Vietnam Publishes Circular on EPR for Recycling of Products and Packaging 
On 25 May 2026, the Ministry of Agriculture and Environment (MAE) issued Circular No. 24/2026/TT-BNNMT, providing detailed guidance for the implementation of selected provisions of Decree No. 110/2026/ND-CP, which elaborates certain articles of the Law on Environmental Protection regarding Extended Producer Responsibility (EPR) for product and packaging recycling and waste management by producers and importers.
The Circular applies to producers and importers subject to EPR obligations, as well as other relevant stakeholders involved in the implementation of EPR and took effect on the date of signing. It introduces financial contribution rates, implementation forms for recycling and waste collection and treatment obligations, and procedures for providing financial support to recycling and waste treatment activities.
The Circular also repeals Articles 78 and 79, Appendix IX and Appendix IXa of Circular No. 02/2022/TT-BTNMT, as amended and supplemented by Circular No. 07/2025/TT-BTNMT, concerning producers’ and importers’ recycling and waste management responsibilities.
Financial contribution rates and applicable products
The financial contribution rate per unit weight of product or packaging (Fs), as stipulated in Appendix I, has been significantly revised compared to Appendix IXa of Circular No. 07/2025/TT-BTNMT:
- Financial contribution rate (Fs): Administrative, monitoring, and implementation support costs are no longer included in the calculation of Fs. As a result, the Fs rates are approximately 2% lower than those under the previous regulation.
- Covered products and packaging: The scope has been updated in accordance with Decree No. 110/2026/NĐ-CP. The most significant changes relate to motor vehicles, together with several other revisions, as summarized below.
| Product/Packaging Category (Circular No. 07/2025/TT-BTNMT) |
Key Changes under Circular No. 24/2026/TT-BNNMT |
|---|---|
| A.1.1 Paper and cardboard packaging | Further specifies coated paper and cardboard packaging, including paper or cardboard coated on one or both sides while retaining its identity as paper or cardboard. |
| A.1.2 Multi-layer composite paper packaging | Revises the definition from “packaging consisting of two or more materials including paper and at least three material layers” to “packaging consisting of two or more layers, including at least one paper layer.” |
| A.3.3 EPS packaging, rigid PVC packaging, and rigid plastic packaging | Explicitly excludes biodegradable plastics. |
| A.3.4 Flexible plastic packaging | Adds a definition describing flexible packaging as packaging with high flexibility that can be bent, stretched, or reshaped without compromising its structural integrity (e.g., woven bags, shrink films, flexible plastic bags). |
| B.1.2 Other batteries | Clarifies that this category refers to batteries other than lead-acid batteries. |
| B.2.1 Rechargeable batteries | Revises the classification to align with Decree No. 110/2026/ND-CP. |
| C.1.1 Lubricating oil for engines | Clarifies that the category includes engine oil, transmission oil, and lubricating oil. |
| D.1.1 Inner tubes and tyres | Clarifies that this category refers to rubber inner tubes and tyres. |
| E.1.1 Road motor vehicles | Removes subcategories E.1.1 Motorcycles and three-wheeled motorcycles and E.1.2 Mopeds and electric motorcycles. The regulation now applies only to automobiles, including: cargo vehicles and specialized cargo vehicles; passenger vehicles with a seating capacity of nine persons or more (excluding the driver); kindergarten and school buses; four-wheeled motorized cargo vehicles; and four-wheeled motorized passenger vehicles subject to statutory service-life requirements under road traffic safety regulations. |
Templates for fulfilling recycling and waste management obligations
The Circular also introduces the following implementation templates:
| No. | Template | Details | Submission procedure |
|---|---|---|---|
| I | Templates for fulfilling recycling and waste management obligations | ||
| 1 | Registration and declaration form | Form No. 01, Appendix II | Producers and importers submit to the MAE via the National EPR Information System. |
| 2 | Recycling results report | Form No. 02, Appendix II | |
| 3 | Declaration of financial contribution for waste treatment:
· finished pesticide packaging; · single-use batteries; diapers, sanitary pads, wet wipes, chewing gum; · cigarettes; · and products containing synthetic plastics. |
Form No. 03, Appendix II | |
| II | Templates for financial support for recycling activities | ||
| 1 | Recycling support agreement | Form No. 01, Appendix III | Agreement between the Vietnam Environmental Protection Fund (VEPF) and the beneficiary. |
| 2 | Recycling progress update | Form No. 02, Appendix III | Submitted by the beneficiary to the MAE via the National EPR Information System before the 20th day of the first month of each quarter. |
| 3 | Recycling results report (for recycling enterprises receiving support) | Form No. 03, Appendix III | Required as part of the disbursement dossier. The beneficiary shall submit an independent auditor–verified report to the MAE (either directly, through the One-Stop Administrative Service Unit, or via the National EPR Information System) according to the milestones specified in the support agreement. |
| 4 | Report on the organization of recycling activities (for Producer Responsibility Organizations (PROs) receiving support) | Form No. 04, Appendix III | |
These templates replace those under the previous regulation and require more detailed information, including data on products and packaging subject to recycling obligations (particularly in the registration and declaration form).
EnviX’s comments
The Circular clearly specifies the financial contribution rates applicable to each category of products and packaging, while also providing comprehensive guidance and standardized implementation templates. These revisions are expected to facilitate businesses’ compliance with administrative procedures and improve the implementation of their Extended Producer Responsibility (EPR) obligations.
View the full text of Circular 24/2026/TT-BNNMT at the link below:
https://chinhphu.vn/?pageid=27160&docid=218478&classid=1&typegroupid=6
