Vietnam EPR Packaging Cost Calculator 2026 — Decree 110 & Circular 24 | GRAC

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Vietnam EPR packaging cost estimator 2026

Compare the two ways to fulfil the recycling responsibility under Article 54 of the Law on Environmental Protection: the financial contribution (Fs) paid into the Vietnam Environment Protection Fund, or actual recycling through GRAC Digital PRO.

Packaging placed on the market

65%

Actual recycling through GRAC typically costs 50–80% of the Fs rate, depending on material and contract volume — drag to adjust.

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GRAC's recycling cost includes: traceable collection with separately tracked documentation per Clause 6, Article 6, Decree 110/2026, and recycling result reports using the Annex II templates of Circular 24/2026/TT-BNNMT.

View Rmin & Fs for all 12 packaging groups
CodePackaging groupRminFs (VND/kg)
A.1.1Paper and carton packaging20%1,900
A.1.2Multi-layer composite paper packaging15%6,420
A.2.1Aluminum packaging22%2,400
A.2.2Iron and other metal packaging20%3,600
A.3.1Rigid PET packaging22%1,940
A.3.2Rigid HDPE, LDPE, PP, PS packaging15%3,880
A.3.3Rigid EPS packaging10%5,820
A.3.3Rigid PVC packaging10%7,760
A.3.3Other rigid plastic packaging10%5,820
A.3.4Mono-material flexible packaging10%8,320
A.3.4Multi-material flexible packaging (laminates)10%10,700
A.4.1Glass packaging15%1,980

Rmin (mandatory recycling rate) — Annex I, Decree 110/2026/NĐ-CP · Fs (financial contribution rate) — Annex I, Circular 24/2026/TT-BNNMT. Both adjust on a 3-year cycle, first revision in 2029.

Fs payable = volume (t) × 1,000 × Rmin × Fs (VND/kg) Formula F = R × V × Fs — Article 8, Decree 110/2026 Declare by 1 April · pay Fs by 20 April each year
Fs rates per Annex I, Circular 24/2026/TT-BNNMT — stable until the 2029 revision. The comparison covers direct financial cost only; non-financial benefits (ESG data, chain-of-custody traceability, documentation) are not quantified. Results are preliminary estimates and depend on packaging type, volume, mandatory recycling rates and valid documentation — they do not replace formal legal advice.

How Vietnam's 2026 packaging EPR cost is calculated

From 2026, the recycling obligation of producers and importers is determined by a single formula set out in Article 8 of Decree 110/2026/NĐ-CP. If a company chooses to pay the financial contribution into the Vietnam Environment Protection Fund (VEPF — Quỹ Bảo vệ môi trường Việt Nam) instead of organizing recycling, the amount payable is:

F = R × V × Fs
F — amount payable (VND) R — mandatory recycling rate (tỷ lệ tái chế bắt buộc), Annex I, Decree 110/2026 V — packaging volume placed on the market (kg) Fs — financial contribution rate (mức đóng góp tài chính, VND/kg), Annex I, Circular 24/2026

In plain terms: take the volume of each packaging type your company placed on the Vietnamese market in the preceding year, multiply by that type's mandatory recycling rate, then by its Fs unit rate. Every packaging group has its own Rmin–Fs pair — so two companies with the same total tonnage can face very different costs depending on material mix. Multi-material flexible packaging (laminates) carries the highest Fs in the schedule: 10,700 VND/kg.

Worked example — 50 tonnes of multi-layer laminates

Volume placed on market50 t (A.3.4 — multi-material flexible)
Mandatory recycling rate (Rmin)10%
Volume subject to recycling5 t
Fs payable = 50,000 kg × 10% × 10,700 VND/kg53.5M VND
Actual recycling via GRAC (at 65% of Fs)≈ 34.8M VND
Estimated difference−18.7M VND / year

Three dates to lock into the annual compliance calendar, all handled through the National EPR Information System:

By 1 AprilDeclare the Fs amount, or register the recycling plan and file the recycling result report for the preceding year (Articles 7 & 8, Decree 110)
By 20 AprilPay the full financial contribution into the Vietnam Environment Protection Fund (if choosing the Fs option)
2029First revision of both Rmin and Fs — 3-year cycle. Current rates hold until then

Pay Fs or recycle — which option should you choose?

