From May 25, Vietnam is taking drastic steps to curb its growing environmental crisis and accumulating waste. Under the latest Decree 110/2026, producers and importers of products and packaging must meet mandatory recycling quotas or make significant financial contributions based on their waste output. In our article, we analyze Vietnam’s new Extended Producer Responsibility (EPR) system in detail, based on data from the World Bank and local environmental authorities.
Background to the Decision: Alarming Waste Management Data and Environmental Burden
The introduction of the new regulation was preceded by worrying statistics in the Southeast Asian country. Official data from the World Bank and Vietnam’s Ministry of Agriculture and Environment highlight the severity of the situation: the country generates around 3.5 million tonnes of plastic waste annually, of which only 33 percent is recycled.
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Average plastic waste generation is estimated at 37–41 kilograms per person each year.
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According to the data, around 65 percent of plastic waste in Vietnam is at risk of leaking into rivers, lakes, canals, and seas.
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A significant portion of the waste is discharged directly into the environment, causing severe land, water, and air pollution.
To encourage the circular economy and strengthen environmental protection, the government decided to issue Decree 110/2026.
Scope of the New Regulation and Extended Producer Responsibility (EPR)
Decree 110/2026 introduces extended producer responsibility (EPR) regulations, requiring producers and importers to recycle products and packaging placed on the market according to mandatory rates and specifications.
The scope of the legislation covers a very broad range of products:
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Paper, plastic, metal, and glass packaging.
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Tyres and lubricants.
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Electronic devices, as well as various batteries and accumulators.
The obligation applies not only to actual manufacturers but also extends to companies outsourcing production or authorizing imports.
Mandatory Recycling Rates and the Quantitative Quota System
Mandatory recycling rates are calculated based on the minimum proportion of products or packaging that must be recycled relative to the total volume placed on the market during the year. The decree sets specific percentage values for different categories:
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For aluminium packaging and rigid PET plastics, the mandatory recycling rate is 22 percent. Under this regulation, for example, a company selling 100 tonnes of aluminium or PET packaging annually must recycle at least 22 tonnes.
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For paper, carton, and ferrous metal packaging, the rate is slightly lower at 20 percent.
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In the category of household electronic devices, mobile phones face the strictest recycling requirement at 15 percent.
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For computers, printers, and photocopiers, this rate is 9 percent.
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The rate for lead-acid batteries and rechargeable batteries (excluding lithium and nickel-metal hydride batteries used in transport vehicles) ranges from 8 to 15 percent.
These mandatory recycling rates will be reviewed and adjusted by the authorities every three years, with the first revision scheduled for 2029.
Compliance Methods and Financial Contributions for Companies
Producers and importers can choose between two methods to fulfill the legal requirements.
The first option is for companies to organize the recycling activities themselves. They can do this internally, hire professional recyclers, or authorize intermediary organizations to collect and recycle products on their behalf. In this case, recycling plans and annual reports must be submitted via the National Information System before April 1 each year.
The second solution is for businesses that do not organize recycling directly. They may fulfill their obligations by making financial contributions to the Vietnam Environmental Protection Fund, thereby supporting recycling activities nationwide. Contribution levels are calculated based on the volume of products placed on the market, mandatory recycling rates, and standard recycling costs per unit. These payments must be made annually before April 20.
Exemptions and the Protection of Small and Medium-Sized Enterprises
The drafters of the decree also took into account the economic capacity of market players and introduced exemptions to protect small and medium-sized enterprises (SMEs).
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Producers and importers with annual revenue of less than $1.2 million from products and packaging subject to recycling obligations will be exempt.
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Products manufactured specifically for export, as well as those temporarily imported for re-export, are also excluded from the requirements.
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