Vietnam Law on Environmental Protection (Resource Circulation and EPR Producer Recycling Obligations)

Overview

Vietnam's amended Law on Environmental Protection (LEP 2020; Law No. 72/2020/QH14) entered into full force on 1 January 2022, with detailed implementation set out in Decree No. 08/2022/ND-CP. At its core is the comprehensive introduction of Extended Producer Responsibility (EPR) and circular economy policy.

Manufacturers and importers operating in Vietnam are required to collect and recycle products and packaging materials (or make monetary payments to the government's Vietnam Environmental Protection Fund, VEPF), applied under the following phased roadmap:

1. From 1 January 2024: packaging and container materials (paper, plastic, metal, glass)

2. From 1 January 2025: batteries, storage batteries, engine oil, tyres

3. From 1 January 2026: electrical and electronic products, office equipment, household appliances

Covered companies must register and report the previous year's distributed weight to the Ministry of Agriculture and Environment (MONRE) by 31 March each year.

Enforcement Timeline

2022: Amended Law on Environmental Protection (LEP 2020) took effect.

2024-2025: Phased EPR recycling fee collection began under Decree No. 08/2022/ND-CP and the more recent Decree No. 05/2025/ND-CP.

Business Impact

Japanese-affiliated local subsidiaries selling food, daily goods, and household appliances in Hanoi, Ho Chi Minh City, and elsewhere are required to report the total weight of packaging materials to MONRE annually by 31 March. As local recycling infrastructure is still being developed, companies unable to achieve their target recycling rate on their own are compelled to make alternative contributions to the Vietnam Environmental Protection Fund (VEPF), creating financial cost pressure. Building alliances with reliable local recycling operators (PROs) is the foremost management challenge.