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

On March 31, 2026, Vietnam’s government issued Decree 102/2026/ND-CP (Decree 102), which amends Decree 75/2019/ND-CP on administrative sanctions for competition law violations (Decree 75). Effective from May 20, 2026, the new decree introduces a number of significant changes aimed at strengthening enforcement, revising penalty structures, and broadening the range of remedial measures, primarily for violations related to economic concentration. Revised Penalties for Economic Concentration Violations Decree 102 significantly revises the penalties for violations related to economic concentration. Failure to notify an economic concentration; implementing an economic concentration before clearance Under the new framework, Articles 14 and 15 of Decree 75 have been amended to impose a range of monetary fines, rather than relying solely on percentage‑based penalties as under the previous regime, for violations involving the failure to notify an economic concentration or the implementation of an economic concentration prior to clearance. The fines range from VND 500 million to VND 1 billion for each enterprise participating in a concentration with combined assets, revenues, or purchase value below VND 3,000 billion in the preceding fiscal year, capped at 5% of the violating enterprise’s total turnover in the relevant market. For concentrations meeting or exceeding the VND 3,000 billion threshold across those same metrics, the fines increase to VND 1 billion to VND 2 billion per enterprise, also subject to the 5% cap. These differentiated thresholds allow penalties to better reflect the size of the transaction and its potential competitive impact. Non-compliance with conditional approvals Enterprises that do not implement or only partially implement the conditions specified in a conditional economic concentration approval decision face fines ranging from 1% to 3% of total turnover in the relevant market during the fiscal year preceding the violation. Decree 102 also adds a new remedial measure requiring enterprises to fully implement all conditions

In March 2026, the United States Trade Representative (USTR) initiated two significant investigations under Section 301(b) of the Trade Act of 1974 that directly affect Thailand. The first investigation examines overproduction in manufacturing sectors caused by government support or policies that distort normal market conditions across 16 economies, including Thailand. The second investigation, launched the following day, targets 60 economies, also including Thailand, for alleged failures to impose and effectively enforce prohibitions on the importation of goods produced with forced labor. Taken together, these investigations represent a significant escalation in US trade enforcement and create substantial risk for Thai exporters, manufacturers, and businesses with supply chain connections to the United States. The investigations are moving on an accelerated timeline, with the USTR indicating that potential trade measures, including tariffs, could be imposed as early as July 2026. This article provides an overview of the investigations, highlights their specific implications for Thailand, and outlines practical considerations for affected businesses. Section 301 as a Trade Enforcement Tool Section 301 of the Trade Act of 1974 gives the USTR authority to investigate foreign acts, policies, or practices that are considered unreasonable or discriminatory and that burden or restrict US commerce. If the USTR concludes that such practices exist, the statute allows a wide range of remedial measures, including the imposition of tariffs, nontariff trade restrictions, and negotiated agreements with foreign governments. Unlike other trade authorities, Section 301 does not set limits on the level of tariffs or the duration of measures, giving the USTR considerable flexibility to address perceived trade imbalances or unfair practices. Historically, Section 301 investigations take up to a year to complete. In this instance, however, the USTR has indicated that the investigations will proceed on a much faster timetable, with an unofficial target of concluding by July 2026.

On March 30, 2026, Thailand’s Customs Department announced a strategy to raise import duties on a broad range of consumer goods—including plastic items and electronics accessories—to their maximum statutory ceilings, which often sit at 30% or 40%. Many of these goods currently benefit from promotional or incentive rates as low as 5%. For importers, e-commerce platforms, and logistics providers, this development demands immediate attention. While these increases generally require cabinet approval, they do not require full parliamentary amendment of the Customs Tariff Decree B.E. 2530, as the Customs director-general and the finance minister hold delegated authority to adjust rates within existing statutory bounds. Businesses should not assume that the legislative process will provide significant lead time before higher rates take effect. Death of the De Minimis: Abolishing the THB 1,500 Loophole This “ceiling-rate” policy, which is designed to equalize the landed cost of foreign goods with the domestic production costs of Thai manufacturers, builds on a sweeping set of customs reforms that have already begun to reshape Thailand’s trade environment. The foundation of this new regime was laid on January 1, 2026, when Thailand formally abolished the longstanding THB 1,500 duty exemption for small imported parcels under Customs Notification No. 219/2568. Every imported item is now subject to VAT and applicable import duties for its declared value, regardless of parcel size or transaction amount. By narrowing the scope of exemptions previously granted to low-value goods under the Customs Tariff Decree B.E. 2530, the government has made clear that the era of tax-free cross-border micro-imports is over. Three-Phased Strategy and Legal Modernization The March 30 announcement is the second phase of a three-part regulatory roadmap: Immediate enforcement: The removal of the THB 1,500 loophole and the imposition of VAT on all parcels, effective January 1, 2026. Tariff realignment: The current