List of Permitted Scrap Imports: A Policy Adjustment to Tighten Environmental Control and Reshape Industrial Raw Material Supply Chains

Decision No. 13/2023/QĐ-TTg, signed by Deputy Prime Minister Lê Minh Khái and effective from June 1, 2023, marks an important update in Vietnam’s policy framework governing the import of scrap materials used as production inputs. Under this decision, the Government continues to allow the importation of certain categories of scrap essential for industrial manufacturing, including ferrous scrap, plastic scrap, paper scrap, glass scrap, and non-ferrous metal scrap, but within a more tightly controlled environmental management framework and in alignment with the actual consumption capacity of importing enterprises.

This regulation replaces Decision No. 28/2020/QĐ-TTg, which had been introduced when Vietnam began facing the risk of becoming a destination for global waste flows following China’s implementation of the “National Sword” policy in 2018 that banned the import of most recyclable waste. Between 2018 and 2020, Vietnam experienced a sharp increase in the volume of imported plastic and paper scrap accumulating at seaports, placing considerable pressure on environmental infrastructure and import control mechanisms.

As a result, since 2019, the Vietnamese Government has continuously improved the legal framework governing scrap imports through amendments to the Law on Environmental Protection, followed by Decree No. 40/2019/NĐ-CP and subsequently Decree No. 08/2022/NĐ-CP guiding the implementation of the 2020 Law on Environmental Protection. These regulations gradually shifted the regulatory approach from strict pre-import inspections toward a conditional post-audit system, while requiring importing enterprises to demonstrate actual usage demand based on their facility’s designed production capacity and compliant waste treatment systems.

In this context, Decision No. 13/2023/QĐ-TTg represents more than a mere update to the list of permitted HS codes for import. It reflects a policy direction aimed at redefining Vietnam’s approach to secondary raw materials within the broader framework of a circular economy. By stipulating that organizations and individuals may import scrap materials solely for use in their own production facilities and strictly in accordance with their registered design capacity, the regulation seeks to prevent imports conducted for intermediary trading purposes or disguised re-export activities.

Another notable aspect is that granulated slag from iron or steel manufacturing (HS Code 2618 00 00) is no longer regulated as imported scrap when used as a raw material in cement production. Instead, it is now governed under construction material regulations. This shift indicates a policy trend toward reclassifying certain industrial by-products based on their end-use applications, thereby enabling the formal integration of selected secondary materials into heavy industrial production chains rather than categorizing them entirely as controlled waste streams.

From a long-term policy perspective, the issuance of this updated list demonstrates Vietnam’s pursuit of two parallel objectives. The first is to secure a stable supply of input materials for resource-intensive sectors such as metallurgy, paper, and plastics amid growing constraints on primary natural resources. The second is to minimize environmental risks associated with substandard scrap imports, in line with international commitments such as the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal.

This development is also closely aligned with Vietnam’s broader strategy for sustainable industrial growth, under which sectors such as steel, cement, and chemicals will increasingly be required to operate within environmental standards approaching those of the European Union and OECD markets. As reflected in recent policy shifts in Malaysia and Thailand that you have been examining, a common trend across ASEAN countries is the tightening of restrictions on mixed scrap imports and the introduction of stricter traceability requirements.

In the next phase, Vietnam is likely to further narrow the list of permitted scrap imports while transitioning toward a licensing regime based on technical quality standards and contamination thresholds rather than relying primarily on HS classification. Such measures will be essential if Vietnam aims to foster a domestic recycling-based raw material market and reduce reliance on imported scrap over the medium to long term, particularly as Extended Producer Responsibility (EPR) policies began taking effect in 2024.

More broadly, Decision No. 13 should not be viewed merely as an import management instrument but rather as a key component in Vietnam’s transition toward a circular economic model, in which scrap materials are treated not as environmental liabilities but as productive resources when properly regulated. This shift is expected to significantly influence the structure of Vietnam’s industrial raw material supply chains in the coming decade.