EPR Compliance in Vietnam:
The Complete Guide for Producers and Importers.
Vietnam's Extended Producer Responsibility framework explained — who must comply, what to recycle, how costs are calculated, and how brands can build audit-ready evidence. Built for FMCG, packaging, and importer compliance teams.
of Decree 110/2026
Compliance Threshold
Calculation Formula
and Payment Deadlines
What is EPR — and why does it matter for producers in Vietnam?
Extended Producer Responsibility (EPR) makes the producer or importer of a product accountable for what happens to it after consumption — including its packaging.
In Vietnam, EPR is no longer voluntary. It is a mandatory legal obligation under the 2020 Law on Environmental Protection, now consolidated and clarified through Decree 110/2026/ND-CP, effective from 25 May 2026.
Under this framework, organizations and individuals that produce or import designated products and packaging into the Vietnamese market must either:
- Organize recycling at the mandatory rate prescribed by regulation, or
- Contribute financially to the Vietnam Environmental Protection Fund based on the statutory cost formula.
The penalty for non-compliance is not symbolic. Producers and importers may face administrative fines, public disclosure of violations, and reputational exposure with global parent companies that increasingly require ESG-grade compliance evidence from their Vietnamese operations.
For multinational FMCG brands operating in Vietnam, EPR has become a practical test of whether sustainability commitments can be backed by verifiable data.
Vietnam's EPR framework, from law to enforcement.
The legal foundation has been built progressively. 2026 is the year the framework moves from fragmented obligations into a dedicated EPR regulatory instrument.
Law Enacted
The Law on Environmental Protection establishes producer and importer responsibility for recycling and waste treatment.
Decree 08/2022
First implementation rules issued. Categories, rates, and reporting structure defined.
Decree 05/2025
Amendments clarify cost coefficients and update implementation requirements.
Decree 110/2026
Standalone EPR decree consolidates the framework. Effective 25/05/2026.
Decree 110/2026/ND-CP consolidates key EPR provisions into a dedicated regulatory instrument, making compliance easier to identify — and harder to ignore.
Who must comply with Vietnam EPR?
EPR applies to producers and importers placing covered products and packaging on the Vietnamese market. This includes Vietnamese-registered companies and the local entities of multinational corporations.
Covered product categories
- Packaging — paper, metal, plastic, glass for food, cosmetics, household products, beverages, and pharmaceuticals
- Batteries and accumulators — lead-acid, rechargeable, lithium, and other batteries
- Lubricant oil — engine oil and relevant lubricant products
- Tires and inner tubes — all covered categories
- Electrical and electronic equipment — refrigerators, air conditioners, washing machines, displays, mobile phones, lighting, solar panels, and related equipment
- Motor vehicles — cars and motorcycles, with recycling obligations beginning from 1 January 2027
Who is exempt?
Decree 110/2026 provides exemptions from the recycling obligation for certain producer and importer groups, including:
- Export-only production or import — products and packaging not placed on the Vietnamese market
- Small producers and importers — annual revenue below 30 billion VND for relevant EPR-covered products and packaging
- Recovered and reused packaging — where packaging is recovered and reused at the rate prescribed by law
Important nuance: Companies near the threshold should not treat exemption as permanent. Revenue, product category, and packaging scope should be reviewed annually before each reporting cycle.
Two legal routes. Several ways to execute.
Vietnam EPR gives producers and importers two core routes: organize recycling or contribute financially to the Vietnam Environmental Protection Fund. Within the recycling route, companies may implement directly, contract recyclers, authorize a PRO, or combine approaches by material category.
Producers may combine pathways — for example, organizing recycling for high-volume packaging while contributing financially for smaller or more difficult material categories. Each category should be tracked and reported separately.
How EPR financial contributions are calculated.
For producers and importers choosing the financial contribution route, Vietnam EPR uses the statutory formula below:
Each variable needs to be documented clearly:
- R (recycling rate) — defined by regulated category and adjusted periodically
- V (volume) — declared by the producer or importer based on market output
- Fs (cost coefficient) — set by regulation and varies significantly by material type
Selected Fs cost coefficients
| Material Category | Fs (VND/kg) | Approx. USD/ton |
|---|---|---|
| A · PACKAGING | ||
| Paper / carton packaging | 1,938 | ~78 |
| Multi-layer paper composite | 6,548 | ~262 |
| Aluminum packaging | 2,448 | ~98 |
| Iron and other metal packaging | 3,672 | ~147 |
| Rigid PET packaging | 1,979 | ~79 |
| Rigid HDPE / LDPE / PP / PS | 3,958 | ~158 |
| Single-material flexible plastic | 8,486 | ~339 |
| Multi-material flexible plastic | 10,914 | ~437 |
| Glass packaging | 2,020 | ~81 |
| B · BATTERIES | ||
| Lead-acid batteries | 18,278 | ~731 |
| Other batteries | 50,796 | ~2,032 |
| Rechargeable batteries | 54,876 | ~2,195 |
| C · LUBRICANT OIL | ||
| Engine oil | 8,568 | ~343 |
| D · TIRES | ||
| All tire categories | 3,488 | ~140 |
| E · ELECTRONICS (selected) | ||
| Refrigerators / freezers | 8,262 | ~330 |
| Air conditioners | 8,874 | ~355 |
| TV / desktop monitors | 10,200 | ~408 |
| Mobile phones | 16,279 | ~651 |
| Solar panels | 4,080 | ~163 |
Indicative table based on published Fs cost coefficients. USD conversion uses an approximate rate of 25,000 VND/USD for readability only. Producers and importers should verify the applicable coefficient and exchange rate before making financial decisions.
