Packaging EPR in Vietnam 2026: What Producers and Importers Need to Know

From the 2026 compliance year, packaging EPR in Vietnam is governed by Decree 110/2026/ND-CP, which took effect on 25 May 2026, with detailed guidance in Circular 24/2026/TT-BNNMT of the Ministry of Agriculture and Environment. For FMCG brands and international producers selling into Vietnam, the practical questions are the same every year: are we obligated, how much must be recycled, which route do we take, and what evidence will stand behind the figures we report? This guide answers them from the text of the Decree.

Who must comply with EPR in Vietnam?

Under Article 4, producers and importers that place covered products and packaging on the Vietnamese market must fulfil recycling responsibility. For packaging, the scope is commercial packaging, both direct and outer, of:

• food (excluding chewing gum);
• cosmetics;
• medicines;
• fertilisers, animal feed and veterinary medicines;
• soaps, detergents, polishing preparations, and cleaning and sanitation preparations used in agriculture, healthcare and households;
• cement.

The Decree also clarifies who counts as the “producer” in common commercial arrangements:

• Same brand, several manufacturers: the entity responsible for product labelling.
• Contract manufacturing: the party placing the order, not the contract manufacturer.
• Consignment imports: the entity responsible for labelling; where this is the consignee, revenue is the total import value plus the consignment fee.
• Corporate groups: a parent company, or an independently accounted branch, may fulfil the obligation for subsidiaries or branches when authorised under civil law.

Exemptions (Article 4.3) cover three cases: (a) products and packaging produced or imported for export, temporary import and re-export, or for research, study or testing; (b) producers and importers whose total revenue from the covered products is below VND 30 billion per year; and (c) packaging that a producer has placed on the market and then itself recovers and repacks for placing on the market again, at a recovery and repacking rate equal to or higher than the mandatory recycling rate in Annex I.

Transition: obligations for 2025 and earlier years remain under Decree 08/2022/ND-CP; obligations from 2026 onwards follow Decree 110 (Article 23).

Packaging categories and recycling obligations

Annex I sets, for each packaging group, a mandatory recycling rate and a mandatory recycling specification. Under Article 5.1, the rate is the minimum mass that must be recycled, according to the mandatory specification, as a share of the total mass placed on the market in the obligation year.

Two points matter in practice. First, the specification decides what counts: for plastics, producing flakes alone does not meet the specification, and for rigid plastics neither does use as fuel. Second, rates will rise: under Article 5.2, the rates are adjusted upward on a three-year cycle, with the first change in 2029. Budgets and recycling capacity should be planned with that trajectory in mind.

Two compliance routes: organise recycling or contribute financially

Article 6 requires a producer to choose one route for each product group listed in Annex I.

Route 1 — Organise recycling. The producer may recycle the packaging itself or use it as feedstock, contract a recycler, authorise a recycling-responsibility organisation (PRO), or combine these options. Before 1 April each year, it registers its recycling plan and reports the previous year’s recycling results through the National EPR Information System (Article 7.1).

Route 2 — Financial contribution. The producer contributes to the Vietnam Environment Protection Fund. It does not register a plan or report recycling results (Article 7.2), but it must declare the contribution for the previous year’s volume before 1 April and pay it in full before 20 April (Article 8.3).

The trade-off is straightforward. The contribution route is administratively lighter, but it is a pure cost that rises with rates and volumes. The recycling route requires partners, records and verification, but it lets a producer build its own collection and recycling supply chain and generate evidence it can use beyond compliance.

Recycling rates and the Fs contribution

Under Article 8.1, the financial contribution for each product or packaging group is:

F = R × V × Fs

• F — total contribution for that group;
• R — the mandatory recycling rate in Annex I;
• V — the volume placed on the market in the obligation year;
• Fs — the contribution rate per kilogram, issued by the Minister of Agriculture and Environment for each product and packaging group and adjusted every three years, with the first change from 2029 (Article 8.2).

For example, rigid PET packaging carries R = 22%: the contribution is calculated on 22% of the kilograms placed on the market, multiplied by the Fs rate for that group. To estimate this across your portfolio, use the GRAC EPR Cost Calculator, then check the result against the official Fs rates before you budget or declare.

How to document recycling results

Under the recycling route, the figures a producer reports have to be supported by records. The Decree sets the following requirements:

• Reporting channel and responsibility: results are reported through the National EPR Information System, and the producer bears full legal responsibility for the accuracy of what it submits (Article 7.1).
• Specification: recycled output must meet the mandatory recycling specification for the group (Annex I).
• PRO confirmation: an authorised PRO must inspect and confirm the volumes the recycler has received and recycled, and it may not sub-authorise another PRO (Article 6.5).
• Separate records: collection, transfer, receipt and warehouse records for packaging recycled under the obligation must be kept separately, using the transfer forms prescribed by the Minister (Article 6.6).

In practice, a defensible file links each reported tonne to a chain of documents: the contract or authorisation, batch transfer records, the recycler’s receipt, and output records showing a product that meets the specification. Collected, received and recycled quantities should be tracked as separate numbers and reconciled. Our article Collected ≠ Recycled: Building Reconcilable Recycling Evidence explains how.

How GRAC Digital PRO supports implementation

GRAC is a recycling-responsibility organisation (PRO) under Decree 110/2026/ND-CP and is listed on the National EPR Information System as an organisation receiving recycling authorisation for products and packaging. Under the Decree, a PRO organises the collection, transport and transfer of packaging to recyclers; the recycling itself is carried out by recyclers. When a producer authorises GRAC, we:

• map the obligation by packaging group: volume placed on the market, mandatory rate and specification;
• organise collection and transfer to recyclers whose output meets the specification;
• confirm the volumes received and recycled, as Article 6.5 requires;
• keep batch and transaction records on our traceability platform, with reconciliation tables and a list of documents still outstanding;
• prepare the data the producer needs for its report on the National EPR Information System.

The producer remains responsible for what it reports; our role is to make that report traceable and supported. For the boundaries of the role, read What a Digital PRO Does — and What It Does Not Do.

This article summarises Decree 110/2026/ND-CP for general information and is not legal advice. Always check the official texts before declaring or reporting.

Official sources

• Decree 110/2026/ND-CP (Official Gazette, Government of Vietnam): Articles 3–8, 23–24 and Annex I.
• Circular 24/2026/TT-BNNMT (Government of Vietnam portal), detailing and guiding the implementation of Decree 110/2026/ND-CP.