EPR – Extended Producer Responsibility

🔷 1. Legal Basis of EPR in Vietnam

• Law on Environmental Protection 2020 (effective from Jan 1, 2022) – first legal basis establishing EPR in Vietnam.
• Decree 08/2022/ND-CP (issued on Jan 10, 2022) – provides detailed guidance on implementing EPR.
• Circular 02/2022/TT-BTNMT and other guiding documents issued by the Ministry of Natural Resources and Environment (MONRE).

🔷 2. Applicable Subjects

EPR applies to producers and importers of the following products:

• Packaging (plastic, paper, metal…)
• Batteries and accumulators
• Tires
• Lubricating oil
• Electrical and electronic products
• Vehicles

Note: Recycling companies are not required to pay EPR fees, but play a critical role as authorized recyclers in the EPR value chain.

🔷 3. Implementation Options

Producers and importers may choose:

1. Self-organized recycling
2. Payment to the EPR Fund (Vietnam Environmental Protection Fund)

• Payment rates are set annually by MONRE, known as standard recycling cost (PFE).
• Qualified recycling enterprises can register to become authorized recyclers or service providers for PROs.

🔷 4. Monitoring and Enforcement

• Annual EPR reporting is mandatory.
• MONRE oversees compliance.
• PRO Vietnam (Producer Responsibility Organization) acts as a key intermediary to coordinate recycling on behalf of members.

🔷 5. Opportunities and Challenges for Recycling Industry

✅ Opportunities:

• Growing demand for professional recycling services
• Expansion of the domestic recycling market
• Integration into the green circular economy

⚠️ Challenges:

• Need for technological upgrades, traceability, transparent reporting
• Disqualification of recyclers that fail to meet legal standards
• Administrative burdens during implementation phase

🔷 6. Implementation Timeline

Recycling rates will increase progressively over time

2022–2023: Voluntary implementation phase

From 2024 onwards: Mandatory recycling for priority product groups

Source : Decree 08/2022/ND-CP (issued on Jan 10, 2022) – provides detailed guidance on implementing EPR.