Worked example
An FMCG brand places 500 tons of multi-material flexible plastic packaging on the Vietnamese market. Assuming a mandatory recycling rate of 22%:
- F = 22% × 500,000 kg × 10,914 VND/kg
- F ≈ 1.2 billion VND (~48,000 USD) per year
This represents the contribution if the brand chooses to pay into the Fund. Under the recycling route, the actual cost depends on material type, collection quality, recycler capacity, evidence requirements, and negotiated execution rates.
Annual deadlines and the National EPR Information System.
Vietnam EPR relies on a centralized digital reporting workflow. Compliance is submitted through the National EPR Information System administered by the competent environmental authority.
Two annual deadlines
- Before 1 April — Submit annual recycling plan, declaration, and relevant prior-year recycling results through the National EPR Information System
- Before 20 April — Pay the financial contribution to the Vietnam Environmental Protection Fund if choosing the financial contribution route
What goes in the report
- Volume of products and packaging placed on the market
- Mandatory recycling rate and target volume by category
- Compliance route chosen: direct recycling, authorized recycler or PRO, financial contribution, or a combined approach
- For recycling routes: documentary evidence of recycling completion, including transaction records, weight confirmations, photographs, invoices, and recycler confirmation where applicable
- Carry-over balance from prior years' over-fulfillment, where applicable
Producers using the financial contribution route still need to make the required declaration and payment within the statutory timeline.
What auditors look for: Authorities and brand compliance teams increasingly scrutinize the chain of custody between brand obligation and recycler output. Self-declared volumes without verifiable transaction-level evidence are the most common source of rejected or challenged reports.
Five common compliance failures — and how to avoid them.
Based on early implementation patterns and audit feedback, these are the most frequent ways producers and importers run into trouble.
1. Volume under-declaration
Reporting only branded primary packaging while excluding secondary or transport packaging. Packaging scope should be reviewed by material and use case.
2. Double-counted recycling
Multiple producers claiming credit for the same recycled volume through overlapping aggregator networks. Without transaction-level evidence, this is invisible until audit.
3. Unverifiable recycling partners
Authorizing a recycler or PRO without confirming permits, transaction logs, weight evidence, and audit-ready data export capability. Producer liability cannot be outsourced blindly.
4. Spreadsheet-based reporting
Excel can support planning, but it is weak as a compliance evidence system. EPR requires structured, time-stamped, transaction-level records at scale.
5. Late-stage scramble
Treating EPR as a year-end exercise. Recycling activities and supporting evidence should be captured during the reporting year, not reconstructed near the April deadline.
Bonus: Overlooking future categories
Some sectors, including motor vehicles, face upcoming obligations. Companies should monitor category-specific timelines even if they are not immediately in scope today.
From regulation to verifiable compliance — in one platform.
GRAC's EPR Platform is built for the operational reality of Decree 110/2026: transaction-level evidence, anti-double-counting controls, and submission-ready reports.
Plan Registration
Volume declarations and recycling plans structured for EPR reporting workflows.
Chain of Custody
Every kilogram tracked through QR, weight, photo, transaction, and recycler confirmation.
Duplicate Claim Checks
AI-assisted checks help detect duplicate or overlapping claims across the recycling network.
Audit-Ready Reports
Submission packs and evidence summaries prepared for internal review and regulatory reporting.
Why Vietnam EPR matters beyond Vietnam.
For multinational producers, Vietnam EPR is no longer a local compliance line item. It is an early signal of how Southeast Asia is moving toward stronger post-consumer responsibility, packaging accountability, and circular economy enforcement.
Several ASEAN markets are strengthening EPR and circular economy regulations. Vietnam can become an early operational reference point for brands building regional compliance systems across markets with different rules but similar evidence needs.
The bigger picture is clear: verified waste-origin data is becoming the foundation for ESG reporting, recycled-content claims, and circular supply chain audits. The infrastructure built for Vietnam EPR can also support recycled material verification, carbon accounting, and responsible sourcing.
Compliance is the entry point. The data layer is the long-term asset.
Read more: About GRAC Technology · Company Profile · ISO Quality and Environmental Policy
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Primary legal references: Law on Environmental Protection 2020; Decree 110/2026/ND-CP; Decree 05/2025/ND-CP; National EPR Information System. This guide is provided for general information based on publicly available regulatory texts. It does not constitute legal advice. Producers and importers should consult licensed legal counsel for specific compliance obligations.