On April 01, 2026, the Government of Vietnam officially issued Decree No. 110/2026/ND-CP, providing detailed guidance on several provisions of the Law on Environmental Protection relating to the recycling responsibilities of manufacturers and importers for products and packaging (“EPR obligations”).
The Decree will take effect from May 25, 2026. Below are the key highlights:
Regulated entities
- Producers and importers of products and packaging subject to recycling responsibility and waste collection and treatment responsibility (hereinafter referred to as producers and importers).
- Agencies, organizations, and individuals related to product and packaging recycling responsibility and waste collection and treatment responsibility of producers and importers.
Implementation method
- Self-organize recycling activities; or
- Make financial contributions to the Vietnam Environmental Protection Fund.
Reporting and timeline
- Direct Recycling Option: Recycling plans and annual recycling reports must be submitted via the National EPR Information System no later than 1st April each year.
- Financial Contribution Option: The annual declaration must be submitted via the National EPR Information System by 1st April each year, and the full contribution must be paid by 20th April each year.
Exemption from EPR obligations
- Entities with annual revenue from specified products below VND 30 billion;
- Export, temporary import for re-export, or production and import for research, study, or testing purposes in accordance with clause 1 Article 55 of the Law on Environmental Protection.
Should you require assistance in navigating this new law, RBA’s advisory team is available to provide tailored guidance.
