑CP and its successive amendments, but the regulatory framework remained insufficiently developed, notably in terms of support mechanisms for waste collection, recycling, and treatment.
The newly launched regulations in Decree No. 110/2026/ND-CP (Decree 110), issued on April 1, 2026, and taking effect on May 25, 2026, stipulate fully and clearly the responsibility of manufacturers and importers to recycle products and packaging and to treat waste. Some key provisions of Decree 110 for manufacturers, importers, and related stakeholders are presented below.
Subjects of EPR
The Law on Environmental Protection assigns responsibility to manufacturers and importers for product and packaging recycling (under Article 54) or waste collection and treatment (under Article 55), depending on the type of products and packaging they produce or import. Decree 110 elaborates on these EPR provisions by specifying the responsible entities and listing out the types of products and packaging subject to recycling and waste treatment responsibilities.
Decree 110 clarifies the responsible entities in special cases, such as when products under the same brand are made by multiple manufacturers, when there is a contract manufacturing or entrusted import relationship, and when the manufacturer or importer is part of a corporate group.
Notably, exemptions may be applied in some scenarios, such as for manufacturers and importers of products and packaging exclusively for export, temporary import and re-export, or research and testing purposes, as well as for entities with annual revenue from related products not exceeding VND 30 billion.
Recycling Responsibilities
Decree 110 clearly lists different types of products and packaging subject to recycling, along with mandatory recycling rates and mandatory recycling measures. For example, for aluminum packaging for food products, the mandatory recycling rate is 22% via at least one of two measures: production of commercial aluminum billets or production of packaging or specific products.
Mandatory recycling rates will be adjusted every three years, with each adjustment capped at 10%. The first adjustment is expected in 2029. Excess recycling achieved through advanced technology may be carried forward to offset future obligations.
If recyclable materials are collected for export for recycling or refurbishment abroad, such activities must comply strictly with notification and control requirements under the Basel Convention.
Compliance may be achieved by conducting recycling activities—such as direct recycling by manufacturers or importers with existing appropriate environmental permits or through third parties such as licensed recyclers or qualified organizations authorized to take responsibility for recycling—or by making a financial contribution to the Vietnam Environmental Protection Fund (VEPF).
Information on recycling entities and authorized organizations responsible for recycling will be published by the Ministry of Agriculture and Environment on the National EPR Information System, details of which are further specified in Decree 110.
Manufacturers and importers must, on an annual basis, register recycling plans or declare financial contributions by April 1 for products and packaging placed on the market in the preceding year. Entities opting for financial contributions must complete payment to the VEPF by April 20. To facilitate the contribution value, the recycling cost norms (Fs) for each product and type of packaging are issued in other legal documents. Manufacturers and importers may apply the formula in Decree 110 to calculate the contribution value to the VEPF.
In cases where manufacturers have proactively established packaging recovery and reuse systems with a high recovery rate, the system may help to waive such recycling responsibility.
Waste Treatment Responsibilities
For six specific groups of products and packaging, instead of the recycling responsibility mentioned above, waste treatment responsibilities (via payment to the VEPF) will be imposed.
Decree 110 lists the relevant financial contribution rates to support waste treatment activities. For example, for each plastic bottle or plastic box (with a size of less than 500 ml) of finished pesticides, an amount of VND 50 (about USD 0.002) will be imposed as payment to the VEPF.
Waste treatment contribution rates will be adjusted every five years, with each adjustment capped at 15% of the rate applied in the previous period. The first adjustment is expected in 2031. Manufacturers and importers must declare waste treatment contributions annually by April 1 via the National EPR Information System and complete payment to the VEPF by April 20.
Outlook
Decree 110 consolidates Vietnam’s EPR regime into a centralized, transparent, and more coherent regulatory framework. It enhances compliance mechanisms for manufacturers and importers while strengthening the capacity of authorities to manage and supervise EPR implementation. The decree also underscores Vietnam’s strong policy commitment to sustainable development, waste reduction, recycling, and efficient resource use.
Businesses operating in Vietnam should review their EPR strategies and internal compliance processes in preparation for the decree’s entry into force on May 25, 2026.
