You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

April 22, 2026

Clearer Picture of Extended Producer Responsibility Emerges in Vietnam

Subscribe to Updates

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.

Related Professionals

Industries

Consumer Products

Life Sciences

Practices

Corporate/M&A

Regulatory Affairs

Location

RELATED INSIGHTS​ 

December 13, 2024
Attorneys from Tilleke & Gibbins in Bangkok have provided updates for the latest edition of The Pharma Legal Handbook: Thailand, published by Pharma Boardroom. This comprehensive guide to the legal framework regulating the healthcare and life sciences industries in Thailand was authored by Alan Adcock, partner and director, intellectual property, and head of the firm’s life sciences practice; Dr. Atthachai Homhuan, manager of regulatory affairs; and San Chaithiraphant, senior associate. The handbook is a must-read for healthcare and life sciences companies that are interested in exploring expansion into the Thai market.
Read More
December 12, 2024
On November 21, 2024, the National Assembly of Vietnam adopted a law amending and supplementing the 2016 Law on Pharmacy (“Amended Law on Pharmacy”). The Amended Law on Pharmacy simplifies some procedures for the pharmaceutical field, and will take effect on July 1, 2025, except for regulations on drug registration and rights and responsibilities of certain types of pharmaceutical business. Some outstanding points in the Amended Law on Pharmacy are presented below. E-commerce Distribution The Amended Law on Pharmacy allows trading in pharmaceutical products by the e-commerce channel, including e-commerce trading floors, e-commerce sales applications, and e-commerce sales websites with online ordering functions. Accordingly, e-commerce retail of non-prescription drugs is permitted if the drugs are neither specially controlled drugs nor drugs included in the list of drugs restricted for retail sale, and e-commerce wholesale of drugs and drug materials is permitted, as long as they are not specially controlled drugs. New Rights for Import FIEs The amendment provides some additional rights to foreign-invested enterprises (“FIEs”) that import drugs, including the rights to: Repurchase drugs and drug materials manufactured through the technology transfer of the FIE itself in Vietnam, and sell such products to wholesalers; Import drug materials to supply to drug manufacturers in Vietnam that are hired by or receive technology transfer from the FIE itself under a processing contract or technology transfer contract; Deliver and transport drugs and drug materials the FIE has imported, outsourced for processing, or transferred technology for in Vietnam, from the FIE’s warehouse to its wholesalers; Deliver and transport drugs used in aid, sponsorship, humanitarian, and disease prevention and control programs to medical facilities receiving funding; and Transport drug materials imported by the FIE from its warehouse to drug manufacturers that are hired by or receive technology transfer from the FIE itself under a
Read More
December 9, 2024
Cambodia’s Law on Seed Management and Plant Breeder’s Rights was enacted in 2008, but it was not until recently that new plant varieties could successfully be registered for protection in the country. Although the law has been in place for some time, recent developments confirmed the application process and a schedule of charges for the registration of new plant varieties. With these developments, breeders have been able to register their new plant varieties in Cambodia since March 1, 2024. Applicants for new plant variety protection must be Cambodian nationals, foreign nationals domiciled in Cambodia, or permanent residents of either a country that is a contracting party to the International Union for the Protection of New Varieties of Plants (UPOV) Convention or a country with which Cambodia has signed a memorandum of understanding on plant variety protection. Applicants can also claim a priority date from the first application for the same plant variety filed in any contracting party of the UPOV Convention within 12 months of the earliest application’s filing date. To be eligible for protection, new plant varieties must satisfy the following criteria: Novelty: A variety is considered “new” if, at the date of filing the application for new plant variety protection, it has not been sold, marketed, or otherwise disposed of others—by or with the consent of the breeder—for more than: One year for any plant variety in Cambodia; Six years for trees and vines or four years for all other plant varieties in countries besides Cambodia. Distinctiveness: A variety must be clearly distinguishable from any other existing varieties. Uniformity: A variety must be sufficiently uniform in its relevant characteristics. Stability: A variety must remain unchanged in its essential characteristics at the end of each cycle of propagation and in each generation. The last three criteria are often
Read More
December 4, 2024
On October 28, 2024, Indonesia officially amended its existing Patent Law when the president ratified Law Number 65 of 2024. This comprehensive update—the third such amendment in the history of Indonesia’s Patent Law—introduces several key changes that will significantly impact patent protection and application processes in Indonesia. Key highlights and changes are outlined below. Definition of Invention The new law broadens the definition of “invention” to explicitly include systems, methods, and uses. Additionally, the law introduces formal definitions for traditional knowledge and genetic resources. Patentability Criteria Notable changes include: Computer programs are now excluded, with an exception for computer-implemented inventions. Theories and methods in science and mathematics are added to the list of excluded inventions. Previous restrictions on new uses of existing products are removed. Grace Periods The grace periods for some patent-related actions have been adjusted: The grace period for disclosures has been extended to 12 months (from 6 months previously), providing inventors with more flexibility in filing patent applications after initial disclosure. A newly introduced item is the grace period for a conventional patent application claiming priority rights, which is 4 months after the 12-month filing deadline under the Paris Convention. The grace period for annuity payments is 6 months (from 12 months previously) with a fine for late payments of 100% of the annual fee payable. Patent Holder Rights and Obligations Patent holders can now grant permissions to enforce patents. There is a new requirement for patent holders to submit annual statements on patent implementation in Indonesia. Compulsory Licensing Significant changes to compulsory licensing include: Establishment of licenses based on the principle of expediency. Limitations on license scope and transferability. Prioritization of domestic market needs. New provisions for technical improvements and economic significance. Government Patent Exploitation The new law contains specific provisions for the government’s implementation
Read More