The law lets each producer choose one of two ways to fulfil the recycling responsibility under Article 54 of the Law on Environmental Protection. The right choice is not only about cost — it determines what your company gets back after the money is spent.

Option 1
Financial contribution (Fs)

Simplest. Declare by 1 April, pay by 20 April — no recycling plan to register, no result report to file (Clause 2, Article 7, Decree 110). Suits small volumes and fragmented packaging portfolios.

The trade-off: this is a sunk cost. Money paid into the Fund generates no recycling documentation in your company's name, cannot support ESG reports or group packaging commitments, and for hard-to-recycle materials such as laminates, Fs is the highest rate in the schedule.

Option 2
Actual recycling (R)

Lower cost, with an asset left behind. Through a collection-and-recycling network such as GRAC, the cost of R typically runs at 50–80% of Fs. More importantly, your company receives a chain-of-custody documentation trail from collection point to recycling plant — data you can use in ESG reporting and in a regulatory post-audit.

The trade-off: you must register a plan, file result reports and keep separately tracked documentation (Clause 6, Article 6, Decree 110) — or authorize a recycling responsibility organization (PRO) such as GRAC to handle the full chain from collection to reporting.

Decision rule: the larger the obligation, the more actual recycling wins — the absolute savings outweigh the administrative workload, and the traceability data becomes an asset rather than an expense. Contact GRAC for a portfolio-specific comparison.

Tool scope: packaging only (Group A). Batteries, accumulators, lubricants, tires and electrical–electronic products have their own Rmin and Fs rates under Decree 110 & Circular 24; some products fall under the waste treatment responsibility (Article 55 of the Law on Environmental Protection), where payment is the only compliance route and recycling cannot substitute. Contact GRAC for a separate calculation for those groups.

FAQ — Vietnam packaging EPR costs 2026

What are the Fs rates for 2026?

Fs rates for 2026 follow Annex I of Circular 24/2026/TT-BNNMT, ranging from 1,900 VND/kg (paper and carton packaging) to 10,700 VND/kg (multi-material flexible packaging). Common rates: rigid PET 1,940 VND/kg, aluminum 2,400 VND/kg, rigid HDPE/LDPE/PP/PS 3,880 VND/kg, multi-layer composite paper 6,420 VND/kg. Rates are stable until the 2029 revision — see the full 12-group table above.

Which companies must comply with packaging EPR in Vietnam? Who is exempt?

Producers and importers placing commercial packaging of food, cosmetics, pharmaceuticals, fertilizers, cement and similar goods on the Vietnamese market (Clause 2, Article 4, Decree 110/2026). Exemptions from the recycling responsibility apply when: total revenue from in-scope products is below 30 billion VND/year; products are made or imported for export, temporary import–re-export, or for research and testing; or the producer itself takes back and reuses its packaging at a rate equal to or above Rmin (Clause 3, Article 4).

What are the declaration and payment deadlines?

By 1 April each year: declare the Fs amount (if paying the contribution) or register the recycling plan and file the recycling result report (if recycling), based on packaging volumes placed on the market in the preceding year. By 20 April: pay the full Fs amount into the Vietnam Environment Protection Fund. Everything runs through the National EPR Information System (Articles 7 & 8, Decree 110/2026).

Fs payment or actual recycling — which is better?

Paying Fs is administratively simplest but is a sunk cost and usually the more expensive route. Actual recycling through a network such as GRAC typically costs 50–80% of Fs and produces chain-of-custody documentation usable for ESG reporting and post-audits. The larger the obligation, the stronger the case for actual recycling.

Does this tool cover batteries, accumulators, lubricants or tires?

No. The tool covers packaging only (Group A of Annex I). Batteries, accumulators, lubricants, tires and electrical–electronic products have their own mandatory recycling rates and Fs; some products fall under the waste treatment responsibility in Article 55 of the Law on Environmental Protection, where payment is the only compliance route. Contact GRAC for those product groups.